Agenda packet — El Centro City Council, April 2, 2024 (part 1 of 2)

AGENDA

CITY OF EL CENTRO

CITY COUNCIL/CITY COUNCIL AS

SUCCESSOR AGENCY TO THE

REDEVELOPMENT

AGENCY/SUCCESSOR HOUSING
AGENCY
TUESDAY, APRIL 2, 2024
Economic Development Department Joint Regular Meeting 11:30 AM

ECONOMIC DEVELOPMENT DEPARTMENT
1249 MAIN STREET
EL CENTRO, CA 92243
City of El Centro Page 1
The public may attend in person. Any member of the public attending in person and wishing to make a comment is asked to complete a speaker slip and follow the instructions below regarding “Notice to the Public”. Any member of the public is invited to submit public comments in advance of the meeting to be answered at the meeting. Please email your questions to [email protected] or call 760-337-4515 by April 2, 2024.

COUNCIL MEMBERS, STAFF AND THE PUBLIC MAY ATTEND VIA ZOOM.

To participate and make a public comment in person, via Zoom or telephone, please raise your hand, speak up and introduce yourself.

Join Zoom Meeting:
https://us06web.zoom.us/j/4180375132?pwd=Rmo5UjZ1cWdyV1VoWUhSZWp6R0tVZz09&omn=87332677880 Optional dial-in number: 1 (669) 900-6833
Meeting ID: 418 037 5132 Passcode: 5iHJYM
Public comments via zoom are subject to the same time limits as those in person.

Mayor & Council Members may be reached at (760) 336-8989 Mayor: Sylvia Marroquin City Manager: Cedric Ceseña
Mayor Pro-Tem: Edgard Garcia City Attorney: Elizabeth Martyn Evans Council Members: Tomás Oliva City Clerk: Norma Wyles
Sonia Carter
Martha Cardenas-Singh
11:30 A.M CLOSED SESSION - RDA CONFERENCE ROOM "A"
ROLL CALL (Open Session)
Agenda City Council of the City of El Centro April 2, 2024 City of El Centro Page 2
CLOSED SESSION PUBLIC COMMENT:

Any member of the public wishing to address the City Council on any matter appearing on the closed session may do so at this time. Unless the Mayor extends the time limit, remarks shall be limited to three (3) minutes. Additional opportunities for Public Comments will be given during and at the end of the meeting.

CITY COUNCIL ADJOURNS INTO CLOSED SESSION

CITY COUNCIL CLOSED SESSION

EXISTING LITIGATION
The City Council will recess to closed session to consider existing matters in Reel v. City of El Centro.

TRADE SECRETS
The City Council will recess to closed session pursuant to Govt. Code Section 37606.1 for the purpose of discussion and/or deliberation of reports involving hospital trade secret(s) as defined therein which it would, if prematurely disclosed create a substantial probability of depriving the hospital of a substantial economic benefit including hospital facilities.

NOTICE TO THE PUBLIC
This is a public meeting. If there is an item on the agenda on which you wish to be heard, you are asked to complete a blue speaker slip and submit it to the City Clerk prior to the start of the meeting. Persons wishing to address the Council are not required to identify themselves (Gov’t Code § 54953.3); however, this information assists the Mayor by ensuring that all persons wishing to address the Council are recognized and also assists the City Clerk in preparing the City Council meeting minutes. When the item is announced and your name is called by the Mayor, please step to the podium and state your name for the record. Unless the Mayor extends the time, there is a three (3) minute time limit for each public presentation. If you wish to address the concerning any other matter not appearing on the agenda, you may do so during the public comment portion of the agenda.

However, you may not show a visual presentation without review of that material. If you do so, you will be considered out of order. * Any information provided on the “Speaker Slip” is voluntary and will be public record.

RECONVENE FOR OPEN SESSION 6:00 P.M.
6:00 P.M. OPEN SESSION:

ALL TIMES ARE APPROXIMATE AND MAY VARY
Agenda City Council of the City of El Centro April 2, 2024 City of El Centro Page 3
CALL TO ORDER:

ROLL CALL BY CITY CLERK:

PLEDGE OF ALLEGIANCE:

INVOCATION:
6:05-6:10 CITY ATTORNEY REPORT ON CLOSED SESSION:
6:10-6:15 (TIME MAY VARY) PUBLIC COMMENTS:

The City Council welcomes your input. At this time, members of the public may address the City Council on any matter not listed on the posted agenda. Pursuant to the Brown Act, no action will be taken on any issue brought forth under Public Comments. We ask that you please complete a “Speaker Slip” and submit it to the City Clerk prior to the start of the meeting. Although you are not required to identify yourself (Gov’t Code §54953.3); this information on the “Speaker Slip” assists the Mayor that all persons wishing to address the Council are recognized and also assists the City Clerk in preparing the City Council meeting minutes. Unless the Mayor extends the time, there is a three (3) minute time limit for each public presentation. * Any information provided on the “Speaker Slip” is voluntary and will be public record. 6:15-6:25 PRESENTATIONS AND ANNOUNCEMENTS BY MAYOR:

1. Sun Community Federal Credit Union celebrated their 70th Year Anniversary on March 16, 2024

2. National Library Workers Day, April 9, 2024
6:25-6:40 SCHEDULED PRESENTATIONS:

3. Imperial County Film Commission Annual Report

4. Imperial Valley Small Business Development Center Annual Report 6:40-6:45 CONSENT AGENDA (ITEMS 5-6):

5. Approval of City Council Minutes of March 19, 2024.

6. Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF EL CENTRO CONFIRMING A FINE-FREE LIBRARY AND TAKING NECESSARY RELATED ACTIONS.

Agenda City Council of the City of El Centro April 2, 2024 City of El Centro Page 4
6:45-7:00 PUBLIC HEARING:

7. Public Hearing to Consider the Recommendation of the Planning Commission Regarding Conditional Use Permit 23-03 to Operate an Inflatable Obstacle Course at 3451 Dogwood Avenue.

PRESENTATION: Angel Hernandez, Director of Community Development RECOMMENDATION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF EL CENTRO, CALIFORNIA APPROVING CONDITIONAL USE PERMIT 23-06 TO OPERATE AN INFLATABLE OBSTACLE COURSE AT IMPERIAL VALLEY MALL PARKING LOT LOCATED AT 3451 DOGWOOD AVENUE. 7:00-8:00 NEW BUSINESS:

8. Discussion and related action regarding naming of Dog Park to be located at 670 Park Avenue
PRESENTATION: Adriana Nava, Community Services Director RECOMMENDATION:

Discussion and related action regarding naming of Dog Park.

9. Discussion and Related Action Regarding Acceptance of the 2024 Draft Housing Conditions Survey Report.

PRESENTATION: Adriana Nava, Community Services Director RECOMMENDATION:

Staff recommends that the City Council accept the Housing Conditions Survey Report as it is mandated by the City's five-year Consolidated Plan.

10. Discussion and Necessary Action Regarding the 2024-2028 Draft Analysis of Impediments to Fair Housing
PRESENTATION: Adriana Nava, Community Services Director RECOMMENDATION:

Adopt Resolution No. 24- , A RESOLUTION AUTHORIZING THE SUBMISSION OF THE 2024-2028 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING TO THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AND TO

IMPLEMENT THE RECOMMENDED ACTIONS TO ADDRESS POTENTIAL
IMPEDIMENTS TO FAIR HOUSING IN THE CITY OF EL CENTRO.

Agenda City Council of the City of El Centro April 2, 2024 City of El Centro Page 5

11. Establishing Mid-Block Crosswalk on Waterman for Jacaranda Apts. Off-Site Improvements
PRESENTATION: Abraham Campos, PE - Public Works Director/City Engineer RECOMMENDATION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF EL CENTRO ESTABLISHING A MID-BLOCK

CROSSWALK ON WATERMAN AVENUE BETWEEN BRADSHAW
AVENUE AND LINCOLN AVENUE.

12. Discussion and any Necessary Action Regarding the Approval of an Agreement Between the City of El Centro and the California Highway Patrol Regard Road Improvements.

PRESENTATION: Abraham Campos, PE - Public Works Director/City Engineer RECOMMENDATION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY OF EL CENTRO

APPROVING AN OFF-SITE IMPROVEMENT AGREEMENT BETWEEN THE

CALIFORNIA HIGHWAY PATROL AND THE CITY OF EL CENTRO RELATED TO CERTAIN ROAD IMPROVEMENTS ALONG DANENBERG DRIVE.

13. Letter of Support SB 1309 - Lithium Battery Production Council PRESENTATION: Cedric Ceseña, City Manager
RECOMMENDATION:

Ratify letter of support requested by Senator Steve Padilla's Office.

14. Discussion and any necessary action regarding appointment to the Library & Community Services Board.

PRESENTATION: Sylvia Marroquin, Mayor
RECOMMENDATION:

Mayor's Recommendation: Appointment to the Library & Community Services Board for one (1) un-scheduled non-voting member with term ending on June 30, 2026
Agenda City Council of the City of El Centro April 2, 2024 City of El Centro Page 6
8:00-8:10 SUCCESSOR AGENCY TO THE REDEVELOPMENT
AGENCY:

15. Discussion and Related Action Regarding Submittal of a Grant Application for Funding Under the HOME Investment Partnerships Program for the Palo Fierro Housing Project
PRESENTATION: Adriana Nava, Community Services Director RECOMMENDATION:

Adopt Resolution No. SA 24- , A RESOLUTION OF THE SUCCESSOR

AGENCY TO THE REDEVELOPMENT AGENCY OF THE CITY OF EL CENTRO

APPROVING THE SUBMITTAL OF AN APPLICATION FOR FUNDING TO THE

CALIFORNIA STATE DEPARTMENT OF HOUSING AND COMMUNITY

DEVELOPMENT UNDER THE HOME INVESTMENT PARTNERSHIPS
PROGRAM; AND, IF SELECTED, AUTHORIZING THE EXECUTION OF AN

AGREEMENT, ANY AMENDMENTS THERETO, AND OF ANY RELATED

DOCUMENTS NECESSARY TO PARTICIPATE IN THE HOME INVESTMENT PARTNERSHIPS PROGRAM.

LEGISLATIVE ACTION:

INFORMATIONAL ITEMS:

16. Received and referred to Community Development Department, Application for Alcoholic Beverage License- 2600 Thomas DR. STE #2 El Centro, CA 92243-7507

17. Received and referred to Community Development Department, Application for Alcoholic Beverage License- URSA Hospitality LLC URSA 612 & 614 W Main St El Centro, CA 92243-2920
8:10-8:40 TASK FORCE REPORTS AND MAYOR - COUNCIL MEMBER

REPORTS
8:40-8:50 CITY MANAGER REPORT:

ADJOURNMENT:

Materials related to an item on this Agenda submitted to the City Council after distribution of the agenda packet will be available for public inspection at the Office of the City Clerk, 1275 Main Street, El Centro, California 92243, Monday-Friday during normal business hours.

In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, you should contact the office of the City Clerk at (760)337-4515. Notification at least 48 hours prior to the meeting will enable the City to make reasonable arrangement to assure accessibility to this meeting.

City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: City Council
El Centro, CA 92243 Category: Presentation
Prepared By: Cynthia De Zilwa
SCHEDULED Department Head: Sylvia Marroquin
PRESENTATION (ID # 6314) DOC ID: 6314
Sun Community Federal Credit Union celebrated their 70th Year Anniversary on March 16, 2024
1 Packet Pg. 7
City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: City Council
El Centro, CA 92243 Category: Presentation
Prepared By: Cynthia De Zilwa
SCHEDULED Department Head: Sylvia Marroquin
PRESENTATION (ID # 6313) DOC ID: 6313
National Library Workers Day, April 9, 2024
2 Packet Pg. 8
City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Community Services
El Centro, CA 92243 Category: Presentation
Prepared By: Stacy Mendoza
SCHEDULED Department Head: Adriana Nava
INFORMATION ITEM (ID # 6300) DOC ID: 6300
Imperial County Film Commission Annual Report
Annual Report to be given by Film Liaison Charla Teeters of the Imperial Valley Film Commission.

Following this presentation, the City contribution of $1,000 will be processed. 3 Packet Pg. 9
City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Community Services
El Centro, CA 92243 Category: Presentation
Prepared By: Stacy Mendoza
SCHEDULED Department Head: Adriana Nava
INFORMATION ITEM (ID # 6302) DOC ID: 6302
Imperial Valley Small Business Development Center Annual Report
Annual Report to be given by Interim Center Manager & Business Project Advisor Viridiana Rosales of the Imperial Valley Small Business Development Center.

Following this presentation, the City contribution of $2,000 will be processed. 4 Packet Pg. 10
City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: City Clerk's Office
El Centro, CA 92243 Category: Minutes
Prepared By: Norma Wyles
SCHEDULED Department Head: Norma Wyles
ACTION ITEM (ID # 6324) DOC ID: 6324
Approval of City Council Minutes of March 19, 2024.

CITY MANAGER’S RECOMMENDATION:

Approval of City Council Minutes of March 19, 2024.

ATTACHMENTS:
• 03-19-2024 Regular CC Minutes (PDF)
5 Packet Pg. 11
Book 37

Page 193 ends

REGULAR MEETING

EL CENTRO CITY COUNCIL

CITY HALL, COUNCIL CHAMBERS
1275 MAIN STREET, EL CENTRO, CA
TUESDAY, MARCH 19, 2024, 11:30 A.M.

The El Centro City Council met in a regular session on Tuesday, March 19, 2024 at 11:35 a.m. in Conference Room “A”, El Centro City Hall, 1275 Main Street, El Centro, California for the purpose of closed session.

PRESENT: Council: Cardenas-Singh, Marroquin, Garcia, Carter City Clerk Wyles, City Manager Ceseña, City Attorney Martyn Evans ABSENT: Council: Oliva (arrived at 11:40 am)

CLOSED SESSION PUBLIC COMMENT
None

CITY COUNCIL CLOSED SESSION
Moved by Cardenas-Singh, second by Carter, to adjourn into closed session for:

ANTICIPATED LITIGATION:

A point has been reached where, in the opinion of the City Council upon the advice of its legal counsel, and based upon existing facts and circumstances, there is a significant possibility of initiation by the City pursuant to Govt. Code Section 54956.9(d)(4) – City challenge to possible LAFCO approval of PMHD expansion.

POSSIBLE LITIGATION:

The City Council will recess to closed session to consider existing matters in City of El Centro v. Local Agency Formation Commission.

ADDED CLOSED SESSION ITEM:

Motion to add Real Property Negotiations, moved by Cardenas-Singh, second by Marroquin.

CONFERENCE WITH REAL PROPERTY NEGOTIATIORS:

Centerpointe Plaza, Parcel 2
Agency Negotiator: City Manager
Negotiating Party: Imperial County Office of Education (ICOE) Under negotiation; price and terms.

Motion carried.

Closed Session concluded at 2:45 p.m.

City Council recessed to 6:00 p.m.

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Attachment: 03-19-2024 Regular CC Minutes (6324 : Approval of City Council Minutes) Book 37

Page 194 ends

OPEN SESSION
The El Centro City Council met in a joint regular session on Tuesday, March 19, 2024 at 6:00 p.m. in Council Chambers, El Centro City Hall, 1275 Main Street, El Centro, California.

PRESENT: Council: Cardenas-Singh, Oliva, Marroquin, Garcia, Carter City Clerk Wyles, City Manager Ceseña, City Attorney Martyn Evans Pledge of Allegiance to the flag of the United States of America was led by Council Member Oliva and Invocation was given by Council Member Carter.

CITY ATTORNEY REPORT ON CLOSED SESSION
No reportable action from closed session.

PUBLIC COMMENTS
None.

SCHEDULED PRESENTATIONS:

1. Captain Ernesto Ruedas, California Highway Patrol, introduced himself to City Council.

2. Douglas Hisel, Operations & Safety Supervisor, CUHSD, and school staff, presented a Pedestrian Safety/Safe Routes to School Survey.

CONSENT AGENDA (ITEMS 3-6)
Moved by Garcia, second by Carter, approving consent items # 3-6.

3. Approval of Warrant Registers for February 2024.

4. Approval of Payroll Registers for the Month of February 2024.

5. Approval of Treasurer’s Report for the month of February 2024.

6. Approval of City Council Minutes of March 5, 2024.

AYES: Cardenas-Singh, Oliva, Marroquin, Garcia, Carter
NOES: None
ABSENT: None
ABSTAINED: None

NEW BUSINESS

7. Presentation by Angel Hernandez, Director of Community Development, discussion and any necessary action regarding the acceptance of 2023 Housing Element Annual Report. Councilmembers had several questions on this item and Mr. Hernandez answered all their questions.

Moved by Garcia, second by Cardenas-Singh, acceptance of the City’s Annual Housing Element Progress Report on the Implementation of the Housing Element and direct that the report be submitted to the Governor’s Office of Planning and Research and the California Department of Housing and Community Development.

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Attachment: 03-19-2024 Regular CC Minutes (6324 : Approval of City Council Minutes) Book 37

Page 195 ends

AYES: Cardenas-Singh, Oliva, Marroquin, Garcia, Carter
NOES: None
ABSENT: None
ABSTAINED:None

8. Presentation by Abraham Campos, PE, Public Works Director/City Engineer, 2023 Solid Waste Contract Compliance Audit.

1. Moved by Cardenas-Singh, second by Garcia, approval of Fiscal Year 2024 budget amendment in the amount of $56,375 from the General Fund.

2. Moved by Cardenas-Singh, second by Garcia, adoption of Resolution No. 24-14, RESOLUTION

OF THE CITY COUNCIL OF THE CITY OF EL CENTRO APPROVING AN AGREEMENT FOR

PROFESSIONAL SERVICES BETWEEN THE CITY AND HF&H CONSULTANTS, LLC FOR SOLID WASTE CONSULTING SERVICES.

AYES: Cardenas-Singh, Oliva, Marroquin, Garcia, Carter
NOES: None
ABSENT: None
ABSTAINED:None

9. Presentation by Abraham Campos, PE, Public Works Director/City Engineer, approval of consulting agreement with Landmark Consulting, Inc. for geotechnical services.

1. Moved by Cardenas-Singh, second by Garcia, adoption of Resolution No. 24-15, RESOLUTION

OF THE CITY COUNCIL OF THE CITY OF EL CENTRO APPROVING A PROFESSIONAL SERVICES AGREEMENT WITH LANDMARK CONSULTANTS, INC. FOR PROFESSIONAL SERVICES RELATING TO THE POLICE STATION PROJECT.

2. Moved by Cardenas-Singh, second by Garcia, authorizing the use of Police bond funds use in the amount of $127,150 requested for this contract.

AYES: Cardenas-Singh, Oliva, Marroquin, Garcia, Carter
NOES: None
ABSENT: None
ABSTAINED:None
City Manager Cedric Cesena explained that additional funding was requested from Congressman Dr.

Ruiz appropriations 101worskshop in January, since a couple of funding opportunities opened up, the city applied for funding for the new El Centro Police Station construction. The City did get funded through the office of Congressman Dr. Ruiz for $850,000 for the South Imperial Avenue Extension Project. The city applied for funding for the police station and we are waiting to see if we will get funded. Measure P funding has been used to fund the need for this project and any other communitybased projects.

LEGISLATIVE
None

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Attachment: 03-19-2024 Regular CC Minutes (6324 : Approval of City Council Minutes) Book 37

Page 196 ends

INFORMATION ITEM

10. Received Imperial and Villa Local Emergency Update.

11. Received and referred to Community Development Department, Application for Alcoholic Beverage License – Sizzler USA Restaurants Inc., 707 N. Imperial Ave., El Centro, CA 92243-1913.

12. Received Southern California Gas Company (SOCALGAS) Notice of Request to Increase Rates for the Hydrogen Blending demonstration Projects Application No. A.22-09-006.

TASK FORCE AND MAYOR & COUNCIL MEMBERS REPORTS
Mayor and Council Members reported on their activities since last City Council meeting and upcoming events.

CITY MANAGER REPORT
Reported on activities.

ADJOURNMENT
With no further business the meeting was adjourned at 7:49 p.m. __________________________
Norma Wyles, City Clerk
APPROVED BY:
________________________________
Sylvia Marroquin, Mayor

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Attachment: 03-19-2024 Regular CC Minutes (6324 : Approval of City Council Minutes) City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Library
El Centro, CA 92243 Category: Resolution
Prepared By: Carla Mason
SCHEDULED Department Head: Carla Mason
ACTION ITEM (ID # 6025) DOC ID: 6025 A
Resolution to Implement a Fine Free Library for Overdue Library Books and Materials and Purge Library Fees
CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO CONFIRMING A FINE-FREE LIBRARY AND TAKING NECESSARY RELATED ACTIONS.

FISCAL IMPACT:

Minimal. The administrative costs associated with collecting fines from patrons can equal or exceed the revenue earned.

STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #4 - Recreation & Lifelong Learning: Offer opportunities for recreation and lifelong learning through innovative, inclusive programming, parks and facilities that serve all residents and visitors.

DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

BACKGROUND:

The City of El Centro City Council wants the library to be welcoming to all members of the community. The library has had an informal policy not to collect fines; this action confirms that policy. More and more libraries throughout the U.S. have become fine free to encourage library use by all. Our research and that from other libraries confirms that fines do not motivate Library users to return items on time, but instead may represent an inequitable barrier to service that disproportionately impacts children, students, and those with limited resources.

DISCUSSION:

Over time, fines accumulated during the April 2010 earthquake, the rebuilding of the library, and during COVID. The prior library director followed the informal direction of the former City Manager not to collect such fines. The majority of these fines no longer are collectible. The purpose of this action and the accompanying change in circulation policy is to confirm the library is fine-free.

This action applies only to fines and not to fees, such as those for lost or damaged materials or library services.

The attached resolution formalizes the fine-free policy as required by state law. The 6 Packet Pg. 16
Action Item (ID # 6025) Meeting of April 2, 2024
Library Director will implement an updated Circulation Policy reflecting the formal termination of fines.

CONCLUSION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO CONFIRMING A FINE-FREE LIBRARY AND TAKING NECESSARY RELATED ACTIONS.

ATTACHMENTS:
• A23-0113 - Final fine free library 3.21 (DOCX)
6 Packet Pg. 17
06/2023/cdz/A23-0112/Reso/PurgeAccumulatedLibraryFees
RESOLUTION NO. 24 -

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

EL CENTRO CONFIRMING A FINE-FREE LIBRARY AND

TAKING NECESSARY RELATED ACTIONS
WHEREAS, the City Council of the City of El Centro, California has had an informal policy of non-collection of unpaid fines for overdue library materials; and WHEREAS, the City Council finds that library fines may discourage library use by those who need the library most; and
WHEREAS, earthquake damage to the library followed by rebuilding and then COVID also have made it difficult for some users to return library materials while the library was closed to the public; and
WHEREAS, the City Council now formally forgives and waives for accounting purposes any and all collectible accumulated library fines from 2010 to the present; and WHEREAS, the Library Director has researched how such fines are treated in other libraries in the area, in California and throughout the United States, and has determined that many libraries now have a “Fine Free” policy; and
WHEREAS, elimination of fines encourages use of the library; and WHEREAS, practically, it is difficult to collect fines and may cost more than the amount of the fine itself; and
WHEREAS, the City Attorney has confirmed that the fines may be forgiven with the consent of the City Council.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

1. That the foregoing is true, correct and adopted.

2. That such fines are forgiven and waived for accounting purposes.

3. That from the effective date of this Resolution, no fines for overdue materials will be incurred.

4. That the Library Director is authorized to adopted the necessary revised policies, including the Circulation Policy, to implement the terms of this Resolution.

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Attachment: A23-0113 - Final fine free library 3.21 (6025 : Resolution to Implement a Fine Free Library and Purge Library Fees) 06/2023/cdz/A23-0112/Reso/PurgeAccumulatedLibraryFees
PASSED AND ADOPTED at a regular meeting of the City Council of the City of El Centro, California held on day of , 2024.

CITY OF EL CENTRO
By _____________________
Sylvia Marroquin, Mayor
ATTEST:

By _____________________________
Norma Wyles, City Clerk
APPROVED AS TO FORM:

Office of the City Attorney
By________________________________
Elizabeth L. Martyn, City Attorney

STATE OF CALIFORNIA )
COUNTY OF IMPERIAL ) ss

CITY OF EL CENTRO )
I, Norma Wyles, City Clerk of the City of El Centro, California do hereby certify that the foregoing Resolution No. 24- was duly and regularly adopted at a regular meeting of the City Council of the City of El Centro, California, held on the day of , 2024, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAINED:

By__________________________
Norma Wyles, City Clerk

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Attachment: A23-0113 - Final fine free library 3.21 (6025 : Resolution to Implement a Fine Free Library and Purge Library Fees) City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Community Development
El Centro, CA 92243 Category: Public Hearing
Prepared By: Sara Silva
SCHEDULED Department Head: Angel Hernandez
ACTION ITEM (ID # 6234) DOC ID: 6234
Public Hearing to Consider the Recommendation of the
Planning Commission Regarding Conditional Use Permit 23- 03 to Operate an Inflatable Obstacle Course at 3451 Dogwood Avenue.

CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA APPROVING CONDITIONAL USE PERMIT 23-06 TO

OPERATE AN INFLATABLE OBSTACLE COURSE AT IMPERIAL VALLEY MALL PARKING LOT LOCATED AT 3451 DOGWOOD AVENUE.

FISCAL IMPACT:

N/A
STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #6 Economic Opportunity, Action 6.7: Cultivate a business climate that welcomes innovation, entrepreneurship, and investment.

DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

N/A
BACKGROUND:

The applicant, Kevaworks, LLC, has submitted a request to obtain a Conditional Use Permit to operate an inflatable obstacle course at the west parking lot of the Imperial Valley Mall located at 3451 Dogwood Avenue (Exhibit A- Project Location). The inflatable course will operate from November 1, 2024 to December 29, 2024 with the tentative hours of Monday through Friday 1:30 P.M to 6 P.M, and Saturday and Sunday from 9 A.M. to 7:30 P.M. Since the project will exceed more than ten (10) calendar days, the project requires a conditional use permit approved by City Council, according to Section 29-225 of the municipal code.

The project will encompass an area of about 35,000 square feet between the JCPenney and Macy’s parking lots. Project features include a large inflatable obstacle course, a toddler bounce area and a food tent. Additionally, it will include a first aid/safety area in which personnel will be able to provide first aid (Exhibit B- Site Plan). The inflatable equipment will be anchored per specifications that are certified by a licensed engineer.

Customers and staff will walk inside the pedestrian area and no private vehicles will be permitted. Staff and customers will use the surrounding parking area for parking. Site plans were distributed to City staff to recommend conditions of approval for the project (Exhibit C- Staff Comments).

The Planning Commission held a public hearing on March 12, 2024 regarding the 7 Packet Pg. 20
Action Item (ID # 6234) Meeting of April 2, 2024
project. After a staff presentation, the Planning Commission voted to recommend that the City Council approve the Conditional Use Permit.

DISCUSSION:

City staff reviewed the site plan for the project for compliance with the City’s temporary use standards. A resolution for the City Council’s consideration is attached as Exhibit DResolution. Said resolution contains the findings and conditions of approval required to approve the project.

Required Findings- In considering approval of Conditional Use Permit 23-06, the City Council shall refer to the required findings found in the City’s Zoning Ordinance:

1. The use applied for at the location set forth in the application is properly one for which a conditional use permit is authorized by this chapter.

The subject property and proposed project are consistent with the general plan designated of General Commercial. Outdoor entertainment subject to more than ten (10) calendar days is a conditionally permitted use in the CGGeneral Commercial zone per Section 29-225 (a) of the City Code.

2. Proposed use is necessary or desirable for the development of the community, is consistent with the City’s General Plan and is not detrimental to the existing uses or the uses specifically permitted in the zone in which the proposed use is to be located.

The temporary inflatable course would not be detrimental to the existing uses or permitted uses in the CG- Zone. The use will not be detrimental to surrounding land uses. Due to the activities associated with entertainment activity, no negative impacts to existing or planned uses in the area are anticipated.

3. Proposed site is adequate in size and shape to accommodate said use.

The project site measures about 35,000 square feet in size and us able to accommodate the proposed use.

4. Site for proposed use relates properly to streets, which are designed to carry the type and quantity of traffic to be generated by the proposed use.

Access to the project site will be via Danenberg Drive to IV Mall Drive, which is a roadway within the mall premises. The project site will be within the mall parking lot that has paved markings to regulate traffic movements.

All roads are capable to serve the traffic generated at the project site.

5. Conditions as stipulated by the City are necessary to protect the public health, safety, and welfare of the community.

Conditions of approval to protect health, safety and welfare of the community have been included in the City Council Resolution as Exhibit D.

CONCLUSION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF THE CITY 7 Packet Pg. 21
Action Item (ID # 6234) Meeting of April 2, 2024
OF EL CENTRO, CALIFORNIA APPROVING CONDITIONAL USE PERMIT 23-06 TO

OPERATE AN INFLATABLE OBSTACLE COURSE AT IMPERIAL VALLEY MALL PARKING LOT LOCATED AT 3451 DOGWOOD AVENUE.

ATTACHMENTS:
• Exhibit A- Project Location Map (PDF)
• Exhibit B - Site Plan (PDF)
• Exhibit C- Staff Comments (PDF)
• Exhibit D- Resolution (DOCX)
7 Packet Pg. 22

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Attachment: Exhibit A- Project Location Map (6234 : CUP 23-06 Inflatable Obsctacle Course) Project Descrip�on – Bounceville – Imperial Valley Mall, 3451 Dogwood Ave, El Centro, CA 92243 (1) inflate park, (1) inflate obstacle course, (1) toddler bounce area, (1) inflate entrance arch, (1) inflate shoe storage, shade area w/tables and chairs.

On the site plan, C1 – C5 is the inflate park, sec�on O1 – O19 is the obstacle course, and the toddler bounce area is the sec�on to the right of the food block.

The tenta�ve hours of opera�on are Mon – Fri 1:30pm - 6pm, Sat & Sun 9:00am - 7:30pm, con�ngent upon weather and session reserva�ons.

We sell up to 350 �ckets per session and there are 3 sessions on weekdays and 7 sessions on weekends.

There will be 1 full-�me manager and 10-14 part-�me employees.

Inflate Park C1 –
C5
Obstacle Course O1 –
O19
Toddler Bounce

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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course)

VENUE LOCATION

IMPERIAL VALLEY MALL
3451 S DOGWOOD RD
EL CENTRO, CA 92243 A2
CLIENT

KEVAWORKS

DESCRIPTION

INFLATABLE BOUNCE
COURSE

DRAFTING BY

WESTON BLAHA

PROGRESS DRAWING
This drawing is not intended to be used for
contract pricing or fabrication purposes.

All content is subject to change

EL CENTRO, CA

EVENT DATE
JAN 24TH - FEB 25TH

ASSET DIRECTORY

NOT TO SCALE

SYMBOL QTY ASSET
DRAFT
12’ FENCE PANEL

ENTRANCE
SHADE 1
1,116’ 4 24’ SWING GATE 4 PORTO POTTY 1 ADA PORTO POTTY 1 RV TRAILER 1 7’ X 14’ SUPPLY TRAILER TREE
1 10’ X 10’ FOOD TENT
FOOD
10’x10’
SHADE 2
O1
C1
O2 O3 O4
O9 O8 O7 O6 O5
O10 O11 O12 O13 O14
O19 O18 O17 O16 O15
C2
C3 C4
C5
RV

STORAGE
SHOE

STORAGE
Exhibit B 7.b
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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course)

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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course)

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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course)

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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course)

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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course)

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Attachment: Exhibit B - Site Plan (6234 : CUP 23-06 Inflatable Obsctacle Course) City of El Centro
Interoffice Memorandum
Department of
Building and Safety
Sara Silvia, Assistant Planner
From: Frank Soto, Building Official
Date: 1/17/2024
Subject: Conditional Use Permit 23-06
Project: Inflatable Obstacle Course
Location: 3451 Dogwood Ave
To:

The Department of Building and Safety has the following comments:
5 percent, but no fewer than one of the portable restrooms clustered at a single location shall be accessible to persons with disabilities.

1. It is recommended that the applicant consults with the Department of Industrial Relations/ Cal-OSHA for any possible state requirements.

2. Respectful!
Frank Soto
Assistant Community Development
Director/ Building Official

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Attachment: Exhibit C- Staff Comments (6234 : CUP 23-06 Inflatable Obsctacle Course) From: Frank Soto
To: Sara Silva
Subject: CUP 23-06 Bounceville 3451 Dogwood Ave
Date: Thursday, February 1, 2024 11:16:04 AM
Sara,
The applicant will need to comply with the following;
Provide an exit analysis showing the exits and exit travel distance.

Provide anchoring details as recommended by the manufacturer's specs or per an engineered recommendation.

Provide evidence that each device has a permanent label affixed to the device that complies with sections 3104.3 and 3104.4 of the 2022 California Fire Code.

They will need an operational permit from the Fire Department.

They will need a building permit if they are installing generators.

Inflatable amusement devices shall be designed, anchored, operated, and maintained in accordance with the manufacturer's instructions and the requirements of ASTM F2374. 3108.3 Combustible Materials
The fabrics, textiles, containment netting, and combustible small mesh materials used in the construction of the inflatable amusement device shall meet the flame propagation criteria of Test Method 2 of NFPA 701. Additionally, a label and affidavit containing the information required in Sections 3104.3 and 3104.4 of this code shall be permanently affixed to the device.

Frank Soto
Assistant Community Development Director, CBO, CASp
1275 W. Main St.

El Centro CA 92243
760-337-4508

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Attachment: Exhibit C- Staff Comments (6234 : CUP 23-06 Inflatable Obsctacle Course)

CITY OF EL CENTRO

DEPARTMENT OF PUBLIC WORKS

ENGINEERING DIVISION

INTER-OFFICE REVIEW MEMORANDUM
DOCUMENT REVIEW TYPE:
☐SPR ☒CUP ☐TPM ☐PM Review Date: January 11, 2024
TO: Sara Silva, Assistant Planner FROM: Hector Salcedo, Engineering Technician SUBJECT: Conditional Use Permit 23-06 – Inflatable Obstacle Course at 3451 Dogwood Ave.

SUBMITTAL STATUS: ☒ Submittal has been reviewed. Refer to comments below. ☐ Unacceptable submittal. Missing information. Refer to additional requirements at end.

GENERAL COMMENTS
☐ Irrigation, building and fire backflow preventers shall be required and a plan depicting their location is necessary for review and approval by the City Water Department.
☐ Any water, sewer and storm-drain systems onsite shall be maintained by the development and not by the City.

Any future tie-ins to the onsite system shall first require a Building Permit for proper inspections. Any future work or maintenance of the onsite utilities shall be performed by contractors properly licensed to do such work. ☐ A sewer pretreatment program will be required. Provide anticipated sewer load to Wastewater department for assessment.
☐ All improvements within the City’s right of way shall be designed and built according to City standards and specifications and submitted for review with:
☒ Encroachment permit application ☐ Reference to Parcel Map name. ☐ Grading permit is required. Approved grading permit shall be obtained prior to building permit issuance. ☐ Provide trash enclosure built to city standards. Provide City Trash Service Purveyor (CR&R) approval letter of trash enclosure sizing prior to issuance of a Grading Permit or Building Permit, whichever comes first. ☒ Other: Refer to Additional Requirements section at end of this document

WATER AND SEWER CAPACITY FEES
☐ Water and sewer capacity fees will be assessed prior to building permit being issued based on increased use and/or intensity from historical conditions.
☒ Based on preliminary provided information, no increase in use or intensity from historical use is anticipated and no sewer or water capacity fee will be assessed. Re-evaluation required if use or intensity change. ☐ Other: Refer to Additional Requirements section at end of this document

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Attachment: Exhibit C- Staff Comments (6234 : CUP 23-06 Inflatable Obsctacle Course)

GRADING AND EROSION CONTROL
☐ A grading, drainage, and erosion control plans prepared by a licensed civil engineer in the State of California depicting the elevations and slopes for all new site work shall be submitted for review and approval prior to building permit. Plans shall comply with Chapter 22, Article VII “Storm Water Regulations” of the El Centro Ordinance, Chapter 7, Article XIX “Grading Regulations” of the El Centro Ordinance and El Centro Post Construction Best Management Practices supporting said ordinances. Plans shall also ensure compliance with the American with Disability Act (ADA).
☐ Project is over 1 acre and requires a SWPPP in compliance with the State Water Resources Control Board. Submit copy of approved Notice of Intent (NOI) as submitted to the SMARTS system as part of Grading Permit application.
☐ If not already installed, all onsite drainage must flow through storm interceptor system in order to decrease grease and other volatile waste from entering the drainage system. The grading plan shall depict the type and location of the storm interceptor system.
☐ Retention basin, if built,shall comply with City retention basin standard. Retention basin must drain within three days. Retention basin must be equipped with systems to re-route nuisance water if connection point is available in compliance with the Storm Water Ordinance.
☐ A Water Quality Management Plan is to be submitted along with grading permit application prepared by a licensed civil engineer.
☐ Provide stabilized entrance/exit in accordance with best management practices to prevent tracking on city streets for review and approval by city. Proposed work to be shown in improvement plans. ☐ Facility type is required to have an Erosion Control Plan for construction activities. ☒ Other: Refer to Additional Requirements section at end of this document ADA
☐ All sidewalks, driveway approaches, and ADA ramps provided must comply with ADA access standards and City standards.
☐ Provide ADA access from nearest public sidewalk to facility main access. ☒ Other: Refer to Additional Requirements section at end of this document

IMPROVEMENTS
☐ Provide improvement plans for all off-site work prepared by a licensed Civil Engineer in the State of California.

Plans shall clearly identify all Right-of-Way lines, proposed improvements, elevations, benchmarks, dimensions and material / workmanship specifications as may be required. ☐ Provide curb/gutter and sidewalks to city standards on all fronting streets. (see notes below) ☐ Provide street lighting to city standards on all fronting streets.

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Attachment: Exhibit C- Staff Comments (6234 : CUP 23-06 Inflatable Obsctacle Course) ☐ Construct half width of the streets fronting the site or one lane each direction plus parking lane, whichever is greater to City standards.
☐ Provide fire hydrants to city standards and spacing requirements. If none within 300 feet distance. ☐ Provide sewer and water off-site utility plans for review and approval by this department with encroachment permit application.
☒ Other: Refer to Additional Requirements section at end of this document

ADDITIONAL REQUIREMENTS

1. Provide an updated letter from Imperial Valley Mall authorizing the event for the requested dates of approximately 03/04/24 – 04/28/24. The provided letter only approves 01/26/24 – 02/25/24.

2. No Activities shall be done within City Right-of-Way. This includes placement of any equipment, signs, cones, etc. related to any activities otherwise approved by this CUP.

3. Applicant must obtain a City Business License prior to commencement of any activities approved by this CUP.

4. Applicant shall provide secondary spill containment trays for all portable restroom units placed onsite.

5. The applicant will be responsible for the repair, replacement, and/or restoration of any/all damages caused by the activities performed under this permit to any City owned property including, but not limited to: road, utilities, curb & gutter, driveway and sidewalks. All incurred costs related to the aforementioned shall be completely borne of the applicant.

6. The applicant shall be responsible to take all necessary safety measures to protect event guests.

7. If utilizing a generator as a source of power (primary, or secondary), provide spill containment for generator.

Must comply with any Imperial County Air Pollution Control District’s regulations/permits for use of generators.

8. The use of the neighboring dirt lot for any activities related to this event, including vehicle parking, is prohibited.

There shall be no vehicle parking on any unimproved surfaces.

9. The shall be no discharging of FOG’s (fats, oils, grease), waste, or debris into any storm system or sewer system.

10. Any violations to these items will revoke this CUP and any other future CUPs from this applicant.

Respectfully,
________________________________ ___________________________ Hector Salcedo,
Engineering Technician Date
01/11/2024

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Attachment: Exhibit C- Staff Comments (6234 : CUP 23-06 Inflatable Obsctacle Course) From: Brad Chapin
To: Sara Silva
Subject: RE: CUP 23-06 Inflatable Obstacle Course at IV Mall/ Memo Date: Tuesday, January 9, 2024 9:51:10 AM
Good morning Sara,
Is there any type of requirement for on site first aid/safety team to reduce the number injuries? I did not see a designated first aid area on the map.

Thanks
Brad Chapin
Battalion Chief | C Shift
City of El Centro Fire Department
1910 N Waterman Avenue
El Centro, CA 92243
Office 760-337-4530
Cell 760-554-5264
From: Sara Silva <[email protected]>
Sent: Thursday, January 4, 2024 4:01 PM
To: Cedric Ceseña <[email protected]>; Frank Soto <[email protected]>; Brad Chapin <[email protected]>; Kelly Brown <[email protected]>; Adriana Nava <[email protected]>; Felix De Leon Jr <[email protected]>; Javier Villaverde <[email protected]>; Anna Garcia <[email protected]> Cc: Poleth Lopez <[email protected]>
Subject: CUP 23-06 Inflatable Obstacle Course at IV Mall/ Memo Good afternoon,
Attached please find the memo for CUP 23-06 Inflatable Obstacle Course at IV Mall. Please provide comments by January 12, 2024.

Thank you,
Sara A. Silva
Assistant Planner, Community Development
Office | (760) 337-4869
Email | [email protected]
1275 W. Main Street, El Centro, CA 92243

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Attachment: Exhibit C- Staff Comments (6234 : CUP 23-06 Inflatable Obsctacle Course) 03/2024/cdz/A24-0050/Reso/CUP23-06ObstacleCourse
RESOLUTION NO. 24-

RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF EL CENTRO, CALIFORNIA APPROVING
CONDITIONAL USE PERMIT 23-06 FOR A

TEMPORARY INFLATABLE OBSTACLE COURSE
AT 3451 DOGWOOD AVENUE
WHEREAS, Kevaworks, LLC has applied for a Conditional Use Permit to operate an inflatable obstacle course at the Imperial Valley Mall parking lot located at 3451 Dogwood Avenue with APN 054-530-002 (the Project); and
WHEREAS, the proposed use is permitted subject to a conditional use permit pursuant to Section 29-225 of the City Code; and
WHEREAS, at a meeting held on March 12, 2024, the Planning Commission conducted a duly noticed public hearing on the petition for Conditional Use Permit No. 23-06; and WHEREAS, the Planning Commission adopted Resolution 24-01 recommending to the City Council that it approve said conditional use permit; and WHEREAS, a legal notice was published on March 22, 2024 in the Imperial Valley Press, a local paper of general circulation, indicating the date and time of the public hearing in compliance with state law concerning Conditional Use Permit 23-06, and said notice was mailed to each property owner within a 300-foot radius of the project site in accordance with state law; and WHEREAS, at such duly noticed public hearing at a regular City Council meeting held on April 2, 2024 in City Council Chambers at 1275 W. Main Street, El Centro, California the City Council heard and considered CUP 23-06; and
WHEREAS, the applicant was present and heard; and
WHEREAS, no one was present to object to the petition nor were any objections filed with the City Council; and
WHEREAS, the proposed use is necessary or desirable for the development of the community, is consistent with the objectives of the City’s General Plan, and is not detrimental to the existing uses or the uses specifically permitted in the zone in which the proposed use is to be located; and
WHEREAS, the proposed site is adequate in size and shape to accommodate said use; and WHEREAS, the project qualifies for a Categorical Exemption pursuant to the California Environmental Quality Act (CEQA), Section 15304, “Minor Alterations to Land”, and is determined to be exempt from further environmental review requirements contained in CEQA; and
WHEREAS, the conditions as stipulated by the City are necessary to protect the public health, safety, and welfare of the community.

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Attachment: Exhibit D- Resolution (6234 : CUP 23-06 Inflatable Obsctacle Course) 03/2024/cdz/A24-0050/Reso/CUP23-06ObstacleCourse

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

1. The findings set out above are true and correct.

2. The City Council hereby approves Conditional Use Permit No. 23-06 to operate an inflatable obstacle course at the Imperial Valley Mall parking lot located at 3451 Dogwood Avenue with APN 054-530-002, subject to the listed Conditions under Exhibit A and Findings under Exhibit B.

PASSED AND ADOPTED at a regular meeting of the City Council of the City of El Centro, California held on the day of , 2024.

CITY OF EL CENTRO
By______________________________
Sylvia Marroquin, Mayor
ATTEST:

By _____________________
Norma Wyles, City Clerk
APPROVED AS TO FORM:

Office of the City Clerk
By____________________________
Elizabeth L. Martyn, City Attorney

STATE OF CALIFORNIA )
COUNTY OF IMPERIAL ) ss

CITY OF EL CENTRO )
I, Norma Wyles, City Clerk of the City of El Centro, California, do hereby certify that the foregoing Resolution No. 24- was duly and regularly adopted at a regular meeting of the City Council of the City of El Centro, California, held on the day of , 2024, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAINED:

By________________________
Norma Wyles, City Clerk

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Attachment: Exhibit D- Resolution (6234 : CUP 23-06 Inflatable Obsctacle Course) 03/2024/cdz/A24-0050/Reso/CUP23-06ObstacleCourse

EXHIBIT A

GENERAL COMMENTS

1. The project shall consist of operate an inflatable obstacle course at the Imperial Valley Mall located at 3451 Dogwood Avenue. The project shall occupy about 35,000 square feet of the parking area between the Macy’s and JCPenney stores. The inflatable obstacle course is to take place from November 1, 2024 to December 29, 2024.

2. Except as noted, all conditions shall be met prior to the final inspection.

3. A business license shall be obtained from the Finance Department prior to commencing business operations.

4. There shall be no activities related to the project within City Right-of-Way. This includes the placement of any equipment, signs, cones, etc. unless otherwise approved.

5. The applicant shall maintain the project site and surrounding 50-foot area in a good, clean, orderly manner, free of any debris or junk materials.

6. The applicant will be responsible for the repair, replacement, and/or restoration of any/all damages caused by the activities performed under this project to any City property. The city property includes, but not limited to: road, utilities, curb and gutter, driveway and sidewalks. All incurred costs related to the aforementioned shall be completely borne of the applicant.

7. The project shall comply with all applicable Federal, State and local codes, ordinances and resolutions.

8. The applicant shall repair any damages or holes caused by the installation of their equipment.

VEHICLE AND PEDESTRIAN CIRCULATION

9. Parking for the project shall be within the parking lot of the Imperial Valley Mall. There shall be no public vehicle access within the project site.

10. There shall be no parking on any unpaved surfaces. The vacant lot to the west of the project site shall not be used for any activity related to this project, including vehicle parking.

SIGNAGE

11. The location, quantity, size and design of all signage shall comply with Chapter 22.1 “Signs” of the El Centro City Code.

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Attachment: Exhibit D- Resolution (6234 : CUP 23-06 Inflatable Obsctacle Course) 03/2024/cdz/A24-0050/Reso/CUP23-06ObstacleCourse

SAFTEY AND SANITATION

12. The applicant shall be responsible for all necessary measures to protect the event guest.

13. The applicant shall provide a secondary spill containment tray for all portable restroom units placed at the project site.

14. The applicant shall provide portable restrooms for guests. Five percent but no fewer than one, shall be accessible for people with disabilities.

15. There shall be no discharging of fats, oils, grease (FOGs), waste or debris into any storm system or sewer system.

16. The applicant shall obtain a Building Permit for the use of generators use as a power source (primary or secondary). Such generators shall provide spill containment and must comply with any Imperial County Air Pollution Control District’s regulations/permits.

17. The applicant shall provide evidence that each equipment device has a permanent label affixed to the device that complies with section 3104.3 and 3104.4 of the 2022 California Fire Code.

18. The applicant shall provide anchoring details as recommended by the manufacturer’s specifications or per a licensed engineer’s recommendation.

19. The project site shall be adequately lit during operating hours. Light towers or any other lighting equipment shall be shown on a site plan submitted with the Building Permit application.

20. The project site shall include a first aid/safety area in which staff can provide first aid.

21. The applicant shall obtain an operational permit from the Fire Department. ###

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Attachment: Exhibit D- Resolution (6234 : CUP 23-06 Inflatable Obsctacle Course) 03/2024/cdz/A24-0050/Reso/CUP23-06ObstacleCourse

EXHIBIT B
Findings:

1. The use applied for at the location set forth in the application is properly one for which a conditional use permit is authorized by this chapter.

The subject property and proposed project are consistent with the general plan designated of General Commercial. Outdoor entertainment subject to more than ten (10) calendar days is a conditionally permitted use in the CG- General Commercial zone per Section 29-225 (a) of the City Code.

3. Proposed site is adequate in size and shape to accommodate said use.

The project site measures about 35,000 square feet in size and us able to accommodate the proposed use.

4. Site for proposed use relates properly to streets, which are designed to carry the type and quantity of traffic to be generated by the proposed use.

5. Conditions as stipulated by the City are necessary to protect the public health, safety, and welfare of the community.

Conditions of approval to protect health, safety and welfare of the community have been included in the City Council Resolution as Exhibit A. ###

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Attachment: Exhibit D- Resolution (6234 : CUP 23-06 Inflatable Obsctacle Course) City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Community Services
El Centro, CA 92243 Category: Naming of City Property
Prepared By: Adriana Nava
SCHEDULED Department Head: Adriana Nava
ACTION ITEM (ID # 6058) DOC ID: 6058
Discussion and related action regarding naming of Dog Park to be located at 670 Park Avenue
CITY MANAGER’S RECOMMENDATION:

Discussion and related action regarding naming of Dog Park.

FISCAL IMPACT:

There is no fiscal impact associated with the naming of the Dog Park (currently under construction).

STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #4: Recreation and Life Long Learning - Offer opportunities for recreation and lifelong learning through innovative, inclusive programming, parks and facilities that serve all residents and visitors.
• Action 4.5: Improve parks, recreational amenities, open space, and trail development, and fulfill critical lifecycle and facility maintenance needs.

DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

Not applicable.

BACKGROUND:

A Dog Park has been proposed in El Centro for a long time and was included in the adopted, Parks Master Plan. A significant donation in the amount of $500,000 was made by Phil and Elise Heald in 2022 for the construction of a Dog Park at 670 Park Avenue, directly west of the Brett Driscoll Sidewinder Skate Park. The total cost of the project was $1,191,565 and of these funds Measure P is covering the balance of $696,565.

DISCUSSION:

In August 2023, the Heald’s submitted an Application for Naming New City Facilities, consistent with Policy Statement No. 51. The proposed name of the new facility was “Heald Family’s El Centro Dog Park.” At that time, the Council considered the proposed name and directed staff to complete a community outreach campaign regarding the proposed dog park’s name.

Subsequently, Mr. Heald proposed a new name, “Pups at Play.” A community outreach survey was completed from February 12, 2024 to March 12, 2024. A total of 106 responses were received from the community. A question was asked regarding residency and 87.74% of the respondents answered they were El Centro residents. A 8 Packet Pg. 42
Action Item (ID # 6058) Meeting of April 2, 2024
second question was asked about the other proposed name, Pups at Play and many respondents indicated they felt the name was too long and that not all dogs were pups.

While many name suggestions were submitted, Bark Park was the name that was submitted the most. A cursory online review noted that “Bark Park” is a popular name for dog parks throughout the nation. Many community members also suggested incorporating the names of the largest park donors with name suggestions such as, “A Place to Heald.” Attached are the comments submitted by the public for review and discussion.

CONCLUSION:

Discussion and related action regarding naming of Dog Park.

HISTORY:
08/15/23 City Council CONTINUED
ATTACHMENTS:
• Survey Results for City of El Centro Dog Park Name (PDF) • Naming Dog Park EC appl (002) (PDF)
• Policy-51-Naming-Streets-and-City-Facility (PDF)
8 Packet Pg. 43
Dog Park Survey
Are you a
resident of
El Centro?
A community member submitted
"Pups at Play Dog Park." How do you
feel about that suggestion and why?
What suggested name for the dog park do you have and why? Yes It’s ok, a little long “The Bark Park” It’s cute, short, to the point, fun.

Yes
The park should be named the Heald Pups
at Play Dog Park.

Heald Pups at Play Dog Park. Phil and Elise Heald have a long history of community engagement as small business owners, elected officials, and philanthropists. They donated a half-million dollars for this park, toured other dog parks to assist with the design, and were the MAJOR advocates in getting the park designed and built. If the City of El Centro wants to encourage other community members to support and donate for other city facilities/needs, they need to honor those who do so.

No
The suggested name is OK but It sounds
more for smaller dogs only "It's a Dogs World" We love this name because it emphasizes all dogs are a priority and where they can socialize at this park and have fun too.

No Too long. "Bark Park" Because that's what it is, and it rhymes.

Yes Not feeling it Phil “Heal” Dog Park - honors the largest donor and the play on words “heal” signifies calm, peace, serenity Yes I believe that name is too long for the park. Skateview Dog Park, Barking Lot, Barkside Park, Fetch Fields, Pawtopia, Wagging Field.

Yes No thanks K-9 AMIGOS DOG PARK
Yes
Kinda feels too long. Who would say "Let's
go to the Pups at Play Dog Park!"
I have a couple of names to choose from such as, Doggo Land park, Pooch Palace park, the Bark park, the Bark Lounge, Waggin Walk's park, Mutt Meadow, Barkside Park, Doggy Hill park(or just Doggy Hill), a couple of more too. I feel like these names would fit better because it's short, memorable, and cute.

Yes
I don't love it. It's too long, and a little
generic. Shouldn't it be Pups N Play Dog
Park? But still I think it's too long. The Spawt Dog Park or Spawt Dog Park, incorporating Spot+ Paw. Bark Heaven Dog Park. K9 Oasis Dog Park or Canine Oasis Dog Park.

Yes
I feel that the name is too long and it
should say something more pleasing than
"dog park."
I personally think I have an awesome recommendation for a name and that is "The Doggy Plaza" or without "the" and just "Doggy Plaza." And this would qualify option 3: to strengthen out identity. Because let's be honest "Imperial Valley Dog Park" sounds so lame, like we can't be naming every place we have starting with "Imperial Valley." For one, this valley is small and not that cool. For two, we need to make it cooler and more appealing by having cool places with unique names. Another recommendation I have is "Fur and Flowers" but that's if there is going to be cute plants and trees, which would satisfy option 4. We can also do "The Dog Zone" or "The Doggy Zone." Yes

suggestions? To be fair, you should listall suggestions or none at all.

Yes The name sounds good "Bark Avenue" Dog Park since it rhymes with Park Avenue, where it's located.

No It’s pretty basic Sunny paws, cause it’s a playful name and represents the weather of the region.

Yes

pups) The Woofs at the Canine Park
Yes
it’s sounds like more of a slogan, not a
name. If it was for example Pappy’s play
park, or Pups Parks, that makes more
Name it after the late Doc Thomson, (vet) he helped thousands of children with their animals for the fair and always only charged $1. Besides all the other things he did. It could be named something like Doc’s Doggie Park. Or name it whatever you want just do it in his honor. Some other ideas for names; Bark Park, Paws Park. So excited for a dog park, keep up the good work EC. Ruff, ruff! No Indifferent Atomic Dog Park
Yes It sounds like talking not as name. FUN PAW Dog Park. 🐾🐾 It is a place where pets would have fun, it is easy to pronounced and remember.

Yes Too simple
Doggy Dreamland Doggy Dog World The Barking Lot Tails and Trails Pawsitive Park Paws and Play Barktopia Barktropolis Bark in The Park Dog Den Dog Park
Yes not all dogs are pups Park Avenue Paws Paws on Park Avenue Park Avenue Bark Park Yes Not all dogs are pups. WHO LET THE DOGS OUT PARK!!?

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Attachment: Survey Results for City of El Centro Dog Park Name (6058 : Naming of Dog Park) Dog Park Survey
Yes Good name but a bit too long. Parque de Woof. It's a fun and playful name for a dog park. I think it would definitely attract attention.

Yes
It works well. It’s a happy and inviting
name for a dog park. Pluto’s Park for Pups and Pals.

Yes Not good Paw Play Park
Yes It’s nice and interesting
Imperial Valley SnoopDog Park. My reasoning for the choice of name is because snoop dog is and inspirational person to people and dogs. Also everyone mostly likes marijuana.

Yes Cute, b/c it's cute :) Furry Friends parks b/c cats and other furry animals owners should feel welcomed Yes Too large. The Barking Spot
Yes I like it Sunny Day Dog park, because it sounds wholesome and it's always sunny here for the most part ;) No NO Name it after the family that donated 500K to that park.

Yes

twister. Liberty dog park
Yes No, sounds not good Pino Park, like pine tree, strong. Also in memory of Pino Pita, proud Lifetime pup el centro resident, a loved Chihuahua 2007-2022 Yes It’s cute, but a little long. Bark Avenue. Simple, cute and flows.

Yes Cute name but long Bark Park, rhymes and short
Yes

long. Woofington Park. I think it’s just a fun name to have “a ton of woof”.

No N/A The Bark Park
Yes
Do not like , because they are not pups
always they grow up Heeld Dog Park you teach a dog to heel and with the d it sounds like Heald , the philanthropists who made this happen Yes
I don’t really like I’d want the name to
present something of the valley in the
name or have some correlation with el
Desert Paws Park Imperial Tails Trail Valley Paw Paradise El centro canine grove Sunset trials dog oasis Imperial legacy paws park I have these suggestions I think these are good names because they have a connection with the imperial valley.

Yes
I don’t think that’s a good name. It could
be a good motto though. Have the official
name. And then below that “pups at play”
This park wouldn’t be possible without the Heald family. By all rights it should be called Heald Family Dog Park. Family can be two meaning. The actual Heald Family. And also calling the park a Family park since we all agree dogs are part of our families Yes 9/10 Barklin Park
Yes Its a little too long. But not terrible El Centro Paws Park Yes Not feeling it. I would name it after the couple that provided the funds to construct the park, the Heald's. Without them, this park would not have happened.

Yes
Negative on the pups at play. Nothing
cute or saccharine. The El Centro Dog Park. This will accurately brand the city and most users will simply refer to it as the dog park.

Yes I am not opposed to the name
Central ‘Bark’ Park 1. It incorporates El Centro into the name 2. It’s catchy and it’s flows 3. Central Park is iconic and it also reminds one of the hit show friends 4. Dogs parks are also known as Bark Parks Yes I’m not opposed to the name
Central ‘Bark’ Park 1. It incorporates El Centro into the name 2. It’s catchy and it’s flows 3. Central Park is iconic and it also reminds one of the hit show friends 4. Dogs parks are also known as Bark Parks Yes I don't like it. The name should be shorter. Doggies City Yes it's basic like we can do better el centro run zone (dogs run) bark n play (self explanatory ) community paw park (sounds really cute) Yes It sounds ok Paw Park or Bark Park
Yes Very excited Jet Plunge

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Attachment: Survey Results for City of El Centro Dog Park Name (6058 : Naming of Dog Park) Dog Park Survey
Yes
It's a good name, however I have other
suggestions
Pawsome Haven ~ it's a haven for dogs and its awesome Pawprints Park ~ clean simple, classy Paw Park Plaza ~ following the same theme of 'paws' Thoughts?
Yes Ok Best friends Park
Yes
Terrible idea. The Healds donated
$500,000 to the park and the park should
be at least partially named after them.

They need to be recognized more than a Phillip and Elise Heald Dog Park Yes
I'm not a big fan as it feels like too many
P's to prounounce. Sunnyside Dog Park because its short and sweet and straight to the sunny El Centro Point.

park. K-9 Korner, it's a dog park located in a corner lot.

No
I believe it's a good name, however, I
think a wittier name would uplift the
overall feeling of bringing your pup or dog I suggest the following 3: 1. Central Bark Dog Park 2. Paw-some Walks Dog Park 3. Friends Fur-ever Dog Park Yes It doesn't rhyme
"Bark Park". Dogs are fun and Playfull and don't judge. so why not a fun name, not every park has to be dedicated to President or DEA agent. Keep it fun and refreshing. Thank you.

Yes Too long Bark Park
Yes No, too long Ruff Ave or The Ruffies
Yes Ehh Bark Park. Its catchy, cute, and to the point.

Yes Doesn't sound right. *Doggie Ave. *Bark Avenue ( SINCE IT'S ON PARK AVE) No No, too many words El Centro Dog Park It’s in el centro Yes I like that. It's catchy. I like the one someone submitted in ? 2.

Yes I think the name is too basic, The Firulais Dog park Yes
Great suggestion, but I feel that it should
be a little more creative. Tails 'n Trails. A fun name for what will be a beautiful and fun place for our furry friends.

No Not all dogs are pups My Best Friend Dog Park
Yes Not Sure. El Centro K9 Park. The name would fit and look good in the Ads. Also, is short and will give you the whole idea of what it is in 1 word.

Yes That has a great ring to it Paws 🐾🐾and Play Park OR Waggy Tails at Play Park Yes It sounds nice Man's Best Friend Dog Park
Yes
To long and the name should represent
the city in some way.

Suggested Name: Desert Tails Park Embraces the unique desert environment of El Centro, creating a connection between the park and the city's geographical identity. Online reference: The use of "Tails" provides a playful and clever twist, incorporating a nod to the animals the park is designed for. The name is likely to stick in people's minds, making it a memorable choice for a dog park with a distinctive local touch. The name offers a blend of geographic relevance, positive imagery, and playfulness, making them suitable options for naming the new dog park in El Centro.

Yes
I don't like it. When said out loud there is
too much syllable repetition. Bark Park, simple to the point and it sends a clear message across of what to expect when someone says, "Hey let's go to Bark Park!"

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Attachment: Survey Results for City of El Centro Dog Park Name (6058 : Naming of Dog Park) Dog Park Survey
Yes
Pups sounds okay.. but I know there are
better options. This is a dog park, the
valleys first and as far as I know, only dog
park. The Valley should be proud about
that, incorporate the Valley, or some of its
features into the name.
• Imperial Valley Dog Park: self explanatory. It’s a Dog Park in the IV! • Desert Tails Dog Park: these fur babies are desert rats just like the rest of its residents, except they got tails. It’s a nice way to bring in the whole Desert aspect of the Valley. • Sandy Paws Dog Park: also pretty self explanatory. The Valley is known for two things, its great agriculture and its sand… cause we’re a desert. • Sunpup Dog Park: I know we’ve all seen our dogs lay out in the sun, their little legs outstretched behind them and they lay on their bellies. Who else in this country gets more sun besides Deathvalley? The Imperial Valley! These are nice and creative ways to incorporate some of the things that makeup the Imperial Valley into its newest addition. Excited for this Dog Park, can’t wait to see what it’s like! Yes Too long Puppy Play Park Triple P, something that can be abbreviated Yes

pronouncing it Sunny Daze Dog Park, sunny represents the valley and daze is hinting at the fun you’ll have with your pet companion.

Yes
After half a million of their dollars was
donated to build it…the Healds deserve to
have their name somewhere in the park The Heald Family Bark Park Yes
This name seems too generic and
redundant.

I feel strongly that the Heald/Meyer family should be part of the name due to their significant financial contribution to the project, their leading the charge to create the new park and their important legacy in the City and region (Imperial Hardware Company). This is our opportunity to thank them for generations of positive impact on our City. Both through business investment and ongoing philanthropy.

Yes Too long Wagging Tails Park/ Four Paws Park/ When dogs are excited they wag their tails. Or dogs have 4 paws.

No Ok DOGS R US PARK MY BEST FRIEND PARK
Yes Too long of a name Imperial dog park Centinela dog park Sun dog park paws dog park Pups world dogpark Dogland dog park Yes Not a big fan PAWS&PLAY, i feel like it is more playful and obvious without being confusing and corny Yes
It's cute but no one is going to call it that.

People in our area are one word or
location descriptors type of people. Now if
you're just looking for something to put
on the sign thats more for
visual/aesthetic purposes them i think its
ok. Either way people are probably going
call it things like "Adams Dog Park" or
Bark Place Dog Park / Park Place Dog Park (a play on Park Place from Monopoly and the street name the dog park is on). A longer version might be : Bark/Park Place Dog Park and Play Area. While less cutesy than the previous suggestion, it makes it easier and more identifiable in my opinion.

My other suggestion would be to name it after a famous dog because people like the sentimental and will more than likely make them remember the actual name instead of giving it it a nickname. Names like: - Marley's Dog Park - Balto's Run Dog Park - Lassie's Rescues Dog Park and Play Area The only issue that might arise is copyright but there shouldn't be any since these are just names. Food for thought 🐶🐶 Yes It’s dumb Best Friend’s Park, Non Aggressives Park, Humane Play Park, No Yorkie, No Chihuahua Park Yes No, Not very original name Barksville Park
Yes No thanks. Too long and basic. The Bark Park
Yes No Off The Leash Dog Park Must Love Dog Park
Yes No good :/ Doggy park because it’s better
Yes It’s ok Spot Park (from the spot the puppy franchise), easy and to the point name Yes I feel like it’s too long. Bark Park It’s short. Simple. It rhymes. And it matches the street name. Yet it still symbolizes a park for dogs.

Yes
Lame its just feels like a event not a dog
park name Edwin Contreras he is a cool person
Yes

my Huskey FIRULAIS PAW CAMP, SINCE MOST OF THE POPULATION IN EL CENTRO ARE HISPANICS, WE ALL RECOGNIZE THE NAME FIRULAIS TO BE A DOG.

Yes Too long it should be something short Dog Central I feel likes it more short and it easier to say in English and Spanish.

No Alliteration doesn't appeal to me. Ruff Times Dog Park

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Attachment: Survey Results for City of El Centro Dog Park Name (6058 : Naming of Dog Park) Dog Park Survey
Yes
No, I dont think it’s a catchy name for the
park.

Bark Park. I’m an owner of Belgian Malinois and they love to bark. The new dog park will be the place where they and other dogs will be able to bark and enjoy themselves.

Yes No, my suggestion is better A Place to Heald, this is a sanctuary for dogs and also honors the donors Yes

reference the park. Playful Pups Park has
more alliteration.

Is there a canine that did a lot for the community like a police dog? I like Toto Park because he is one of the most famous dogs. Pluto Park because he is another famous dog and there is more alliteration.

Yes
The name of the park is an opportunity to
highlight an aspect of El Centro history. If
this is the only suggestion, please continue
to receive alternative names. Further research to consider historic nicknames for El Centro or a historic individual who advocates for parks/recreation in El Centro Yes I don’t like it. Fido Park or North Side Dog Park
Yes That is fine Dogs To Depend On, Bark. Different rhyme Yes Too generic Central Bark Dog Park
Yes

the name. Tail Wagging Park
Yes Yes, our family our dogs pups
Yes I feel it’s a little long and repetitive I have a suggested (Pawsitivity park) (Dogs and Paws park) Yes
Heck yea, that’s a great name for the dog
park because most dogs would just go to
play, besides it’s very simple and easy
Yes
It’s a no for me. As a memeber of this
community I know we like stories and
places that are meaningful, that create a
connection with each individual. The park
would benefit much more with a name of
a dog or dog owner
A dogs name. Easier to remember and something touching. I had a dog named Matias. He was 2 years old. A great cattle dog who loved to explore, go to the park and roll in the mud. He was an excellent dog. He took care of my entire family, was a beautiful dog and a sweet boy.

Unfortunately once walking towards my youngest brother he was hit by a car. It was devastating and tragic. All of my neighbors were deeply saddened by his sudden death. I know that he would have been beyond excited to visit this new dog park. It would have been amazing to see him run around, meet new dogs and allow others to see what an amazing and beautiful dog he was. Even though he isn’t here anymore, people can still know his story. I’m sure there are much greater stories out there this one is just my favorite because he was my dog. Hope i get to visit the “Matias dog park” or learn about another amazing pup who earned the title. Thank you.

Yes

general. Bark Avenue Park It’s a play on both the barking which ties it to dogs and also Park Avenue Yes Too long. Lincoln Dog Park. Lincoln is a great name.

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Attachment: Survey Results for City of El Centro Dog Park Name (6058 : Naming of Dog Park)

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Attachment: Naming Dog Park EC appl (002) (6058 : Naming of Dog Park) The "Heald Family"
"Heald Family" encompasses four generations of Healds and Meyers from 1906 to now.

Howard Meyer, 17 years old, traveled weekly in 1906 to Holtville coming from San Diego while driving a wagon drawn by mules carrying goods to supply local stores. He soon used opportunity to purchase his first store, preceding future Imperial Hardware stores throughout Southern California and the Yuma area. Over the years, Meyer and his first wife Edith (& 3 daughters) were persuasive leaders of community fulfillment needs. At an early time in his career, Meyer organized and funded the Holtville and Calipatria libraries. Later throughout his life he lead local efforts for El Centro's Community Hospital on Ross Ave. and provided leadership and funding for IVC and many other Valley organizations, as well as helping and advising troubled "downtowns" in smaller cities.

Elmer Heald arrived the Valley as a fledgling attorney in 1919. Just home from WWI, he met and soon married Helene, and began a family. He progressed in a legal career to be a highly respected Superior Court Judge, and later was elected to Grand Master of California Masons. The Judge's stepson, Fred Heald, attended El Centro schools where Fred met his future wife Marjorie Meyer. After graduating college and medical school Fred returned to El Centro.

With his bride Marjorie he began a family, adding 3 children Alan, Phillip and Kathleen. Dr.

Fred's life was interrupted by Army Air Force shortly after the third child was born. He served as a Flight Surgeon in India, returning home as the war was ending in 1945. After return he established Desert Medical Group including several specialists within his group. Following his leadership of his group and he was a strong factor in creating the El Centro Community Hospital. In addition, Dr Fred and Marjorie made many trips around the USA to recruit doctors to benefit and improve the local medical quality and experience. Those efforts brought an entire generation of excellence among the many doctors he introduced to our Valley.

Phil Heald, and his cousin Mike Kearney, were third generation Meyer grandsons. Both had worked in Imperial Hardware in summer jobs. After military service they both returned to begin lifetime careers in the family business. Phil has chaired fund drives for important public causes, and he and Elise have been generous with their time and donations to many causes. They also take pride in their Jacques 'n Jills Health Club, which was a first in its creation as a needed community health addition. Meanwhile, as the years passed with both successes and defeats to tough challenges to retail merchants, Phil and Mike decided it was time to sell the remaining stores. The sale to an Ace store owner was completed in July 2020. Sadly, Mike Kearney succumbed to a fast and deadly cancer attack just after the sale was completed.

Retired now, Phil and Elise Heald, married for 58 years, are thrilled to be able to provide the City of El Centro the means and incentive to create this outstanding planned Dog Park. The entire Heald Family, our children, parents and grandparents have all raised, loved and been comforted by our many wonderful dogs. This becomes our gift to dog lovers and to all breeds of friendly pups who soon will romp and socialize together. We hope it will also provide healthy exercise for people with their canine friends, bringing pleasure to all who utilize the park!

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Attachment: Naming Dog Park EC appl (002) (6058 : Naming of Dog Park)

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Attachment
1 CITY OF EL CENTRO

POLICY STATEMENT
Policy Statement No: 51 Adopted: August 7, 2002
Category: Revised: June 2, 2010
Subject: Street and Facility Naming Policy Distribution:

I Purpose
The purpose of this policy is to establish uniform criteria and procedures, applicable to all persons, groups, firms and agencies, for the permanent naming of a city street name, for changing existing street names, or for adopting a name for a city facility. Streets and facilities should generally be named after people, places and events having made significant impact on the quality of life within the city, and/or events of significance to the city’s development.

II Policy
A) Proposed names should generally meet one of the following criteria:

1. to honor and commemorate individuals who have achieved prominence as a result of his or her significant, positive contribution to the United States and/or the local community;

2. to commemorate local history, places, events or culture;

3. to strengthen neighborhood identity; or

4. to recognize native wildlife or natural features related to the City of El Centro.

B) Consideration should be given to names of local areas of historical significance. The following names shall not be used:

1. names of living persons, other than a recognized national figure;

2. duplicative names of streets already existing within the city or the city’s sphere of influence;

3. names which are, and could be considered discriminatory or derogatory, or that express a particular political affiliation; and

4. names that could be considered as advertising.

Features within facilities, such as fountains, reflective pools, special rooms, special features or equipment can be dedicated to the memory of individuals meeting the above criteria in Section A by appropriate plaques without actually naming or renaming the facility.

Buildings, parks, or other facilities previously named for individuals shall not be renamed.

III Procedures

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Attachment: Policy-51-Naming-Streets-and-City-Facility (6058 : Naming of Dog Park) 2 A. Naming New Streets
It is the policy of the City of El Centro that all new public and private streets shall be named prior to City Council consideration of a tentative or parcel map creating a new street or street segment. The criteria for naming new streets shall be as follows:
1) Consistency in naming shall be maintained within a Subdivision Tract, Planned Development, or other development or geographic area where street name themes currently exist, are planned or are discernible.
2) Street names shall remain the same across intersecting streets. 3) Street names shall be in compliance with the City’s Circulation Element. 4) The use of the same name but different suffices for adjacent streets shall be avoided, with the exception of a small court or cul-de-sac adjacent to a main street. 5) The number of letters in the street name, including suffix, shall be compatible with the physical limitations of street name signs used in the City. 6) Similarly spelled or pronounced street names shall be avoided within the City. 7) Spelling and Pronunciations – Street names shall be easy to spell and easy to pronounce.

8) Spelling – Spelling shall be standard American Spelling and verified with the proper sources.
9) Duplication shall not be permitted within the city limits or in adjacent communities.

Similar sounding names shall be considered duplications. Proposed Street names shall be checked against a City/County street atlas before proposal to the City Council. 10) Unacceptable names include:
a) New numerical names (except for extensions of existing streets); b) New letter names (except for extension of existing streets); c) Directional names (such as North Street).

B. Renaming Inhabited Streets
It is the policy of the City of El Centro to maintain approved and established street names on inhabited streets whenever convenient and necessary for the public safety and welfare. The City Council acknowledges that street name changes on inhabited streets may lead to confusion and inconvenience for residents and existing businesses. Therefore, street name changes on inhabited streets shall be approved only when it can be clearly demonstrated that more than 50% of all property owners, or their authorized designee, within 300 feet of the subject city street favor the action. The application procedure to rename a street shall be as follows:
1) Petitioner submits an Application for Renaming City Streets to the Planning and Zoning Department.

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Attachment: Policy-51-Naming-Streets-and-City-Facility (6058 : Naming of Dog Park) 3 2) The application shall include the following:
a) the present official city name of the street
b) the proposed new name;
c) a street map showing the location of the proposed street name change; d) the name, address and contact information of the person requesting name change; e) a statement of reasons supporting a street name change; f) a petition signed by more than 50% of all affected property owners or their authorized designee, indicating their support of the proposed street renaming. “Affected property owners” means property owners within 300 feet of the street whose name is proposed for change. Property owners shall be determined from the current city real property ad valorem tax roll;
g) a non refundable application fee in the amount set by resolution of the City Council.

After receipt of a completed application for a street name change, the Planning Director shall distribute the request to the following departments for input regarding the potential impacts of the name change on the operations of city departments and other affected entities: City Manager, Public Works/Engineering Department, Economic Development, Police Department, Fire Department, and Parks and Recreation Department.

Some of the criteria which shall be used in consideration of public street rename requests are as follows:
1) Number of businesses/residents directly affected. Consideration in this category would focus on the number of properties directly affected.
2) Recognition of community diversity. Consideration of this criterion would endorse evolving community diversity.
3) Recognition of historical significance. Consideration of this criterion recognizes the historical significance of existing street names and the importance of recognizing the potential future historical importance of current events and developments. 4) Appropriateness given types of uses along subject street. Consideration of this criterion would ensure reasonable compatibility between land use and street name. 5) Impacts on emergency services. Consideration of this criterion will ensure that replacement names for existing streets will not result in confusion related to efficient access for emergency purposes.
6) Precedent. Consideration of this criterion will determine whether an action to rename a street might establish a desirable or undesirable precedent. 7) Continuity and Stability. Consideration of this criterion will evaluate the affect of a rename request on the public’s general connection with the existing name.

Applications for street name changes which meet the criteria outlined in this policy shall be considered by the Planning Commission for its recommendation. The recommendation of the Planning Commission shall be forwarded to the City Council for final action. A public hearing before the Planning Commission and the City Council shall be held with proper notice of the hearing. Written notice of the public hearing shall be sent to all property owners within 300 feet of

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Attachment: Policy-51-Naming-Streets-and-City-Facility (6058 : Naming of Dog Park) 4 the street whose name is proposed for change, as indicated on the most recently approved ad valorem tax roll, at least ten (10) days prior to the hearing via first-class mail and shall contain the proposed name change and the date and time of the public hearing.

The favorable vote of a majority of the Council members present is required to change the name of the street except as follows: The favorable vote of four-fifths of all members of the City Council is required if a written protest against the street name change has been signed by the owners of at least 20 percent of all lots abutting the street. Written petitions need to be filed with the City Clerk’s office before the start of the scheduled public hearing.

Costs of Renaming Street
The costs of making and installing all the necessary signage for the honorary designation shall be paid for by the proponents. The Director of Public Works shall compute the costs of the making and installation of the signs and provide the amount of the costs to the proponents. If the City Council approves the designation, the proponents shall pay the full amount of the costs to the City prior to the making of any of the necessary signs.

C. Facility Naming Procedure
Requests for renaming existing City facilities or naming new City facilities may be initiated by any person or group and submitted to the appropriate Board/Commission or City Council as follows:

Community Services Commission - Parks and recreation facilities.

Library Board – Libraries.

City Council – Other Buildings or Facilities.

The request for renaming existing facilities or naming new facilities must be reviewed by the designated Board/Commission prior to consideration by the City Council. The recommendation by the designated Board/Commission shall be submitted to the City Council for final action. A public hearing before the Board/Commission and/or City Council shall be held with proper notice of the hearing. Written notice of the public hearing shall be sent to all persons requesting such notice at least ten (10) days prior to the hearing via first-class mail and shall contain the proposed name of the existing or new facility and the date and time of the public hearing.

The favorable vote of a simple majority of the Council members present is required to adopt a name of a new facility or to change the name of an existing facility.

All costs associated with a request for renaming a city facility shall be borne by the applicant.

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Attachment: Policy-51-Naming-Streets-and-City-Facility (6058 : Naming of Dog Park) City of El Centro
Application for Naming New or Renaming Existing City Facilities Name of Person/Group requesting change: _______________________________________ Address: _________________________________________________________ _________________________________________________________ Phone Number: _________________________________________________________ E‐Mail Address: _________________________________________________________ Location/description of new City facility: _________________________________________ _________________________________________
Present official City name of existing facility: _______________________________________

Proposed name of new or existing facility: ________________________________________ Reasons supporting facility name change:
______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ Contributions to the City of El Centro:
______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ ______________________________________________________________________________________ Person for whom naming is proposed: _________Living _________ Deceased Applicant acknowledges responsibility for cost of replacement signs or new plaques____Yes (please initial) _______________________________________ _________________________________________ Signature Date

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Attachment: Policy-51-Naming-Streets-and-City-Facility (6058 : Naming of Dog Park) City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Community Services
El Centro, CA 92243 Category: Acceptance of Report
Prepared By: Clara Obeso
SCHEDULED Department Head: Adriana Nava
ACTION ITEM (ID # 6312) DOC ID: 6312
Discussion and Related Action Regarding Acceptance of the 2024 Draft Housing Conditions Survey Report.

CITY MANAGER’S RECOMMENDATION:

Staff recommends that the City Council accept the Housing Conditions Survey Report as it is mandated by the City's five-year Consolidated Plan.

FISCAL IMPACT:

This report had no impact on the general fund. Approximately $74,000 was utilized from the 2023-2024 CDBG Entitlement Program funds.

STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #3 - Community Health, Safety & Welfare
Goal #4 - Recreation and Lifelong Learning
DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

The Economic Development Division staff completed the Request for Proposals (RFP) and released the RFP on July 28, 2023. A proposal from R3E Services was received.

Staff reviewed the proposal from R3E Services and determined that R3E Services is qualified to complete the scope of work regarding the Housing Conditions Survey.

BACKGROUND:

The City's previous Housing Conditions and Vacant Land survey was completed in 2015. As such, an updated report was required in order to comply with the City's fiveyear Consolidated Plan. For the purpose of this 2023-2024 survey, the vacant land component was excluded given that it had been incorporated in the Housing Element.

DISCUSSION:

The Housing Conditions Survey attached hereto for review, encompassed five key dwelling features: foundation, roofing, siding/stucco, windows, and electrical. These features were surveyed using specific criteria. The survey encompassed nearly 200,000 individual data points, including key site conditions, such as landscaping, frontage improvement conditions, and missing frontage improvements. Results indicate that in the residential zones, there are properties lacking 461 sidewalks, 275 curbs, 230 gutters, 551 driveways, and 497 inadequate site drainage due to obstructions or damaged, and/or missing curb gutters.

Based on the survey results, the report listed the following recommendations:

1. Targeted Outreach Program- Develop a targeted outreach program to collaborate with homeowners of properties with the goal of informing them about funding opportunities for property rehabilitation and to track the progress of these programs.
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Action Item (ID # 6312) Meeting of April 2, 2024
Through the City’s Community Development Block Grant, a total of 9 housing rehabilitation projects have been completed over the last 15 years. The Economic Development Division is currently in the final stages of a rehabilitation project. Earlier this month, one (1) application was approved and three (3) others are presently undergoing review.

There are currently 40 interested parties on the wait list. The Economic Development Division continues to target homes that are in disrepair in order to improve the housing stock of El Centro.

2. Neighborhood Beautification Program- Develop a Neighborhood Beautification Program involving outreach, tracking, and monitoring of homes with debris or junk in the yard. Provide courtesy notices.

The Code Enforcement Division works to beautify neighborhoods by tracking, completing outreach and monitoring homes that don’t meet Code requirements. This includes overgrown vegetation and junk in the front yard.

3. City-wide Vacant Property Assessment- Conduct a city-wide vacant property assessment identifying vacant properties in both residential and commercial zones for community and economic development. Knowledge of vacant properties could help identify areas of opportunity to address affordable housing issues. Identifying vacant land in commercial zones can assist in classifying and identifying areas for enticing coveted business sectors in the City.

A Housing Vacant Property Assessment was completed with the Housing Element. The City will work towards completing a vacant commercial property survey for the purpose of spurring economic development.

4. City-wide Inventory and Condition Assessment of Stormwater Drainage AssetsConduct a city-wide inventory and condition assessment of the City’s stormwater drainage assets, including non-residential properties. This is in preparation for the development and implementation of a master drainage plan.

Public Works is in the process of completing an Inventory and Condition Assessment of Stormwater Drainage Assets. Additionally, a total of $892,902 has recently been allocated for curbs, gutters, and sidewalks using CDBG funds.

5. Future housing surveys should be conducted in a similar manner, employing the same data structure to track housing condition trends and the progress of implemented programs.

Will continue to conduct housing surveys to remain updated and aligned with the housing conditions and stock in the City.

CONCLUSION:

Staff recommends that the City Council accept the Housing Conditions Survey report and integrate it into the City's five-year Consolidated Plan.

ATTACHMENTS:
• DRAFT Housing Conditions Survey Report (PDF)
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R3E 1
| Services
R3E
February 15, 2024
City of El Centro
Housing Conditions Survey
(Draft) Report v1.3

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 2 Contents
Executive Summary.......................................................................................................................................4 Introduction ..................................................................................................................................................5 Purpose and Scope....................................................................................................................................5 Definitions.....................................................................................................................................................6 Methodology.................................................................................................................................................6 Preparation ...............................................................................................................................................6 Research and Prep ................................................................................................................................6 Quality Assurance .................................................................................................................................6 Database ...............................................................................................................................................7 Survey........................................................................................................................................................7 Included.................................................................................................................................................7 Excluded................................................................................................................................................8 About El Centro.............................................................................................................................................8 City Profile.................................................................................................................................................8 Demographics...........................................................................................................................................9 Key Findings ................................................................................................................................................10 Overall Housing Quality ..........................................................................................................................10 Health and Safety/Quality of Life............................................................................................................11 Drainage ..............................................................................................................................................11 Accessibility and Compliance with Regulations......................................................................................12 Analysis .......................................................................................................................................................12 Construction Type...................................................................................................................................15 Structure Type.........................................................................................................................................15 Landscaping.............................................................................................................................................16 Other Conditions.....................................................................................................................................16 Frontage Improvements.........................................................................................................................17 Sidewalk, Curb, and Gutter Conditions...............................................................................................17 Missing Frontage Improvements ........................................................................................................19 ............................................................................................................................................................19 Structure Element Conditions.....................................................................................................................19 Foundations............................................................................................................................................19 Roofing....................................................................................................................................................20

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 3 Siding/Stucco ..........................................................................................................................................20 Windows.................................................................................................................................................20 Electrical..................................................................................................................................................21 Recommendations......................................................................................................................................21 Future Considerations.................................................................................................................................21 Trends and Progress............................................................................................................................21 Vacant Land.........................................................................................................................................21 Drainage ..............................................................................................................................................21 Disclaimer....................................................................................................................................................22

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 4 Executive Summary
The Housing Conditions Survey, concluded in February 2024, reveals that El Centro boasts a predominantly robust housing stock, with 88.04% classified as being in sound condition based on the California Housing and Community Development criteria. The breakdown is as follows: 5.23% exhibited minor damage, 1.44% were classified as moderate, 0.01% had substantial damage, 0.03% were in the worst category of dilapidated, and 5.15% were either non-residential or vacant land, with scores not assessed.

The evaluation encompassed five key dwelling features: Foundation, Roofing, Siding/Stucco, Windows, and Electrical. These features were surveyed using specific criteria with weighted values, and the total was calculated to determine their respective classifications.

The survey encompassed nearly 200,000 individual data points, including key site conditions such as Landscaping, Frontage Improvement Conditions, and Missing Frontage Improvements. Results indicate that in the residential zones, there are properties lacking 461 sidewalks, 275 curbs, 230 gutters, 551 driveways, and 497 with inadequate site drainage due to obstructions or damaged, and/or missing curb and gutters.

Based on the survey results, we have listed five recommendations below:

1. Targeted Outreach Program:

Develop a targeted outreach program to collaborate with homeowners of properties identified as moderate, substantial, and dilapidated. The goal is to inform them about funding opportunities for property rehabilitation and to track the progress of these programs.

2. Neighborhood Beautification Program:

Develop a Neighborhood Beautification program involving outreach, tracking, and monitoring of homes with debris or junk in the yard. Provide courtesy notices to remove debris or junk. Additionally, make efforts to connect local landscapers with property owners to encourage site improvements.

3. City-wide Vacant Property Assessment:

Conduct a city-wide vacant property assessment identifying vacant properties in both residential and commercial zones for community and economic development. Knowledge of all vacant properties could help identify areas of opportunity to address affordable housing issues. Identifying vacant land in commercial zones can assist in classifying and identifying areas for enticing coveted business sectors to the city.

4. City-wide Inventory and Condition Assessment of Stormwater Drainage Assets:

Conduct a city-wide inventory and condition assessment of the city's stormwater drainage assets, including non-residential properties. This is in preparation for the development and implementation of a master drainage plan.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 5 5. Future Housing Surveys:

Future housing surveys should be conducted in a similar manner, employing the same data structure to track housing condition trends and the progress of implemented programs.

Introduction
Purpose and Scope
In November 2023, the City of El Centro contracted R3E Services LLC to conduct a Housing Conditions Survey according to Community Development Block Grant (CDBG) requirements. The City sought to gain insights into the current housing stock conditions within the City of El Centro to empower the City’s executive leadership team to make informed decisions on using CDBG funds for housing rehabilitation programs.

The work consisted of the following key stages:
• Research & Coordination
o Compiled authoritative data from various government sources, including California Department of Housing and Community Development requirements, land-based datasets, and other pertinent information.
o Worked with City staff to identify expected outcomes, necessary data, and requirements.
• Database Design & Build
o Designed and build a GIS-enabled relational database to be consumed into a mobile GIS application for field technicians to assess and collect data. • Mobile GIS Application Deployment
o Configured and deployed a mobile GIS application to perform field surveys based on the California Department of Housing and Community Development guidelines. • Field Survey
o A parcel-by-parcel field survey was conducted to assess the conditions of buildings within the residential land use zones (R1, R2, R3, RAP, and MU1) inside the city’s geographic boundaries.
o A Quality Control process was conducted on approximately 33% of completed surveys to identify errors and make corrections.
• Data Analysis and Map Creation
o Field data collected was analyzed, and cartographic visual aids and charts were created for the report to help tell the story of the current housing stock in the city. • Report
o A draft report of the Housing Conditions Survey created by R3E Services LLC was submitted to city staff for review and approval before completing the final report for evaluation by the Planning Commission and the City Council. o After the final report was accepted the Final Report, raw data in both GIS-compatible format and tabular data were submitted for consumption on the City’s website. • Present
o Results were presented to the City Planning Commission and the City Council to answer any questions and empower the City’s leadership to make data-driven decisions on how to best utilize the data for programs and mitigation measures that best serve the City of El Centro residents.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 6 Definitions
Term Abbreviation Definition
California Department of
Housing and Community
Development
HCD
State Agency administering
CDBG funds to municipalities
Community Development Block
Grant Program CDBG
Program to support the
expansion of community and
economic development
Dwelling Structure (Either residential or
Commercial)
Housing Unit
Also known as a household. It
can be a house, apartment, or
room where people live and call
their home.

Methodology
Preparation
Research and Prep
All parcels within the city limits were identified and isolated utilizing GIS software. Further analysis was performed to identify only the parcels within the residential zones inside the city boundary lines. The parcels were then converted to points for ease of use in the mobile GIS application developed for data collection.

Quality Assurance
To provide the most accurate results, two critical components were identified and addressed to mitigate risk and ensure the best possible outcomes. It was crucial to develop well-defined processes for collecting the data. The idea was to identify as many scenarios as possible in conjunction with the project requirements to ensure that the application developed would meet the needs of the survey and have the ability to collect the required data, be user-friendly to field personnel, and provide accurate location data would be collected and stored with minimal risk to data corruption and data loss.

Well-defined processes were developed to support efforts in collecting data consistently to provide the most reliable results.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 7 Database
A database was designed using the California Department of Housing and Community Development Sample Housing Conditions Survey. The database stored the spatial (location) data as well as all of the critical features of the dwelling: Construction Type, Structure Type, and Frontage Improvements. In addition, dwelling-specific features with specific ratings were included in the database.

Although vacant land identification was not included as a deliverable for this project, the database was designed to hold data regarding vacant land. Further attribute data was included in the database design to store data regarding squatter presence, occupancy status, possible ADU presence, and landscaping conditions.

Survey
R3E Services LLC developed a custom GPS-enabled mobile GIS application to capture the data in the field via a user-friendly interface. Field technicians were able to see the status of each inspection. Field technicians could visualize each HCS Point to be inspected and perform the necessary survey. Once the inspection was completed, the symbol color would change to show the survey had been conducted.

Field Techs could also see the land use zones inside the application as an overlay. They were instructed to capture any dwellings that appeared to be residential by placing a new point on the map and performing the survey. Non-residential dwellings were also identified if they fell within the residential zones or close to them to ensure no dwellings were missed.

Surveys were conducted using a combination of windshield-style surveys along with walking. Field Techs were instructed not to enter private property and were only authorized to inspect from the public right of way.

Images were captured on some properties during the QC process and when the Field Technicians submitted a Data Validation request. Data Validation requests were part of our quality assurance process. This enabled the Field Technician to escalate an issue. Issues could be that they ran into a situation where they were unsure how to classify a particular property feature or condition. An Analyst or higher-ranking person would review the data and images and make the necessary adjustments. A senior ranking person would perform a field check to make the updates if further clarification was needed.

Included
All parcels with residential dwellings were identified, and surveys were completed on at least one dwelling if dwellings existed on the property. In cases where large parcels had multiple dwellings on a single parcel, Field Technicians were instructed to assess the similarities in the condition of the dwellings. If all dwellings appeared in similar condition and looked similar in style, such as the same paint, finish, and architecture, then only one survey was collected on that parcel. Those situations were

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 8 classified as multi-family since they likely had the same owner and were maintained similarly. However, if the dwellings appeared different in style, color, architecture, or condition, then individual surveys were completed to capture the unique characteristics of each dwelling.

Multi-family dwellings on a single parcel and multi-family dwellings that spanned across multiple parcels that appeared to be part of the same units were treated as one unit since their conditions were generally the same. However, if noticeable differences were identified, then individual surveys were performed.

Excluded
Any property that could not be seen from the road was not inspected and noted in the survey database.

Several properties in the north part of the city along Pico Rd and El Dorado Dr have very long parcels, making it challenging to collect accurate data. Some parcels were behind others, which were only accessible via private roads. Field Techs were instructed to travel only down public roads and not enter private property via private roads even if signs were not posted. It was best to err on the side of caution and respect the privacy of property owners.

Mobile home parks were not included in the survey as many are on private property and are not viewable from the public right of way.

About El Centro
City Profile
Strategically situated along Interstate 8, approximately 120 miles east of San Diego, 60 miles west of Yuma, Arizona, and 12 miles north of Mexicali, Baja California, Mexico, the City of El Centro (see Fig 1) plays a pivotal role as the County seat and the largest municipality in Imperial County, one of the nation's most developed agricultural regions with an annual crop production exceeding $1 billion.

Being the County seat, it serves as the administrative nucleus and employment hub for the region.

Notably, it houses various County offices, including the Public Health Department, the Agricultural Commissioners’ office, and other administrative facilities associated with the County. The City spans approximately 11 square miles and boasts a population of around 49,149. However, this figure undergoes a temporary increase during weekday working hours due to visitors engaged in county business or individuals working within the City.

Operating as a charter city, the City is committed to providing a comprehensive array of services to meet the needs of its residents and businesses, both within the City and its sphere of influence. The spectrum of services and facilities the City offers encompasses Administration, Drainage, Fire, Law Enforcement, Library, Parks and Recreation, Transportation, Wastewater Collection and Treatment, and Water Distribution and Treatment.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 9 Demographics
Location
Total Population - 49,149
Housing - 16,709
Hispanic or Latino - 42,193

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 10 Fig 1: Location of the city of El Centro within the County of Imperial.

Key Findings
Overall Housing Quality
The scoring criteria provided by the HCD in their Sample Housing Conditions Survey were used to determine the structure classification. The following guidelines were used as the scoring criteria:

Classification Score Criteria
Sound: 9 or Less
Minor: 10 – 15
Moderate: 16 – 39
Substantial: 40 – 55
Dilapidated: 56 and Over
Five housing features were used in the scoring criteria. Foundation, Roofing, Siding/Stucco, Windows, and Electrical were each given four or five weighted choices for Field Technicians to evaluate. Conditions that had more severe damage were weighted with a higher score. The scores from each feature were totaled to determine the housing condition classification.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 11 The majority (88.04%) of housing in El Centro is classified as Sound, meaning the homes are in good condition and do not interfere with the quality of life. 5.23% had minor issues, and less than 1% of homes were considered to have substantial damage or dilapidated.

Health and Safety/Quality of Life
Although most homes were considered to be in sound condition, over 1500 frontage features are missing.

Frontage Missing Description Quantity
Sidewalk 461
Curb 275
Gutter 230
Adequate Site Drainage
Curb and gutter obstructed or
curb elevation below are
nearly even with the road
where water pooling may
occur.
497
1526 homes have primarily no landscaping, and 292 properties have very poor landscaping conditions, including overgrown grass and or debris or junk in their yard, which can affect the overall quality of life for nearby residents.

Drainage
Poor drainage can cause pooling of stagnant water, mosquito infestations, and property damage.

Sound, 88.04%
Minor, 5.23%
Moderate, 1.44%
Substantial, 0.10%
Dilapidated, 0.03%
Not Applicable, 5.15%
Sound
Minor
Moderate
Substantial
Dilapidated
Not Applicable

0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00% 70.00% 80.00% 90.00% 100.00%

STRUCTURE CLASSIFICATION
Structure Classification

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 12 Accessibility and Compliance with Regulations
Sidewalks and adequate drainage are necessary to ensure fair access to safe pedestrian transportation throughout the city for those with disabilities who may require assistance when walking or traveling via pedestrian networks. It is also essential to have sidewalks to reduce the need for children to enter the roadway when traveling on foot.

Analysis
Nearly 200,000 individual data points were evaluated during this survey to capture the details needed to adequately assess the overall housing conditions within the city of El Centro. Twenty-two different characteristics were assessed in over 9,000 units (see fig 2 for a general reference of locations surveyed). The primary targets were residential dwellings. However, 144 non-residential dwellings were noted in or very near residential zones. Non-residential properties include churches, businesses, and parking lots. Twenty locations were classified as Other, which included parking lots. These items were identified during the survey to ensure that the property was not overlooked, as it is challenging to locate the properties used from a plan view, such as aerial imagery. See Fig 3 for a map of locations classified as Non-residential and Other.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 13 Fig 2: Locations surveyed in the City of El Centro. See Appendix A for locations classified as Dilapidated or Substantial, See Appendix B for all other Unit Condition ratings.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 14 Fig 3: Clustered locations classified as Non-residential and Other. See appendix C for larger map.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 15 Construction Type
Structure Type

96.20%

2.53% 0.67% 0.61%

0.00%

20.00%

40.00%

60.00%

80.00%
100.00%
120.00%
Wood Frame Masonry Mobile Modular
Construction Type
Construction Type

24.73%

4.81%

1.77%

68.22%

0.48%

0.00%

10.00%

20.00%

30.00%

40.00%

50.00%

60.00%

70.00%

80.00%
Single Family With
Detached Garage
Multi-Family Duplex Single Family With
Attached Garage
Other
Structure Type
Structure Type

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 16 Landscaping
Each site was assessed to determine the condition of the landscaping. The following criteria were used in determining the classification for the landscaping conditions:

Classification Criteria
Good condition Lawn well maintained
Fair condition Patchy grass or needs a little maintenance Poor condition Primarily no grass or landscaping
Very poor condition Debris or junk present or poor maintenance Other Conditions
Thirty-five homes were identified as being for sale during the survey. 127 homes were possibly unoccupied. It is challenging to determine occupancy from outside the home. However, Field Technicians were instructed to note if a home might be unoccupied. Twenty-two sites appeared to have people living in tents or substandard conditions without electricity or city services connected. 305 ADUs were identified. Field Techs only captured those they noticed from the street or sidewalk. There are likely many more than that in the city. Further evaluation of some of these is required to determine if action is needed.

Good Condition
69%
Fair
10%
Poor
18%
Very Poor
3%
Landscaping
Good Condition
Fair
Poor
Very Poor

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 17 Frontage Improvements
Sidewalk, Curb, and Gutter Conditions
Several areas in the city were identified as having substandard frontage conditions (see Fig 5). These areas either presented cracking, lips (tripping hazard), or other defects ranging from minor to major.

However, the damage classification was not captured as it was outside this project's scope. The data provides a good starting point for remediation programs. 0 50
100
150
200
250
300
350
For Sale Possibly Unoccupied ADU Squatters
35 127
305
22 Other Conditions
Other Conditions

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 18 Fig 5: Heat map showing concentrations of poor sidewalk, curb, and gutter locations. See Appendix D for larger map.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 19 Missing Frontage Improvements
Structure Element Conditions
Foundations
Foundations were difficult to assess since they are under the house and challenging to evaluate with a visual inspection. However, Field Technicians were instructed to search for evidence of structural cracking in the siding, near windows, doors, and lopsided structures. These provided clues that there were possible foundation issues present.

The criteria used to determine conditions are as follows:

Classification Criteria
Good condition Good condition
No foundation or needs a complete foundation Missing or very damaged foundation Repairs needed Cracks or chipping present
Needs a partial foundation Structural cracks present
0 100
200
300
400
500
600
Sidewalk Curb Gutter Driveway Adequate
Drainage
461
275 230
551
497
Missing Frontage Improvements
Missing Frontage Improvements

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 20 Roofing
There are many types of roofing materials, such as shingles, rolled material, tiles, slates, wood, etc. To keep things simple and align with the HCD sample survey criteria, field personnel were instructed to look for the following criteria and select the most closely matched classification.

Classification Criteria
Good condition Good condition
Shingles missing and or Chimney needs repair Some missing Shingles or Chimney Damage Needs re-roofing Several missing or broken shingles
Roof structure needs replacement and re-roofing Roof sinking in or looks structurally damaged Siding/Stucco
Most homes have a stucco finish. However, various types of siding materials exist, such as wood, vinyl, brick veneer, masonry, etc. Field personnel were instructed to select the criteria best aligned with the available choices. Below are the criteria used.

Classification Criteria
Good condition Good condition
Needs re-painting Paint peeling, extremely faded or mismatched Needs to be patched and re-painting Holes or cracks in stucco or siding damage Needs replacement and painting Siding has major damage, large holes or unfinished Windows
Since the HCD Sample Survey options were somewhat similar, we developed criteria to help stay as consistent as possible. If windows were boarded up where they covered the window panes, then it was impossible to determine the condition of the windows. Some homeowners will board up windows to prevent vandalism, while others board up the windows when the panes are broken. So, if the boards were installed on the inside of the dwelling, then we assumed the glass was broken and selected the option that best fit. Below are the classification criteria used:

Classification Criteria
Good condition Good condition
Broken window panes Broken window panes
In need of repair Window frame is damaged
In need of replacement Multiple windows broken or multiple window frames damaged Boarded Up Boarded Up

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 21 Electrical
Most panels were not visible from the street. However, when they were visible, field personnel selected the choice most closely aligned with the available options. Below are the criteria.

Classification Criteria
Panel not visible Panel not visible from the street
Good condition Appears good condition
Minor repair Minor rust, bent conduit, or low-hanging wires Replace main panel Panel in obvious poor condition
Recommendations
Future Considerations
Trends and Progress
R3E Services LLC recommends conducting future surveys with the same methodology and data structures to track housing conditions trends in the City of El Centro. Doing so will enable the City to evaluate trends and track the progress and benefits of city-wide initiatives related to housing rehabilitation. Housing conditions can affect quality of life and may directly correlate with crime rates.

Therefore, it is essential to track the housing conditions and the effectiveness of any programs implemented as a result of the survey findings.

Vacant Land
Although R3E Services LLC captured vacant land found during the survey, not all vacant land was captured. Therefore, a focused effort is to capture all vacant land within the city of El Centro to help identify opportunities for both community and economic development. The nation is currently experiencing an affordable housing crisis. Identifying vacant land in residential zones can help the city provide data to developers for building affordable housing and identify lots for tiny housing opportunities to alleviate homelessness. A city-wide vacant land assessment can also identify land with specific characteristics that support specific industries that the city seeks to encourage industry development for the city’s business profile.

Drainage
During the survey, we captured areas lacking adequate site drainage in the city's residential zones.

However, it was outside this project's scope to identify the storm drains, and adequate site drainage was not evaluated in non-residential areas.

In recent months, the County of Imperial and the City of El Centro have experienced heavy rains and storms that have caused significant damage. Establishing an updated database of the inventory and conditions of the entire City’s drainage assets will support future efforts to update the City’s Drainage Master Plan, allow the city to update its cost estimates for repairs, and provide updated schedules.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 22 Disclaimer
The survey documented site and dwelling conditions as observed at the time of the survey. It's important to note that conditions may change over time due to natural occurrences, such as rain and wind. Additionally, homeowners may independently take corrective actions, such as yard maintenance, painting, or other repairs.

The choices made during the survey were based on the best options available. However, it's essential to acknowledge a level of subjectivity in the results, as not all scenarios may precisely align with the parameters defined by the Housing and Community Development (HCD) criteria.

Furthermore, substantial efforts were made to minimize errors through process development and several training sessions. However, it's crucial to consider that, given the substantial number of data points assessed, the presence of errors is inevitable.

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 23 Appendix A: Dwellings Categorized as Dilapidated or Substantial

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 24 Appendix B: Dwellings Categorized as Sound, Minor, or Moderate

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 25 Appendix C: Clusters of Non-Residential Dwellings

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) 26 Appendix D: Concentrations of Poor Frontage Conditions

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Attachment: DRAFT Housing Conditions Survey Report (6312 : Draft Housing Conditions Survey Report) City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Community Services
El Centro, CA 92243 Category: Resolution
Prepared By: Clara Obeso
SCHEDULED Department Head: Adriana Nava
ACTION ITEM (ID # 6298) DOC ID: 6298
Discussion and Necessary Action Regarding the 2024-2028 Draft Analysis of Impediments to Fair Housing
CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 24- , A RESOLUTION AUTHORIZING THE SUBMISSION OF THE 2024-2028 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING TO THE U.S.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AND TO IMPLEMENT

THE RECOMMENDED ACTIONS TO ADDRESS POTENTIAL IMPEDIMENTS TO FAIR HOUSING IN THE CITY OF EL CENTRO.

FISCAL IMPACT:

This report had no impact on the general fund. Approximately $44,490 was utilized from the 2023-2024 CDBG Entitlement Program funds.

STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #3 - Community Health, Safety & Welfare
Goal #4 - Recreation and Lifelong Learning
DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

On July 20, 2023, the City of El Centro released a Request for Proposals (RFP) to conduct an Analysis of Impediments to Fair Housing Choice as a component to the City of El Centro's 2024-2028 Consolidated Plan under the Community Development Block Grant Program. City staff followed the required competitive RFP procurement process to select a contractor as set forth in the Community Development Block Grant (CDBG) Procurement Regulations.

BACKGROUND:

In accordance with 24 CFR 91 et seq., 24 CFR 570 et seq., and the U.S. Department of Housing and Urban Development's (HUD) Fair Housing Planning Guide, the City of El Centro is required to conduct an assessment of Fair Housing: Analysis of Impediments to Fair Housing (AI) as a component to its 2024-2028 Consolidated Plan.

The Assessment of Fair Housing is a comprehensive review of a jurisdiction's laws, regulations, and administrative policies, procedures, and practices affecting the location, availability, and accessibility of housing as it relates to fair housing choice. The Assessment of Fair Housing is also a disclosure and review of impediments to fair housing choice in the public and private sector. The research and analysis was focused within the city limits of El Centro.

The proposed Analysis of Impediments is intended to provide the City with technical 10 Packet Pg. 85
Action Item (ID # 6298) Meeting of April 2, 2024
data, analysis, maps, and optional actions, which may be taken by the City and other organizations to overcome impediments to fair housing choice.

DISCUSSION:

As a recipient of federal funds from the U.S. Department of Housing and Urban Development (HUD), the City of El Centro is required to submit an Analysis of Impediments once every five years.

The Analysis of Impediments (AI) is part of the certification to affirmatively further fair housing that grantees are required to help inform the City’s Consolidated Plan. The AI is designed to help identify fair housing issues and contributing factors to those issues.

Grantees must certify their commitment to addressing identified impediments and actively promoting fair housing to meet HUD requirements.

The Analysis of Impediments is a review of impediments to fair housing choice in the City of El Centro, and involves:
• A comprehensive review of the City’s laws, regulations, and administrative policies, procedures, and practices;
• An assessment of how those laws and how they affect the location, availability, and accessibility of housing;
• An assessment of conditions, both public and private, affecting fair housing choice for all protected classes;
• An assessment of the availability of affordable, accessible in a range of unit sizes.

The Draft Analysis of Impediment includes data about the community and will be used as a tool to guide programs, policies, and procedures. The document is attached hereto for Council consideration, review, and certification.

CONCLUSION:

Staff recommends adoption of Resolution No. 24- , A RESOLUTION AUTHORIZING THE SUBMISSION OF THE 2024-2028 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING TO THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

AND TO IMPLEMENT THE RECOMMENDED ACTIONS TO ADDRESS POTENTIAL IMPEDIMENTS TO FAIR HOUSING IN THE CITY OF EL CENTRO.

ATTACHMENTS:
• Resolution (PDF)
• DRAFT Analysis of Impediments to Fair Housing (PDF)
10 Packet Pg. 86
03/2024/cdz/A24-0044/Reso/AnalysisofImpedimentsFairHousing RESOLUTION NO. 24-
A RESOLUTION AUTHORIZING THE SUBMISSION OF THE 2024-2028 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING TO THE U.S.

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT AND TO

IMPLEMENT THE RECOMMENDED ACTIONS TO ADDRESS POTENTIAL

IMPEDIMENTS TO FAIR HOUSING IN THE CITY OF EL CENTRO
WHEREAS, on July 20, 2023, the City of El Centro released a Request for Proposals (RFP) to conduct an Analysis of Impediments (AI) to Fair Housing Choice as a component to the City of El Centro’s 2024-2028 Consolidated Plan under the Community Development Block Grant (CDBG) Program; and
WHEREAS, on September 12, 2023, City Council approved a contract with Mosaic Community Planning (Resolution No. 23-90) to complete such AI; and WHEREAS, the AI identified five primary impediments to fair housing and recommended actions to address each impediment; and
WHEREAS, the five impediments include: 1) Aging housing stock in need of rehab and repair; 2) Disparities in access to community resources and services; 3) Low wages impeding access to opportunities, resources, and restricting housing choice for low/moderate income households and protected classes; 4) Limited supply of affordable housing for low/moderate income households; and 5) Limited housing options for persons with disabilities; and WHEREAS, the recommended actions include, among others, the continued support of the City’s Housing Rehabilitation Program; partnering with Imperial Valley Housing Authority and the California Housing Finance Agency to explore potential funding opportunities to increase the supply of affordable, accessible housing; and fostering collaboration with community partners to broaden the availability of job training and workforce development opportunities; and WHEREAS, it is a CDBG requirement that the AI is certified by City Council for the receipt of funding; and
WHEREAS, with this Resolution, the City Council of the City of El Centro certifies that will affirmatively further fair housing and take appropriate actions to address the effects of impediments identified in the AI report prepared by Mosaic Community Planning.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EL CENTRO, DOES, HEREBY RESOLVE AND ORDAIN AS FOLLOWS:

1. That the foregoing is true, correct and adopted hereby.

2. That the City Council hereby certifies the Analysis of Impediments to Fair Housing Choice prepared by Mosaic Community Planning for the City of El Centro.

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3. That the City Manager of the City of El Centro or designee is hereby authorized to submit the 2024-2028 Analysis of Impediments to Fair Housing Choice to the U.S.

Department of Housing and Urban Development and to implement the recommended actions to address potential impediments to fair housing in the City of El Centro.

PASSED AND ADOPTED at a regular meeting of the City Council of the City of El Centro, California held on the day of , 2024.

CITY OF EL CENTRO
By __________________________
Sylvia Marroquin, Mayor
ATTEST:

By ___________________________
Norma Wyles, City Clerk
APPROVED AS TO FORM:

Office of the City Attorney
By ______________________________
Elizabeth L. Martyn, City Attorney

STATE OF CALIFORNIA )
COUNTY OF IMPERIAL )ss

AYES:

NOES:

ABSENT:

ABSTAINED:

By ______________________________
Norma Wyles, City Clerk

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ANALYSIS OF IMPEDIMENTS

TO FAIR HOUSING CHOICE

PREPARED BY

MOSAIC COMMUNITY PLANNING

BACKGROUND
Title VIII of the Civil Rights Act of 1968, more commonly known as the Fair Housing Act, ensures protection of housing opportunity by prohibiting discrimination in the sale or rental of housing based on race, color, religion, sex, and national origin (the federally protected classes). The Act was amended in 1988 to include familial status and disability status as protected classes.

As a recipient of federal funds, the City of El Centro is required by HUD to complete an Analysis of Impediments to Fair Housing Choice (AI). The AI studies patterns of integration and segregation; racially and ethnically concentrated areas of poverty; disparities in access to opportunity; disproportionate housing needs; locations, occupancy, and policies for publicly supported housing; disability and access; and fair housing enforcement and outreach resources and activities. Based on the findings of this research, the AI proposes a series of strategies to overcome the identified fair housing issues.

EXECUTIVE SUMMARY

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COMMUNITY INVOLVEMENT
An important component of the research process for this Analysis of Impediments to Fair Housing Choice involved gathering input regarding fair and affordable housing conditions, perceptions, and needs in El Centro. The project team used a variety of approaches to achieve meaningful public engagement with residents and other stakeholders, including public meetings, focus groups, interviews, and a fair housing questionnaire.

Stakeholder Focus Groups and Interviews
The planning team also engaged with stakeholders representing a variety of perspectives through individual and small group interviews. Discussion topics included barriers to fair housing, housing discrimination, access to opportunity, and fair housing resources.

A virtual focus group was held with the Imperial Valley Housing Authority (IVHA). The focus group began with a short presentation providing an overview of the Analysis of Impediments to Fair Housing Choice, and related grant programs. The presentation was followed by an interactive discussion of housing and community development needs and fair housing issues. Four staff members participated in this virtual focus group. A stakeholder interview was held via telephone with staff from Inland Fair Housing Mediation Board (IFHMB), which focused on fair housing issues in the area, complaint patterns, and community development needs.

Fair Housing Questionnaire
A fair housing questionnaire was also prepared and emailed to area developers, mortgage lenders, insurance agents, and real estate agents to assess their understanding of fair housing laws and access to training opportunities. A total of 7 stakeholders responded to the survey.

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FAIR HOUSING ISSUES &

CONTRIBUTING FACTORS

SEGREGATION AND INTEGRATION
Demographic trends in El Centro show that segregation between Black and white residents has decreased between 2000 and 2020. However, segregation has increased once again within the last ten years, growing from 32.96 to 44.63 which calculated a moderate segregation between Black and White residents. Overall, there has been an increase in segregation between white residents and all different racial/ethnic groups in El Centro, particularly within the last ten years.

El Centro’s racial and ethnic neighborhood composition has also changed between 2000 to 2022. The most noticeable change over the past 20 years is the growth of the Hispanic population, shown in orange. Black residents of El Centro have increased slightly and are mainly clustered in the central part of the city within the RECAPs tract and with a slight expansion in the surrounding tracts. Hispanic residents have expanded outwards from the central city in a less concentrated way. In 2000, white residents were mostly concentrated in the western portion of the city, and while they are still mostly living in this part of the city in 2022, their overall population has decreased significantly. Overall population growth and density has increased in a few areas in El Centro including the far northeast quadrant and the far southern portion of the city.

El Centro has a high concentration of Mexican-born residents throughout the city which may be due to its close proximity to Mexico’s border and surrounding predominantly Hispanic/Latino communities in southern California. Due to the high concentration of Mexican-born residents, there does not appear to be a concentration of residents born in other countries. The other most populous countries residents in El Centro are from include China, Korea, Guatemala, and El Salvador.

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RACIALLY OR ETHNICALLY CONCENTRATED

AREAS OF POVERTY
As of the 2018-2022 American Community Survey, (1) census tract in El Centro fit the U.S.

Department of Housing and Urban Development’s definition of racially or ethnically concentrated areas of poverty (R/ECAPs), defined as census tracts in which 1) more than half of the population is non-white and 2) 40% or more of the population is in poverty, or the poverty rate is greater than three times the average poverty rate in the area, whichever is lower. This tract is located in the north-central portion of the city.

Notably, the R/ECAPs tract exists in areas with higher-than-average concentrations of both Black and Hispanic residents, as well as areas with a high concentration of foreign-born residents as shown in Figure 2. This tract meets the definition of a Racially or Ethnically Concentrated Area of Poverty in that they have an individual poverty rate of 40% or more (or an individual poverty rate that is at least three times that of the tract average for the metropolitan area, whichever is lower) and a non-White population of 50% or more.

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ACCESS TO OPPORTUNITY
Where people live shapes prospects for economic mobility and access to resources and services such as high-quality education; affordable transportation; a healthy environment; fresh, affordable food; and healthcare. However, neighborhood or housing choices are often limited by discrimination in housing markets or public policies that result in concentrated poverty, disinvestment, and a lack of affordable housing in neighborhoods with access to highperforming schools and jobs that pay living wages. In this way, limited housing choices reduce access to opportunity for many protected classes. In addition to proximity, access to opportunity is also shaped by economic, social, and cultural factors. For example, residents may live in locations with high numbers of jobs but may be unable to obtain them due to gaps in education or skills, a lack of reliable transportation, or childcare needs. Residents of El Centro face disparities in access to opportunity in the following areas:

High-paying jobs: residents of central and eastern El Centro have the lowest median household incomes, despite having the highest concentration of jobs. This indicates that jobs in these areas likely pay low wages.

Transportation: households in central El Centro are less likely to have access to a vehicle than households nearer to the City limits.

Community members who provided feedback said that limited bus routes and hours greatly limit commuting opportunities for residents who do not have a car.

Food access: central El Centro contains many neighborhoods where 30% or more of all residents are considered low-income with low access to a supermarket. An estimated 17% of El Centro residents struggle with food insecurity.

Healthcare: the entirety of Imperial County has been designated as a medically underserved area since the 1990s, meaning that there are not enough primary care physicians in the area to properly care for all residents. In addition, residents in some portions of central El Centro are significantly less likely to have health insurance than residents in the rest of the City.

Education: educational achievement levels vary significantly within El Centro and generally correlate with labor market participation - unemployment rates are higher in areas with lower educational achievement. In addition, most elementary, middle, and high schools in El Centro have an unusually high number of economically disadvantaged students, and schools with more economically disadvantaged students typically have lower overall rates of student proficiency in math and English language arts.

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DISABILITY AND ACCESS

16.3% of El Centro residents have at least one disability, a rate nearly 50% higher than the average for the state of California. Despite this, neither El Centro nor Imperial County has any Section 811 units, or subsidized units dedicated as supportive housing for people with disabilities. Residents who rely on Supplemental Security Income, or SSI payments, can only afford a rent of $314 per month without becoming cost burdened, but the average rent for a one-bedromm apartment in El Centro as of February 2024 was $1,231 per month. In combination with a higher-than-average disability rate among Housing Choice Voucher holders, this indicates an increased need for publicly supported housing for disabled residents in El Centro.

PUBLICLY SUPPORTED HOUSING
The City of El Centro contains 155 units of public housing, 145 units subsidized by project-based Section 8, and 795 Housing Choice Voucher holders. There are also approximately 503 Low Income Housing Tax Credits (LIHTC) units, 494 are identified as low-income units. Hispanic households account for nearly all the city’s publicly supported housing residents, comprising 97% of public housing households, 99% of project-based Section 8 households, and 94% of voucher holders.

During conversations with community members receiving public housing assistance and other stakeholders in the field, policies related to assistance qualification and subsidies were frequently cited frustrations, as increases in household income might disqualify a household from assistance but would still not enable them to afford market rate rents in the area. Additionally, residents who receive public housing assistance shared frustrations about the condition of their units, such as poor insulation, pest infestations, and plumbing issues.

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FAIR HOUSING ENFORCEMENT, OUTREACH

CAPACITY, AND RESOURCES
Besides protections under the federal Fair Housing Act (FHA), residents of El Centro are protected from discriminatory housing practices by state level fair housing law. California’s Fair Employment and Housing Act (FEHA) has been deemed substantially equivalent to the rights, procedures, remedies, and enforcement affirmed via the FHA. Thus, complaints of housing discrimination are most often reported, investigated, mediated, and resolved through the work of either the California Civil Rights Department (formerly known as the Department of Fair Employment and Housing) as the state’s Fair Housing Assistance Program (FHAP) agency, or Inland Fair Housing Mediation Board (IFHMB), a private Fair Housing Initiatives Program (FHIP) grantee. Most fair housing complaints processed by the CRD or IFHMB in the recent five-year period involve disability as a basis of discrimination and accessible, quality, affordable housing as the most cited challenge.

The City of El Centro identified several impediments to affordable housing in its last 2019-2024 Analysis of Impediments to Fair Housing Choice, which included: a concentration of Section 8 residents in neighborhoods with high poverty rates; ill-informed property management practices; a lack of knowledge of fair housing laws among on-site property managers; and a lack of special provisions for accessible housing for persons with disabilities.

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HOUSING NEEDS
To assess affordability and other types of housing needs, HUD defines four housing problems:

1. Cost burden: A household has a cost burden if its monthly housing costs (including mortgage payments, property taxes, insurance, and utilities for owners and rent and utilities for renters) exceed 30% of monthly income.

2. Overcrowding: A household is overcrowded if there is more than 1 person per room, not including kitchens and bathrooms.

3. Lack of complete kitchen facilities: A household lacks complete kitchen facilities if it lacks one or more of the following: cooking facilities, refrigerator, or a sink with piped water.

4. Lack of complete plumbing facilities: A household lacks complete plumbing facilities if it lacks one or more of the following: hot and cold piped water, a flush toilet, or a bathtub or shower.

Lack of complete kitchen or plumbing facilites is considered a severe housing problem, as are housing costs exceeding 50% of monthly income and crowding of 1.5 or more people per room.

DISPROPORTIONATE HOUSING NEEDS
In El Centro, rates of housing problems vary significantly by race and ethnicity. In particular, Black residents are more than three times as likely to have at least one housing problem as white residents, and Hispanic residents are nearly twice as likely to have at least one housing problem as white residents. Black residents experience severe housing cost burden at a rate more than five times that of white residents, while Hispanic residents experience it at nearly triple the rate and Asian/Pacific Islander residents at nearly double the rate of white residents.

Rates of housing problems also vary by household type. Non-family households are least likely to have a housing problem, while large family households of 5 or more people are most likely to have at least one housing problm. However, large family households are least likely out of all household types to be severely cost burdened, while small family households are most likely.

Overall, 40% of households in El Centro have at least one housing problem, and 13% of all households are severly cost burdened.

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FAIR HOUSING GOALS AND ACTIONS
The Analysis of Impediements concludes by identifying six barriers to fair housing choice in El Centro and creating corresponding goals and strategies designed to alleviate each barrier.

These include:

Impediment #1: Aging housing stock in need of rehab and repair Data shows that El Centro’s housing stock is aged overall – less than 20% of the City’s housing is under 20 years old, while 65% is more than 40 years old. A city with aged housing stock typically has a greater need for rehabilitation and repair programs and funding than a city with newer housing stock. This contributes to a high rate of housing problems in the City - 40% of El Centro households experience one or more HUD-defined housing problem, and race and ethnicity greatly impact a household’s likelihood of experiencing one or more problems. Nearly 90% of Black households in El Centro experience at least one housing problem, in comparison to less than one quarter of white households. Nearly half of all Hispanic households experience one or more housing problems. When negative factors in housing disproportionately impact protected classes, such as racial or ethnic groups, this constitutes a barrier or impediment to fair housing choice.

Suggested strategies to overcome this impediment include:
• Gather data and produce a report on factors impacting the lack of new housing built in El Centro in the past twenty years and use it to create a plan to encourage the development of new housing within the jurisdiction
• Implement or expand any existing rehab and repair programs using CDBG funding • Create or expand rehab and repair programs targeting traditionally Black and Hispanic communities, as well as neighborhoods with low median household incomes Impediment #2: Disparities in access to community resources and services
In many cities, a person’s location within the city impacts the resources they are able to access.

Neighborhoods without equal access to resources may present a barrier or impediment to fair housing choice when residents of a city are limited to such neighborhoods by financial or other circumstances. In El Centro, several census tracts have limited access to resources when compared to other areas of the City. This includes disparities in job, transportation, food, and healthcare access, educational attainment levels, and wages.

In combination, these factors have the potential to severely limit a person’s housing choice and therefore their access to resources. A person living in a tract with lower rates of health insurance is less likely to have a vehicle, meaning that they may be forced to remain in the same neighborhood in order to be within walking distance of a low-wage job, and may be unable to access higherwage jobs with better benefits, such as health insurance, due to lack of transportation. As many of these access issues overlap in El Centro’s only R/ECAP tract, which is primarily occupied by Black and Hispanic residents, it is clear that resource access issues within the City disproportionately impact protected class groups and therefore constitute and impediment to fair housing choice.

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• Create or expand job training and employment assistance programs in areas of the City with low median household income
• Create or expand upward mobility and financial education and assistance programs in areas of the City with low median household incomes
• Expand bus routes and operational hours in areas of the City with low vehicle access rates • Investigate the potential to expand subsidized rideshare programs for non-disabled residents in areas of the City with low vehicle access rates
• Ensure that bus routes throughout the city provide easy access to supermarkets and that operational hours allow residents to grocery shop after work or on the weekends • Produce a report on steps the City could take to encourage the development of new supermarkets in low-access areas
• Create educational campaigns and workshops to help uninsured residents access and apply for Medicaid, Medicare, or other public health insurance • Create educational campaigns to educate workers on legally required job benefits such as health insurance and resources or assistance for instances in which employers are not providing required benefits
Impediment #3: Low Wages Impede Access to Opportunities, Resources, and Restrict Housing Choice for Low/Mod Income Households and Protected Classes
Disparities in labor market engagement exist by geography, race, and ethnicity in El Centro.

Unemployment is highest among Native American residents (over 50% as of the 2018-2022 ACS estimates), and the share of residents aged 25 and over with a bachelor’s degree or higher is lowest among Black residents (less than 1.1%). Residents and stakeholders noted that in addition to income, residents’ housing choices are shaped by a variety of factors, including access to grocery stores, healthcare, and other needed resources; access to public transportation; and availability of public infrastructure such as sidewalks.

In particular, there is a high need for investment in public schools throughout all of El Centro. The majority of the public schools’ students are over 90% minorities with more than 60% coming from economically disadvantaged backgrounds. Based on the percentage of overall performance levels, the majority of schools have more than a quarter of students who have not met their performance standards. Funding for programs that provide collaborative, integrated support for students can help increase access to proficient schools for residents who may lack the opportunity to move to higher-performing schools or zones. The City of El Centro and Imperial County leadership must collaborate on coordinating community school services and distribution of resources and support throughout the district.

Suggested strategies to overcome this impediment include:
• Work with community partners to support resident and employer participation in job search, placement, and training programs. In particular, expand paid job training programs. • Invest/expand job training and placement initiatives for individuals with LEP to increase their self-sufficiency and housing stability.

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A general lack of affordable housing options available to low- and moderate-income households was one of the most frequently cited issues identified in our conversations with El Centro community stakeholders. This shortage has become increasingly dire over the past few years as housing costs in the area have drastically increased and wages have remained comparatively stagnant. Additionally, there is limited public housing assistance, and existing resources are often coupled with waitlist periods of 1 year or more, source of income discrimination by area landlords, and housing quality issues. There is a great need for increased numbers of affordable multifamily units and assistance for low-income homebuyers.

An estimated 12.8% of households in El Centro are severely cost-burdened, spending over 50% of income on housing, (See Table 12: Demographics of Households with Severe Housing Cost Burdens). Black households are the most impacted by severe cost burdens (27.3%, or 120 of 440 Black households). Hispanic households are the second group most impacted by severe cost burdens with a rate of 15.9% (1,510 of 9,515 Hispanic households). Additionally, 15.4% of smallfamily households and 10.6% of non-family households are severely cost burdened in El Centro.

Suggested strategies to overcome this impediment include:
• Continue to review the Annual Qualified Allocation Plans issued by the California Tax Credit Allocation Committee under the Low Income Housing Tax Credit (LIHTC) program to identify local government policies or actions that may positively impact the competitiveness of developers’ applications
• Consider and adopt zoning code amendments that could increase possibilities for development of affordable housing
• Convene a focus group of local affordable housing developers to identify challenges to working in the region, and develop strategies to address these barriers Impediment #5: Limited Housing Options for Persons With Disabilities
According to 2018-2022 ACS 5-Year Estimates, approximately 16.3% of the population in El Centro has at least one disability. This rate is higher than the overall disability rate in California (11.0%) and Imperial County (14.2%), suggesting that El Centro has a particular need for accessible housing suitable for persons with disabilities, who often have specialized housing needs. In addition, as persons with disabilities often live on limited incomes, such as standard Supplemental Security Income (SSI) payments, affordability is a key concern. This issue is further exacerbated by El Centro’s high housing costs, as those living on fixed incomes— often receiving less than $1,000 per month, according to average SSI estimates— are unlikely to be able to afford market-rate housing in the city, where 1-bedroom units rent for approximately $1,500 a month, according to ACS estimates.

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• Partner with the Imperial Valley Housing Authority and the California Housing Finance Agency to explore potential funding opportunities for affordable, accessible housing that meets the needs of persons with disabilities, such as the Section 811 program • Convene a focus group comprised of local disability advocacy and supportive service providers to gain a deeper understanding of the unique challenges and issues that residents with disabilities face in El Centro’s housing landscape Impediment #6: Need for Continued and Expanded Fair Housing Activities
Knowledge of fair housing rights and resources is generally good in the City of El Centro.

Stakeholders noted that over the past decade, local knowledge about fair housing has improved dramatically, and residents who did not know how to file a fair housing complaint were referred to the appropriate organization. According to our stakeholder fair housing questionnaire results, professionals in the real estate, mortgage, and development industries seem to have a strong understanding of fair housing protections. However, conversations with stakeholders also revealed that discrimination in housing still occurs in the area. Barriers to housing often include factors such as poor credit history, 3x or more minimum income requirements, and source of income discrimination, which is prohibited under California law (FEHA).These results indicate that while ongoing education efforts within the community have been successful, there is a continuing need to provide fair housing education and resources. The diversity of the city’s population suggests that this fair housing education should be targeted to communities of color and people with limited English proficiency.

Strengthening of connections between the City of El Centro and its fair housing service providers (like IFHMB) with local organizations that serve groups known to be vulnerable to housing discrimination, such as El Centro Hispano.

Suggested strategies to overcome this impediment include:
• Continue to offer fair housing education activities, with a focus on expanding the pool of partners the City and IFHMB works with (ex: LEP communities/organizations, disability advocacy and supportive service providers, schools, etc.) to ensure meaningful connections are established with vulnerable populations
• Collaborate with property managers and landlords to ensure that they have an understanding of property management practices that affirmatively further fair housing

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TABLE OF CONTENTS
Introduction.............................................................................................................................. 4 Community Participation Process .......................................................................................... 9 Community Engagement Results ......................................................................................... 11 Socioeconomic & Public Investment Patterns..................................................................... 20 Demographic Profile .............................................................................................................. 20 Racially and Ethnically Concentrated Areas of Poverty .................................................. 31 Segregation and Integration ................................................................................................ 34 Access to Opportunity ........................................................................................................... 43 Housing Profile ......................................................................................................................... 73 Public Investment Patterns .................................................................................................... 86 Public Transportation Impacts .............................................................................................. 87 Lending and Insurance Practices......................................................................................... 95 Housing for People with Disabilities .....................................................................................103 Public Sector Policies ...........................................................................................................111 Publicly Supported Housing.................................................................................................119 Fair Housing Activities...........................................................................................................129 Identification of Impediments..............................................................................................135 Appendix: Zoning Analysis Matrix.......................................................................................144

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INTRODUCTION
Fair Housing Planning
Equal access to housing choice is crucial to America’s commitment to equality and opportunity for all. Title VIII of the United States Civil Rights Act of 1968, more commonly known as the Fair Housing Act, provides housing opportunity protection by prohibiting discrimination in the sale or rental of housing on the basis of race, color, religion, sex, and national origin. The Act was amended in 1988 to provide stiffer penalties, establish an administrative enforcement mechanism and to expand its coverage to prohibit discrimination on the basis of familial status and disability. The U.S. Department of Housing and Urban Development (HUD), specifically HUD’s Office of Fair Housing and Equal Opportunity (FHEO), is responsible for the administration and enforcement of the Fair Housing Act and other civil rights laws.

Provisions to affirmatively further fair housing (AFFH) are basic long-standing components of HUD’s housing and community development programs. The AFFH requirements are derived from Section 808(e)(5) of the Fair Housing Act which requires the Secretary of HUD to administer the Department’s housing and urban development programs in a manner to affirmatively further fair housing.1 Local communities, such as the City of El Centro, that receive grant funds from HUD through its entitlement process satisfy this obligation by performing an “Analysis of Impediments to Fair Housing Choice” (AI). In an AI, local communities that receive HUD entitlement grant funds evaluate barriers to fair housing choice and develop and implement strategies and actions to overcome any identified impediments based on their individual histories, circumstances, and experiences. Through this process, local entitlement communities promote fair housing choices for all persons, including classes protected under the Fair Housing Act, and provide opportunities for racially and ethnically inclusive patterns of housing occupancy, identify structural and systemic barriers to fair housing choice, and promote housing that is physically accessible and usable by persons with disabilities.

HUD will presume that the grantee is meeting its obligation and certification to affirmatively further fair housing by taking actions that address the impediments, including:

1 U.S. Department of Housing and Urban Development Office of Fair Housing and Equal Opportunity. Fair Housing Planning Guide: Volume 1 (Chapter 1: Fair Housing Planning Historical Overview, Page 13). March 1996.

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• Analyzing and eliminating housing discrimination within the jurisdiction; • Promoting fair housing choice for all persons;
• Providing opportunities for racially and ethnically inclusive patterns of housing occupancy;
• Promoting housing that is physically accessible to all persons to include those persons with disabilities; and
• Fostering compliance with the nondiscrimination provisions of the Fair Housing Act.

Through its Community Planning and Development (CPD) programs, HUD’s goal is to expand mobility and widen a person’s freedom of choice. The Department also requires Community Development Block Grant (CDBG) program grantees to document AFFH actions in the annual performance reports that are submitted to HUD.

In 2015, HUD published a final rule on Affirmatively Furthering Fair Housing, which outlined procedures that jurisdictions and public housing authorities who participate in HUD programs must take to promote access to fair housing and equal opportunity. This rule stipulated that grantees and housing authorities take meaningful actions to overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected class characteristics. Under HUD’s final rule, grantees must take actions to:
• Address disparities in housing need;
• Replace segregated living patterns with integrated and balanced living patterns;
• Transform racially and ethnically concentrated areas of poverty into areas of opportunity; and
• Foster and maintain compliance with civil rights and fair housing laws.

To assist grantees and housing authorities affirmatively further fair housing, HUD provided publicly-available data, maps, and an assessment tool to use to evaluate the state of fair housing within their communities and set locally-determined priorities and goals. HUD’s final rule mandated that most grantees begin submitting to HUD an assessment developed using this tool in 2017; however, a 2018 HUD notice withdrew the requirement to prepare such assessments. A subsequent notice further required that grantees instead prepare and keep on file a current Analysis of Impediments to Fair Housing Choice. HUD’s data and maps remain available for grantees to use in preparing their AIs. For further information, please see HUD’s notices appended to this report.

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Mosaic Community Planning partnered with the City of El Centro to develop this Analysis of Impediments to Fair Housing Choice. This AI follows HUD’s Fair Housing Planning Guide but also incorporates elements of HUD’s assessment tool established in the 2015 final rule. In some places, it uses data developed by HUD for use by grantees as part of the Affirmatively Furthering Fair Housing final rule.

Definitions
Affirmatively Further Fair Housing: In keeping with the latest proposed guidance from HUD, to Affirmatively Further Fair Housing Choice (AFFH) is to comply with “the 1968 Fair Housing Act’s obligation for state and local governments to improve and achieve more meaningful outcomes from fair housing policies, so that every American has the right to fair housing, regardless of their race, color, national origin, religion, sex, disability or familial status.”2
Affordable: Though local definitions of the term may vary, the definition used throughout this analysis is congruent with HUD’s definition:

HUD defines as "affordable" housing that costs no more than 30% of a household's total monthly gross income. For rental housing, the 30% amount would be inclusive of any tenant-paid utility costs. For homeowners, the 30% amount would include the mortgage payment, property taxes, homeowners’ insurance, and any homeowners’ association fees.

Fair Housing Choice: This Analysis of Impediments to Fair Housing Choice uses the following definition of “Fair Housing Choice”:

The ability of persons of similar income levels to have available to them the same housing choices regardless of race, color, religion, sex, national origin, familial status, or handicap.

Impediments to Fair Housing Choice: As adapted from the HUD Fair Housing Planning Guide, impediments to fair housing choice are understood to include: 3 • Any actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices.

2 U.S. Department of Housing and Urban Development. “HUD Publishes New Proposed Rule on Affirmatively Furthering Fair Housing Choice.” Press Release No. 13-110. July 19, 2013. 3 U.S. Department of Housing and Urban Development Office of Fair Housing and Equal Opportunity. Fair Housing Planning Guide: Volume 1 (Chapter 2: Preparing for Fair Housing Planning, Page 2-17). March 1996.

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• Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices on the basis of race, color, religion, sex, disability, familial status, or national origin.

Protected Classes: The following definition of federally protected classes is used in this document:

Title VIII of the Civil Rights Act of 1968 prohibits housing discrimination based on race, color, national origin or ancestry, sex, or religion. The 1988 Fair Housing Amendments Act added familial status and mental and physical handicap as protected classes.

Data Sources
Decennial Census Data: Data collected by the Decennial Census for 2010 and 2000 is used in this Assessment (older Census data is only used in conjunction with more recent data in order to illustrate trends). The Decennial Census data is used by the U.S. Census Bureau to create several different datasets:
• 2010 and 2000 Census Summary File 1 (SF 1): This dataset contains what is known as “100% data,” meaning that it contains the data collected from every household that participated in the Census and is not based on a representative sample of the population. Though this dataset is very broad in terms of coverage of the total population, it is limited in the depth of the information collected.

Basic characteristics such as age, sex, and race are collected, but not more detailed information such as disability status, occupation, and income. The statistics are available for a variety of geographic levels with most tables obtainable down to the census tract or block group level. • 2000 Census Summary File 3 (SF 3): Containing sample data from approximately one in every six U.S. households, this dataset is compiled from respondents who received the “long form” Census survey. This comprehensive and highly detailed dataset contains information on such topics as ancestry, level of education, occupation, commute time to work, and home value. The SF 3 dataset was discontinued for the 2010 Census, but many of the variables from SF 3 are included in the American Community Survey.
• 2010 and 2020 Redistricting Data: The Census Bureau released redistricting data for all states on August 12, 2021. The dataset provides demographic characteristics of the nation by state, county, city, all the way down to the census block level, including race and ethnicity; population 18 years and over; occupied and vacant housing units; and people living in group quarters like nursing homes, prisons, military barracks and college dorms.

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American Community Survey (ACS): The American Community Survey is an ongoing statistical survey that samples a small percentage of the U.S. population every year, thus providing communities with more current population and housing data throughout the 10 years between censuses. This approach trades the accuracy of the Decennial Census Data for the relative immediacy of continuously polled data from every year.

ACS data is compiled from an annual sample of approximately 3 million addresses rather than an actual count (like the Decennial Census’s SF 1 data) and therefore is susceptible to sampling errors. This data is released in two different formats: single-year estimates and multi-year estimates.
• ACS Multi-Year Estimates: More current than Census 2010 data, this dataset is one of the most frequently used. Because sampling error is reduced when estimates are collected over a longer period of time, 5-year estimates will be more accurate (but less recent) than 1-year estimates. The 2012-2016 ACS 5-year estimates are used most often in this assessment.
• HUD Affirmatively Furthering Fair Housing Data and Mapping Tool (AFFH-T): HUD’s AFFH Data and Mapping Tool provides a series of online, interactive maps and data tables to assist grantees in preparing fair housing analyses. Topics covered include demographics and demographic trends; racial and ethnic segregation; housing problems, affordability, and tenure; locations of subsidized housing and Housing Choice Voucher use; and access to educational, employment, and transportation opportunities. This report uses HUD’s latest data and maps, AFFHT0004, which was released in November 2017. HUD’s source data includes the American Community Survey (ACS), Decennial Census / Brown Longitudinal Tract Database (BLTD), Comprehensive Housing Affordability Strategy (CHAS), Longitudinal Employer-Household Dynamics (LEHD), HUD’s Inventory Management System (IMS) / Public and Indian Housing (PIH) Information Center (PIC), and others. For a complete list of data sources, please see HUD’s Affirmatively Furthering Fair Housing Data and Mapping Tool Data Documentation appended to this report or available online at:
https://www.hudexchange.info/resources/documents/AFFH-T-DataDocumentation-AFFHT0004-November-2017.pdf

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COMMUNITY

PARTICIPATION PROCESS
Community Engagement Overview
An important component of the research process for this Analysis of Impediments to Fair Housing Choice involved gathering input regarding fair and affordable housing conditions, perceptions, and needs in El Centro. The project team used a variety of approaches to achieve meaningful public engagement with residents and other stakeholders, including public meetings, focus groups, interviews, and a communitywide survey.

Public Meeting
1 meeting open to the general public was held to inform the public about and gather information for the Analysis of Impediments to Fair Housing Choice. Each meeting began with a short presentation providing an overview of the AI followed by an interactive discussion of fair housing, neighborhood conditions, and community resources in the region. A total of XX members of the public attended one of the three meetings. Meeting dates, times, and locations are shown below:

Public Meeting
Date: March 19, 2024
Time: 11:30am
Address: City Hall,
1275 Main Street, El Centro,
CA 92243
Stakeholder Focus Groups and Interviews
The planning team also engaged with stakeholders representing a variety of perspectives through individual and small group interviews. Discussion topics included barriers to fair housing, housing discrimination, access to opportunity, and fair housing resources.

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followed by an interactive discussion of housing and community development needs and fair housing issues. Four staff members participated in this virtual focus group. A stakeholder interview was held via telephone with staff from Inland Fair Housing Mediation Board (IFHMB), which focused on fair housing issues in the area, complaint patterns, and community development needs. A fair housing questionnaire was also prepared and emailed to area developers, mortgage lenders, insurance agents, and real estate agents to assess their understanding of fair housing laws and access to training opportunities.

Overall, one or more representatives from 6 organizations and agencies participated in a stakeholder interview, focus group, questionnaire, or written request for information.

Organizations and agencies from which someone participated in the development of this AI include:
• Inland Fair Housing Mediation Board (IFHMB)
• Imperial Valley Housing Authority (IVHA)
• Imperial Valley Transit (IVT)
• Prince & Associates Realtors
• Wallick & Volk Mortgage
• Golden Group Real Estate Services
Public Comment Period and Hearing
The City of El Centro will hold a 30-day public comment period and public hearing to receive input on the draft Analysis of Impediments in approximately 1 month. Further information about the comment period, including any public comments received, will be included here in the final draft of this document.

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COMMUNITY

ENGAGEMENT RESULTS
For the community participation process, the consulting team developed a standard question set for use in public meetings, focus groups, and interviews. Listed below are the summarized comments from interview participants and focus group attendees, as well as a summary of survey results. All input was considered in the development of this AI, and no comments or surveys were not accepted. Note that these comments do not necessarily reflect the views of the City of El Centro or Mosaic Community Planning.

Focus Group

1. What types of housing needs are greatest in the community (e.g. workforce housing, affordable rental housing, housing for people who are homeless, assistance for first-time homebuyers, rehab/repair programs for homeowners, housing for seniors or people with disabilities, etc.)? How important a need is affordable multifamily rental housing? • Overall affordable rental housing. Voucher holders and non-holders both used to easily be able to find housing, but the market is now super tight, and landlords are very picky. Rents have close to doubled for all bedroom sizes in the past two years.
• First time homebuyers’ assistance. Some residents are paying more in rent than they would for a mortgage, but they don’t know where to start the homebuying process and need general assistance in the process and also with down payments, etc.
• Financial literacy programs and consolidated info on assistance programs would help. Many program participants are very intimidated by making the transition to home ownership, especially by the lack of safety nets when leaving HA programs.
• Also concerned by new housing being built that is targeted to farm laborers (USDA developments) – too many developments are targeting this demographic and the demand is inconsistent and seasonal.

2. What parts of the city are generally seen as areas of opportunity (i.e. places people aspire to live, places that offer good access to schools, jobs, and other amenities)? What makes them attractive places to live? Are there barriers someone might face in moving to one of these areas? Are you aware of any housing discrimination?

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• Area in a two mile radius from Southwest High School is very desirable due to proximity to the school and quality of housing
• Credit score is a big barrier for many people looking to move to a more desirable neighborhood, even for people with complete rental subsidies.

3. Are there actions the housing authority could take or is taking to overcome these barriers?
• IVHA participants are given an orientation packet that talks about housing discrimination and fair housing rights and resources – it’s important that participants are educated on what protected classes are and what counts as discrimination.
• IVHA is addressing lack of supply by increasing percentage of units in new developments that are designated for project based vouchers. • There are currently two new developments in progress behind Costco that are working with IVHA to bring in low-income units.

4. What funding sources or programs have been most successful in the past? • There is a development that was allowed to lapse in its USDA designation to open it up to more people than just farm laborers while still prioritizing keeping existing residents in place. Maintaining reasonable rent increases is important in the HA being able to maintain properties.
• HA received special funding for 156 emergency housing vouchers for people exiting shelters and for their related needs like furniture, deposits, utilities, etc.

There is also special targeted funding for people who are under 62 and disabled and for veteran vouchers.

5. What are the biggest challenges affordable housing providers face? • Many contractors in the area are priced too high for subsidized project bids – it’s hard to find affordable contractors, especially since the pandemic

6. Is El Centro experiencing barriers related to poor credit history, past evictions, income requirements, or income discrimination?
• The discrimination isn’t blatant but it’s there, especially poor credit and past evictions. There is a sense that voucher holders are discriminated against especially with the tight housing market, but there is no concrete evidence or complaints.
• Source of income discrimination is against the law in California but it still happens • Seeing more discrimination about not meeting 3x income than about voucher holders – median income is only 67.5k and that hasn’t kept up with recent rent

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doubling. Clients can also be discriminated against for receiving welfare or disability – basically any payments that aren’t from wages

7. How are landlords encouraged to participate in the HCV program? Are there common issues that arise in HCV participation?
• The pandemic eviction moratorium really helped tenants, and landlords of voucher holders kept receiving payments when other landlords didn’t, which may have helped landlords view the HCV program more favorably • There is a $2,000 one-time cash incentive for landlords who sign new Section 8 leases, and landlords also like knowing they are getting the emergency housing voucher deposits. Most participating landlords are repeat customers so the HA really tries to maintain good will and be as flexible as possible with landlords.

Most new landlords come to the housing authority through word of mouth.

Landlords also like that the HA uses direct deposit because they can count on receiving rent each month.
• IVHA just started sending out thank you letters to landlords with info on new participation opportunities like VASH vouchers

8. How well known are fair housing resources and how could they be publicized? • Over the past 20 years I’ve noticed that participants are better informed now than they used to be, maybe because of social media.
• The housing authority provides contact info for fair housing assistance to clients. • The Imperial Valley CoC Council meetings help with collaboration and coordination between agencies. CoC also has a Mercy Housing hotline number that can help with fair housing issues
Stakeholder Interview

1. What types of housing needs are greatest in the community (ex. affordable rental housing, housing for people who are homeless, assistance for first-time homebuyers, rehab/repair programs for homeowners, housing for seniors or people with disabilities, etc.)?
• Overall, increased affordable housing opportunities
• More housing accessible for persons with disabilities • Newer housing units should be built in areas of opportunity • Need for homeless services

2. Are public resources (e.g. parks, schools, roads, police & fire services, etc.) available evenly throughout all neighborhoods in your community?

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• No, we need better infrastructure – improved drainage, roads, sidewalks, etc.

3. Are people aware of their fair housing rights?
• Still a need for more awareness, we provide education and outreach on fair housing issues, but it’s one of those things that we need continual outreach… they affect people at different times
• Outreach needed for both tenants and housing providers • Help people enforce their existing rights – who can help them if they did need to put together a housing complaint - referrals

4. Do you have collaborative partnerships with housing providers in the region? • We have a federal grant for fair housing, its not just El Centro funds • We reach out to different nonprofits
• California Legal Services
• Education is provided in English and Spanish
• We also provide language assistance in other languages (partnership with language line)

5. Is there anything we haven’t discussed that you feel is important to our research? • In the last year, there’s definitely an increase for eviction-related help. Looks like people are having a harder time staying housed
• Fair housing has been steady in their complaints – disability related discrimination definitely the most common one

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Fair Housing Questionnaire

1. What is your primary role in the housing industry?

2. What is the name of your organization or agency?
A summary of participating organizations and agencies can be found in the prior section, Community Participation Process.
1 0
0 3
1 0
2 0
0 0 1 2 3 4
Affordable Housing Development
Construction/Development
Insurance
Lending/Mortgage Industry
Local Government
Property Management
Real Estate Sales/Brokerage
Service Provision
Other

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3. Does your organization or agency service a specific geographical area or areas? • State of California
• Imperial County
• City of El Centro

4. How familiar are you with fair housing laws?

71.4%

28.6%
Yes No

71.4%

14.3%

14.3%
Very familiar Somewhat familiar Not so familiar Not at all familiar

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If you selected "very familiar" or "somewhat familiar," please describe how you became aware
• Part of continuing education
• Annual training required for license renewal
• Requirement of all operations to abide by all current fair housing laws

5. Outreach and education activities, such as training and seminars, are used to help people better understand their rights and obligations under fair housing law.

Are you aware of any educational activities or training opportunities available to you to learn about fair housing laws?

6. If you answered "yes" above, have you participated in fair housing activities or training?

85.7%

14.3%
Yes No

85.7%

14.3%
Yes No

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7. HUD defines barriers to fair housing choice as “actions, omissions, or decisions taken because of race, color, religion, sex, disability, familial status, or national origin which restrict housing choices or the availability of housing choices.” In the question below, please tell us if you are aware of any barriers related to fair housing choice in each private sector area. If you can think of practices or barriers, please describe them in the box provided. Please note, examples provided represent only one of many possible scenarios.

Do any of these issues create barriers to fair housing in El Centro?

8. Does your institution have any policies or procedures in place that address the barriers to fair housing indicated above?
If yes, please explain the policies and procedures.
• Continuing education
• Offer loans tailored for people of all means – protected classes have nothing to do with qualifying criteria
• Have posted Fair Housing Guidelines in waiting room
2 1
2 2
1 2
4 4 4
3 3
4 1 1
2 0
1 2
3 4
5 The rental
housing
market
The real
estate
industry
The
mortgage
and home
lending
industry
The housing
construction
or housing
design fields
The home
insurance
industry
The home
appraisal
industry
Yes No Don't Know

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• Creating barriers to fair housing causes lenders to lose licensing

9. Use this space to provide any additional info that you think would be helpful for our plan.

N/A

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SOCIOECONOMIC &

PUBLIC INVESTMENT PATTERNS
The El Centro entitlement jurisdiction is home to an estimated 44,184 residents according to the 2018-2022 Five-Year American Community Survey (ACS). The City of El Centro’s population accounts for 24.6% of residents in Imperial County (a total population of 179,578), which includes seven cities and eight unincorporated communities. El Centro’s population grew slightly between 2000 and 2010 (9.9%), and recent estimates show growth was slower in recent years (a 6.3% growth rate between 2010 and 2022 estimates).

Demographic Profile
Race / Ethnicity
El Centro’s racial and ethnic demographics have remained consistent in the last 20 years, as depicted in TABLE 1 and Table 2. In the past 20 years, El Centro has been comprised of a predominantly Hispanic/Latino population, growing from 73.6% to 81.4% of the total population between 2000 and 2010. As of 2022, Hispanic/Latino residents account for 88.2% of the total population, a 19.8% increase since 2000.

White residents hold the second largest share of the total population in the city; however, the white population has experienced a significant decline during this time, from 18.9% of the total population in 2000 to 7.1% in 2022, a -62.4% decline. The Asian/Pacific Islander population has also seen a loss of over half, declining from 3.6% in 2000 to 1.3% in 2022, (-63.9%). The Native American share of the total population has decreased from 0.5% in 2000 to 0.1% in 2022, accounting for the largest population decline rate of -80.0%.

The Black population is the only other group besides Hispanic/Latino residents that have increased since 2000, growing from 2.9% of the population in 2000 to 3.1% in 2022, (a growth of 6.9%.

Potential fair housing considerations related to rapidly shifting racial and ethnic demographics include the following:
• Increased potential for realtor or landlord discrimination due to race or ethnicity • Increased potential for lender discrimination due to race or ethnicity • Increased potential for neighborhood pushback towards new residents or developments due to race or ethnicity

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• Increased need for consideration of traditional household structures of non-white households in determination of size and style of future housing unit developments (extended family members living as one household is more common in many non-white cultures than in white American culture).

Disability
According to 2022 ACS data, approximately 16.2% of the population living in the city of El Centro have a disability, slightly higher than the population share in Imperial County (13.6%). The population with disabilities in the city and the county has similar distributions by disability type. The most common disability type in El Centro is difficulty with ambulatory movement. People experiencing ambulatory difficulties comprise 51.4% of the city’s total population with a disability. People with cognitive difficulties comprise of the second largest disability type (44.9%). People with disabilities that may require extensive assistance, including independent living or self-care difficulties, make up

23.3% and 21.7% of El Centro’s population, respectively. The population of people with hearing and vision difficulties make up 25.6% and 19.7% of the city’s population, respectively.

The population share of residents with disabilities in Imperial County (13.6%) is slightly lower compared to the city of El Centro. The distribution by disability types in Imperial County follow general patterns found in the city but are also slightly lower in shares of the population, except for people with ambulatory, self-care, and independent living difficulties which account for 56.4%, 27.7%, and 37.8% of the total population with a disability, respectively.

Potential fair housing considerations related to an increase in the population with a disability include:
• Increased potential for realtor or landlord discrimination due to disability status • Increased potential for neighborhood pushback towards residents or developments due to disability status
• Increased need for accessible housing programs and fair housing materials • Increased need for reasonable accommodations
• Increased need for housing suitable for live-in caregivers • Increased need for nearby transit options
National Origin
The share of foreign-born residents in El Centro has slightly declined (-14.5%) between 2000 to 2022. As of 2022, foreign-born residents still account for more than a quarter of the population (29.0%). In the larger El Centro Region, the foreign-born population has grown by 3.4% and comprises over 33.3% of the total population.

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Top countries of origin for El Centro’s foreign-born population are Mexico, Korea, Philippines, Canada, and India. The population originating from Mexico is the largest, comprising 27.3% of city residents and 94.1% of foreign-born residents. Residents from all other countries each account for less than 1% of the city’s total population. Foreignborn residents from Korea, Philippines, Canada, and India comprise 0.9%, 0.7%, 0.5%, and 0.5% of the total foreign-born population, respectively.

Foreign-born residents account for 30.5% of the current population in Imperial County.

The top countries of origin for Imperial County’s foreign-born population are Mexico, El Salvador, Korea, China, and Guatemala. Residents originating from Mexico account for

28.5% of the total population and 93.2% of the foreign-born population, a similar proportion compared to El Centro. Residents originating from El Salvador, Korea, China, and Guatemala make up 0.9%, 0.8%, 0.5%, and 0.5% of the foreign-born population, respectively, closely aligning with El Centro’s rates.

Potential fair housing considerations related to changing national origin demographics include the following:
• Increased potential for realtor or landlord discrimination due to national origin • Increased potential for lender discrimination due to national origin • Increased potential for neighborhood pushback towards new residents or developments due to national origin
• Increased need for consideration of traditional household structures of foreign households in determination of size and style of future housing unit developments (extended family members living as one household is more common in many foreign cultures than in American culture)
• Increased need for housing and fair housing materials available in non-English languages
LEP
The demographics of the population with limited English proficiency (LEP) typically resembles the patterns of the foreign-born population in most communities. The population trends of the LEP population in El Centro follow a similar trajectory as the foreign-born population, however, LEP populations in the larger El Centro Region deviate slightly from these patterns wherein its LEP population has decreased while its foreign-born population has increased slightly since 2000. Both the foreign-born and LEP populations in El Centro have decreased slightly since 2000.

The LEP population in the city of El Centro accounts for 27.7% of the current population after declining by -10.1% since 2000. However, the decline rate has been slower within the past ten years, with a loss of -0.4%. The majority (81.1%) of the LEP population speak

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Spanish and the second and third most common languages spoken among the LEP population are Tagalog and Chinese, although both account for only 0.7% of the LEP population.

The change in the LEP population in the larger El Centro region slightly varied from the growth patterns of the foreign-born population because there was a slight decline in the LEP population between 2000 and 2010. The LEP population has decreased by -3.2 since 2000 and comprises 30.7% of the current population. The varying growth and decline rates could indicate disproportionate change in the number of foreign-born residents from countries where English is the primary language or commonly used and/or improved English language skills for existing foreign-born residents. Compared to the LEP population in the city of El Centro, a lower percentage of LEP residents (77.3%) speak Spanish. The second most common language among the LEP population is Korean and is spoken by 0.4% of the population. Other/unspecified languages, Chinese, and Arabic are the next most common languages and spoken by 0.4%, 0.3%, and 0.3% of the LEP population, respectively.

Potential fair housing considerations related to an increase in population with limited English proficiency include the following:
• Increased potential for realtor or landlord discrimination due to limited English proficiency
• Increased potential for lender discrimination due to limited English proficiency • Increased potential for neighborhood pushback towards new residents or developments due to limited English proficiency
• Increased need for housing and fair housing materials available in non-English languages
Age
Age distribution in El Centro and Imperial County loosely resemble each other’s population shares. People between the ages of 18 and 64 comprise a slightly larger percentage in the county (58.4%) compared to the city (56.0%). From 2000 to 2010, the population between 18 and 64 in the city of El Centro grew at a rate of 6.4% and expanded in proportion by 3.6 percentage points. The proportion of residents under the age of 18 (30.0%) is more than double the share of residents that are 65 and over (13.9%) in the city. The population under 18 declined by 13.0%. since 2000 while the 65 and above population increased by 44.8%.

The majority of Imperial County’s population (58.4%) is between the ages of 18 and 64, however, the population share of residents under the age of 18 (28.4%) is slightly smaller than in El Centro. The population share of residents aged 65 and over at 13.2 is similar to that of the city’s. People aged 18 and over in the region experienced growth since

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2000, however, those under 18 decreased in population share with a 3% change in percentage points. However, there did not appear to be a decline of people aged 18 and under between 2010 and 2022.

Data shows that the population of El Centro and its overall region is trending older. As the population of El Centro ages and families have fewer children, it is likely that the city will require a greater capacity for housing individuals with disabilities and in need of caregivers in the future.

While families with children constitute a protected class, age itself and advanced age are not federally protected classes. However, Imperial County’s Human Rights Ordinance lists age as a protected class in regard to fair housing, and the County’s aging population and its continued popularity among retirees present the following fair housing considerations:
• Increased need for disability accessible housing, as disability rates increase with age
• Increased need for housing suitable for live-in caregivers • Increased need for smaller housing units suitable for independent retirees • Increased need for nearby transit options, as age-related disability may prevent driving
Sex
The population of El Centro is 50.1% male and 49.9% female, similar to the population of Imperial County. This is a slight decrease from 2000, when the population was 50.7% female and 49.3% male. Within the past 20 years, there has been a small decline in female residents compared to male residents which have increased by 1.6% since 2000.

However, within the overall region, both male and female populations have slightly decreased in the past 20 years. Sex demographics within El Centro are unlikely to impact fair housing considerations when decoupled from age or disability, as covered above.

Family Type
The City of El Centro has experienced a slight decline in the number of families having children over the past 20 years, from 61.6% of all households in 2000 to 58.6% of all households in 2020. The greater El Centro region experienced a larger decline, with households with children dropping from 58.5% to 52.9% of the total population since 2000. Of families with children roughly 26.1% are headed by a married couple, 12.7% by a single mother, and 3.4% by a single father. The remainder of households with children are either unmarried couples with children or unspecified relationships. Families with children may experience fair housing concerns related to:

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TABLE 1. DEMOGRAPHIC OVERVIEW
Demographic Indicator
El Centro Imperial County
# % # %

RACE / ETHNICITY
Non-Hispanic 5,210 11.8% 26,196 14.6%
White 3,140 7.1% 17,181 9.6%
Black 1,369 3.1% 4,084 2.3%
Asian or Pacific Islander 577 1.3% 2,381 1.3%
Native American 26 0.1% 1,277 0.7%
Two or More Races 98 0.2% 1,185 0.7%
Other 0 0.0% 88 0.0%
Hispanic or Latino 38,974 88.2% 153,382 85.4%
TOTAL POPULATION 44,184 100.0% 179,578 100.0%

NATIONAL ORIGIN
#1 Country of Origin Mexico 12,063 94.1% Mexico 51,138 93.2% #2 Country of Origin Korea 109 0.9% El Salvador 509 0.9% #3 Country of Origin Philippines 84 0.7% Korea 439 0.8% #4 Country of Origin Canada 67 0.5% China 299 0.5%
#5 Country of Origin India 65 0.5% Guatemala 272 0.5%

TOTAL FOREIGN-BORN
POPULATION 12,818 29.0% 54,859 30.5%

LIMITED ENGLISH PROFICIENCY (LEP) LANGUAGE
#1 LEP Language Spanish 9,915 81.1% Spanish 36,358 77.3% #2 LEP Language Tagalog (incl.

Filipino) 46 0.4% Korean 183 0.4%
#3 LEP Language
Chinese (incl.

Mandarin,
Cantonese)
44 0.4%
Other and
unspecified
languages
166 0.4%

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#4 LEP Language Korean 40 0.3%
Chinese (incl.

Mandarin,
Cantonese)
134 0.3%
#5 LEP Language
Other and
unspecified
languages
36 0.3% Arabic 129 0.3%
TOTAL LEP POPULATION 12,225 27.7% 47,024 26.2%

DISABILITY TYPE
Hearing Difficulty 1,833 25.6% 5,635 23.1%
Vision Difficulty 1,409 19.7% 4,206 17.3%
Cognitive Difficulty 3,217 44.9% 9,929 40.8%
Ambulatory Difficulty 3,678 51.4% 13,744 56.4%
Self-Care Difficulty 1,557 21.7% 6,739 27.7%
Independent Living Difficulty 1,668 23.3% 9,198 37.8%

TOTAL POPULATION WITH A
DISABILITY 7,159 16.2% 24,352 13.6%
SEX
Male 22,117 50.1% 92,430 51.5%
Female 22,067 49.9% 87,148 48.5%
AGE
Under 18 13,276 30.0% 51,049 28.4%
18 to 64 24,749 56.0% 104,858 58.4%
65+ 6,159 13.9% 23,671 13.2%

HOUSEHOLD TYPE
Family Households
Married Couple, with one or
more people under 18 3,196 26.1% 11,128 23.7%
Female Householder, with
one or more people under
18 1,548 12.7% 5,733 12.2%

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Male Householder, with one
or more people under 18 418 3.4% 1,745 3.7%

TOTAL HOUSEHOLDS WITH

ONE OR MORE PEOPLE
UNDER 18
7,159 58.6% 24,352 51.8%
Married Couple, no people
under 18 2,902 23.7% 11,150 23.7%
Female Householder, no
people under 18 862 7.1% 3,275 7.0%
Male Householder, no
people under 18 549 4.5% 1,831 3.9%
Non-Family Households
Female Householder 1,497 12.2% 6,292 13.4%
Male Householder 1,234 10.1% 5,764 12.3%
TOTAL HOUSEHOLDS 12,225 100.0% 47,024 100.0%
Data Source: 2018-2022 5-Year American Community Survey, Tables B03002, B05006, B01001, B18101 to B18107, and B11005; 2018-2022 5-Year American Community Survey Table B16001.

NOTE: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families. The most populous places of birth and languages at the city and regional levels may not be the same, and are thus labeled separately.

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TABLE 2. DEMOGRAPHIC TRENDS, EL CENTRO
Demographic Indicator 2000 2010 2022 (Current)
# % # % # %

RACE / ETHNICITY
White, Non-Hispanic 7,158 18.9% 5,840 13.7% 3,140 7.1%
Black, Non-Hispanic 1,104 2.9% 962 2.3% 1,369 3.1%
Hispanic or Latino 27,888 73.6% 34,707 81.4% 38,974 88.2% Asian or Pacific Islander 1,352 3.6% 918 2.2% 577 1.3%
Native American 200 0.5% 147 0.3% 26 0.1%

NATIONAL ORIGIN
Foreign-Born 12,853 33.9% 12,844 30.1% 12,818 29.0%

LIMITED ENGLISH PROFICIENCY (LEP) LANGUAGE
Limited English Proficiency 11,657 30.8% 11,870 27.8% 12,225 27.7% SEX
Male 18,655 49.3% 20,748 48.7% 22,117 50.1%
Female 19,218 50.7% 21,900 51.4% 22,067 49.9%
AGE
Under 18 13,075 34.5% 12,731 29.9% 13,276 30.0%
18 to 64 21,161 55.9% 25,387 59.5% 24,749 56.0%
65+ 3,637 9.6% 4,530 10.6% 6,159 13.9%

HOUSEHOLD TYPE
Families with Children 4,675 61.6% 5,356 52.5% 7,159 58.6%

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TABLE 3. DEMOGRAPHIC TRENDS, EL CENTRO MSA
Demographic Indicator
2000 2010 Current
# % # % # %

RACE / ETHNICITY
White, Non-Hispanic 28,764 20.2% 23,927 13.7% 23,927 13.7% Black, Non-Hispanic 5,341 3.8% 5,445 3.1% 5,114 2.9%
Hispanic or Latino 102,812 72.2% 140,271 80.4% 140,271 80.4% Asian or Pacific Islander 2,855 2.0% 2,664 1.5% 2,288 1.3% Native American 2,098 1.5% 1,981 1.1% 1,642 0.9%

NATIONAL ORIGIN
Foreign-Born 45,783 32.2% 53,614 30.7% 58,057 33.3%

LIMITED ENGLISH PROFICIENCY (LEP) LANGUAGE
Limited English Proficiency 45,144 31.7% 50,035 28.7% 53,606 30.7% SEX
Male 74,591 52.4% 89,646 51.4% 89,646 51.4%
Female 67,770 47.6% 84,882 48.6% 84,882 48.6%
AGE
Under 18 45,911 32.3% 51,098 29.3% 51,098 29.3%
18 to 64 81,934 57.6% 105,278 60.3% 105,278 60.3%
65+ 14,516 10.2% 18,152 10.4% 18,152 10.4%

HOUSEHOLD TYPE
Families with Children 16,297 58.5% 20,706 52.9% 20,706 52.9% Data Sources: U.S. Census 2000 SF1 Tables P008, P012, P019, P021, P027 and P035, U.S. Census 2010 SF1 Tables P5, P12, P29 and P38; 2006-2010 5-Year American Community Survey, Tables B16001 and B05012.

NOTE: All % represent a share of the total population within the jurisdiction or region for that year, except family type, which is out of total families.

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Racially and Ethnically Concentrated Areas of
Poverty
This study uses a methodology developed by HUD that combines demographic and economic indicators to identify racially or ethnically concentrated areas of poverty (RECAPs). These areas are defined as census tracts that have:
• An individual poverty rate of 40% or more
o or an individual poverty rate that is at least three times that of the tract average for the metropolitan area, whichever is lower
• and a non-White population of 50% or more
Using a metric that combines demographic and economic indicators helps to identify a jurisdiction’s most vulnerable communities.

The racial and ethnic composition of neighborhoods with concentrations of poverty is disproportionate relative to the U.S. population overall. According to the U.S.

Department of Health and Human Services, Black and Hispanic populations comprise nearly 80% of the population living in areas of concentrated poverty in metropolitan areas, but only account for 42.6% of the total poverty population in the U.S4.

Overrepresentation of these groups in areas of concentrated poverty can exacerbate disparities related to safety, employment, access to jobs and quality education, and conditions that lead to poor health.

Identification of RECAPs is significant in determining priority areas for reinvestment and services to ameliorate conditions that negatively impact RECAP residents and the larger region. Since 2000, the prevalence of concentrated poverty has expanded by nearly 75% in both population and number of neighborhoods. The majority of concentration of poverty is within the largest metro areas, but suburban regions have experienced the fastest growth rate5.

The following figures show poverty levels by census tract in comparison to concentrations of residents by race/ethnicity and national origin. The maps also show

4 United States, Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation. “Overview of Community Characteristics in Areas With Concentrated Poverty.” ASPE Issue Brief, May 2014, https://aspe.hhs.gov/system/files/pdf/40651/rb_concentratedpoverty.pdf. 5 Kneebone, Elizabeth. "The Growth and Spread of Concentrated Poverty, 2000 to 2008-2012." The Brookings Institution, 29 July 2016, www.brookings.edu/interactives/the-growth-and-spread-of-concentrated-poverty2000-to-2008-2012/.

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R/ECAP census tract in El Centro outlined in pink, as well as concentration of Black and Hispanic residents by census tract.

FIGURE 1.

POVERTY RATES AND POPULATION BY RACE AND ETHNICITY IN EL CENTRO, 2018 TO 2022
Source: 2018-2022 ACS 5-Year Estimates, Tables S1701, B03002

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FIGURE 2.

POVERTY RATES AND POPULATION BY NATIONAL ORIGIN IN EL CENTRO, 2018 TO 2022
Source: 2018-2022 ACS 5-Year Estimates, Tables S1701, B05006

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As shown in Figure 1, El Centro currently contains one (1) census tract with R/ECAP designation. This tract exists in areas with higher-than-average concentrations of both Black and Hispanic residents, as well as areas with a high concentration of foreign-born residents as shown in Figure 2. This tract meets the definition of a Racially or Ethnically Concentrated Area of Poverty in that they have an individual poverty rate of 40% or more (or an individual poverty rate that is at least three times that of the tract average for the metropolitan area, whichever is lower) and a non-White population of 50% or more.

Segregation and Integration
Communities experience varying levels of segregation between different racial, ethnic, and socioeconomic groups. High levels of residential segregation often lead to conditions that exacerbate inequalities among population groups within a community.

Increased concentrations of poverty and unequal access to jobs, education, and other services are some of the consequences of high residential segregation.6 Federal housing policies and discriminatory mortgage lending practices prior to the Fair Housing Act of 1968 not only encouraged segregation, but mandated restrictions based on race in specific neighborhoods. The Fair Housing Act of 1968 outlawed discriminatory housing practices but did little to address the existing segregation and inequalities. Other federal housing policies and programs, like Section 8 and HOPE VI, have been implemented in an effort to ameliorate the negative effects of residential segregation and reduce concentrations of poverty. Despite these efforts, the repercussions of the discriminatory policies and practices continue to have a significant impact on residential patterns today.

Race and Ethnicity
A significant share of El Centro’s population is Hispanic/Latino (88.2%), and based on the spatial distribution of residential patterns, Hispanic residents appear to live throughout the city without any major indications of segregation. However, there appears to be a higher concentration of white residents in the far west side of El Centro.

The one RECAP tract in the city also contains the smallest concentration of white residents compared to the rest of the city. Downtown El Centro and its surrounding neighborhoods appear to be the most racially and ethnically integrated areas.

However, neighborhoods that appear integrated based on current residential patterns may be in the stages of gentrification and amidst changes in racial and ethnic

6 Massey, D. (1990). American Apartheid: Segregation and the Making of the Underclass. American Journal of Sociology, 96(2), 329-357. Retrieved from http://www.jstor.org/stable/2781105.

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composition that will eventually make them less diverse.

Figure 3 and Figure 4 show the development of El Centro’s racial and ethnic neighborhood composition from 2000 to 2022. The most noticeable change over the past 20 years is the growth of the Hispanic population, shown in orange. Black residents of El Centro have increased slightly and are mainly clustered in the central part of the city within the RECAPs tract and with a slight expansion in the surrounding tracts.

Hispanic residents have expanded outwards from the central city in a less concentrated way. In 2000, white residents were mostly concentrated in the western portion of the city, and while they are still mostly living in this part of the city in 2022, their overall population has decreased significantly. Overall population growth and density has increased in a few areas in El Centro including the far northeast quadrant and the far southern portion of the city.

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FIGURE 3.

POPULATION BY RACE AND ETHNICITY IN EL CENTRO, 2018 TO 2022 Source: 2018-2022 ACS 5-Year Estimates, Table B03002

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FIGURE 4.

POPULATION BY RACE AND ETHNICITY IN EL CENTRO, 2000
Source: 2000 Decennial Census

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Segregation Levels
In addition to visualizing racial and ethnic compositions of the area with the preceding maps, this study also uses a statistical analysis – referred to as dissimilarity – to evaluate how residential patterns vary by race and ethnicity, and how these patterns have changed since 1990. The Dissimilarity Index (DI) indicates the degree to which a minority group is segregated from a majority group residing in the same area because the two groups are not evenly distributed geographically. The DI methodology uses a pair-wise calculation between the racial and ethnic groups in the region. Evenness, and the DI, are maximized and segregation minimized when all small areas have the same proportion of minority and majority members as the larger area in which they live.

Evenness is not measured in an absolute sense but is scaled relative to the other group.

The DI ranges from 0 (complete integration) to 100 (complete segregation). HUD identifies a DI value below 40 as low segregation, a value between 40 and 54 as moderate segregation, and a value of 55 or higher as high segregation.

The proportion of the minority population group can be small and still not segregated if evenly spread among tracts or block groups. Segregation is maximized when no minority and majority members occupy a common area. When calculated from population data broken down by race or ethnicity, the DI represents the proportion of minority members that would have to change their area of residence to match the distribution of the majority, or vice versa.

The table below shares the dissimilarity indices for three pairings in El Centro. This table presents values for 1990, 2000, 2010, and 2020, all calculated using census tracts as the area of measurement.

The Dis calculated for each pairing in El Centro show that segregation between Black and white residents has decreased between 2000 and 2020. However, segregation has increased once again within the last ten years, growing from 32.96 to 44.63 which calculated a moderate segregation between Black and White residents. Overall, there has been an increase in segregation between white residents and all different racial/ethnic groups in El Centro, particularly within the last ten years.

TABLE 4. RACIAL AND ETHNIC DISSIMILARITY INDEX TRENDS IN EL CENTRO Race / Ethnicity

EL CENTRO, CA
1990 2000 2010 Current
Non-White/White 29.84 30.82 25.42 29.66
Black/White 54.99 46.83 32.96 44.63
Hispanic/White 30.04 31.79 26.12 30.21
Asian or Pacific
Islander/White 19.67 17.94 19.43 31.38
Source: HUD Affirmatively Furthering Fair Housing Data and Mapping Tool, AFFHT0006, released July 2020, https://egis.hud.gov/affht/.

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National Origin and Limited English Proficiency Population Settlement patterns of immigrants significantly impact the composition and landscape of communities across the United States. Large central cities have the largest population of foreign-born residents, but suburban areas are experiencing rapid growth of foreign-born populations recently.7 Clusters of immigrants of the same ethnicity form for a variety of reasons. Social capital in the form of kinship ties, social network connections, and shared cultural experiences often draw new immigrants to existing communities. Settling in neighborhoods with an abundance of social capital is less financially burdensome for immigrants and provides opportunities to accumulate financial capital through employment and other resources that would otherwise be unattainable.8
Populations with limited English proficiency (LEP) are typically composed of foreign-born residents that originate from countries where English is not the primary language, however, a substantial portion (19%) of the national LEP population is born in the United States. Nationally, the LEP population has lower levels of education and is more likely to live in poverty compared to the English proficient population.9 Recent studies have also found that areas with high concentrations of LEP residents have lower rates of homeownership.10
Communities of people sharing the same ethnicity and informal networks are able to provide some resources and opportunities, but numerous barriers and limited financial capital influence residential patterns of foreign-born and LEP populations.

As shown in FIGURE 5, El Centro has a high concentration of Mexican-born residents throughout the city which may be due to its close proximity to Mexico’s border and surrounding predominantly Hispanic/Latino communities in southern California. Due tot the high concentration of Mexican-born residents, there does not appear to be a concentration of residents born in other countries. The other most populous countries

7 James, F., Romine, J., & Zwanzig, P. (1998). The Effects of Immigration on Urban Communities. Cityscape, 3(3), 171-192.
8 Massey, D. (1999). Why Does Immigration Occur?: A Theoretical Synthesis. In Hirschman C., Kasinitz P., & DeWind J. (Eds.), Handbook of International Migration, The: The American Experience (pp. 34-52). Russell Sage Foundation.
9 Zong, J. & Batalova, J. (2015). “The Limited English Proficient Population in the United States” Migration Information Source. Retrieved: http://www.migrationpolicy.org/article/limited-english-proficientpopulation-united-states 10 Golding, E., Goodman, L., & Strochack, S. (2018). “Is Limited English Proficiency a Barrier to Homeownership.” Urban Institute. Retrieved: https://www.urban.org/research/publication/limited-englishproficiency-barrier-homeownership

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residents in El Centro are from include China, Korea, Guatemala, and El Salvador.

As shown in Figure 6, the primary language spoken by residents with a Limited English Proficiency is Spanish. Residents speaking primarily this language are dispersed throughout the entire city given that majority of residents born in Mexico, El Salvador, and Guatemala may be fluent in Spanish. This corresponds the locations of Hispanic communities (Figure 1) within El Centro.

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FIGURE 5.

FOREIGN-BORN POPULATION BY NATIONALITY IN EL CENTRO, 2018 TO 2022 Source: 2018-2022 ACS 5-Year Estimates, Table B05006

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FIGURE 6.

POPULATION WITH LIMITED ENGLISH PROFICIENCY IN EL CENTRO, 2018 TO 2022 Source: 2018-2022 ACS 5-Year Estimates, Table B16002

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Access to Opportunity
Where people live shapes prospects for economic mobility and access to resources and services such as high-quality education, affordable transportation, a healthy environment, fresh, affordable food, and healthcare. However, residents’ neighborhood or housing choices are often limited by discrimination in housing markets or public policies that result in concentrated poverty, disinvestment, and a lack of affordable housing in neighborhoods with access to high-performing schools and jobs that pay living wages. In this way, limited housing choices reduce access to opportunity for many protected classes.

In addition to proximity, access to opportunity is also shaped by economic, social, and cultural factors. For example, residents may live in locations with high numbers of jobs but may be unable to obtain them due to gaps in education or skills, a lack of reliable transportation, or childcare needs.

The strategy to improve access to opportunity through housing and community development programs has been two-pronged. Programs such as tenant-based housing vouchers provide recipients with mobility to locate in lower-poverty areas, while programs such as the Community Development Block Grant and Choice Neighborhoods Initiative provide funds to increase opportunities in low- or moderateincome neighborhoods. The following sections access to opportunity in El Centro, including employment and workforce development, education, transportation, environmental quality, fresh food, and healthcare.

Employment and Workforce Development
Neighborhoods with jobs in close proximity are often assumed to have good access to jobs. However, distance alone does not capture any other factor such as transportation options, the type of jobs available in the area, or the education and training necessary to obtain them. There may be concentrations of jobs and low-income neighborhoods in urban centers, but many of the jobs are unattainable for residents of low-income neighborhoods. Therefore, this section analyzes both the labor market engagement and jobs proximity indices which, when considered together, offer a better indication of how accessible jobs are for residents of a specific area.

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Labor Market Engagement
Educational attainment, labor force participation, and unemployment are indicators of residents’ engagement with the labor market. In El Centro, about 72% of all residents have at least high school graduate level of education, and about 16% have a bachelor’s degree or higher of education. However, as shown below, educational attainment levels vary by race and ethnicity. Asian and Pacific Islander residents have the highest levels of both high school and college education, while Black residents have the lowest levels of college education and Native American residents have the lowest levels of high school education. Hispanic residents, who are the predominant racial or ethnic group in the City, have high school education rates of about 62% and college education rates of about 11%. White, Black, and Asian/Pacific Islander residents all have high school education levels of over 90%, but have significantly varying levels of college education, with only 1.1% of Black residents holding a bachelor’s degree in comparison with nearly half of Asian/Pacific Islander residents and nearly a third of white residents.

FIGURE 7.

EDUCATIONAL ATTAINMENT FOR RESIDENTS AGED 25+ BY RACE / ETHNICITY Source: 2018-2022 ACS 5-Year Estimates, Table S1501

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Educational attainment also varies by location within El Centro. In three census tracts in the northern central portions of the City, including one tract designated as a R/ECAP, 10% or less of all residents aged 25+ have a bachelor’s degree. In one census tract in western El Centro, more than 25% of residents aged 25+ have a bachelor’s degree.

These education rates strongly correlate with unemployment rates and median household income levels as presented in Figure 12Figure 11 and Figure 13.

FIGURE 8.

EDUCATIONAL ATTAINMENT FOR RESIDENTS AGED 25+ BY CENSUS TRACT Source: 2018-2022 ACS 5-Year Estimates, Table S1501

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Labor force participation rate refers to the percent of a population aged 16 or over that is employed or actively seeking work. This rate varies in El Centro by race and ethnicity. As shown below, Black and Asian/Pacific Islander residents have the highest labor force participation rates in El Centro and are the only two racial or ethnic groups with participation rates over 60%. White and Native American residents have the lowest labor force participation rates, and white residents are the only group with rates under 50% at 49.9%.

FIGURE 9.

LABOR FORCE PARTICIPATION RATE FOR POPULATION AGED 16+ BY RACE /

ETHNICITY
Source: 2018-2022 ACS 5-Year Estimates, Table S2301
The average participation rate for El Centro as a whole is 58%, but this also varies by location within the City, as shown below. Four census tracts in El Centro have labor force participation rates of 52% or less, while three have rates of 61% or more. Notably, all three tracts shown in Figure 8 where fewer than 10% of residents hold a bachelor’s degree also have lower-than-average labor force participation rates.

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FIGURE 10.

LABOR FORCE PARTICIPATION BY CENSUS TRACT
Source: 2018-2022 ACS 5-Year Estimates, Table S2301

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An unemployment rate refers not to a share of the overall population but to the share of a group’s labor force that is unemployed but actively seeking work. This rate varies significantly in El Centro by race and ethnicity, as shown below. All racial and ethnic groups have unemployment rates of less than 12% with the notable exception of Native American residents, who have an unemployment rate of 52.9%. Among other groups Black residents have the lowest unemployment rate at just 3.1%, and white, Asian/Pacific Islander, and multi-racial residents also all have unemployment rates under 10%. Hispanic residents and residents of other races or ethnicities have unemployment rates just over 10%, at 11% and 10.6% respectively.

FIGURE 11.

UNEMPLOYMENT IN EL CENTRO BY RACE / ETHNICITY
Source: 2018-2022 ACS 5-Year Estimates, Table S2301
Unemployment rates in El Centro also vary significantly by geography and are strongly correlated to education rates, as shown in Figure 8 and Figure 12. Just one census tract in south El Centro has an unemployment rate of 5% or less, while four tracts, including the City’s only R/ECAP tract, have unemployment rates over 15%. Two of these tracts are tracts in which fewer than 10% of residents hold a bachelor’s degree.

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FIGURE 12.

UNEMPLOYMENT RATE IN EL CENTRO
Source: 2018-2022 ACS 5-Year Estimates, Table S2301
Median household income, or MHI, is another indicator of access to employment and jobs that pay living wages. The median household income in El Centro was $54,922 as of the 2018-2022 American Community Survey five-year estimates, which is significantly lower than the MHI of $91,551 for California and slightly lower than the MHI of $57,310 El Centro, CA Metro area. Median household incomes are lowest in two census tracts

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located in northwest El Centro, one of which is designated as a R/ECAP. Both of these tracts, in which median household income is $40,000 or less per year, are also tracts where fewer than 10% of residents hold a bachelor’s degree (see Figure 8).

FIGURE 13.

MEDIAN HOUSEHOLD INCOME
Source: 2018-2022 ACS 5-Year Estimates, Table S1901

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Low median household incomes in many of the City’s census tracts highlight the fact that a high proportion of households do not have sufficient incomes to afford basic needs. The MIT Living Wage Calculator estimates that for a family of two working adults and one child living in Imperial County, the minimum annual household income considered to be a living wage is $81,304, or approximately $6,775 per month combined ($3,387.50 per month per wage earner)11. However, as shown in Figure 13, only two census tracts in El Centro have a median household income of over $80,000 per year. Additionally, the U.S. Census Bureau reports that only 44.5% of primary jobs in El Centro pay more than $3,333 per month12. This means that the majority of El Centro households do not have access to jobs paying living wages to meet the area’s cost of living.

Jobs Proximity
Jobs in El Centro are clustered in the center of the City, where three tracts contain more than 2,000 jobs each. Most tracts in the northern, southern, and eastern portions of the City also contain a high number of jobs, with western tracts tending to have fewer jobs.

11 https://livingwage.mit.edu/counties/06025
12 https://onthemap.ces.census.gov/

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FIGURE 14.

JOB PROXIMITY IN EL CENTRO
Source: 2021 American Community Survey, accessed from onthemap.ces.census.gov Longitudinal Employer-Household Dynamics data, or LODES data, also indicates that a substantial share of workers living in El Centro work outside of the City, and that many people who work in the City live outside of the jurisdiction. As shown below, only about 31% of El Centro’s work force, or about 5,875 people, live within El Centro City limits. The remaining 69% of the work force, around 13,000 people, commute to El Centro from

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outside of the City limits. Additionally, over 11,000 El Centro residents live within the City limits but work outside – nearly double the number of City residents who work within City limits. The high level of commuting across jurisdictions indicates that limited access to vehicles and a lack of frequent public transportation in some areas may present a significant barrier for residents in accessing employment, which can in turn present a barrier to fair housing access.

FIGURE 15.

INFLOW AND OUTFLOW OF WORKERS IN EL CENTRO
Source: Longitudinal Employer Household Dynamics (LODES) data, 2021, accessed via https://onthemap.ces.census.gov/.

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Transportation
Affordable, accessible transportation makes it easier for residents to access a range of opportunities, providing connections to employment, education, fresh food, healthcare, and other services. Low-cost public transit can facilitate access to these resources, while a lack to access to affordable transportation poses barriers to meeting key needs, particularly in areas with low levels of walkability and a lack of access to vehicles.

Vehicle Access
Access to vehicles also shapes residents’ ability to connect to employment and education opportunities, resources, and services, particularly in areas with limited access to public transit. According to the 2018-2022 American Community Survey estimates, 6.2% of El Centro households do not have access to a vehicle. This rate varies by location, as depicted below – in one census tract in southern El Centro every household has access to a vehicle, while in two census tracts in central and western El Centro, including the City’s only R/ECAP tract, more than 10% of households do not have vehicle access.

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FIGURE 23.

Vehicle Access and Race / Ethnicity in El Centro
Source: 2018-2022 ACS 5-Year Estimates, Table S2504
Other Affordable Transportation Access
For residents who do not have access to a vehicle, other affordable transit options are crucial in supporting fair housing access. Without access to affordable and reliable transit, residents are severely limited in their choice of residential location by a need to

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live very near their place of work. This is especially prominent in areas with limited walkability – according to the website WalkScore, El Centro has an average walkability score of 51 and a bike score of 46, meaning that minimal errands can be accomplished on foot or by bicycle. El Centro’s walkability score increases near the City center and decreases near the City limits.

FIGURE 16.

WALKSCORE IN EL CENTRO
Source: walkscore.com/CA/El_Centro
Figure 17 maps the area’s walkability by block group using EPA’s National Walkability Index, which is “based on measures of the built environment that affect the probability of whether people walk as a mode of transportation: street intersection density, proximity to transit stops, and diversity of land uses.” Certain areas of downtown/central El Centro are scored as “most walkable”, and a large portion of the city is deemed “above average walkable”. In accordance with previously examined patterns of transit & vehicle access, areas along the outskirts of the city were categorized as “below average walkable”. No area inside El Centro’s city limits was scored as “least walkable”.

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FIGURE 17.

WALKABILITY INDEX IN EL CENTRO
Source: U.S. EPA National Walkability Index, from https://www.epa.gov/smartgrowth/nationalwalkability-index-user-guide-and-methodology Figure 18 visualizes transportation costs as a percentage of household income by census tract, using H+T® Index data provided by the Center for Neighborhood Technology (CNT). Considering transportation costs together with housing costs can provide an expanded view of a neighborhood’s affordability. Based on this data,

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households near central/downtown El Centro, where bus routes are more robust, spend slightly less on transportation than those living on the outskirts or outside of the city limits.

FIGURE 18.

TRANSPORTATION COSTS AS A PERCENTAGE OF HOUSEHOLD INCOME Source: Center for Neighborhood Technology, H+T Affordability Index, 2019. https://htaindex.cnt.org/download/data.php

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The 2018-2022 ACS estimates that during this 5-year period, approximately 0.4% of El Centro’s labor force used public transit to commute to work, 1.7% walked to work, and

1.7% used a taxicab or other similar method to commute to work. None of El Centro’s workforce reported bicycling to work during this time, emphasizing WalkScore’s report of limited to no bicycle infrastructure within the City. These rates varied significantly by location within the City, as shown below.

FIGURE 25.

MEANS OF TRANSPORTATION TO WORK IN EL CENTRO FOR RESIDENTS WITHOUT

VEHICLES
Source: 2018-2022 ACS 5-Year Estimates, Table S0801

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The City of El Centro’s official website lists the following public transit options, which will be discussed in greater detail in the following chapter13:
• Imperial Valley Transit provides bus service to the greater area, including El Centro.
• IVT RIDE provides curb to curb transit service for seniors; persons aged 60 years and over, and persons with disabilities upon advance phone reservation. • IVT MedTrans provides transit between Imperial Valley and San Diego County medical facilities, clinics and doctor offices. This service is provided four days a week to transit-dependent persons requiring essential or lifeline medical services who meet the established criteria.
• IVT Access offers transit services to residents who cannot drive due to disability with advanced reservation.

13 https://cityofelcentro.org/publicworks/public-transportation/

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Low-Poverty Neighborhoods
Poverty rates are highest in central and far eastern/western El Centro (see Figure 19).

The City has an overall poverty rate of 21.1%, with three tracts reporting poverty rates over 20% and two tracts with rates over 30%. No one race or ethnicity is overrepresented in these areas, but there is correlation present between poverty rates, educational attainment, and unemployment (see Figure 8 and Figure 12). When residents’ housing choices are limited to high-poverty neighborhoods by factors like vehicle or transit access, job availability, food access, etc., this may constitute a barrier to fair housing choice.

Housing-related factors which limit residents to high-poverty areas frequently include the following:
• a lack of supply of affordable housing supply;
• a lack of supply of housing in general, which drives up overall housing prices; • a lack of variety of housing types available, including tiny homes, townhomes, and smaller homes that may be more affordable;
• high rental rates and displacement of residents due to increases in rents; • limited development of multifamily housing and smaller, more affordable housing units due to restrictive zoning ordinances

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FIGURE 19.

POVERTY RATES IN EL CENTRO
Source: 2018-2022 ACS 5-Year Estimates, Table S1710

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Environmental Quality
Environmental quality and access to environmental amenities also shape the opportunities available to residents. Access to parks and other green infrastructure in counties, cities, and neighborhoods provides a range of environmental, social, and health benefits, including access to nature and recreation opportunities; cleaner air and water; alternative transportation options; improvements in physical and mental health and wellbeing; and opportunities for food production and other local economic development. At the same time, environmental hazards, such as poor air quality and toxic facilities, are associated with negative health effects including increased respiratory symptoms, hospitalization for heart or lung diseases, cancer and other serious health effects, and even premature death. Certain population groups, such as children, have a greater risk of adverse effects from exposure to pollution.

Access to Parks
The Trust for Public Land estimates the need for parks by census block group based on population density, density of low-income households, density of people of color, rates of poor mental health and low physical activity, urban heat islands, and pollution burden.14 Based on these factors, El Centro has adequate park access within a 10- minute walk of residents within most of the central portion of the City, but lacks access in most areas surrounding the City borders (see Figure 20).

The Trust for Public Land also measures park access by age, income level, and race and ethnicity (see Figure 28). In El Centro, Black residents and residents of other races have the highest levels of park access, while white and Asian residents have the lowest levels. Unusually, low-income residents have higher levels of park access than mid- and high-income residents. This may be due to increased park access in the City center and the tendency of high-income residents to reside in suburbs on the fringes of cities.

Park access by age is fairly evenly distributed, with 70-73% of residents of all ages having access to a park within a 10 minute walk.

14 Trust for Public Land. (2022). The ParkServe Database. Retrieved from:
https://www.tpl.org/ParkServe/About

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FIGURE 20.

PARKS ACCESS BY GEOGRAPHY IN EL CENTRO
Source: Trust for Public Land, parkserve.tpl.org/mapping/#/?CityID=0621782

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FIGURE 21.

PARK ACCESS BY DEMOGRAPHICS IN EL CENTRO
Source: Trust for Public Land, /www.tpl.org/city/el-centro-california

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Environmental Hazards
Toxic sites may pose risks to residents living nearby and thus may constitute fair housing concerns if they disproportionately impact protected classes. A Superfund site is any land in the United States that has been contaminated by hazardous waste and identified by the EPA as a candidate for cleanup because it poses a risk to human health and / or the environment. These sites are placed on the National Priorities List (NPL). There are no Superfund sites in close proximity to El Centro, but one site has been proposed by Stoker Company for future development within Imperial County15.

The EPA’s National Air Toxics Assessment (NATA) estimates health risks from air toxics. The most recent assessment uses data from 2019 to examine cancer risk from ambient concentrations of pollutants16 and is presented below. The are four facilities in El Centro which produce emissions that may contribute to cancer risk, but overall risk is low and does not vary by location within the City.

FIGURE 22.

AIR TOXICS SCREENING ASSESSMENT
Source: https://www.epa.gov/AirToxScreen/airtoxscreen-mapping-tool

15 https://semspub.epa.gov/src/document/09/2400177
16 United States Environmental Protection Agency. National Air Toxics Assessment. (2019). Retrieved from:
https://www.epa.gov/national-air-toxics-assessment

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The Toxics Release Inventory (TRI) tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. Certain industrial facilities in the U.S. must report annually how much of each chemical is recycled, combusted for energy recovery, treated for destruction, and disposed of or otherwise released on- and off-site. This information is collectively referred to as productionrelated waste managed. There are six TRI sites located within El Centro, which may potentially pose additional risk to residents living nearby.

FIGURE 23.

TOXIC RELEASE INVENTORY FACILITIES
Source: https://enviroatlas.epa.gov/enviroatlas/interactivemap/

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Food
Many individuals and families in the United States face challenges in accessing food that is both healthy and affordable. In neighborhoods in which the nearest grocery store is many miles away, transportation costs and lack of access to vehicles may pose particular challenges for low-income households, who may be forced to rely on smaller stores that are often unaffordable and may not offer a full range of healthy food choices. Even in areas with fresh food retailers nearby, the higher cost of healthy foods such as produce often present barriers to accessing healthy food.

The USDA Food Research Atlas indicates food access issues in urban areas by measuring the share of residents who have low incomes and live further than one-half mile from the nearest supermarket. In El Centro, the share of residents with food access issues is greatest in the central and eastern parts of the City, including within the City’s only R/ECAP census tract (see Figure 24). There are five tracts within the City where 30- 40% of residents are considered low income and low access, and one tract where more than 40% of residents face these issues. A lack of close access to a supermarket may be compounded by lack of transit access, and Figure 23 shows that all tracts where 30% or more of residents have food access issues are also tracts where 5% or more of households do not have access to a vehicle.

The non-profit Feeding America estimates that 17% of Imperial County residents face food insecurity, or more than 30,000 people (see Figure 25). They further estimate that 85% of such residents would be income-eligible for SNAP benefits. This indicates a potential need to expand SNAP and other similar benefits in the area.

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FIGURE 24.

FOOD ACCESS IN EL CENTRO
Source: USDA 2019 Food Access Research Atlas Data

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FIGURE 25.

FOOD INSECURITY IN IMPERIAL COUNTY
Source: map.feedingamerica.org/county/2021/overall/california/county/imperial

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Healthcare
Access to high-quality, affordable physical and mental healthcare shapes community health outcomes, including both length of life and quality of life. The United States Health Resources and Services Administration (HRSA) identifies geographic areas with a lack of access to primary care services, known as Medically Underserved Areas17. The HRSA calculates an Index of Medical Underservice based on the number of providers per 1,000 population ratio, the percent of population at 100% of the Federal Poverty Level, the percent of population age 65 and over, and the infant mortality rate.

According to this metric, Imperial County has been designated as a medically underserved area for primary care physicians since 199318.

TABLE 5. RATIO OF POPULATION TO HEALTHCARE PROVIDERS, IMPERIAL COUNTY AND THE STATE OF CALIFORNIA, 2019-2021
Imperial County California
Primary Care Physicians 26.69 93.79
Dentists 22.24 79.08
Psychologists N/A 101.2
Source: County Health Rankings, Area Health Resource File/ American Medical Association, 2019-2021 Note: ratio is presented as number of providers per 100,000 residents In addition to access to healthcare providers, health insurance coverage is an important component of access to needed healthcare—including preventive care— and to maintaining financial security. While the share of residents with health insurance in El Centro overall has increased to 94.3% as of the 2018 to 2022 American Community Survey five-year estimates, up from 82.4% in the 2011-2015 estimates, shares of uninsured residents continue to vary by location across the county.

The share of residents without health insurance is highest in the northeastern portion of the City, which contains two census tracts where more than 10% of residents are uninsured. Two more tracts, including El Centro’s only R/ECAP tract, have uninsurance rates of between 8% and 10%.

Overall, healthcare access is shaped by multiple factors, including availability of providers, health insurance coverage, income, housing affordability and stability, and access to vehicles or other transportation options. Investments in programs designed to increase access to healthcare—such as expanding access to health insurance, investing in telehealth and mobile health services, education about where to access health services, and improved cultural responsiveness—may help increase access for

17 Health Services and Resources Administration. (2022). Scoring Shortage Designations. Retrieved from:
https://bhw.hrsa.gov/workforce-shortage-areas/shortage-designation/scoring 18 https://data.hrsa.gov/tools/shortage-area/mua-find

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residents. Because of geographic disparities in health insurance coverage, efforts such as increasing enrollment in Medicaid and Marketplace health insurance plans and providing access to low-cost health services may be most effective in addressing goals of improving access to healthcare by focusing efforts on census tracts with low levels of health insurance coverage.

FIGURE 26.

ACCESS TO HEALTH INSURANCE IN EL CENTRO
Source: 2018-2022 ACS 5-Year Estimates, Table S2701

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Housing Profile
The availability of quality affordable housing plays a vital role in ensuring housing opportunities are fairly accessible to all residents. On the surface high housing costs in certain areas are exclusionary based solely on income; however, the disproportionate representation of several protected class groups in low- and middle-income levels can lead to unequal access to housing options and neighborhood opportunity in high-cost housing markets. Black and Hispanic residents, immigrants, people with disabilities, and seniors often experience additional fair housing barriers when affordable housing is scarce.

Beyond providing fair housing options, the social, economic, and health benefits of providing quality affordable housing are well-documented. National studies have shown affordable housing encourages diverse, mixed-income communities, which result in many social benefits. Affordable housing also increases job accessibility for lowand middle-income populations and attracts a diverse labor force critical for industries that provide basic services for the community. Affordable housing is also linked to improvements in mental health, reduction of stress, and decreased cases of illnesses caused by poor-quality housing.19 Developing affordable housing is also a strategy used to prevent displacement of existing residents when housing costs increase due to economic or migratory shifts.

Conversely, a lack of affordable housing eliminates many of these benefits and increases socioeconomic segregation. High housing costs are linked to displacement of low-income households and an increased risk of homelessness.20 Often lacking the capital to relocate to better neighborhoods, displaced residents tend to move to socioeconomically disadvantaged neighborhoods where housing costs are most affordable.21
This section discusses the existing supply of housing in El Centro. It also reviews housing costs, including affordability and other housing needs by householder income.

Homeownership rates and access to lending for home purchases and mortgage refinancing are also assessed.

19 Maqbool, Nabihah, et al. "The Impacts of Affordable Housing on Health: A Research Summary." Insights from Housing Policy Research, Center for Housing Policy, www.rupco.org/wp-content/uploads/pdfs/TheImpacts-of-Affordable-Housing-on-Health-CenterforHousingPolicy-Maqbool.etal.pdf. 20 “State of the Nation’s Housing 2015.” Joint Center for Housing Studies of Harvard University, http://www.jchs.harvard.edu/sites/default/files/jchs-sonhr-2015-full.pdf 21 Deirdre Oakley & Keri Burchfield (2009) Out of the Projects, Still in the Hood: The Spatial Constraints on Public-Housing Residents’ Relocation in Chicago.” Journal of Urban Affairs, 31:5, 589-614.

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Housing Supply Summary
Vacancy rates within a jurisdiction’s housing supply can indicate certain characteristics of the overall supply. For example, a high vacancy rate in an area where residents report housing access issues can indicate that a barrier to access may lie in price or condition of housing, rather than in an inadequate number of units. Conversely, a low vacancy rate in an area with housing access issues may indicate a need for new unit construction.

Vacancy data for the City of El Centro and for the El Centro, CA Metro Area is shown below. In this instance, it is important to note that there are discrepancies present between 2020 Census data and 2018-2022 ACS data. Most notably, ACS data indicates that there are fewer housing units in the jurisdiction in 2022 than there were in 2020 and that vacancy rates in both the City and County reversed twenty-year trends to more than double between 2020 and 2022. This is highly unusual, as numbers of housing units typically increase within a jurisdiction over time due to new construction. Potential explanations for such a notable loss of units could include a large natural disaster event destroying a significant number of units or an adjustment of City limits to exclude areas which were previously incorporated. Absent these explanations, it is possible that 2018- 2022 ACS data contains an error when reporting number of units for El Centro. For this reason, the table below depicts both 2020 Census data, which is more consistent with previous housing trends, and 2018-2022 ACS data, which may provide more up-to-date information.

In comparison to the overall state of California vacancy rate of 7.7%22, vacancy rates within both the City and County as reported by the 2018-2022 ACS are unusually high and have increase significantly within the past ten to twenty years. Most notably, the number of occupied housing units has gone down in both jurisdictions since 2010.

Within El Centro, the total number of housing units also went down from 2010-2022. This is unusual, as numbers of housing units typically increase within a jurisdiction over time due to new construction. Loss of overall units indicates that more units were destroyed over time than were built, either intentionally or by natural disaster.

22 2017-2022 American Community Survey 5-Year Estimates, Table DP04

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TABLE 6. HOUSING UNITS BY OCCUPANCY STATUS
2000 2010 2020 2022
2000 to
2022
Change

EL CENTRO
TOTAL HOUSING UNITS 12,263 14,476 15,041 13,958 +1,695
Occupied Housing Units 11,439 13,108 14,137 12,225 +786 Vacant Housing Units 824 1,368 904 1,733 +909
Vacancy Rate 6.7% 9.5% 6.0% 12.4% +5.7

IMPERIAL COUNTY
TOTAL HOUSING UNITS 43,891 56,067 56,625 56,907 +13,016 Occupied Housing Units 39,384 49,126 52,050 47,024 +7,640 Vacant Housing Units 4,507 6,941 4,575 9,883 +5,376
Vacancy Rate 10.3% 12.4% 8.1% 17.4% +7.1%
Sources: 2000, 2010, and 2020 U.S. Census and 2018-2022 5-Year ACS, Tables H003, H1, and DP04.

Availability of housing in a variety of sizes is important to meet the needs of different demographic groups. Neighborhoods with multi-bedroom detached, single-family homes will typically attract larger families, whereas dense residential developments with smaller unit sizes and fewer bedrooms often accommodate single-person households or small families. However, market forces and affordability impact housing choice and the ability to obtain housing of a suitable size, and markets that do not offer a variety of housing sizes at different price points can lead to barriers for some groups. Rising housing costs can, for example, lead to overcrowding as large households with lower incomes are unable to afford pricier, larger homes and are forced to reside in smaller units. On the other hand, people with disabilities or seniors with fixed incomes may not require large units but can be limited by higher housing costs in densely populated areas where most studio or one-bedroom units are located.

In El Centro and surrounding Imperial County single-family detached homes are by far the most common housing type, making up more than half of all housing units in both jurisdictions. The next most common housing type in El Centro is 2-4 unit structures, or duplexes, triplexes, and quadplexes, followed by small apartment buildings with 5-19 units. Large apartment complexes with 20 or more units and mobile homes each make up nearly 9% of El Centro homes, while single-family attached units like townhomes make up just 2.5%. Home types such as RVs, boats, or vans are very uncommon.

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TABLE 7. HOUSING UNITS BY STRUCTURE
Units in Structure
El Centro Imperial County
# % # %
1, Detached 7,731 55.4% 35,947 63.2%
1, Attached 351 2.5% 1,129 2.0%
2 to 4 1,822 13.1% 5,453 9.6%
5 to 19 1,618 11.6% 6,192 10.9%
20 or more 1,202 8.6% 2,330 4.1%
Mobile Home 1,196 8.6% 5,612 9.9%
Other (RV, Boat, Van, etc.) 38 0.3% 244 0.4%
TOTAL 13,958 100.0% 56,907 100.0%
Source: 2018-2022 5-Year American Community Survey, Table B25024.

Many areas have distinct differences in housing characteristics between owners and renters. This is particularly true regarding unit size. In El Centro housing is split fairly evenly between owners and renters, with approximately 51% of residents residing in a home they own and 49% of residents residing in a home they rent; however, renters are significantly more likely to reside in a small unit than owners. Nearly one-third of renters in the City live in a studio or one-bed unit, in comparison to less than 4% of owners.

Conversely, only 8.8% of renters live in a home with four or more bedrooms, in comparison with 43.8% of owners. Trends are similar in Imperial County, where 4.3% of owners live in a studio or one-bed home while almost one-quarter of all renters live in a home this size.

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TABLE 8. HOUSING UNITS BY SIZE AND TENURE
Number of Bedrooms
El Centro Imperial County
# % # %

OWNER-OCCUPIED HOUSING UNITS
0 Bedrooms 52 0.8% 359 1.3%
1 Bedroom 184 3.0% 818 3.0%
2 or 3 Bedrooms 3,250 52.4% 15,892 58.6%
4 or More Bedrooms 2,714 43.8% 10,053 37.1%
TOTAL 6,200 100.0% 27,122 100.0%

RENTER-OCCUPIED HOUSING UNITS
0 Bedrooms 395 6.6% 1,137 5.7%
1 Bedroom 1,515 25.1% 3,782 19.0%
2 or 3 Bedrooms 3,586 59.5% 13,012 65.4%
4 or More Bedrooms 529 8.8% 1,971 9.9%
TOTAL 6,025 100.0% 19,902 100.0%
Source: 2018-2022 5-Year ACS Estimates, Table B25042.

NOTE: Total add to the total number of occupied housing units in each geography. Unoccupied units are not included in this table because tenure data is not available for these units.

Assessing housing conditions in an area can provide a basis for developing policies and programs to maintain and preserve the quality of the housing stock. The age of an area’s housing can have substantial impact on housing conditions and costs. As housing ages, maintenance costs rise, which can present significant affordability issues for low- and moderate-income homeowners. Aging rental stock can lead to rental rate increases to address physical issues or deteriorating conditions if building owners defer or ignore maintenance needs. Deteriorating housing can also depress neighboring property values, discourage reinvestment, and eventually impact the quality of life in a neighborhood. Additionally, homes built prior to 1978 present the potential for lead exposure risk due to lead-based paint or lead pipes carrying drinking water.

Data shows that 46.5%, or nearly half, of El Centro’s housing stock was built prior to 1980 and therefore is likely at risk of lead exposure (data is available from the U.S. Census Bureau only in decade categories and it is therefore impossible to ascertain the number of homes built prior to exactly 1978, so prior to 1980 is the best estimate). Housing stock in El Centro trends older than housing stock in the wider County, as shown below. The 2008 housing crisis had a significant impact on the area, with a sharp drop in housing built in 2010 or later. Less than 20% of El Centro’s housing units are under 20 years old,

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while 65% of all units are over 40 years old. This indicates that El Centro will likely experience elevated costs associated with maintenance and repair of older housing units in comparison to cities with an overall newer housing stock.

FIGURE 27.

AGE OF HOUSING IN EL CENTRO AND IMPERIAL COUNTY
Source: 2018-2022 ACS 5-Year Estimates, Table B25034

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Housing Costs and Affordability
The availability of housing that is both affordable and in good condition was a common need identified by stakeholders, particularly for low- and moderate-income households.

The National Low Income Housing Coalition’s annual Out of Reach report examines rental housing rates relative to income levels for counties throughout the U.S. The figure below shows annual household income and hourly wages needed to afford Fair Market Rents in Imperial County. As shown below, no units in the County would be considered affordable to an individual working 40 hours per week at minimum wage, and only a one-bed unit would be affordable to an individual working 40 hours per week at the County’s average renter wage. It is likely that this issue particularly impacts single-parent households, who have a need for larger unit sizes but typically only have one wageearner per household.

FIGURE 28.

REQUIRED INCOME, WAGES, AND HOURS TO AFFORD FAIR MARKET RENTS IN IMPERIAL COUNTY, 2023
Source: National Low Income Housing Coalition Out of Reach 2021, Accessed from https://reports.nlihc.org/oor/florida.

Data is also available from the U.S. Census Bureau on average monthly housing costs for owners and renters within a given jurisdiction. The graphs below show average costs for owners and renters in both El Centro and Imperial County. It is important to note that this American Community Survey is aggregate data for the years 2018-2022 and is therefore somewhat of a lagging indicator. 2018-2022 ACS data shows that in El Centro, 50% of renters pay between $500 and $999 in rent per month; however, the real estate site Zumper, which is the largest privately held rental platform in the U.S., reports that rental prices in El Centro have increased exponentially within the past year, especially for smaller housing units. This data is also depicted below.

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FIGURE 29.

GROSS MONTHLY RENT FOR RENTER HOUSEHOLDS IN EL CENTRO AND IMPERIAL COUNTY, 2018-2022
Source: 2018-2022 ACS 5-Year Estimates, Table B25063.

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FIGURE 30.

MONTHLY HOUSING COSTS FOR OWNER HOUSEHOLDS IN EL CENTRO AND IMPERIAL COUNTY, 2018-2022
Source: 2018-2022 ACS 5-Year Estimates, Table B25094.

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FIGURE 31.

AVERAGE MONTHLY RENTS IN EL CENTRO, FEBRUARY 2024
Source: www.zumper.com/rent-research/el-centro-ca
These sources combined indicate that rental costs are rising significantly more rapidly than wages in the area. While 2018-2022 ACS data showed that renters were compressed into an overall smaller price range than owners, especially in regard to monthly costs over $1,500, Zumper data indicates that this gap may be rapidly shrinking.

It is also notable that 2018-2022 ACS data showed that only about 8.8% of renters spent less than $500 per month on housing, in comparison with around 12.5% of owners. With rapidly increasing rental costs, it is highly likely that the number of renters in this price range has dwindled drastically since 2022, while the number of owners in this price range likely remains about the same due to the relative stability of a mortgage.

Housing Needs
Housing cost and condition are key components to housing choice. Housing barriers may exist in a jurisdiction when some protected class groups have greater difficulty accessing housing in good condition and that they can afford. To assess affordability and other types of housing needs, HUD defines four housing problems:

1. A household is cost burdened if monthly housing costs (including mortgage payments, property taxes, insurance, and utilities for owners and rent and utilities for renters) exceed 30% of monthly income.

2. A household is overcrowded if there is more than 1.0 people per room, not including kitchen or bathrooms.

3. A housing unit lacks complete kitchen facilities if it lacks one or more of the following: cooking facilities, a refrigerator, or a sink with piped water.

4. A housing unit lacks complete plumbing facilities if it lacks one or more of the following: hot and cold piped water, a flush toilet, or a bathtub or shower.

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HUD also defines four severe housing problems, including a severe cost burden (more than 50% of monthly housing income is spent on housing costs), severe overcrowding (more than 1.5 people per room, not including kitchens or bathrooms), lack of complete kitchen facilities (as described above), and lack of complete plumbing facilities (also as described above).

To assess housing need, HUD receives a special tabulation of data from the U. S. Census Bureau’s American Community Survey that is largely not available through standard Census products. This data, known as Comprehensive Housing Affordability Strategy (CHAS) data, counts the number of households that fit certain combination of HUDspecified criteria, such as housing needs by race and ethnicity. CHAS data for El Centro is provided in the tables that follow.

As depicted in Table 9, the share of households with at least one housing need varies drastically by race and ethnicity in El Centro. White residents are least likely to have a housing problem, with just under one quarter of all white households having at least one housing problem. In contrast, nearly 90% of Black households have at least one housing problem, and nearly half of all Hispanic households have at least one housing problem.

Large families were more likely to have housing problems than small families, and nonfamily households were significantly less likely to have a housing problem than either small or large family households. Overall, 40.3% of households in El Centro have at least one housing problem.

The most common type of housing problem in most areas is cost burden, which is defined as a situation in which a household spends more than 30% of its income on housing expenses each month. If a household spends more than 50% of its income on housing each month, this qualifies as severe cost burden. Table 10 examines rates of severe cost burden by race, ethnicity, and household type, revealing that Black households in El Centro are severely cost burdened at a rate over five times higher than that of white households. Hispanic households are nearly three times more likely to be cost burdened than white households, and Asian households are nearly twice as likely.

Large family households were about half as likely to be severely cost burdened as small family households, which may indicate more wage earners per household in large family homes. Overall, 12.8% of El Centro households spend more than 50% of their income on housing every month.

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TABLE 9. DEMOGRAPHICS OF HOUSEHOLDS WITH DISPROPORTIONATE HOUSING NEEDS
Households Experiencing any of the Four
Housing Problems
#with
Problems
# of
Households
% with
Problems
Race & Ethnicity
White, Non-Hispanic 355 1,484 23.9%
Black, Non-Hispanic 395 443 89.2%
Hispanic 4,630 9,510 48.7%
Asian or Pacific Islander, Non-Hispanic 84 288 29.2%
Native American, Non-Hispanic 0 0 0.0%
Household Type
Family Households, <5 People 3,210 7,220 44.5%
Family Households, 5+ People 1,080 2,095 51.6%
Non-Family Households 1,165 4,230 27.5%
TOTAL 5,455 13,545 40.3%
Source: CHAS Tables 1 and 4.

NOTE: Total estimates do not align with categorical numbers. 2016-2020 ACS Estimates for the “Other-NonHispanic” racial / ethnic category are not shown, as they have been suppressed due to increased disclosure avoidance protections instituted by Census. All % represent a share of the total population, except household type and size, which is out of total households.

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TABLE 10. DEMOGRAPHICS OF HOUSEHOLDS WITH SEVERE HOUSING COST

BURDENS
Households Experiencing Severe Cost Burden # with
Problems
# of
Households
% with
Problems
Race & Ethnicity
White, Non-Hispanic 80 1,475 5.4%
Black, Non-Hispanic 120 440 27.3%
Hispanic 1,510 9,515 15.9%
Asian or Pacific Islander, Non-Hispanic 30 290 10.3%
Native American, Non-Hispanic 0 00 0.0%
Other 0 30 0.0%
Household Type
Family Households, <5 People 1,110 7,220 15.4%
Family Households, 5+ People 180 2,095 8.6%
Non-Family Households 449 4,230 10.6%
TOTAL 1,739 13,545 12.8%
Source: CHAS, Tables 7, 9.

NOTE: Severe housing cost burden is defined as greater than 50% of income. All % represent a share of the total population within the jurisdiction or region, except household type and size, which is out of total households. The # of households is the denominator for the % with problems, and may differ from the # of households for the table on severe housing problems.

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Public Investment Patterns
Jurisdictions that receive CDBG funds, such as the City of El Centro, must prepare an annual report of their accomplishments and progress towards goals identified in the Consolidated Plan. This report is known as a Consolidated Annual Performance and Evaluation Report (CAPER). The City of El Centro’s CAPER also provides a report of progress made towards goals identified in the Analysis of Impediments to Fair Housing (AI), which are summarized in TABLE 23.

Here, the City of El Centro’s CAPERs were reviewed from FY2018-FY2023 as a means of analyzing patterns of public investment in services and their potential to create barriers to housing and opportunity for protected classes. Over this time period, the City’s CDBG investments generally fell under the following categories:
• Affordable Housing
• Economic Development
• Fair Housing
• Homeless
• Non-Housing Community Development
• Non-Homeless Special Needs
• Public Housing
CDBG amounts allocated towards the promotion of fair housing services in the City of El Centro have remained steady over this period, though resulting activities have yielded variable numbers of participants. Most years have fallen short of expectations based on the expected number (#) of persons assisted outlined in each program year and the 2019-2023 Consolidated Plan. Reports also note that participation in the City’s Housing Rehabilitation Program, which falls under the affordable housing category and includes the Lead Based Paint Abatement Program, has been low. However, projects focused on providing other public services, such as services for the homeless, seniors, and youth have been quite successful in meeting Consolidated Plan and program year expectations.

It is unlikely that any of the City’s planning, financing, and administrative actions related to the siting of social services would inhibit or concentrate housing opportunities among protected classes. The City allocates CDBG funds towards a wide range of opportunities across the area, partnering with a variety of organizations and leveraging funds with other funding opportunities when possible to make affordable housing development more feasible.

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PUBLIC TRANSPORTATION

IMPACTS
The City of El Centro and broader Imperial County are served by Imperial Valley Transit (IVT), which provides daily fixed-route services in the city on the Green Line and Blue Line from 6:00am to 6:30pm (see Figure 32 and Figure 33).23 IVT also offers several regional routes that connect El Centro to other cities in the county. Discounted fares are available for students, seniors, and persons with disabilities.

Other programs that are administered and funded by the Imperial County Transportation Commission (ICTC) include:
• IVT Ride: which provides curb-to-curb services for seniors (55+ years) and persons with disabilities upon phone reservation at (760) 337-1760. Reservations are encouraged to be made at least 2 days in advance, but can be made between one day to two weeks in advance of a rider’s planned tripped. Same day requests will only be fulfilled if seats and vehicles are available.24 • IVT MedTrans: which takes riders between Imperial Valley and San Diego County for non-emergency medical appointments. The schedule can be found at:
https://www.ivtmedtrans.com/rider-information/schedule/calendar o The pickup & return location in El Centro is located at:
139 S 7th St
El Centro, CA 92243
• IVT Access: a paratransit service created in response to the Americans with Disabilities Act (ADA), for persons with disabilities who cannot use the regular, fixed-route bus system. The service operates within a ¾ mile corridor and 30 minute window of regular IVT bus services.

The locations of publicly supported housing developments in the City of El Centro are mapped in , along with the Blue and Green Line routes. This visualization indicates that all publicly supported housing options in the city are located on or near existing bus routes.

23 Imperial Valley Transit Rider’s Guide, October 2022. https://www.ivtransit.com/assets/rider-guide/riderguide-20221001.pdf 24 IVT Ride Brochure. https://www.ivtride.com/pdf/IVT-NewRideBrochure_new.pdf

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FIGURE 32.

IVT BLUE LINE IN EL CENTRO
Source: IVT Rider’s Guide, October 2022. https://www.ivtransit.com/assets/rider-guide/rider-guide20221001.pdf

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FIGURE 33.

IVT GREEN LINE IN EL CENTRO
Source: IVT Rider’s Guide, October 2022. https://www.ivtransit.com/assets/rider-guide/rider-guide20221001.pdf

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FIGURE 34.

PUBLICLY SUPPORTED HOUSING AND TRANSIT ROUTES IN EL CENTRO Source: 2022 A Picture of Subsidized Housing (APSH); Imperial Valley Transit Rider’s Guide, October 2022. https://www.ivtransit.com/assets/rider-guide/rider-guide-20221001.pdf Based on data provided by the State of California’s Employment Development Department (EDD), the top 13 employment centers with the City of El Centro are listed in Table 11, along with their distance to the nearest bus stop. The location of these centers is mapped in Error! Reference source not found. along with IVT’s Blue and Green

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Lines. As demonstrated, all major employment centers, except for 8A Packing located on W Ross Ave and the El Centro Naval Air Facility, which is located outside the city limits, are serviced by the fixed bus routes.

TABLE 11. MAJOR EMPLOYERS IN THE CITY OF EL CENTRO
Employer Name Location # of Employees Distance to
Nearest Bus Stop
8A Packing LLC 696 E Ross Ave
El Centro, CA 92243 250-499 5.4 mi
Central Union High
School District
1001 W Brighton Ave
El Centro, CA 92243 250-499 0.3 mi
Costco Wholesale 2030 N Imperial Ave
El Centro, CA 92243 100-249 115 ft
El Centro Naval Air
Facility
2024 Bennett Rd
El Centro, CA 92243 500-999 2.2 mi
El Centro Regional
Medical Center
1415 Ross Ave
El Centro, CA 92243
500-999 0.1 mi
Imperial County
Behavioral
202 N 8th St
El Centro, CA 92243 250-499 0.2 mi
Imperial County
Coroner
328 Applestille Rd
El Centro, CA 92243 250-499 250 ft
Imperial County Office
of Education
1398 Sperber Rd
El Centro, CA 92243 500-999 0.5 mi
Imperial County Sheriff 328 Applestille Rd
El Centro, CA 92243 250-499 384 ft
Imperial Irrigation
District
2151 W Adams Ave
El Centro, CA 92243 1,000-4,999 0.2 mi
Target 2295 N Imperial Ave
El Centro, CA 92243 100-249 0.2 mi
US Border Patrol 1111 N Imperial Ave
El Centro, CA 92243 500-999 0.2 mi
Walmart 2150 N Waterman Ave
El Centro, CA 92243 250-499 390 ft
Source: California Employment Development Department from America’s Labor Market Information System (ALMIS) Employer Database, 2024 1st Edition, labormarketinfo.edd.ca.gov/majorer/MajorER.asp; distance to nearest bus stop calculated using Google Maps.

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FIGURE 35.

MAJOR EMPLOYERS IN THE CITY OF EL CENTRO AND TRANSIT ROUTES Source: California Employment Development Department; Imperial Valley Transit Rider’s Guide, October 2022. https://www.ivtransit.com/assets/rider-guide/rider-guide-20221001.pdf

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Policies and Procedures
IVT Transit and the other programs mentioned in this section are funded and administered by the Imperial County Transportation Commission (ICTC), which was established under Senate Bill 607 in 2009. According to the California Association of Councils of Governments (CALCOG) website, the responsibilities of the ICTC include:25 • The development of the Regional Transportation Plan for the Imperial region and its Regional, State and Federal transportation improvement programs and their updates
• The distribution of Local Transportation Fund monies
• The preparation and submittal of applications for transportation related funds • Allocation for Transportation Development Act funds
• The planning, programming, and administration of regional transit services • The encouragement of active citizen participation
The ICTC 2021 Coordinated Public Transit – Human Services Transportation Plan, which the Federal Transit Administration (FTA) defines as a “locally developed, coordinated transportation plan that identifies the transportation needs of individuals with disabilities, seniors and people with low incomes, provides strategies for meeting those needs, and prioritizes transportation services for funding and implementation.”26 The planning, financing, and administrative actions associated with this latest coordinated plan were reviewed to evaluate the relationship between public transportation and affordable housing opportunities.

As displayed in Figure 34 and Figure 35, IVT provides fixed route bus services to all publicly supported housing developments in the city and most major employers.

However, there are still challenges to accessing these services. The coordinated transportation plan identified several recommendations based on community and stakeholder feedback, which included (but are not limited to): expanding weekday evening service; expanding weekend service; increasing service frequency on weekdays; expanding fare purchase and payment options; and implementing realtime bus service information.

According to the same plan, the average IVT rider is employed and uses IVT services to travel to/from work. Among these riders, many work outside the traditional work hours of

25 CALCOG, “Member Profile: Imperial County Transportation Commission (ICTC).” last modified 04/07/2023, https://calcog.org/imperial-county-transportation-commission-ictc/ 26 Federal Transit Administration, “Coordinated Public Transit Human Services Transportation Plans.” Last modified 04/27/2022, https://www.transit.dot.gov/funding/grants/coordinated-public-transit-humanservices-transportation-plans

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Monday-Friday from 9:00am – 5:00pm. As such, there is a demand for IVT to expand its weekday evening services, increase its service frequency, and expand weekend services to better serve the needs of this transit-dependent population. Additionally, expanding fare purchase and payment options could encourage increased ridership.

Currently, riders must provide exact change when boarding the bus, or they may purchase a multi-ride pass at the transit office, City Hall, or at Imperial Valley College.

Allowing passes to be purchased online and/or at a greater number of physical locations would help alleviate this challenge to accessing IVT services.

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LENDING AND INSURANCE

PRACTICES
Homeownership and Lending
Homeownership is vital to a community’s economic well-being. It allows the opportunity to build wealth, is generally associated with higher levels of civic engagement,27 and is correlated with positive cognitive and behavioral outcomes among children.28 Federal housing policies and discriminatory mortgage lending practices prior to the Fair Housing Act of 1968, along with continuing impediments to access, have had significant impacts on the homeownership rates of racial and ethnic minorities, particularly Black and Hispanic populations. The gap between the White and Black homeownership rate is the largest among racial and ethnic groups. In 2017, the U.S.

Census Bureau reported a 21.6 percentage point gap in homeownership rate between White and Black households; just a 2.9 percentage point decrease since 1997.29 Homeownership trends have changed in recent years because of significant events in the housing market and labor force. The homeownership rate for Millennials (the generation born between 1981 and 1997) is 8 percentage points lower than the two previous generations, controlling for age. This discrepancy can be attributed to a multitude of factors ranging from preference to urban areas, cost of education and associated debt, changes in marriage and childbearing patterns, rising housing costs, and the current supply of affordable houses.30
The table that follows shows the number of owner and renter households, as well as the homeownership rate, by race and ethnicity for El Centro. Overall, tenure data indicates that El Centro is nearly evenly split between owners and renters, but that home ownership rates vary significantly by race and ethnicity. As shown in Table 12, white residents are significantly more likely to be homeowners than any other racial or ethnic

27 Manturuk K, Lindblad M, Quercia R. “Homeownership and civic engagement in low-income urban neighborhoods: a longitudinal analysis.” Urban Affairs Review. 2012;48(5):731–60. 28 Haurin, Donald R. et al. “The Impact of Homeownership on Child Outcomes.” Low-Income Homeownership Working Paper Series. Joint Center for Housing Studies of Harvard University. October 2001, http://www.jchs.harvard.edu/sites/default/files/liho01-14.pdf. 29 U.S. Census Bureau. Homeownership Rates by Race and Ethnicity of Householder: 1994 to 2017. 30 Choi, Jung et al. “Millennial Homeownership: Why Is It So Low, and How Can We Increase It?” The Urban Institute. February 2000.
https://www.urban.org/sites/default/files/publication/98729/millennial_homeownership_0.pdf

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group despite not being the predominant racial or ethnic group in the City, which is predominantly Hispanic. Just over three quarters of white residents own their homes, in comparison to just 46.2% of Hispanic residents and 36.4% of Black residents. The only other groups with home ownership rates exceeding 50% are Asian and Pacific Islander residents at 51.7% and residents who identify as some other unlisted race or ethnicity at

66.7%.

TABLE 12. HOME OWNERSHIP AND RENTAL RATES BY RACE AND ETHNICITY Householder Race / Ethnicity Owner
Households
Renter
Households
Home
Ownership Rate
White 1,110 365 75.3%
Black 160 280 36.4%
Hispanic 4,400 5,115 46.2%
Asian/Pacific Islander 150 140 51.7%
Native American 0 0 0.0%
Other/Multiple 20 10 66.7%
TOTAL 5,840 5,910 49.7%
Source: CHAS, Table 9
NOTE: Data presented are number of households, not individuals.

Spatial data, presented in Figure 36 and Figure 37, does not show significant geographic clustering in ownership by race or ethnicity; however, there is clustering of renters in general to the City center, including within the City’s only R/ECAP tract.

Clustering of renters also coincides with several factors which may limit access to opportunity.

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FIGURE 36.

HOMEOWNER HOUSEHOLDS BY RACE AND ETHNICITY IN EL CENTRO Source: 2016 to 2020 CHAS, Table 9

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FIGURE 37.

RENTER HOUSEHOLDS BY RACE AND ETHNICITY IN EL CENTRO
Source: 2016 to 2020 CHAS, Table 9

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Mortgage Lending
Prospective homebuyers need access to mortgage credit, and programs that offer homeownership should be available without discrimination. The proceeding data and analysis assesses the degree to which the housing needs of local residents are being met by home loan lenders.

The Home Mortgage Disclosure Act of 1975 (HMDA) requires most mortgage lending institutions to disclose detailed information about their home-lending activities annually.

The objectives of HMDA include ensuring that borrowers and loan applicants receive fair treatment in the home loan market.

The national 2017 HMDA data consists of information for 12.1 million home loan applications reported by 5,852 home lenders, including banks, savings associations, credit unions, and mortgage companies.31 HMDA data, which is provided by the Federal Financial Institutions Examination Council (FFIEC), includes the type, purpose, and characteristics of each home mortgage application that lenders receive during the calendar year. It also includes additional data related to those applications including loan pricing information, action taken, property location (by census tract), and information about loan applicants such as sex, race, ethnicity, and income.

The source for this analysis is tract-level HMDA data for census tracts in El Centro for the year 2022, which includes a total of 1,183 home purchase loan application records.

Within each record, some data variables are 100% reported, but other data fields are less complete. According to the HMDA data, these records represent applications taken entirely by mail, Internet, or phone in which the applicant declined to identify their sex, race and / or ethnicity. Missing race, ethnicity, and sex data are potentially problematic for an assessment of discrimination. If the missing data are non-random there may be adverse impacts on the accuracy of the analysis. Ideally, any missing data for a specific data variable would affect a small proportion of the total number of loan records and therefore would have only a minimal effect on the results.

Of these applications 10.82% were denied by the lending institution. There is no requirement for reporting reasons for a loan denial, but all denials within El Centro in the given year did have a reason provided. HMDA data also does not include a borrower’s total financial qualifications such as an actual credit score, property type and value, loan-to-value ratio, or loan product choices. Research has shown that differences in denial rates among racial or ethnic groups can arise from these credit-related factors

31 Consumer Financial Protection Bureau. “FFIEC Announces Availability of 2017 Data on Mortgage Lending.” May 7, 2018. https://www.consumerfinance.gov/about-us/newsroom/ffiec-announcesavailability-2017-data-mortgage-lending/

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The HMDA data presented in tables 15 and 16 indicates that within El Centro, Asian and Pacific Islander residents are most likely to be denied a home loan, while Black residents are least likely. However, it is important to note that these two groups had a significantly smaller overall number of completed applications in comparison to other racial or ethnic groups and therefore denial rates may be less accurate than for groups with larger sample sizes. In particular, only 5 Black households applied for home loans in 2022, and all were approved. Aside from these two groups, all other groups have very similar denial rates that are consistent with the overall denial rate.

When examining income brackets, denial rates vary significantly. Nearly one-quarter of applications submitted by low-income residents, defined as residents earning less than 80% of the area’s median household income, were denied for home loans. In comparison, only 11.7% of mid-income residents (earning 80-120% of area MHI) and

7.2% of high-income residents (earning more than 120% area MHI) were denied for loans.

The most common reason cited for loan denial among all applicants was an incomplete credit history, followed by debt-to-income ratio. These two reasons combined accounted for just over 35% of all denials. There were no denials due to inability to obtain mortgage insurance, and no denials were given without a reason provided.

32 R. B. Avery, Bhutta N., Brevoort K.P., and Canne, G.B. 2012. “The Mortgage Market in 2011: Highlights from the Data Reported Under the Home Mortgage Disclosure Act.” Board of Governors of the Federal Reserve System. Federal Reserve Bulletin, Vol. 98, No. 6.

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Packet Pg. 200 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 101 TABLE 13. LOAN APPROVAL RATES BY RACE, ETHNICITY, AND INCOME IN IMPERIAL COUNTY, 2022 Applicant Home

APPLICANT RACE AND ETHNICITY
Non-Latino
Latino All
White Applicants Black Asian / Pacific
Islander Other

LOW INCOME
Completed Applications 6 0 3 10 127 146
Denial Rate 16.67% 0.00% 33.33% 20.00% 25.20% 24.66%

MIDDLE INCOME
Completed Applications 21 0 4 20 340 385
Denial Rate 14.29% 0.00% 25.00% 10.00% 11.47% 11.69%

HIGH INCOME
Completed Applications 64 5 23 50 510 652
Denial Rate 9.38% 0.00% 8.70% 8.00% 6.86% 7.21%

ALL APPLICANTS
Completed Applications 91 5 30 80 977 1,183
Denial Rate 10.99% 0.00% 13.33% 10.00% 10.85% 10.82%
Data Source: 2022 Home Mortgage Disclosure Act Data, Accessed via https://ffiec.cfpb.gov/data-browser/data/2022 Note: applications with no income provided were excluded.

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Packet Pg. 201 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 102 TABLE 14. REASONS FOR LOAN DENIAL BY APPLICANT RACE AND ETHNICITY IN IMPERIAL COUNTY, 2022 Reason for Denial

APPLICANT RACE AND ETHNICITY
Non-Latino
Latino All
Applicants White Black Asian Other

DENIAL REASON PROVIDED HOME PURCHASE LOANS
Collateral 2 0 2 1 13 18
Credit Application Incomplete 4 0 0 3 28 35
Credit History 0 0 0 2 5 7
Debt to Income Ratio 2 0 0 2 23 27
Employment History 0 0 2 0 3 5
Insufficient Cash 1 0 0 0 15 16
Mortgage Insurance Denied 0 0 0 0 0 0
Other 1 0 0 0 10 11
Unverifiable Information 0 0 0 0 9 9
Reason not Provided 0 0 0 0 0 0
TOTAL DENIALS 10 0 4 8 106 128
Data Source: 2022 Home Mortgage Disclosure Act Data, Accessed via https://ffiec.cfpb.gov/data-browser/data/2022 NOTE: Some applications were denied for multiple reasons; thus, the total number of denial reasons reported are greater than the total number of loans denied.

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Packet Pg. 202 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 103

HOUSING FOR PEOPLE WITH

DISABILITIES
According to the U.S. Census Bureau, 19% of the population reported having a disability in 2010. Research has found an inadequate supply of housing that meets the needs of people with disabilities and allows for independent living. The U.S. Department of Housing and Urban Development identified that approximately one third of the nation’s housing stock can be modified to accommodate people with disabilities, but less than 1% is currently accessible by wheelchair users.33
Identifying and quantifying existing accessible housing for all disabilities is a difficult task because of varying needs associated with each disability type. People with hearing difficulty require modifications to auditory notifications like fire alarms and telecommunication systems while visually impaired individuals require tactile components in design and elimination of trip hazards. Housing for people that have difficulty with cognitive functions, self-care, and independent living often require assisted living facilities, services, and staff to be accessible.

Modifications and assisted living arrangements tend to pose significant costs for the disabled population, which already experiences higher poverty rates compared to populations with no disability. Studies have found that 55% of renter households that have a member with a disability have housing cost burdens, compared with 45% of those with no disabilities.34

33 Chan, S., Bosher, L., Ellen, I., Karfunkel , B., & Liao, H. . L. (2015). Accessibility of America’s Housing Stock:

Analysis of the 2011 American Housing Survey. U.S. Department of Housing and Urban Development: Office of Policy Development and Research.
34 America's Rental Housing 2017. (2017). Joint Center for Housing Studies of Harvard University.

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Packet Pg. 203 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 104 Residential Patterns
El Centro and Imperial County both have disability rates higher than the overall U.S. and state of California disability rates, which are 12.9% and 11.0%, respectively (see Table 19). This indicates that El Centro may have a greater need for disability accessible housing than the average U.S. city.

In El Centro approximately 7,159 people have at least one disability, representing 16.3% of the population. Seniors (aged 65 and over) have a significantly higher disability rate than the rest of the population, with nearly half of all seniors experiencing at least one disability. In contrast, children aged 5-17 have a disability rate of 7.8% and adults aged 18 to 64 have a rate of 13.5%.

The most common disability type is an ambulatory difficulty, which impacts 9% of the population, followed by a cognitive disability at 7.8%. The only other disability type impacting more than 5% of the population is an independent living difficulty at 5.4%.

Hearing, self-care, and vision difficulties impact between 3.2% and 4.2% of the population each.

TABLE 15. DISABILITY BY TYPE IN EL CENTRO AND IMPERIAL COUNTY Disability Type
El Centro Imperial County
# % # %
Hearing Difficulty 1,833 4.2% 5,635 3.3%
Vision Difficulty 1,409 3.2% 4,206 2.4%
Cognitive Difficulty 3,217 7.8% 9,929 6.3%
Ambulatory Difficulty 3,678 9.0% 13,744 8.7%
Self-Care Difficulty 1,557 3.8% 6,739 4.3%
Independent Living Difficulty 1,668 5.4% 9,198 7.6%
TOTAL 7,159 16.3% 24,352 14.2%
Source: 2018-2022 5-Year American Community Survey, Table S1810.

NOTE: All % represent a share of the total population within the jurisdiction or region. Total of numbers of each disability category may total to more than overall total, as some residents have mutliple disabilities.

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Packet Pg. 204 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 105 TABLE 16. DISABILITY BY AGE GROUP IN EL CENTRO AND IMPERIAL COUNTY Age of People with Disabilities
El Centro Imperial County
# % # %
Age 5 to 17 with Disabilities 807 7.8% 2713 7.2%
Age 18 to 64 with Disabilities 3,316 13.5% 10,462 10.8% Age 65+ with Disabilities 3,013 49.5% 10940 46.6%
TOTAL 7,159 16.3% 24,352 14.2%
Source: 2018-2022 5-Year American Community Survey, Table B18101.

NOTE: All % represent a share of the total population within the jurisdiction or region.

Accessible Housing Supply and Affordability
Any new multifamily housing with five or more units constructed after 1988 using federal subsidies must include a minimum of 5% of units accessible to persons with mobility impairments and an additional 2% of units accessible to persons with vision / hearing impairments (or one unit of each type, whichever is greater). Additionally, HUD provides support for accessible housing through its Section 202 Supportive Housing for the Elderly and Section 811 Supportive Housing for Persons with Disabilities programs.

A search for affordable elderly and special needs housing using HUD’s Resource Locator tool was conducted to identify affordable rental properties in El Centro designed to serve people with disabilities. The search returned six results; none of which have units specifically set aside for people with disabilities. Of the six, three had units specifically set aside for elderly residents. APSH data additionally reports that El Centro has one Section 202 unit available and no Section 811 units, and that Imperial County has a total of 38 Section 202 units available and no Section 811 units. Because there are fewer than 11 reported Section 202 households, APSH data suppresses demographic information to protect privacy and therefore no information is available about whether El Centro’s Section 202-unit household has a member with a disability.

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Packet Pg. 205 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 106 TABLE 17. DISABILITY BY HOUSING PROGRAM CATEGORY IN EL CENTRO AND

IMPERIAL COUNTY
Housing Type
El Centro Imperial county
% %
Public Housing 8.0% 10.0%
Project-Based Section 8* 13.0% 20.0%
Section 202 N/A 5.0%
Section 811 None None
HCV Program 22.0% 11.0%
Source: 2023 APSH.

Supportive housing, a typically subsidized long-term housing option combined with a program of wrap-around services designed to support the needs of people with disabilities, is another important source of housing for this population. Unique housing requirements for people with an ambulatory difficulty may include accessibility improvements such as ramps, widened hallways and doorways, and installation of grab bars, along with access to community services such as transit. For low- and moderateincome households, the costs of these types of home modifications can be prohibitive, and renters may face particular hardships as they could be required to pay the costs not just of the modifications, but also the costs of removing or reversing the modifications if they later choose to move.

Publicly supported housing is often a key source of accessible and affordable housing for people with disabilities. Based on a standard Supplemental Security Income (SSI) payment of $943 per month35 (equating to an affordable rent of $283 or less), it is highly likely that people with disabilities who are unable to work and rely on SSI as their sole source of income face substantial cost burdens and difficulty locating affordable housing, frequently relying on subsidized housing. However, despite having an unusually high disability rate, El Centro and the broader Imperial County both have no Section 811 units, or subsidized units designated for and accessible to disabled residents. This fact, coupled with El Centro’s average rent of over $1,200 per month for a one-bed unit, means that disabled residents may face extreme difficulty in finding affordable and accessible housing. This presents a barrier to fair housing choice for El Centro’s disabled population.

35 https://www.ssa.gov/oact/cola/SSI.html

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Packet Pg. 206 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 107 Zoning and Accessibility
From a regulatory standpoint, local government measures to control land use typically rely upon zoning codes, subdivision codes, and housing and building codes, in concurrence with comprehensive plans. Local zoning authority is directed by the state enabling laws as part of the local government’s police power but limited by superseding state laws related to specific land use, for example the regulation of public property, flood plains, utilities, natural resources, airports, housing regulated by a state licensing authority for persons with disabilities, higher education institutions, etc.

Fair housing laws do not preempt local zoning laws but do apply to municipalities and local government units and prohibit them from making zoning or land use decisions or implementing land use policies that exclude or otherwise discriminate against protected persons. This includes a local government’s affirmative obligation to provide reasonable accommodations to land use or zoning policies when such accommodations may be necessary to allow persons with disabilities to have an equal opportunity to use and enjoy housing. It also includes the affirmative obligation not to segregate housing for protected classes into lower-opportunity, less desirable areas of the jurisdiction. Even where a specific zoning decision does not violate a fair housing law, HUD entitlement communities accept an obligation to set and implement standards and policies that protect and advance fair housing choice for all. Conditions of El Centro’s zoning codes affecting accessibility are assessed in the following sections.

Several elements of the following analysis refer to the scored zoning code review in this report (Table 18 and Error! Reference source not found.).

Definition of “family” and group housing for persons with disabilities
One of the most often scrutinized provisions of a municipality’s zoning code is its definition of “family.” Local governments use this provision to limit the number of unrelated persons who may live together in a single dwelling. Unreasonably restrictive definitions may have the unintended or intended (depending on the motivations behind the drafting of the jurisdiction’s definition) consequence of limiting housing for nontraditional families and for persons with disabilities who reside together in congregate living situations.

El Centro’s zoning code defines “family” in the following way:

Two (2) or more individuals related by birth, marriage, adoption or convenience who occupy the same dwelling unit. A family also includes the residents of residential care facilities and group homes for people with disabilities. A family does not include larger institutional group living situations such as dormitories, fraternities, sororities, monasteries or nunneries, nor does it include such

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Packet Pg. 207 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 108 commercial group living arrangements as boardinghouses, lodging houses and farm labor camps.

Because of its explicit inclusion of disabled individuals living in residential care facilities or group homes, as well as its inclusion of families related by adoption or convenience, El Centro’s zoning code is more inclusive and supportive of disabled residents and of non-traditional family types than many similar zoning codes, particularly those for small towns. The code also contains the following definitions of residential care facilities, and further designates between small (6 or fewer residents) and large (7 or more residents) facilities:

Residential care facility: Various types of licensed and unlicensed facilities that provide twenty-four (24) hour non-medical supportive and custodial care for children, adults, and the elderly who need general assistance for everyday living. Residential care facilities may include: group homes, family care homes, foster family homes, small family homes, special needs housing, adult residential facilities, social rehabilitation facilities, residential board and care facilities, assisted living facilities, residential care facilities for the chronically ill, residential care facilities for the elderly.

Once again, the explicit inclusion of various types of care facilities under the definition of group home offers a certain level of support and protections to disabled residents that may not be available in other similar zoning codes. Small residential care facilities are permitted in all single-family zoned areas, and large residential care facilities are permitted in all residential zones except the Residential Airport Zone, or RAP zone.

Some restrictions exist on the development of large residential care facilities. These facilities must be located more than 300 feet from other such facilities, and developers must mail a notice of intent to construct the facility to all property owners located within 100 feet of the proposed site boundaries at least 10 days before any decision is finalized. The recipients of these notices may then request an administrative hearing to contest the construction within 15 days of receiving such a notice. If no affected party requests a hearing, construction may proceed without a hearing. Small residential care facilities have no such stipulations.

Reasonable accommodations
Adopting a reasonable accommodation ordinance is one specific way to address land use regulations’ impact on housing for persons with disabilities. Federal and state fair housing laws require that municipalities provide individuals with disabilities or developers of housing for people with disabilities flexibility in the application of land use and zoning and building regulations, practices, and procedures or even waive certain requirements, when it is reasonable and necessary to eliminate barriers to housing opportunities, or “to afford persons with a disability the equal opportunity to use and enjoy a dwelling.” (The requirements for reasonable accommodation under the

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Packet Pg. 208 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 109 Americans with Disabilities Act (ADA) are the same as those under the FHA. 42 U.S.C. 12131(2).) However, the FHA does not set forth a specific process that must be used to request, review, and decide a reasonable accommodation.

Because of El Centro’s generous definitions of “family” and “residential care facility”, and because such facilities may be developed in any residential zone other than an RAP zone without a hearing except in the case of an administrative hearing request by an impacted party, it is not typically necessary to seek a variance or special exception in order to construct such facilities. However, in the case that reasonable accommodation exceptions are required for construction or modification of existing facilities to accommodate disabled residents, the El Centro zoning code sets forth instructions specific to the reasonable accommodation process as follows:
• Any individual with a disability may submit a reasonable accommodation request in writing to the administrative committee. This request must include the name and address of the individual seeking accommodation, the name and address of the property and owner in question, a description of the requested accommodation, and a reason the accommodation is necessary. The administrative committee accepts reasonable accommodation requests at any time, and the City provides aid to any person needing assistance in submitting the request.
• The committee reviews and decides on applications within 30 days of receipt and must publish a written decision.
• An individual may appeal a decision on a reasonable accommodations request to the planning commission within 30 days of the decision.

Supportive housing for persons recovering from alcohol or substance addiction
Under federal law (e.g. FHA, ADA, Rehabilitation Act), it is discriminatory to deny an individual or entity the right to site a residential treatment program in a residential zone because it will serve individuals with alcohol or other drug problems or mental health disabilities. While housing for persons with disabilities may be subject to state and local regulations related to health and safety, they cannot be excluded from residential districts altogether, and such regulations must not be based on stereotypes or presumptions about specific types of disabilities.

In El Centro, supportive and transitional housing is explicitly permitted by right in all residential zones. The zoning code’s definition of “supportive housing” includes persons using such housing to “improve his or her health status”. In the absence of any

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Packet Pg. 209 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 110 provisions specifically naming drug or alcohol treatment facilities, it is reasonable to assume that this definition encompasses such facilities.

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PUBLIC SECTOR POLICIES
Zoning, Affordability, and Housing Choice
Comprehensive land use planning is a critical process by which communities address a myriad of public policy issues such as housing, transportation, health, recreation, environmental protection, commercial and retail services, and land values, and address how the interconnection and complexity of these issues can ultimately impact the entire municipality. “The land use decisions made by a community shape its very character – what it’s like to walk through, what it’s like to drive through, who lives in it, what kinds of jobs and businesses exist in it, how well the natural environment survives, and whether the community is an attractive one or an ugly one.”36 Likewise, decisions regarding land use and zoning have a direct and profound impact on affordable housing and fair housing choice, shaping a community or region’s potential diversity, growth, and opportunity for all. Zoning determines where housing can be built, the type of housing that is allowed, and the amount and density of housing that can be provided. Zoning also can directly or indirectly affect the cost of developing housing, making it harder or easier to accommodate affordable housing.

Intersection of Local Zoning with Federal and State Fair Housing Laws
One goal of zoning is to balance individual property rights with the power of government to promote and protect the health, safety, and general welfare of the overall community. Zoning codes regulate how a parcel of land in a community may be used and the density of development. Local governments may divide their jurisdiction into zoning districts by adopting a zoning map consistent with the comprehensive plan; define categories of permitted and special/conditional uses for those districts; and establish design or performance standards for those uses. Zoning may regulate the height, shape, and placement of structures and lot sizes or shapes.

Jurisdictions also can expressly prohibit certain types of uses within zoning districts.37 In this way, local ordinances may define the type and density of housing resources

36 John M. Levy. Contemporary Urban Planning, Eighth Edition. Upper Saddle River, NJ: Pearson Prentice Hall, 2009.
37 Local government power to regulate land use derives from the State's expressly delegated police power, first to municipal governments and then to counties, as found in the various enabling statues of the state constitution and Official Code of Georgia Annotated. See O.C.G.A. § 36-66-1 et seq. (zoning authority cities). State law grants local municipalities authority to adopt and enact local comprehensive plans, but such plans are not intended to limit or compromise the right of the governing body of any county or municipality to exercise the power of zoning. See O.C.G.A § 36-70-5.

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Packet Pg. 211 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 112 available to residents, developers, and other organizations within certain areas, and as a result influence the availability and affordability of housing.

While local governments have the power to enact zoning and land use regulations, that power is limited by state and federal fair housing laws (e.g., the California's Fair Employment and Housing Act (FEHA), the federal FHA, the Americans with Disabilities Act, constitutional due process and equal protection). The FHA prohibits both private individuals and government authorities from denying a member of a protected class equal access to housing, including through the enforcement of a local zoning ordinance that disproportionately limits housing choice for protected persons. In Texas Department of Community Affairs v. The Inclusive Communities Project, a 2015 landmark disparate impact case under the FHA, the Supreme Court affirmed that part of the FHA’s central purpose is to eradicate discriminatory housing practices, including specifically unlawful zoning laws and other housing restrictions.

Besides intentional discrimination and disparate impact, discrimination on the basis of disability also includes:
[A] refusal to make reasonable accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling. FHA § 804(f)(3)(b).

This provision has been held to apply to zoning and land use decisions by local governments.

California’s fair housing protections contained within the Fair Employment and Housing Act (“FEHA”) (Cal. Gov. Code § 12900 - 12996) meet or exceed federal standards under the FHA. Accordingly, HUD has certified the FEHA as “substantially equivalent” to the substantive rights, procedures, remedies, and judicial review processes of the FHA, making California eligible for annual funding through the Fair Housing Assistance Program (FHAP) for fair housing enforcement activities and programs. The California Civil Rights Department (renamed as of July 1, 2022, from the previously named Dept. of Fair Employment and Housing), created by the state legislature and certified by HUD as a participating FHAP agency, partners with HUD to enforce federal and state fair housing laws.

City of El Centro Zoning Ordinance Review
Although comprehensive plans and zoning and land use codes play an important role in regulating the health and safety of the structural environment, overly restrictive codes can negatively impact housing affordability and fair housing choice within a jurisdiction.

Examples of zoning provisions that most commonly result in barriers to fair housing choice include:
• Restrictive forms of land use that exclude any specific form of housing,

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Packet Pg. 212 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 113 particularly multi-family housing, or that require large lot sizes or low-density that deter affordable housing development by limiting its economic feasibility. • Restrictive definitions of family that impede unrelated individuals from sharing a dwelling unit.
• Placing administrative and siting constraints on group homes for persons with disabilities.
• Restrictions making it difficult for residents with disabilities to locate housing in certain neighborhoods or to modify their housing.
• Restrictions on occupancy of alternative sources of affordable housing such as accessory dwellings, mobile homes, and mixed-use structures.

The City of El Centro’s treatment of these types of issues are explored and evaluated in the tables and narrative below. The city’s latest available zoning ordinances were reviewed and evaluated against a list of ten common fair housing issues. Taken together, these issues give a picture of:
• The degree to which exclusionary zoning provisions may impact affordable housing opportunities within those jurisdictions.
• The degree to which the zoning code may impact housing opportunities for persons with disabilities.

The zoning ordinance was assigned a risk score of either 1, 2, or 3 for each of the ten issues and was then given an aggregate score calculated by averaging the individual scores, with the possible scores defined as follows:
1 = Low Risk:

The provision poses little risk for discrimination or limitation of fair housing choice, or is an affirmative action that intentionally promotes and / or protects affordable housing and fair housing choice.
2 = Medium Risk:

The provision is neither among the most permissive nor most restrictive; while it could complicate fair housing choice, its effect is not likely to be widespread.
3 – High Risk:

The provision causes or has potential to result in systematic and widespread housing discrimination or the limitation of fair housing choice, or is an issue where the jurisdiction could take affirmative action to further affordable housing or fair housing choice but has not.

The following table lists the ten issues reviewed and the city’s scores for each issue. A complete report for each jurisdiction, including citations to relevant statutes, code

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Packet Pg. 213 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 114 sections, and explanatory comments, is included as an appendix to this document.

TABLE 18. ZONING RISK SCORES
Issue Risk Score
1a. Does the jurisdiction’s definition of “family” have the effect of preventing unrelated individuals from sharing the same residence? Is the definition unreasonably restrictive?
1b. Does the definition of “family” discriminate against or treat differently unrelated individuals with disabilities (or members of any other protected class)?
1 2a. Does the zoning code treat housing for individuals with disabilities (e.g. group homes, congregate living homes, supportive services housing, personal care homes, etc.) differently from other single family residential and multifamily residential uses? For example, is such housing only allowed in certain residential districts, must a special or conditional use permit be granted before siting such housing in certain residential districts, etc.?
2b. Does the zoning ordinance unreasonably restrict housing opportunities for individuals with disabilities who require onsite supportive services? Or is housing for individuals with disabilities allowed in the same manner as other housing in residential districts?
1 3a. Do the jurisdiction’s policies, regulations, and/or zoning ordinances provide a process for persons with disabilities to seek reasonable modifications or reasonable accommodations to zoning, land use, or other regulatory requirements?
3b. Does the jurisdiction require a public hearing to obtain public input for specific exceptions to zoning and land-use rules for applicants with disabilities? If so, is the public hearing process only required for applicants seeking housing for persons with disabilities or required for all applicants?
1 4. Does the ordinance impose spacing or dispersion requirements on certain protected housing types? 1

5. Does the jurisdiction restrict any inherently residential uses protected by fair housing laws (such as residential substance abuse treatment facilities) only to non-residential zones?
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6. Does the jurisdiction’s zoning and land use rules constitute exclusionary zoning that precludes development of affordable or low-income housing by imposing unreasonable residential design regulations (such as high minimum lot sizes, wide street frontages, large setbacks, low FARs, large minimum building square footage or large livable floor areas, restrictions on number of bedrooms per unit, and/or low maximum building heights)?
1 7. Does the zoning ordinance fail to provide residential districts where multi-family housing is permitted as of right? Are multifamily dwellings excluded from all single-family dwelling districts?
7b. Do multi-family districts restrict development only to low-density housing types?
1 8. Are unreasonable restrictions placed on the construction, rental, or occupancy of alternative types of affordable or low-income housing (for example, accessory dwellings or mobile/manufactured homes)? 1 9a. Are the jurisdiction’s design and construction requirements (as contained in the zoning ordinance or building code) congruent with the Fair Housing Amendments Act’s accessibility standards for design and construction?
9b. Is there any provision for monitoring compliance?
1 10. Does the zoning ordinance include an inclusionary zoning provision or provide any incentives for the development of affordable housing or housing for protected classes?
1 Average Risk Score 1.0
Our research has shown that restricting housing choice for certain historically / socioeconomically disadvantaged groups and protected classes can happen in any number of ways and should be viewed on a continuum. The zoning analysis matrix developed for this report and the narrative below are not designed to assert whether the cities’ codes create a per se violation of the FHA or HUD regulations, but are meant as a tool to highlight significant areas where zoning and land use ordinances may otherwise jeopardize the spirit and intent of fair housing protections and HUD’s AFFH standards for its entitlement communities.

The issues chosen for discussion show where zoning ordinances and policies could go further to protect fair housing choice for protected and disadvantaged classes, and yet

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Packet Pg. 215 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 116 still fulfill the zoning objective of protecting the public’s health, safety, and general welfare. Specifically, the issues highlighted by the matrix inform, first, the degree to which the zoning ordinance may be overly restrictive and exclusionary to the point of artificially limiting the affordable housing inventory and directly contributing to higher housing and rental costs. And secondly, the matrix helps inform the impact the local regulations may have on housing opportunities for persons with disabilities, a protected class under state and federal fair housing law.

Impact of Zoning Provisions on Affordable Housing
Academic and market research have proven what also is intuitive: land use regulations can directly limit the supply of housing units within a given jurisdiction, and thus contribute to making housing more expensive, i.e. less affordable.38 Zoning policies that impose barriers to housing development and artificially limit the supply of housing units in a given area by making developable land and construction costlier than they are inherently can take different forms and may include: high minimum lot sizes, low density allowances, wide street frontages, large setbacks, low floor area ratios, large minimum building square footage or large livable floor areas, restrictions on number of bedrooms per unit, low maximum building heights, restrictions against infill development, restrictions on the types of housing that may be constructed in certain residential zones, arbitrary or antiquated historic preservation standards, minimum off-street parking requirements, restrictions against residential conversions to multi-unit buildings, lengthy permitting processes, development impact fees, and / or restrictions on accessory dwelling units.

Where these zoning regulations are not congruent with the actual standards necessary to protect the health and safety of residents and prevent overcrowding, they may not be in express violation of fair housing laws but may nonetheless contribute to exclusionary zoning and have the effect of disproportionately reducing housing choice for moderate to low-income families, minorities, persons with disabilities on fixed incomes, families with children, and other protected classes by making the development of affordable housing cost prohibitive.

El Centro’s design standards, density allowances, and housing-type diversity, do not

38 See Gyourko, Joseph, Albert Saiz, and Anita A. Summers, A New Measure of the Local Regulatory Environment for Housing Markets: The Wharton Residential Land Use Regulatory Index (2007), available at real.wharton.upenn.edu; Randal O’Toole, The Planning Penalty: How Smart Growth Makes Housing Unaffordable (2006), available at independent.org/pdf/policy_reports/2006-04-03-housing.pdf; Edward L.

Glaeser and Joseph Gyourko, The Impact of Zoning on Housing Affordability (2002), available at law.yale.edu/system/files/documents/pdf/hier1948.pdf; The White House’s Housing Development Toolkit, 2016, available at
whitehouse.gov/sites/whitehouse.gov/files/images/Housing_Development_Toolkit%20f.2.pdf.

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Packet Pg. 216 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 117 appear facially exclusionary, and the City received “1 / low risk” scores for Issues 6 and 7 regarding exclusionary zoning regulations for single and multifamily housing types.

While the zoning ordinance may impact the feasibility of developing affordable housing within some lower-density districts, thus creating a barrier to fair housing choice for some protected groups in some neighborhoods, the code provides for lot sizes and densities that could accommodate affordable housing somewhere within the residential districts.

The zoning code and map divide El Centro’s residential zones into: residential airport (RAP) rural residential (RR), single-family residential (R1), variable residential (R2), and multiple family residential (R3). The minimum lot size for single-family dwellings in R1 is 6,000 sq. ft., while the minimum lot size for single-family dwellings in R2 and R3 is 3,600 sq. ft. Attached or multi-family dwellings are subject to minimum lot sizes of 7,200 sq. ft. in R2 and R3 zones. Single-family dwellings in RR have much larger minimum lot areas at 21,780 sq. ft, and those in RAP have the largest at 43,560 sq. ft.

A review of the City of El Centro’s most current zoning map (see Figure 38) shows that large portions of the city are designated as R1 single-family residential, with most residential areas outside of the central city carrying this designation. R2 variable residential and R3 multiple family residential parcels are concentrated in the central and northern parts of the city, with only a handful of these parcels existing below Interstate 8. Given the increased density allowed in R2 and R3 zones, it seems as if there is a balance of housing types within the city.

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Packet Pg. 217 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 118 FIGURE 38.

ZONING MAP OF EL CENTRO
Source: https://cityofelcentro.org/communitydevelopment/maps/

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Packet Pg. 218 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 119

PUBLICLY SUPPORTED

HOUSING
Publicly supported housing encompasses several strategies and programs developed since the 1930s by the federal government to ameliorate housing hardships that exist in neighborhoods throughout the country. The introduction and mass implementation of slum clearance to construct public housing projects during the mid-1900s signified the beginning of publicly supported housing programs. Government-owned and managed public housing was an attempt to alleviate problems found in low-income neighborhoods such as overcrowding, substandard housing, and unsanitary conditions.

Once thought of as a solution, the intense concentration of poverty in public housing projects often exacerbated negative conditions that would have lasting and profound impact on their communities.

Improving on public housing’s model of high-density, fixed-site dwellings for very lowincome households, publicly supported housing programs have since evolved into a more multi-faceted approach overseen by local housing agencies. The Housing and Community Development Act of 1974 created Section 8 rental assistance programs.

Section 8, also referred to as the Housing Choice Voucher (HCV) program, provides two types of housing vouchers to subsidize rent for low-income households: project-based and tenant-based. Project-based vouchers can be applied to fixed housing units in scattered site locations while tenant-based vouchers allow recipients the opportunity to find and help pay for available rental housing on the private market.

The Tax Reform Act of 1986 created the Low-Income Housing Tax Credit (LIHTC) program to incentivize development of affordable, rental-housing development. Funds are distributed to state housing finance agencies that award tax credits to qualified projects to subsidize development costs. Other HUD Programs including Section 811 and Section 202 also provide funding to develop multifamily rental housing specifically for disabled and elderly populations.

The now-defunct HOPE VI program was introduced in the early 1990s to revitalize and rebuild dilapidated public housing projects and create mixed-income communities.

Although HOPE VI achieved some important successes, the Choice Neighborhoods Initiative program was developed to improve on the lessons learned from HOPE VI. The

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Packet Pg. 219 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 120 scope of Choice Neighborhoods spans beyond housing and addresses employment access, education quality, public safety, health, and recreation.39 Current publicly supported housing programs signify a general shift in ideology toward more comprehensive community investment and de-concentration of poverty.

However, studies have shown a tendency for subsidized low-income housing developments and residents utilizing housing vouchers to continue to cluster in disadvantaged, low-income neighborhoods. Programmatic rules and the point allocation systems for LIHTC are thought to play a role in this clustering and recent years have seen many states revising their allocation formulas to discourage this pattern in new developments.40 The reasons for clustering of HCVs is more complicated since factors in decision-making vary greatly by individual household. However, there are indications that proximity to social networks, difficulties searching for housing, and perceived or actual discrimination contribute to clustering.41 This section will review the current supply and occupancy characteristics of publicly supported housing types and its geographic distribution within the study area.

Supply and Occupancy
Residents of the City of El Centro receive publicly supported housing through the Imperial Valley Housing Authority (IVHA). The IVHA offers public housing units as well as project-based and tenant-based housing choice vouchers (HCVs) to local residents.

According to A Picture of Subsidized Housing, a HUD database on the supply of publicly supported housing, the IVHA manages 159 public housing units, 1,642 housing choice vouchers, and 145 project-based section 8 units in El Centro. On a broader scale, the IVHA manages 767 public housing units, 2,059 housing choice vouchers, 377 projectbased Section 8 units, and 38 “Other Multifamily” units, which include elderly (Section 202) and disabled (Section 811) units throughout Imperial County.

Subsidized housing units are also available through the state’s Low Income Housing Tax Credit (LIHTC) program. The LIHTC program provides housing units to renters earning no

39 Department of Housing and Urban Development. Evidence Matters: Transforming Knowledge into Housing and Community Development Policy. 2011. www.huduser.gov/portal/periodicals/em/EMnewsletter_FNL_web.pdf. 40 Dawkins, Casey J. Exploring the Spatial Distribution of Low-Income Housing Tax Credit Properties. US Department of Housing and Urban Development,
www.huduser.gov/publications/pdf/dawkins_exploringliht_assistedhousingrcr04.pdf. 41 Galvez, Martha M. What Do We Know About Housing Choice Voucher Program Location Outcomes? A Review of Recent Literature. What Works Collaborative, 2010. www.urban.org/sites/default/files/publication/29176/412218-What-Do-We-Know-About-Housing-ChoiceVoucher-Program-Location-Outcomes-.PDF.

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Packet Pg. 220 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 121 more than 60% AMI. The City of El Centro has approximately 503 LIHTC units, 494 of which are identified as low-income units and may include the city’s project-based Section 8 units. Bedroom size is listed for 494 of these units, indicating that the majority of LIHTC units in the city are 1-bedroom units (58%). 2-bedroom units make up 24% of LIHTC units in the city, while 3-bedroom units make up 15%. Only 3% of LIHTC units are 4- bedroom units, and no efficiency/studio units are listed in the city.

The LIHTC database identifies 3,467 LIHTC units in the county, of which 3,423 are currently low-income units. Bedroom size is listed for 3,042 of these units, of which 44% (11,210) are two-bedroom units, 35% (8,797) are one-bedroom units, 16% (4,045) are three-bedroom units, 3% (660) are efficiency units and 1% (258) are four-bedroom units.

TABLE 19. HOUSING UNITS BY PROGRAM CATEGORY FOR EL CENTRO Housing Units
El Centro City Imperial County
# % # %
TOTAL HOUSING UNITS 13,958 56,907
Public Housing 159 1.1% 767 1.3%
HCV Program 795 5.7% 2,059 3.6%
Project-Based Section 8 145 1.0% 377 0.7%
Other Multifamily 0 0.0% 38 0.1%
LIHTC Program 503 3.6% 3,467 6.1%
Source: 2018-2022 ACS 5-Year Estimates; 2022 A Picture of Subsidized Housing; HUD User LIHTC Database.

Table 20 below shows the racial/ethnic composition of publicly supported housing residents, as well as estimates for the numbers of low-to-moderate income households in the city. Very low-income households (households earning less than 30% AMI) are often the primary recipients of publicly supported housing types.

Looking at El Centro’s very low-income households, nearly 90% of these households are Hispanic. However, this is similar to their share of the city’s general population (88%).

White households, on the other hand, make up 42% of the city’s low-income population but only 7% of the general population, suggesting that this group has disproportionately high rates of low-incomes in El Centro. The makeup of Black and Asian/Pacific Islander low-income households is similar, if not slightly less than, their share of the overall population.

Hispanic households comprise the greatest shares of households living in the city’s publicly supported housing units by large margins. According to APSH data, approximately 94% of HCV holders, 99% of Project-Based Section 8 residents, and 97% of public housing residents are Hispanic. As such, Hispanic households are considered

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Packet Pg. 221 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 122 overrepresented in El Centro’s publicly supported housing, while other races and ethnicities are underrepresented.

White households make up 1% of public housing residents and 3% of HCV holders. Black households make up 2% of public housing residents and 2% of HCV holders. Asian or Pacific Islander households comprise the smallest shares of subsidized housing, comprising only 1% of public housing residents and 1% of HCV holders.

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Packet Pg. 222 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 123 TABLE 20. PUBLICLY SUPPORTED HOUSING RESIDENTS BY RACE / ETHNICITY Housing Type

RACE / ETHNICITY
White Black Hispanic Asian / Pacific
Islander
# % # % # % # %

EL CENTRO CITY
Public Housing 2 1.2% 3 2.0% 163 97.0% 2 1.2%
Project-Based Section 8 0 0.0% 1 0.7% 144 99.3% 0 0.0%
Other Multifamily 0 0.0% 0 0.0% 0 0.0% 0 0.0%
HCV Program 29 3.0% 19 2.0% 899 94.0% 10 1.0%
0 to 30% AMI 1,000 42.0% 55 2.3% 2,130 89.5% 10 0.4%
0 to 50% AMI 1,069 25.3% 274 6.5% 3,645 86.3% 49 1.2%
0 to 80% AMI 1,229 15.9% 403 5.2% 5,450 70.6% 68 0.9%
TOTAL HOUSEHOLDS 1,475 12.6% 440 3.7% 9,515 81.0% 290 2.5%

IMPERIAL COUNTY
Public Housing 15 2.0% 8 1.0% 744 97.0% 0 0.0%
Project-Based Section 8 15 4.0% 8 2.1% 362 97.1% 0 0.0% Other Multifamily 0 0.0% 0 0.0% 38 100.0% 0 0.0%
HCV Program 31 1.6% 15 0.8% 1,832 93.0% 8 0.4%
0 to 30% AMI 3,535 36.8% 345 3.6% 8,385 87.3% 85 0.9%
0 to 50% AMI 4,590 27.0% 654 3.9% 14,250 83.9% 135 0.8% 0 to 80% AMI 5,640 18.4% 869 2.8% 20,715 67.6% 220 0.7% TOTAL HOUSEHOLDS 7,315 16.0% 1,195 2.6% 35,885 78.4% 790 1.7% Source: 2016-2020 CHAS, Tables 1 and 9; 2022 APSH.

NOTE: Data presented are number of households, not individuals. Percentages may not add up to 100% due to the suppression of the “Other (including multiple races, non-Hispanic) race/ethnicity category, which is included in the total household count.

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Packet Pg. 223 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 124 Geography of Supported Housing
The map that follows shows the locations of publicly supported housing developments and voucher use within the City of El Centro. Conventional public housing developments in the city are highly clustered within the R/ECAP, located in Downtown El Centro, north of W Main St and east of the Southern Pacific Railroad.

The two public housing developments here include Fairfield Homes (117 total units) and Orangewood Homes (117 total units). Other publicly supported housing developments located within the R/ECAP tract include a Section 202 Supportive Housing for the Elderly Program development, Cedar Homes (19 total units) and several LIHTC developments.

The city’s Project-Based Section 8 developments are located to the west of the R/ECAP, with three (3) located on N Waterman Ct. Valley Apartments #1, #2, and #3, providing a total of 86 units combined. Another Project-Based Section 8 development, Euclid Villas (42 total units), is located on W Euclid Ave. There is also a LIHTC development, Imperial Gardens Family Apartments (77 total units), on the opposite side of this street.

The map also provides information on the number of Housing Choice Vouchers within each census tract in the city. HCV usage is highest within the city’s R/ECAP, with a total of 274 vouchers used in this tract. Voucher usage is second highest in the tract immediately west of the R/ECAP, tract 112.02, with a total of 215 vouchers. As shown, voucher use is concentrated in the central and northern areas of the city, while tracts on the southern edges of the city limits contain only 1-3 vouchers.

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Packet Pg. 224 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 125 FIGURE 39.

PUBLICLY SUPPORTED HOUSING IN EL CENTRO
Source: 2022 A Picture of Subsidized Households (APSH), https://www.huduser.gov/portal/datasets/assthsg.html#2009-2021_data

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Packet Pg. 225 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 126 Policies and Procedures
The Imperial Valley Housing Authority (IVHA) Administrative Plan sets policy for who may be housed through project-based or tenant-based vouchers, serving the jurisdictions of the City of Brawley, City of Calipatria, City of El Centro, City of Holtville, City of Imperial, City of Westmorland and the County of Imperial. Four aspects of the administrative plan are examined here: tenant selection, local preference, tenant screening, and subsidy standards. The application of these policies is central to matters of fair housing choice.

Tenant Selection
To be eligible for admission in the IVHA’s public housing units and housing choice voucher program, an applicant household must meet several criteria: (1) income at or below HUD income limits, (2) fall under the HUD and PHA definition of “family,” (3) provide accurate social security numbers for all household members, (4) qualify on the basis of citizenship or eligible immigrant status, (5) provide social security number information for household members as required; and (6) consent to the PHA collecting certain data for tenant screening.

In its Admin Plan, the IVHA defines “family” using HUD’s definition of Family, which includes “a single person, who may be an elderly person, disabled person, near-elderly person, or any other single person; or a group of persons residing together.” This broad definition is extended to include “a family with or without children (a child who is temporarily away from the home because of placement in foster care is considered a member of the family), an elderly family, a near-elderly family, a disabled family, a displaced family, or the remaining member of a tenant family.” The IVHA maintains one waiting list for HCV assistance. Depending upon the length of time that applicants are expected to wait to receive assistance, the PHA may use a one- or two-step application process. The entire application process complies with HUD’s accessibility standards, which stipulates that the application must be accessible to persons with disabilities, certain elderly individuals, and persons with limited English proficiency (LEP).
• A one-step process is used when it is expected that a family will be selected from the waiting list within 60 days of the date of application. At application, the family must provide all of the information necessary to establish family eligibility and level of assistance.
• A two-step process is used when it is expected that a family will not be selected from the waiting list for at least 60 days from the date of application. The PHA initially will require families to provide only the information needed to make an

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Packet Pg. 226 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 127 initial assessment of the family’s eligibility, and to determine the family’s placement on the waiting list. The family will be required to provide all of the information necessary to establish family eligibility and level of assistance when the family is selected from the waiting list.

Tenant Screening
To screen all applicants, the IVHA performs criminal background checks and checks the National Sex Offender database to screen applicants for admission. The IVHA does not conduct additional screening to determine an applicant’s suitability as a tenant— this is the responsibility of the unit’s owner.

Local Preferences
In selecting applicants from the waiting list, PHAs are permitted to establish local preferences. The IVHA maintains the following local preference policies, where each preference receives an allocation of points. The more preference points an applicant has, the higher the applicant’s place on the waiting list. • Residency preference for families who live, work, or have been hired to work in the jurisdiction (1 point)
• Veteran’s preference is available to a person who served in the active military, naval, or air service and who was discharged or released from such service under conditions other that dishonorable or surviving spouses of veterans (1 point)
• Graduates of Transitional Housing Program preference for families who have graduated from transitional housing programs for homeless and victims of domestic violence funded by the government (3 points)
• Involuntary Displacement for families who claim they are being displaced due to either a Federally declared disaster such as fire (not caused by the applicant or applicant’s family or guest), earthquake or flood or government action within IVHA’s jurisdiction (3 points)
• Foster youth preference for emancipated foster youth 18 years of age being displaced as identified by the Imperial County Department of Social Services (3 points)
Subsidy Standards
The PHA must establish subsidy standards that determine the appropriate number bedroom unit size for a variety of family sizes and compositions. IVHA’s policy is as

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Packet Pg. 227 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 128 follows:
• One bedroom will be assigned for every two persons within the household. • An additional bedroom for a live-in-aide will not be authorized unless there is an approved reasonable accommodation request for a separate bedroom for the resident.

The following table is referenced in determining the appropriate unit size for a family.

TABLE 21. VOUCHER HOUSING UNIT SIZES AND HOUSEHOLD SIZES Voucher Size Persons in Household
(Minimum – Maximum)
1 bedroom 1-2
2 bedrooms 2-4
3 bedrooms 3-6
4 bedrooms 4-8
5 bedrooms 6-10
Source: Imperial Valley Housing Authority Administrative Plan 2022.

Exceptions to these subsidy standards may be granted to persons with disabilities who require exceptions as a reasonable accommodation.

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Packet Pg. 228 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 129

FAIR HOUSING ACTIVITIES
Fair Housing Resources
California’s fair housing protections contained within the Fair Employment and Housing Act (“FEHA”) meet or exceed federal standards contained within Title VIII of the Civil Rights Act of 1968, as amended by the Fair Housing Amendments Act of 1988, (the “Fair Housing Act” or “FHA”). Accordingly, HUD has certified the FEHA as “substantially equivalent” to the substantive rights, procedures, remedies, and judicial review processes of the FHA, which makes California eligible for annual funding through the Fair Housing Assistance Program (FHAP) for fair housing enforcement activities and programs. The California Department of Fair Employment and Housing, created by the state legislature and certified by HUD as a participating agency, partners with HUD to enforce federal and state fair housing laws.

Fair Housing Education and Enforcement Resources
Under its Fair Housing Initiatives Program (FHIP), HUD awards grant money to local fair housing advocacy organizations who assist persons believed to have been harmed by discriminatory housing practices; to help people identify government agencies that handle complaints of housing discrimination; to conduct preliminary investigation of claims; to carry out testing and enforcement activities to prevent or eliminate discriminatory housing practices; and to educate the public and housing providers about equal opportunity in housing and compliance with the fair housing laws.

The Inland Fair Housing Mediation Board (IFHMB) is a private, nonprofit agency that offers fair housing services, landlord/tenant mediation, housing counseling, alternative dispute resolution, and senior services to residents of San Bernardino County and parts of Riverside and Imperial Counties. It is located in the City of Ontario, CA, with satellite offices in Victorville and El Centro.

Fair Housing Complaints
Complaints Filed with HUD
Region IX of the Office of Fair Housing and Equal Opportunity (FHEO) receives complaints by households regarding alleged violations of the Fair Housing Act for cities and counties throughout California (as well as Arizona, American Samoa, Guam, Hawaii, and Nevada). The mission of the FHEO is to eliminate housing discrimination, promote economic opportunity, and achieve diverse, inclusive communities. To achieve this mission, the FHEO receives and investigates complaints of housing

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Packet Pg. 229 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 130 discrimination, and leads in the administration, development, and public education of federal fair housing laws and policies.

The San Francisco Regional Office of the FHEO maintains data reflecting the number of complaints of housing discrimination received by HUD, the status of all such complaints, and the basis/bases of all such complaints. The office responded to a request for data regarding complaints received affecting housing units in El Centro for the period January 1, 2019 through December 31, 2023. For the requested time period, HUD received 0 alleged housing discrimination affecting aggrieved persons or subject properties in El Centro. HUD received 1 complaint located in Imperial County but outside of the City of El Centro in August 2022 on the basis of national origin.

Complaints Filed with the California Civil Rights Department The California Civil Rights Department (CRD) is the State of California’s Fair Housing Assistance Program (FHAP) agency for fair housing enforcement actions. For the requested time period, the CRD received a total of 4 fair housing complaints within El Centro.

TABLE 22. CA CRD COMPLAINTS IN EL CENTRO, 2019-2023
Filing Year Bases Alleged Issues Disposition
2020
Disability,
retaliation
Failure to make reasonable
accommodation
Conciliation/settlement
successful
2021 Race, disability
Discriminatory terms, conditions,
privileges, or services and
facilities; Discrimination in
terms/conditions/privileges
relating to rental; Failure to
make reasonable
accommodation
No cause determination
2022 Familial status
Discriminatory terms, conditions,
privileges, or services and
facilities
No cause determination
2022 Disability
Discriminatory refusal to rent;
Discriminatory terms, conditions,
privileges, or services and
facilities; Failure to make
reasonable accommodation
Conciliation/settlement
successful
Local Complaints
El Centro residents may also file fair housing complaints with the Inland Fair Housing & Mediation Board (IFHMB). Conversations with IFHMB staff revealed that disability remains

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Packet Pg. 230 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 131 the most common basis for fair housing complaints. [Will insert table of local complaint data here when received]
Past Fair Housing Goals and Related Activities
The City of El Centro completed its last Analysis of Impediments to Fair Housing Choice in 2019, which identified several goals to focus on over the course of 2019 to 2024. TABLE 23 below is a reproduction of the goals presented in the 2019-2024 AI, along with an updated column detailing what progress has been made on each goal since the implementation of the previous AI.

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Packet Pg. 231 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 132 TABLE 23. ASSESSMENT OF PAST FAIR HOUSING GOALS AND ACTIONS 2019-2024 Impediment(s)
Identified Proposed Actions Progress Made
Section 8 Householders
Disproportionately Reside in
Neighborhood with a High
Poverty Rate
Continue to actively encourage families to
seek housing in neighborhoods with low
concentrations of low-income families
The City partnered with a developer for the
construction of the El Dorado Family
Apartments, an affordable housing
development completed in 2021. Although this
development is located adjacent to an
apartment complex with affordable housing
units, it is also located across the street from a
new, larger apartment development that is
considered to be “luxury” apartments with no
affordability restrictions.

On-Site Property Managers are
Not Fully Aware of Fair Housing
Laws
The IVHA will prepare a guide for landlords
and owners and upload it to its website
The guide is available on the Housing
Authority’s website. However, it has not been
supplemented with information on property
management practices that affirmatively
further fair housing as recommended in the AI.

The City will continue encourage the IVHA to
supplement the information in their program
guide.

Senior Housing Standards are
not Consistent with Federal Law
on Housing for Older Persons
The Zoning Ordinance should be updated to
mirror the senior age thresholds provided by
Section 51.3.

Lack of Special Provisions for
Making Housing Accessible to
Persons with Disabilities
The Community Development Department will
explore the potential adoption of a Universal
Design Ordinance
In order to increase an understanding of
accessibility requirements, the Economic
Development Division will continue to post the

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Packet Pg. 232 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 133 following link on their respective web pages:
www.ada.gov/doj_hud_statement.pdf
Housing Discrimination The City will continue to offer to its residents fair housing services which will include the
processing of housing discrimination
complaints and landlord/tenant counseling
services. Sometimes a landlord/tenant issue
has as its basis a housing discrimination
concern.

Efforts will be made to increase community
awareness of the IFHMB services through
postings on the City’s web pages, publication
of newspaper display ads, and Community
Newsletter articles. A greater community
awareness of Inland may result in a higher
number of families expressing their right to file
a housing discrimination complaint.

The City of El Centro continues to provide
information on
IFHMB’s services on City web pages.

IFHMB conducted six fair housing workshops in
English and Spanish to the community, three (3)
in Spanish and three (3) in English]. A total of
eighty (80) attendees received fair housing and
landlord/tenant education. The webinars
provided information on the Federal and State
fair housing laws with an emphasis on fair
housing rights including information regarding
race discrimination, national origin
discrimination, identifying possible steering
regarding rental or home purchases, disability
discrimination, the reasonable accommodation
and modification process, how to recognize
and report discrimination, fair housing rights
and responsibilities, sex discrimination, and the
fair housing services provided by IFHMB.

Mortgage Lending Practices Continue to offer first-time home buyer seminars to explain to borrowers the need to
lower debt-to-income ratios to a level
acceptable to lenders. Implementation of this
recommended action should result in better
prepared borrowers and cause an increase in
loan approval rates of all loan applicants,
regardless of race or ethnicity.

The City of El Centro is working with IFHMB to
ensure that these services are covered by their
current service contract. If not included, the
contract will be amended to incorporate the
services.

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Packet Pg. 233 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 134 Work with the lenders to determine why a few
census tracts have high loan denial rates in
order to gather information that could assist
would be homebuyers to increase the
probability of garnering loan approval for
homes in neighborhoods of their choice.

This Analysis of Impediments includes an
assessment of lending approval/denial rates in
the “Lending and Insurance Practices” chapter
of this report.

Ill-Informed Property
Management Practices
Invite the apartment managers to one or more
workshops; the topics could include:
• Fair housing laws in general
• Fair housing laws regarding occupancy
limits
• Fair housing laws regarding reasonable
accommodations and modifications
• Sample written policies regarding
service and companion animals
Distribute information on the above and other
topics and distribute it to the apartment
managers of all small, medium and large
apartment complexes.

The City of El Centro is working with IFHMB to
ensure that this service is incorporated into their
Professional Services Agreement.

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Packet Pg. 234 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 135

IDENTIFICATION OF

IMPEDIMENTS
Described below are the fair housing impediments identified in this Analysis of Impediments to Fair Housing Choice, along with associated contributing factors.

Contributing factors are issues leading to an impediment that are likely to limit or deny fair housing choice or access to opportunity. Recommended activities to address priority contributing factors are provided in the table that follows, along with associated activities, goals, timelines, and responsible parties.

Impediment #1: Low Wages Impede Access to
Opportunities, Resources, and Restrict Housing Choice for Low/Mod Income Households and Protected Classes
Disparities in labor market engagement exist by geography, race, and ethnicity in El Centro. Unemployment is highest among Native American residents (over 50% as of the 2018-2022 ACS estimates), and the share of residents aged 25 and over with a bachelor’s degree or higher is lowest among Black residents (less than 1.1%).

Educational attainment is lowest in the RECAPs tract in the city as well as the northern portion of the city, where unemployment is also the highest. Median household incomes in El Centro are lowest in the central portion of the city within and around the RECAPs tract, where they fall below $40,000 in two census tracts. Residents and stakeholders noted that in addition to income, residents’ housing choices are shaped by a variety of factors, including access to grocery stores, healthcare, and other needed resources; access to public transportation; and availability of public infrastructure such as sidewalks.

Place-based strategies allow for the targeting of resources and outreach efforts to areas with high proportions of residents whose housing choices may be limited by low earnings or unemployment. These strategies can be combined with other approaches focused on closing skills gaps and developing career pathways, increasing job creation and quality standards, and raising the wage floor. Examples of place-based strategies to increase labor market engagement include increasing awareness of high-growth jobs that pay family-sustaining wages and connections to the training necessary to obtain them, and targeting neighborhoods with high proportions of low-earning workers as priorities for interventions that increase awareness of available subsidies and

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Packet Pg. 235 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 136 resources.

In addition to investing in workforce development, the City can continue to use CDBG, bond referendum, or other funding to collaborate on projects that develop, expand, or improve community spaces and programming, increase access to fresh food retailers, provide access to health and wellness resources and services, improve housing condition, and support development of needed retail and services in low- and moderate-income census tracts.

Impediment #2: Limited Supply of Affordable Housing for Low/Mod Income Households
A general lack of affordable housing options available to low- and moderate-income households was one of the most frequently cited issues identified in our conversations with El Centro community stakeholders. This shortage has become increasingly dire over the past few years as housing costs in the area have drastically increased and wages have remained comparatively stagnant. Additionally, there is limited public housing assistance, and existing resources are often coupled with waitlist periods of 1 year or more, source of income discrimination by area landlords, and housing quality issues.

There is a great need for increased numbers of affordable multifamily units and assistance for low-income homebuyers.

According to 2022 ACS data, housing in El Centro and Imperial County is predominantly comprised of single-family detached structures (around 55.4% and 63.2%, respectively, See Table 8: Housing Units by Structure Type). The lack of structures with multiple units decreases the availability of housing affordable for low-moderate income earning households who cannot afford to purchase single family homes. Apartments and smaller units are also essential for many seniors and residents with disabilities.

Affordability is a problem affecting both owner and renter households in El Centro. The 2023 Fair Market Rent for a 1-bedroom unit in El Centro is $904 (See Figure 35). To afford

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Packet Pg. 236 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 137 a $904 1-bedroom unit, a household would need to work a 45-hour week with a minimum wage of $17.38. However, the minimum wage in El Centro is only $15.50, which would require a 58-hour work week to afford a $904 lease. Based on these estimates, no units in the County or El Centro would be considered affordable to an individual working 40 hours per week at minimum wage.

An estimated 12.8% of households in El Centro are severely cost-burdened, spending over 50% of income on housing, (See Table 12: Demographics of Households with Severe Housing Cost Burdens). Black households are the most impacted by severe cost burdens (27.3%, or 120 of 440 Black households). Hispanic households are the second group most impacted by severe cost burdens with a rate of 15.9% (1,510 of 9,515 Hispanic households). Additionally, 15.4% of small-family households and 10.6% of nonfamily households are severely cost burdened in El Centro.

Impediment #3: Aging Housing Stock in Need of Repair and Rehabilitation
Data shows that El Centro’s housing stock is aged overall – less than 20% of the City’s housing is under 20 years old, while 65% is more than 40 years old. A city with aged housing stock typically has a greater need for rehabilitation and repair programs and funding than a city with newer housing stock. Additionally, homes built before 1979, or about 47% of El Centro’s homes, present a high risk of lead exposure and a need for lead abatement and education programs. Without these programs, housing problems may disproportionately impact low-income and historically disadvantaged communities.

Forty percent (40%) of El Centro households experience one or more HUD-defined housing problem. In El Centro, race and ethnicity greatly impact a household’s likelihood of experiencing one or more problems. Nearly 90% of Black households in El Centro experience at least one housing problem, in comparison to less than one quarter of white households. Nearly half of all Hispanic households experience one or more housing problems. When negative factors in housing disproportionately impact protected classes, such as racial or ethnic groups, this constitutes a barrier or impediment to fair housing choice.

Impediment #4: Disparities in Access to Community
Resources and Services
In many cities, a person’s location within the city impacts the resources they are able to access. Neighborhoods without equal access to resources may present a barrier or impediment to fair housing choice when residents of a city are limited to such

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Packet Pg. 237 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 138 neighborhoods by financial or other circumstances.

In El Centro, several areas have limited community resources in comparison to the rest of the City. In particular, two census tracts in northern El Centro, including the City’s only R/ECAP tract, have a median household income lower than $40,000 per year despite having some of the City’s highest concentration of jobs. In this same R/ECAP tract, along with one tract in western El Centro, more than 10% of residents do not have access to a vehicle. In several tracts in central El Centro, including the R/ECAP tract, 30- 40% of residents are considered to fall within low income-low food access group, meaning that they are considered low-income and live more than one-half mile from a supermarket; in one tract in northeastern El Centro, this number is greater than 40%. This low-food-access portion of the City also overlaps with areas where a significant portion of residents do not have vehicle access, which intensifies food access issues. Finally, El Centro contains five census tracts in which more than 8% of residents do not have health insurance, including the City’s only R/ECAP tract. These tracts also represent some of the lowest median household incomes in the City, meaning that it is likely that residents of these tracts work low-wage part-time hourly jobs that do not provide health insurance. As Imperial County as a whole has been designated as a medically underserved area since the 1990s, a lack of access to health insurance has the potential to greatly intensify overall healthcare access issues.

In combination, these factors have the potential to severely limit a person’s housing choice and therefore their access to resources. Many of these resource access issues affect the same census tracts, therefore compounding each other. A person living in a tract with lower rates of health insurance is less likely to have a vehicle, meaning that they may be forced to remain in the same neighborhood in order to be within walking distance of a low-wage job, and may be unable to access higher-wage jobs with better benefits, such as health insurance, due to lack of transportation. As many of these access issues overlap in El Centro’s only R/ECAP tract, which is primarily occupied by Black and Hispanic residents, it is clear that resource access issues within the City disproportionately impact protected class groups and therefore constitute and impediment to fair housing choice.

Impediment #5: Limited Housing Options for Persons With Disabilities
According to 2018-2022 ACS 5-Year Estimates, approximately 16.3% of the population in El Centro has at least one disability. This rate is higher than the overall disability rate in California (11.0%) and Imperial County (14.2%), suggesting that El Centro has a particular need for accessible housing suitable for persons with disabilities, who often have specialized housing needs. In addition, as persons with disabilities often live on limited incomes, such as standard Supplemental Security Income (SSI) payments,

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Packet Pg. 238 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 139 affordability is a key concern. This issue is further exacerbated by El Centro’s high housing costs, as those living on fixed incomes— often receiving less than $1,000 per month, according to average SSI estimates— are unlikely to be able to afford marketrate housing in the city, where 1-bedroom units rent for approximately $1,500 a month, according to ACS estimates.

As such, publicly supported housing plays a key role in providing persons with disabilities with affordable, accessible housing options. However, a review of HUD’s most recent A Picture of Subsidized Housing (APSH) data reveals that there are only two (2) Section 202 unit for seniors (Boatwright Homes and Cedar Homes) and no Section 811 units for persons with disabilities within El Centro. Disability was also the most cited basis among fair housing discrimination complaints in El Centro. The city’s overall lack of housing options tailored towards persons with disabilities, along with patterns of housing complaints suggests that this protected class faces distinct barriers to fair housing choice.

Impediment #6: Need for Continued and Expanded Fair
Housing Activities
Knowledge of fair housing rights and resources is generally good in the City of El Centro.

These results indicate that while ongoing education efforts within the community have been successful, there is a continuing need to provide fair housing education and resources. The diversity of the city’s population suggests that this fair housing education should be targeted to communities of color and people with limited English proficiency.

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Packet Pg. 239 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 140 TABLE 24. FAIR HOUSING GOALS AND ACTIVITIES
Contributing Factors Recommended Activities Responsible Parties and Partners
IMPEDIMENT #1: LOW WAGES IMPEDE ACCESS TO OPPORTUNITIES, RESOURCES, AND RESTRICT HOUSING CHOICE FOR LOW/MOD

INCOME HOUSEHOLDS AND PROTECTED CLASSES
Continued need for
professional job training and
workforce development
Overall low wages
throughout the city of El
Centro with multiple tracts
where households are low
income
Low access to healthy foods,
healthcare, and high
performing schools
Collaborate with key stakeholders on implementing workforce development goals and strategies including eliminating the education achievement gap, and funding increased access to quality public goods and services, including transportation, housing, food access and affordability, quality childcare and digital broadband access Work with community partners to support resident and employer participation in job search, placement, and training programs. In particular, expand paid job training programs
Collaborate with residents and community partners to understand barriers to accessing job training programs and employment, and continue to develop and fund strategies to address these barriers Invest/expand job training and placement initiatives for individuals with LEP to increase their self-sufficiency and housing stability City of El Centro
Imperial County
Local job training and
employment assistance
programs
Majority of schools in El
Centro are underperforming
High concentration of
minority populations,
particularly Hispanic/Latino,
throughout the city
Partner with Imperial County Public Schools, community stakeholders, and others to provide facilities, resources, and services to students attending lower-performing schools. These may include basic school resources and supplies, school readiness, mentoring and tutoring, family engagement and literacy, health services, behavioral and social supports, enrichment programs, programs to increase food security and access, support for ESL students and students with disabilities, resources for students experiencing homelessness or who are part of economically disadvantaged households, and other resources and services.

City of El Centro
Imperial County
Imperial County Public
School District

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Packet Pg. 240 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 141 Contributing Factors Recommended Activities Responsible Parties and Partners
IMPEDIMENT #2: LIMITED SUPPLY OF AFFORDABLE HOUSING FOR LOW/MOD INCOME HOUSEHOLDS Rents are increasing and
over 13% of households are
cost burdened
Continue to review the Annual Qualified Allocation Plans issued by the California Tax Credit Allocation Committee under the Low Income Housing Tax Credit (LIHTC) program to identify local government policies or actions that may positively impact the competitiveness of developers’ applications
Consider and adopt zoning code amendments that could increase possibilities for development of affordable housing
Convene a focus group of local affordable housing developers to identify challenges to working in the region, and develop strategies to address these barriers
Assess the need for publicly supported housing and opportunities to expand housing options
City of El Centro
Imperial Valley Housing
Authority (IVHA)
Imperial County
Area affordable
housing developers
IMPEDIMENT #3: AGING HOUSING STOCK IN NEED OF REPAIR AND REHABILITATION Aging housing stock Gather data and produce a report on factors impacting the lack of new housing built in El Centro in the past twenty years • Using this report, create a plan to encourage the development of new housing within the jurisdiction
City of El Centro
Disproportionate impact of
housing problems on
protected class groups
Create or expand rehab and repair programs targeting traditionally Black and Hispanic communities, as well as neighborhoods with low median household incomes
Existing affordable units are
in need of rehabilitation
Continue to support the rehabilitation of existing affordable housing options through the City’s Housing Rehabilitation Program, providing outreach to affected homeowners

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Packet Pg. 241 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 142 Contributing Factors Recommended Activities Responsible Parties and Partners
IMPEDIMENT #4: DISPARITIES IN ACCESS TO COMMUNITY RESOURCES AND SERVICES Low median household
income concentrated in
certain areas of the city
Create or expand job training and employment assistance programs in areas of the city with low median household income
Create or expand upward mobility and financial education and assistance programs in areas of the city with low median household incomes
City of El Centro
Local job training and
employment assistance
programs
Lack of vehicle access
concentrated in certain areas
of the city
Expand bus routes and operational hours in areas of the city with low vehicle access rates
Investigate the potential to expand subsidized rideshare programs for non-disabled residents in areas of the city with low vehicle access rates Imperial Valley Transit
Lack of food access
concentrated in certain areas
of the city
Ensure that bus routes throughout the city provide easy access to supermarkets and that operational hours allow residents to grocery shop after work or on the weekends
Produce a report on steps the city could take to encourage the development of new supermarkets in low-access areas
IMPEDIMENT #5: LIMITED HOUSING OPTIONS FOR PERSONS WITH DISABILITIES Insufficient affordable,
accessible housing that serves
the needs of residents with
disabilities
Partner with the Imperial Valley Housing Authority and the California Housing Finance Agency to explore potential funding opportunities for affordable, accessible housing that meets the needs of persons with disabilities, such as the Section 811 program
City of El Centro
Imperial Valley Housing
Authority
California Housing
Finance Agency
(CalHFA)

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Packet Pg. 242 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 143 Contributing Factors Recommended Activities Responsible Parties and Partners
IMPEDIMENT #5: LIMITED HOUSING OPTIONS FOR PERSONS WITH DISABILITIES (CONT.) Disability remains the most
common basis for fair housing
complaints in the area
Convene a focus group comprised of local disability advocacy and supportive service providers to gain a deeper understanding of the unique challenges and issues that residents with disabilities face in El Centro’s housing landscape
Local disability
advocacy and
supportive service
providers
IMPEDIMENT #6: NEED FOR CONTINUED AND EXPANDED FAIR HOUSING ACTIVITIES Continuing need to support
existing fair housing activities
Need to expand fair housing
activities and education
Source of income
discrimination, prohibited
under FEHA, still occurs
Continue to offer fair housing education activities, with a focus on expanding the pool of partners the City and IFHMB works with (ex: LEP communities/organizations, disability advocacy and supportive service providers, schools, etc.) to ensure meaningful connections are established with vulnerable populations
Collaborate with property managers and landlords to ensure that they have an understanding of property management practices that affirmatively further fair housing
City of El Centro
Inland Fair Housing
Mediation Board
(IFHMB)
Mercy Housing
California Civil Rights
Department (CRD)

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Packet Pg. 243 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 144 APPENDIX:

ZONING ANALYSIS MATRIX
City of El Centro, CA
Average Total Risk Score: 1.0
Risk Scores Key
1 = low risk: the provision poses little risk for discrimination or limitation of fair housing choice, or is an affirmative action that intentionally promotes and/or protects affordable housing and fair housing choice;
2 = medium risk: the provision is neither among the most permissive nor most restrictive; while it could complicate fair housing choice, its effect is not likely to be widespread; 3 = high risk: the provision causes or has potential to result in systematic and widespread housing discrimination or the limitation of fair housing choice, or is an issue where the jurisdiction could take affirmative action to further affordable housing or fair housing choice but has not.

Source Documents:
• Code of the City of El Centro, available at:
https://library.municode.com/ca/el_centro/codes/code_of_ordinances?nodeId=COELCE (Adopted March 19, 1980).

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Packet Pg. 244 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to Fair Housing) 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 145 TABLE 25. ZONING ANALYSIS MATRIX
Issue Conclusion Risk Score Reference
1a. Does the jurisdiction’s definition
of “family” have the effect of
preventing unrelated individuals
from sharing the same residence? Is
the definition unreasonably
restrictive?
1b. Does the definition of “family”
discriminate against or treat
differently unrelated individuals with
disabilities (or members of any other
protected class)?
1a. The zoning ordinance’s definition of
“family” is not unreasonably restrictive.

It includes two (2) or more individuals
related by convenience who occupy
the same dwelling unit.
1b. The definition of “family” does not
discriminate against or treat unrelated
individuals with disabilities differently.

The definition of “family” explicitly
includes residents of residential care
facilities and group homes for people
with disabilities.
1 Sec. 29-21: Definition of “family” -
Family: Two (2) or more individuals
related by birth, marriage, adoption
or convenience who occupy the
same dwelling unit. A family also
includes the residents of residential
care facilities and group homes for
people with disabilities. A family does
not include larger institutional group
living situations such as dormitories,
fraternities, sororities, monasteries or
nunneries, nor does it include such
commercial group living
arrangements as boardinghouses,
lodging houses and farm labor
camps.
2a. Does the zoning code treat
housing for individuals with
disabilities (e.g. group homes,
congregate living homes,
supportive services housing,
personal care homes, etc.)
differently from other single family
residential and multifamily
residential uses? For example, is
such housing only allowed in certain
residential districts, must a special or
conditional use permit be granted
before siting such housing in certain
residential districts, etc.?
2a. The code does not treat housing for
persons with disabilities differently than
other residential uses. Small residential
care facilities that provides care for six
(6) or fewer persons are a permitted
use in all residential zones. Large
residential care facilities that provide
care for seven (7) or more persons are
a permitted use in 4 out of 5 residential
zones – RR, R1, R2, and R3. Supportive
or transitional housing is a permitted use
in all residential zones.
1 Sec. 29-53: Residential zones use
regulations and Table 29-53.1

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Packet Pg. 245 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 146 2b. Does the zoning ordinance
unreasonably restrict housing
opportunities for individuals with
disabilities who require onsite
supportive services? Or is housing for
individuals with disabilities allowed in
the same manner as other housing
in residential districts?
2b. Supportive or transitional housing is
a permitted use in all residential zones.
3a. Do the jurisdiction’s policies,
regulations, and/or zoning
ordinances provide a process for
persons with disabilities to seek
reasonable modifications or
reasonable accommodations to
zoning, land use, or other regulatory
requirements?
3b. Does the jurisdiction require a
public hearing to obtain public
input for specific exceptions to
zoning and land-use rules for
applicants with disabilities? If so, is
the public hearing process only
required for applicants seeking
housing for persons with disabilities
or required for all applicants?
3a. The City provides a process for
persons with disabilities seeking
reasonable accommodations in Sec.
29-300.2 of the zoning code.
3b. The City does not require a public
hearing in the process of evaluating
requests for reasonable
accommodations.
1 Sec. 29-300: "Reasonable
accommodation" in the land use and
zoning context means providing
individuals with disabilities, or
developers of housing for people with
disabilities, flexibility in the application
of land use and zoning and building
regulations, policies, practices and
procedures, or even waiving certain
requirements, when it is necessary to
eliminate barriers to housing
opportunities.

Sec. 29-300.2

4. Does the ordinance impose
spacing or dispersion requirements
on certain protected housing
types?
The ordinance states that large
residential care facilities cannot be
placed within 300 ft of one another on
the same street. Exemptions may be
approved depending on certain
conditions. These spacing requirements,
combined with the ability to appeal for
1 Sec. 29-162: “Spacing/concentration.

A large residential care facility shall
not be located within three hundred
(300) feet of another such facility on
the same street as measured from the
exterior property lines. An exemption
to the spacing requirement may be

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Packet Pg. 246 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 147 an exemption, are unlikely to pose risk
for discrimination against large
residential care facilities.
approved by the city if the existing
facility is at capacity or the applicant
demonstrates that a need exists for a
unique or particular service not
currently provided by the existing
large residential care facility.”

5. Does the jurisdiction restrict any
inherently residential uses protected
by fair housing laws (such as
residential substance abuse
treatment facilities) only to nonresidential zones?
The City does not restrict any inherently
residential uses protected by fair
housing laws to non-residential zones.
1 Sec. 29-53: Residential zones use
regulations and Table 29-53.

6. Does the jurisdiction’s zoning and
land use rules constitute
exclusionary zoning that precludes
development of affordable or lowincome housing by imposing unreasonable residential design
regulations (such as high minimum
lot sizes, wide street frontages, large
setbacks, low FARs, large minimum
building square footage or large
livable floor areas, restrictions on
number of bedrooms per unit,
and/or low maximum building
heights)?
Though the zoning code could be
reevaluated to determine whether
these design regulations could be
adjusted to further incentivize the
production of affordable housing, they
do not impose unreasonable standards
on development.
1 Sec. 29-54. - Residential zones
property development standards and
Table 29-54.1.
7a. Does the zoning ordinance fail
to provide residential districts where
multifamily housing is permitted as
of right? Are multifamily dwellings
excluded from all single-family
dwelling districts?
No, MFR districts hold multifamily
dwellings as a permitted use as of right.

They provide the highest yielding
residential density allowed.
1 Sec. 29-52: “R2 variable residential
zone. This zone is intended to permit
the development of medium density,
single-family, duplex, or multiplefamily dwellings with a maximum density of twelve (12) dwelling units
per net acre.”

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Packet Pg. 247 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 148 7b. Do multi-family districts restrict
development only to low-density
housing types?
“R3 multiple-family residential zone.

This zone is intended to permit the
development of medium high-density
apartment and condominium
dwellings with a maximum density of
twenty-five (25) dwelling units per net
acre, on lots not less than seven
thousand two hundred (7,200) square
feet in net area.”

8. Are unreasonable restrictions
placed on the construction, rental,
or occupancy of alternative types
of affordable or low-income
housing (for example, accessory
dwellings or mobile/manufactured
homes)?
No, there are no unreasonable
restrictions placed on special types of
affordable or low-income housing, such
as accessory dwelling units (ADUs),
mobile homes, or manufactured
homes.
1 Sec. 29-168. - Accessory dwelling unit
regulations.

Secs. 29-188-190 – Mobile Home
Regulations
Sec. 8-59 - Standards for
manufactured homes
9a. Are the jurisdiction’s design and
construction requirements (as
contained in the zoning ordinance
or building code) congruent with
the Fair Housing Amendments Act’s
accessibility standards for design
and construction?
9b. Is there any provision for
monitoring compliance?
The City has adopted and
incorporated the 2022 edition of the
California Building Code, which is
based on the International Building
Code (IBC) 2021 edition. HUD currently
recognizes the 2009, 2012, 2015 and
2018 editions of the IBC as safe harbors
under the Fair Housing Act, and should
begin review of the 2021 soon.

Under the City of El Centro’s
Community Development Department,
the Building and Safety Division
monitors compliance and provides
Building Code enforcement for all
construction projects located in the
city. The Code Enforcement Division
1 Sec. 7-36. - Adoption of the California
Building Code, 2022 edition; deletions,
amendments, additions

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Packet Pg. 248 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to 2024 ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE 149 provides enforcement for city code
violations.

10. Does the zoning ordinance
include an inclusionary zoning
provision or provide any incentives
for the development of affordable
housing or housing for protected
classes?
Yes 1 Article IV, Division 4 – Density Bonus
Program
Sec. 29-205 – Intent and purpose.
“Density bonuses for qualified
residential development shall be
provided as specified in California
Government Code Sections 65915
through 65918.”
California Government Code
Chapter 4.3. Density Bonuses and
Other Incentives (Sec. 65915 – 65918)

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Packet Pg. 249 Attachment: DRAFT Analysis of Impediments to Fair Housing (6298 : Draft Analysis of Impediments to City Council of the City of El Centro Meeting: 04/02/24 11:30 AM 1275 Main Street Department: Public Works
El Centro, CA 92243 Category: Resolution
Prepared By: Elizabeth Zarate
SCHEDULED Department Head: Abraham Campos
ACTION ITEM (ID # 6056) DOC ID: 6056
Establishing Mid-Block Crosswalk on Waterman for
Jacaranda Apts Off-Site Improvements
CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 24- , RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF EL CENTRO ESTABLISHING A MID-BLOCK

CROSSWALK ON WATERMAN AVENUE BETWEEN BRADSHAW
AVENUE AND LINCOLN AVENUE.

FISCAL IMPACT:

There will no fiscal impact to the General Fund.

STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #2, Ensure the city’s infrastructure is enhanced and maintained to support existing and future development through innovative and sustainable principles. Action 2.14:

Promote connectivity to public amenities throughout the city by requiring new development to provide direct and safe bike/pedestrian connections to key destinations.

DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

N/A
BACKGROUND:

Chelsea Investments with the support of the City of El Centro Successor Agency and the City of El Centro, is developing the Jacaranda Gardens Apartment on Waterman Avenue. This project includes public facilities such as pedestrian, and roadway improvements.

Given the layout of Waterman Avenue, it is expected that the natural pedestrian traffic flow will not walk towards the intersections at Waterman/Bradshaw or Lincoln Bradshaw due to the distance, and instead cross mid-block to access the park. To address this, the project proposes the construction of a mid-block crosswalk to connect the new multifamily development to the city park across the street.

DISCUSSION:

City Ordinance 17-43 requires City Council approve mid-blocks by Resolution. In support of the request, the Public Works Director/City engineer contracted the services of LLG Consultants to perform a traffic study for the proposed Waterman Avenue midblock crosswalk. The location qualifies for a marked crosswalk per the study. To enhance safety, the proposed crosswalk will include the following measures:

1. Road diet. The lanes will reduced from 2-lanes in each direction to 1-lane in each direction.

2. Rectangular Rapid Flashing Beacons
11 Packet Pg. 250
Action Item (ID # 6056) Meeting of April 2, 2024

3. Pedestrian refuge island
CONCLUSION:

Staff recommends that the City Council adopt Resolution No. 24- , RESOLUTION OF

THE CITY COUNCIL OF THE CITY OF EL CENTRO ESTABLISHING A MID-BLOCK

CROSSWALK ON WATERMAN AVENUE BETWEEN BRADSHAW AVENUE AND LINCOLN AVENUE.

ATTACHMENTS:
• Approved Resolution (PDF)
• Waterman Ave Crosswalk Warrant Study Memo (PDF)
11 Packet Pg. 251
07/2023/cdz/A23-0143/Reso/Mid-BlockCrosswalkWatermanAvenue RESOLUTION NO. 24-

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EL

CENTRO ESTABLISHING A MID-BLOCK CROSSWALK ON

WATERMAN AVENUE BETWEEN BRADSHAW AVENUE

AND LINCOLN AVENUE
WHEREAS, the State of California (“State”) promotes Active Transportation Activities to increase the proportion of trips accomplished by biking and walking, increase safety and mobility for non-motorized users and enhance public health; and
WHEREAS, the City of El Centro, California (“the City”) has partnered with Chelsea Investment Corporation (“Developer”) and secured grant funding for offsite improvements promoting Active Transportation surrounding the Jacaranda Gardens Apartments Project (“the apartments”), including a mid-block crosswalk (“the crosswalk”); and WHEREAS, the crosswalk is proposed on Waterman Avenue between Bradshaw Avenue and Lincoln Avenue to provide a direct connection between the proposed multi-family apartments and First Responders Park (“the Park”); and
WHEREAS, out-of-direction travel exists to access the Park from the apartments, and WHEREAS, the National Association of City Transportation Officials (“NACTO”) recommends mid-block crossings where there is a significant pedestrian desire line, such as accessing a park via a direct route; and
WHEREAS, the 2022 Imperial County Transportation Commission Regional Active Transportation Plan (“RATP”) states mid-block crossings provide convenient locations to cross where the nearest intersection creates out-of-direction travel; and WHEREAS, NACTO and RATP recommend the use mid-block crossings be supplemented with other safety features such as curb extensions, pedestrian refuge islands and flashing signs; and
WHEREAS, as required by CalJPIA, the City has obtained a traffic study; LLG Engineers performed a midblock crosswalk traffic study (attached as Exhibit A) recommending the crosswalk, and listing specific crossing treatments; and WHEREAS, after a review of the proposed mid-block crossing treatments, the Public Works Director has determined to utilize Striping changes such as narrower lanes, painted medians, road diets, or other speed reducing treatments and Rectangular Rapid Flashing Beacons (RRFBs) as recommended by the consultant; and
WHEREAS, El Centro City Municipal Code Section 17-43 indicates that no mid-block crosswalk shall be established in any block except as designated by City Council resolution; and

11.a
Packet Pg. 252 Attachment: Approved Resolution (6056 : Establishing Mid-Block Crosswalk on Waterman for Jacaranda Apts Off-Site Improvements) 07/2023/cdz/A23-0143/Reso/Mid-BlockCrosswalkWatermanAvenue WHEREAS, El Centro City Council finds the placement of the mid-block crosswalk with the included crossing treatments is in the best interests of the neighborhood and residents living on or near the aforementioned crosswalk; and

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS;

1. That the foregoing is true, correct and adopted.

2. The proposed design for the mid-block crosswalk on Waterman Avenue between Bradshaw and Lincoln Avenue, as detailed in attached Exhibit A, is hereby approved.

3. That the City Manager or designee is hereby authorized and directed to establish said mid-block crosswalk by appropriately painted markings, signs, and other crossing treatments.

PASSED AND ADOPTED at a regular meeting of the City Council of the City of El Centro held on the day of , 2024.

CITY OF EL CENTRO
By __________________________
Sylvia Marroquin, Mayor
ATTEST:

By ____________________________
Norma Wyles, City Clerk
APPROVED AS TO FORM:

Office of the City Attorney
By _______________________________
Elizabeth L. Martyn, City Attorney

STATE OF CALIFORNIA )
COUNTY OF IMPERIAL ) ss

11.a
Packet Pg. 253 Attachment: Approved Resolution (6056 : Establishing Mid-Block Crosswalk on Waterman for Jacaranda Apts Off-Site Improvements) 07/2023/cdz/A23-0143/Reso/Mid-BlockCrosswalkWatermanAvenue AYES:

NOES:

ABSENT:

ABSTAINED:

By ___________________________
Norma Wyles, City Clerk

11.a
Packet Pg. 254 Attachment: Approved Resolution (6056 : Establishing Mid-Block Crosswalk on Waterman for Jacaranda Apts Off-Site Improvements)

MEMORANDUM
N:\3825 - Waterman Crosswalk\Report\Crosswalk Memo.3825.docx To: Abraham Campos, PE
City of El Centro
Date: February 15, 2024
From: Shankar Ramakrishnan, PE
Charlene Sadiarin, PE
LLG, Engineers
LLG Ref: 3-23-3825
Subject: Waterman Avenue Midblock Crosswalk
Linscott, Law & Greenspan Engineers (hereafter referred to as LLG) has prepared this memo for the Waterman Avenue Midblock Crosswalk Project in the City of El Centro. A new midblock crosswalk is proposed on Waterman Avenue between Bradshaw Avenue and W. Lincoln Avenue in the City of El Centro.

This memo reviews crosswalk warrant thresholds and analyzes if the proposed midblock pedestrian crossing meets such thresholds.

CROSSWALK INFORMATION
A midblock pedestrian crosswalk is proposed on Waterman Avenue as part of offsite improvements for the Jacaranda Gardens Apartments Project. Waterman Avenue in this vicinity is currently constructed as a 4-lane roadway with center turn lane. A road diet of Waterman Avenue within the Jacaranda Gardens Apartment Project is proposed to convert the 4-lane roadway to a 2-lane roadway with a center turn lane, on-street parking, and buffered bike lanes. The nearest cross-street north of the proposed crossing location is Bradshaw Avenue (signalized), which is approximately 800 feet away from the proposed crosswalk. The nearest cross-street south of the proposed crossing location is N. Lincoln Avenue (two-way stop-controlled), which is approximately 450 feet away. Therefore, a midblock pedestrian crosswalk to connect the proposed Jacaranda Gardens Apartment Project with the existing First Responders Park.

Figure 1 shows a vicinity map. Figure 2 shows a crosswalk location map.

Attachment A provides a conceptual plan of the proposed midblock crosswalk on Waterman Avenue.

Average Daily Traffic (ADT) volumes and speed survey data collection were conducted on Thursday, November 16, 2023. Attachment B contains the count sheets.

11.b
Packet Pg. 255 Attachment: Waterman Ave Crosswalk Warrant Study Memo (6056 : Establishing Mid-Block Crosswalk on Waterman for Jacaranda Apts Off- Mr. Abraham Campos
February 15, 2024

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El Centro City CouncilApril 2, 2024

El Centro City Council
April 2, 2024