PUBLIC COMMENTS AND CITY RESPONSES
Public Review Period Written Comments Received –
March 3, 2025 – April 3, 2025
Comments Received Through City’s Survey:
1. Look to provide additional grants for shared housing, stabilization programs and woman and children housing
[City Response: This comment has been considered and accepted.]
2. made a job for someone to do..
[City Response: This comment has been considered and accepted.]
3. I'd like to have help for families who have debt that they are paying off and are above income average to be able to be eligible for low cost housing even if it's a few years at a time so that we don't have to pay higher rent simply because our outstanding loans aren't taken into consideration for apartment eligibility and are left struggling to make ends meet.
[City Response: The entitlement funds received from HUD through CDBG and HOME are meant to benefit persons who are low- and moderate-income, those with incomes at or below 80% of the area median income.
This comment has been considered and accepted.]
4. I would like to start off by saying. That we as residence of Fresno County needs improvement on sidewalks throughout our City polk and w Ashcroft Can use sidewalks instead of walking on the roadways as children cross the street daily from into school in cars through here speed in our neighborhoods that can cause injuries and bodily so would be nice to see that in our neighborhood. Thank you. [City Response: This comment has been considered and accepted.]
Comments Received Through City’s E-mail:
5. Informacion del aviso en español por favor
[City Response: The public notice of the 30-day Public Comment Period was published in the Fresno Bee in English and Spanish.
The draft documents were translated to Spanish, Hmong, and Punjabi prior to the final Public Hearing before City Council.
This comment has been considered and accepted.]
6. Hi! I’m [name redacted] and wanted to request hat within the Consolidated Plan put forward by the City of Fresno that affordable housing would be a high priority.
So often either apartments (which aren’t bad, just aren’t the best) or high-end housing is the priority. I believe this is a mistake. Allowing more people to thrive will allow more money to be poured into the community. Consolidation of wealth, which is what happens when affordable housing is not prioritized, creates a stagnant and ineffective economy. Affordable housing allows for people to amass generational wealth and benefits all of Fresno by improving the general community of Fresno. Just as a person is known by how they treat those around them, so a city is known by how it treats its people, even those who are of lower income and influence. I believe Fresno has a bright path forward if it builds affordable housing. Not only would it help families to get a strong foothold in this community, but it would also allow students graduating from Fresno State and Fresno City to be able to begin their lives and careers in this great city. Again, lack of affordable housing creates stagnation and a degradation of the city.
Affordable housing benefits everyone by improving the city they depend on.
Thank you.
[City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates providing $22 million in HUD entitlement funds through CDBG and HOME to improve the access and quality of affordable housing through rehabilitation of existing units and new construction of both single-family and multi-family housing.
This comment has been considered and accepted.]
7. I greatly appreciate the work and the data and documentation/research findings integrated into this document. The findings regarding housing challenges and other needs in the community, demographic information, as well as community priorities are important.. The priorities outlined capture what needs to drive policy and planning are also important.
Without minimizing any of the important actions outlined, which I cannot fully reference, to this document want to add some suggestions.
Regarding the priority of improved administration of funds and plan for monitoring, it is important that we work on having greater oversight and accountability for all programs, especially among vulnerable populations who have not historically had as much of a voice in how the services and program affects them, what importance could be made, and so forth.
We need to have third party review of programs to allow for those who are affected by programs and services to securely express their experiences and thoughts to an entity without a conflict of interest or potentially compromised, whose finding would be addressed for the proposed of improving services or identifying areas that need to be changed, this includes such things as shelters, HART, outreach, and other services. The beneficial nature of services depends on how well they are operated.
It is important that the City of Fresno creates a lived experience board to allow those who have experienced being unsheltered to speak on proposed and current programs and services as they relate to the unhoused and to seek ways to overcome barriers for those who are unhoused to be heard, such as going to those with lived experience to assess programs that affect them, rather than simply through online or in person means due to lack of access to information and mobility.
The city staff have taken efforts to do so, such as having community needs meetings in areas such as nearby Roeding. The challenge is that as people are spread across the city and have limited access to information, planning direct contact through such things as doing direct surveys on paper would be helpful.
On Homeless Prevention:
The assessment on page 127 on gaps in homeless housing needs should drive the city’s policy regarding those at risk or experiencing lack of housing, including that “The rise of unsheltered homelessness is likely due to the rising cost of rent and the severe lack of affordable rental housing in Fresno County. Once a person becomes homeless, the housing resources to help them exit homelessness are also very scarce.”
As well, it is notable that “The top domestic violence and elder abuse needs identified by participants were permanent housing and transitional/ supportive housing programs.” as many of those unhoused we have encountered were survivors of abuse.
Strengthening the programs that prevent homelessness, such as eviction protection programs, rental assistance, rapid rehousing, housing rehabilitation, and such are important to prevention.
There are other displacement actions that the city needs to implement that were outlines in the Here to Stay report and it would be helpful to also utilize this document, including the rent stabilization program as outlined in the report, as rising rent was outlined as a factor affecting the number of affordable housing units available. It is crucial to pursue the goal to preserve affordable housing and set aside a portion of the units for permanent supportive housing.
Aggressively seeking to provide the conditions of a Housing First approach are also key, as noted on the Housing element, as this approach has been most successful. Itis crucial that the city prioritize and implement the strategies contained in the Analysis of Impediments to Fair Housing Choice as detailed on page 180. The goals on page 140 to increase affordable housing are crucial, such as Project 4 on page 160.
As shelters established with Project Homekey funding are being transitioned to permanent housing, the plan should ensure that those who are unhoused can access this housing, among other plans in the Housing Element to increase affordable housing.
I wish to correct the section on page 127 that includes the HART team and description. Beyond the outreach and community organizations, HART is not improving the quality of life of those who are unhoused. They are not only decreasing the quality of life, by throwing away all of the belongings of those who are unhoused, including living essentials like blankets, clothing, food, water, medications, work items, in addition to items of personal value like photograph, family mementos and generally refuse to store belongings, but the practice of HART are impeding the process of getting into housing, as IDs, phones, documentation, and other needed materials are thrown away, and for some documents, there is a limitation on how often these can be replaced. As well, the practice often makes it difficult for those who are unhoused to stay connected to case workers.
As well, current city policies, which are outside this consolidated plan, such at the ordinance to prohibit being on public property with the penalty of arrest, is creating greater barriers to overcoming homelessness.
I oppose the listing of law enforcement in prevention/ outreach services.
The community has called for a community based, non-law enforcement based response. Provision and aid should not require law enforcement. As well, other communities have implement non-law enforcement approaches to conflict resolution and de-escalation, such as Mental Health First in Oakland, Heart in Hayward, and Kahoots in Oregon. Having trained mediators, mental health professionals, those versed in conflict resolution and de-escalation who know how to work with the population, and other community based response options that the city can explore, s would not only address safety concerns, but serve in relationship building that lead into aiding in getting services and more long term solutions for the individuals, and save the community resources.
While Housing First should be the focus, on page 128 it is noted the lack of temporary shelter. It would be useful to note that there is also a lack of drop in overnight shelters. I noted as well that domestic violence shelters are not listed in the funding (I note that the city plans to use state HHAP funding for shelters) and recommend that funding be allocated as I have experienced this as a high need among those escaping crisis.
This is among the reasons why another service that needs to be provided is seasonal warming centers through the winter months, as the health and safety needs are even greater when temperatures are low and when it rains. Having warming centers open continuously, rather than based on weather forecasts, also will make the resource more accessible, as the predictability increases the likelihood of people knowing about the shelter and not having to rely so heavily on the chance of being notified in time. The warming centers also provide increased contact and coordination with service providers.
Regarding the shelters, the coordinated plan would be more successful with a policy change to the maximum days of occupancy to allow occupants to have adequate time to become housing ready and find permanent housing, considering the gaps identified to housing such as the severe lack of affordable housing.
There also is a need to ensure that shelters have sufficient oversight and policies to ensure practices regarding occupants protect them from unjust treatment and exits, that they have a means of having concerns and grievances adequately addressed, and that practices are trauma informed.
Regarding Workforce Development, many of those who are unhoused have requested help with employment and I note that among the projects on the plan is a culinary workforce development program. In addition to this, I recommend working on development of a program also tailored to the needs of those without housing, including connecting with other employers who may not need to be funded but will work with and train those with housing challenges and have services to make maintaining employment viable.. Possible services as well, could include job assistance brought to the shelters.
I appreciate the use of information and direction by the Street To Home Report. I see that there are elements that have been implemented, such as low barrier shelters and HMIS. As we seek more shelters and housing, the recommendation to not have crisis housing concentrated in one area, but throughout the city is important, as is being by public transportation and other resources. [City Response: The City provides oversight of all HUD-funded programs. Each year the Community Development Division assesses each activity funded to assign a risk score to establish a monitoring schedule. Over the course of the Program Year, each activity funded will be monitored by the Community Development Division. The City and each of its subrecipients are also subject to monitoring performed by HUD.
Each of the City-funded shelters has its own procedure for filing grievances and/or complaints. Additionally, all agencies operating shelters are required to be members of the Fresno-Madera Continuum of Care (FMCoC) which has written standards that participants, participating providers, and other parties may use to submit written grievances to the FMCoC. Lastly, in accordance with state law AB- 362, a flyer with steps to report potential code violations is placed in a common area of each shelter. On an annual basis, the City must report to the state information about the AB-362 complaints received and the outcomes of each.
To gain input from individuals who have experienced being unsheltered, the City held a pop-up event at a City-owned emergency shelter. Additionally, the Fresno- Madera Continuum of Care has a Lived Experience Advisory Board that they City could use to receive input from individuals with lived experience.
As noted, the plan indicates that rising rental costs and a lack of affordable housing is likely a cause of unsheltered homelessness. As a result, the Draft 2025-2026 Annual Action Plan includes $321,240 in HOME funds for Tenant Based Rental Assistance and $333,601 in ESG funds for Rapid Rehousing and Homeless Prevention to aid in preventing homelessness.
In addition to Poverello House’s Culinary Workforce Development Program that is recommended for funding under CDBG Public Services, Poverello House’s HOPE Team is recommended for funding under ESG for street outreach. One of the many services to be provided by Poverello House’s HOPE Team is job training and/or job search.
This comment has been considered and accepted.]
Comments Received Through Project Website (FresnoConPlan.org)
8. What is your plans for building affordable housing? And what does that look like ? Price, square footage etc?
[City Response: Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates that it will provide $14.5 million in HOME funds to develop 55 affordable rental units and 44 single family units. Project specific details will be determined following the appropriate Request for Proposals process that includes underwriting and technical assessment of each proposed project. Funding recommendations will then be taken to Council for consideration.
This comment has been considered and accepted.]
9. Fresno desperately needs more rental housing options. The current market is dominated by older, often outdated apartments, leaving many residents with limited choices. As rental rates continue to climb, it becomes increasingly difficult for individuals, particularly those with lower credit scores, to secure affordable housing. The lack of new, modern rental units exacerbates this problem, making it nearly impossible for many to find suitable homes. Among the various challenges facing Fresno, the urgent need for increased housing supply stands out as the most critical issue demanding immediate attention. [City Response: Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates that it will provide $14.5 million in HOME funds, a portion of which it anticipates will fund to develop 55 affordable rental units.
This comment has been considered and accepted.]
10. Fresno's housing crisis is reaching a breaking point. The lack of quality, affordable rental housing is forcing people to choose between terrible living conditions and homelessness. We need to prioritize building more housing to address this urgent issue.
[City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates providing $22 million in HUD entitlement funds through CDBG and HOME to improve the access and quality of affordable housing through rehabilitation of existing units and new construction of both single-family and multi-family housing.
This comment has been considered and accepted.]
11. Fresno's housing market is in dire need of an overhaul. The current rental landscape is dominated by aging, often substandard apartments, leaving residents with limited choices. As rental rates steadily climb, it becomes increasingly difficult for individuals, especially those with lower incomes or credit scores, to secure affordable housing. The scarcity of new, modern rental units exacerbates this issue, making it nearly impossible for many to find suitable homes. Among the various challenges facing Fresno, the urgent need for increased housing supply stands out as the most critical issue demanding immediate attention.
[City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates providing $22 million in HUD entitlement funds through CDBG and HOME to improve the access and quality of affordable housing through rehabilitation of existing units and new construction of both single-family and multi-family housing.
This comment has been considered and accepted.]
12. As a property manager in Fresno, I witness firsthand the pressing need for more housing options in our city. The current rental market is incredibly tight, with high demand and limited supply, especially for larger units suitable for families. Many of our residents are struggling to find affordable, quality housing that meets their needs. The lack of new construction and the aging housing stock contribute to this shortage. Additionally, rising rental rates and income inequality make it increasingly difficult for many to secure stable housing. To address this issue, we need increased investment in affordable housing initiatives, as well as streamlined zoning regulations to encourage new development. By expanding our housing stock, we can improve the quality of life for our residents and strengthen our community.
[City Response: Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates that it will provide $14.5 million in HOME funds, a portion of which it anticipates will fund to develop 55 affordable rental units.
This comment has been considered and accepted.]
13. As a long-time resident of Fresno, I've noticed a significant need for more and better rental housing options. Many of the older apartment complexes are outdated and in need of significant repairs. This limits the choices for residents, especially those seeking modern, comfortable, and affordable housing.
Additionally, the lack of new construction has contributed to a shortage of rental units, driving up prices and making it increasingly difficult for families and individuals to find suitable homes. We need more diverse housing options, including affordable housing, senior housing, and student housing, to meet the growing needs of our community.
[City Response: Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates that it will provide $14.5 million in HOME funds, a portion of which it anticipates will fund to develop 55 affordable rental units. Student housing is not eligible under the HOME program, but affordable housing for families and seniors are both eligible activities.
This comment has been considered and accepted.]
14. It's nearly impossible to find a decent, affordable place to live in Fresno. All the cheap rentals are old and often have problems. We need more affordable housing options, especially for people with low incomes. [City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates providing $22 million in HUD entitlement funds through CDBG and HOME to improve the access and quality of affordable housing through rehabilitation of existing units and new construction of both single-family and multi-family housing.
This comment has been considered and accepted.]
15. With rising rents and limited housing options, it's becoming increasingly difficult for large families to find a safe, affordable place to live in Fresno. We need more family-friendly housing options to accommodate our growing community.
[City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, $14.5 million in HOME funds, a portion of which it anticipates will fund to develop 55 affordable rental units.
This comment has been considered and accepted.]
16. Fresno's housing market is seriously lacking. There's a huge need for more housing options, especially affordable ones. It's getting harder and harder for people to find decent places to live, and many are getting priced out of the market. We need more new construction and better rental options to keep up with the growing demand.
[City Response: Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates that it will provide $14.5 million in HOME funds to develop 55 affordable rental units and 44 single family units.
This comment has been considered and accepted.]
17. As a professional working in Fresno, I see a critical need for more multi-family affordable housing developments. Currently, the city's housing market is dominated by single-family tract homes, limiting options for lower-income families. We need to diversify our housing stock to provide more affordable and flexible living arrangements. Multi-family developments, such as apartments and condos, can offer lower upfront costs, reduced maintenance expenses, and diverse lease terms, making housing more accessible to a wider range of residents.
[City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, $14.5 million in HOME funds, a portion of which it anticipates will fund to develop 55 affordable rental units.
This comment has been considered and accepted.]
18. Fresno needs more housing options. The current market is limited, especially for lower-income families. We need more affordable housing to address homelessness and boost the local economy.
[City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates providing $22 million in HUD entitlement funds through CDBG and HOME to improve the access and quality of affordable housing through rehabilitation of existing units and new construction of both single-family and multi-family housing.
This comment has been considered and accepted.]
19. As we transition from college to the workforce, we need affordable, spacious housing to establish ourselves as young professionals. However, the rental market is dominated by small, overpriced units. As a first-time renter, I'm overwhelmed by the lack of affordable housing options in Fresno. The high cost of rent and the limited availability of units are making it very difficult. [City Response: The first goal identified through the Consolidated Plan process is to improve housing access and quality. Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, $14.5 million in HOME funds, a portion of which it anticipates will fund to develop 55 affordable rental units.
This comment has been considered and accepted.]
20. Is there a location on vacant lot property where homeless can be serviced and gather in a communal environment until housing can be found? Rather than moving them out of a residential area from block to block, only to return hours later to the original location. Individuals could be assisted with various needs in a large group area rather than pushing them throughout residential areas. The homeless roam the residential streets all night.
[City Response: Through its ESG allocation, the City is proposing to fund Poverello House’s HOPE Team to provide daily street outreach services to engage unhoused individuals “where they are at” to link them to navigation services to get them into shelters, temporary housing, or family and connect them to supportive services.
This comment has been considered and accepted.]
21. I live and work in Northwest Fresno. In the last 2 years this area has goes downhill. We have the homeless all over and also turning it into a section 8 neighborhood which brings in it's own problems. You also brought a troubled teen home right in the middle of a housing community where children walk to school. How does this make sense.
[City Response: This comment has been considered and accepted.]
22. This 179 page thesis is damned difficult to digest or even read. I'm sure you have good support for every comment, figure, etc! BUT WHAT IS THE CONCLUSION??THE FINDINGS! Is there a short recap that tells us what in hell you are telling us??? 179 pages of facts, figures, garbedly goop without a recap is just plain bull! Im your audience, have no idea of what in hell your conclusions are! What is good, bad, etc! I personally am not equipped to read this and understand what it really says. Nor do I have the time or energy to do so! [City Response: This comment has been considered and accepted.]
23. What is this mean? Is Fresno going to demolish the properties? [City Response: The City has in the past funded demolition of buildings in support of affordable housing. For instance, the through Substantial Amendment 202-04 the City used CDBG funds to acquire land at 4323-4333 N Blackstone and through Substantial Amendment 2024-01 proposed to use additional CDBG funds to demolition the existing buildings in order to develop senior affordable housing at the site. However, the Draft 2025-2026 Annual Action Plan does not include any planned activities related to demolition.
This comment has been considered and accepted.]
24. Lets beautify Fresno! To make sure our city is not filled with rental properties. how are you making sure there are more planned developments for owner occupied units? What plans do we have for new owner occupied homes? What is the planned percentage of rental units to owner occupied units? [City Response: Over the five-year Consolidated Plan period of July 1, 2025, to June 30, 2030, the City estimates that it will provide $14.5 million in HOME funds to develop 55 affordable rental units and 44 single family units.
This comment has been considered and accepted.]
25. I got denied help for my daughter and I since my wife died. I'm a man I was told, I won't get the help I'm looking for so give up.
[City Response: The City’s Housing and Community Development webpage at www.fresno.gov/planning/housing-community-devleopment lists available resources and programs. The division can also be reached via e-mail at [email protected] or by telephone at 559-621-8300 to provide further information or assistance.
This comment has been considered and accepted.]
26. March 14, 2025
Concerns Regarding the 2025-2029 Analysis of Impediments to Fair Housing Choice Dear Honorable Members of the Fresno City Council, I am writing to express significant concerns about the "2025-2029 Analysis of Impediments to Fair Housing Choice" (AI) currently under review during the public comment period ending April 3, 2025.
While I commend the City’s efforts to address housing challenges and comply with federal and state fair housing obligations, I believe the AI contains legal and practical flaws that warrant reconsideration before adoption. Below, I outline these issues and propose an alternative path forward to ensure a legally sound and feasible plan that serves all Fresno residents.
Legal and Practical Concerns
1. **Lack of Clear Nexus to Fair Housing Violations** The AI identifies broad issues like housing affordability (Impediment #1) as impediments to fair housing choice. However, under the Fair Housing Act (42 U.S.C. § 3601 et seq.), impediments must be tied to discriminatory practices or policies affecting protected classes. Without robust evidence of intent or disparate impact, as required by *Texas Dept. of Housing v. Inclusive Communities* (2015), these findings risk diluting the AI’s legal foundation. I urge the Council to revise the document to focus narrowly on barriers directly linked to unlawful discrimination.
2. **Vague Recommendations Undermine Accountability** Many proposed activities, such as "considering affordable housing bonds" or "partnering with developers," lack specificity in funding, timelines, or metrics for success. HUD’s Affirmatively Furthering Fair Housing (AFFH) obligations require meaningful, actionable steps. The current vagueness could expose the City to legal challenges for failing to meet its certification requirements. I recommend that each impediment be paired with concrete, funded strategies to ensure compliance and effectiveness.
3. **Threats to Property Rights and Local Control** Proposals to upzone single- family neighborhoods and mandate universal design requirements raise serious concerns about property rights and municipal authority. Such changes could infringe on due process or constitute regulatory takings under the U.S.
Constitution, while conflicting with Fresno’s zoning autonomy under the California Constitution. I request that the Council assess these measures’ legal risks and prioritize voluntary incentives over mandatory regulations.
4. **Economic Feasibility Overlooked** The AI’s ambitious goals—expanding shelters, funding wraparound services, and increasing affordable housing—do not account for Fresno’s fiscal constraints, particularly under Proposition 13’s limits on revenue. Without a clear funding plan, these recommendations are impractical and could strain City resources. I suggest a fiscal impact analysis be conducted to align the AI with budgetary realities.
5. **Weak Enforcement Mechanisms** Despite noting high rates of disability- based discrimination complaints, the AI relies heavily on education rather than enforcement. The Fair Housing Act and California’s FEHA empower the city to penalize violators, yet no strategies for enhanced code enforcement or litigation support are proposed. I urge the Council to strengthen the AI with proactive enforcement measures to address documented discrimination.
6. **Overreliance on Subjective Community Input** The AI’s dependence on surveys and workshops, while valuable, risks prioritizing anecdotal concerns (e.g., NIMBYism) over objective data. HUD expects a data-driven analysis, and this imbalance could weaken the AI’s defensibility. I recommend supplementing community feedback with statistical evidence to validate each impediment.
Proposed Alternative Plan To address these concerns, I propose the following revisions to the AI:
1. **Refine Impediments**: Limit impediments to those with a clear legal basis under the FHA or FEHA, supported by data showing discriminatory impact on protected classes.
2. **Specify Actions**: Replace vague recommendations with detailed, funded plans, including timelines and responsible parties, to meet HUD’s AFFH standards.
3. **Protect Property Rights**: Favor incentives (e.g., tax credits for affordable housing) over mandates like upzoning, ensuring compliance with constitutional protections.
4. **Conduct a Fiscal Analysis**: Assess the AI’s cost and identify sustainable funding sources, such as leveraging existing HUD grants or public-private partnerships, before adoption.
5. **Enhance Enforcement**: Add provisions for investigating and penalizing fair housing violations, such as a dedicated task force or increased legal aid funding.
6. **Balance Input with Data**: Integrate comprehensive statistical analysis (e.g., mortgage denial rates by census tract) alongside community feedback to strengthen the AI’s foundation.
Conclusion: The 2025-2029 AI is a critical opportunity to advance fair housing in Fresno, but its current form risks legal vulnerability and practical failure. I respectfully request that the Council delay adoption pending these revisions and hold an additional public hearing to discuss the amended plan. I am available to provide further input and would appreciate the opportunity to present these concerns at the May 1, 2025, public hearing.
[City Response:
1. The AI identifies eight impediments to fair housing choice, the first of which is the lack of quality and affordable housing which was identified as the top barrier to fair housing in the city by survey respondents. This is a significant impediment to fair housing choice when it disproportionately affects protected classes.
As stated in the AI, the disproportionate representation of several protected class groups in low- and middle-income levels can lead to unequal access to housing options and neighborhood opportunities in high-cost housing markets as found in the city of Fresno. Black and Hispanic residents, immigrants, people with disabilities, and seniors often experience additional fair housing barriers when affordable housing is scarce. For instance, individuals with disabilities are disproportionately impacted by substandard housing conditions as indicated in Table 10. Housing problems by race and ethnicity also indicate that Native American and Black households experience housing problems at the highest rates with Native Americans disproportionality experiencing severe housing problems.
Identifying ways to increase the production of affordable housing and improve existing affordable housing stock, as the AI does in Table 26, will aid in addressing the lack of quality and affordable housing that disproportionately impacts protected classes.
2. HUD has terminated the Affirmatively Furthering Fair Housing (AFFH) rule, replacing it with an Interim Final Rule which requires a general commitment that grantees will take active steps to promote fair housing. The City remains committed to ensuring fair housing for all residents and will work to achieve the recommendations outlined in the 2025-2029 Analysis of Impediments.
The recommendations included balance specificity and flexibility to ensure the realistic implementation of the activities.
3. Upzoning would provide opportunities to increase housing supply by allowing new capacity for development of multifamily housing like duplexes and triplexes, particularly in areas of opportunity, which would address the “missing middle” and increase affordability. The recommended activity includes consideration of amendments to upzone, which would include an assessment of legal considerations. The FMC requires all proposed rezones to follow Article 58 which includes district review committee review, ALUC review, a PC hearing, and City Council hearing.
Universal design requirements ensure that accessibility is incorporated from the initial design phase, rather than as an afterthought thereby ensuring that developments are focused on inclusion rather than merely meeting requirements.
4. The recommended activities included in the Analysis of Impediments account for the realities of limited resources. Specifically, rather than expanding shelter operations the recommendation is to continue funding emergency and transitional shelters considering the City’s limited resources for shelter operations. Similarly, the recommendations related to wraparound services specifically acknowledges and addresses the need for additional funding by including the application to future grants to obtain the funding necessary to provide the needed wraparound services. Finally, the recommendation for increasing affordable housing specifically identifies existing funding sources available to the City such as the Local Housing Trust Fund, CDBG, and HOME funds; provides considerations for ways to increase the funding of the Local Housing Trust Fund through mechanisms like housing bonds and development fees; and includes actions that do not require additional funding such as zone code amendments or prioritizing affordable housing when disposing of City-owned land.
5. The City’s Code Enforcement divisions currently provide for the enforcement of housing laws and issue violations as appropriate. Furthermore, the City’s Eviction Protection Program provides legal aid to individuals facing illegal evictions.
Increasing fair housing education for both tenants and landlords help individuals understand their rights and provide a means for reporting instances of discrimination.
6. While data analysis is required and included throughout the Analysis of Impediments, public participation is also an expectation of HUD. Since the Analysis of Impediments is a component of the Consolidated Plan, the citizen participation requirements for the Consolidated Plan apply. Affected people in the community, especially those historically underrepresented, must be included in and participate in the development of the plans. The City’s Analysis of Impediments evaluates input received from the community as a means to support the thorough data analysis conducted.
This comment has been considered and accepted.]
27. March 14, 2025 Concerns Regarding the 2025-2029 Analysis of Impediments to Fair Housing Choice
Dear Honorable Members of the Fresno City Council,
I am writing to express significant concerns about the "2025-2029 Analysis of Impediments to Fair Housing Choice" (AI) currently under review during the public comment period ending April 3, 2025. While I commend the City’s efforts to address housing challenges and comply with federal and state fair housing obligations, I believe the AI contains legal and practical flaws that warrant reconsideration before adoption. Below, I outline these issues and propose an alternative path forward to ensure a legally sound and feasible plan that serves all Fresno residents.
Legal and Practical Concerns
1. Lack of Clear Nexus to Fair Housing Violations
The AI identifies broad issues like housing affordability (Impediment #1) as impediments to fair housing choice. However, under the Fair Housing Act (42 U.S.C. § 3601 et seq.), impediments must be tied to discriminatory practices or policies affecting protected classes. Without robust evidence of intent or disparate impact, as required by *Texas Dept. of Housing v. Inclusive Communities* (2015), these findings risk diluting the AI’s legal foundation. I urge the Council to revise the document to focus narrowly on barriers directly linked to unlawful discrimination.
2. Vague Recommendations Undermine Accountability
Many proposed activities, such as "considering affordable housing bonds" or "partnering with developers," lack specificity in funding, timelines, or metrics for success. HUD’s Affirmatively Furthering Fair Housing (AFFH) obligations require meaningful, actionable steps. The current vagueness could expose the City to legal challenges for failing to meet its certification requirements. I recommend that each impediment be paired with concrete, funded strategies to ensure compliance and effectiveness.
3. Threats to Property Rights and Local Control
Proposals to upzone single-family neighborhoods and mandate universal design requirements raise serious concerns about property rights and municipal authority. Such changes could infringe on due process or constitute regulatory takings under the U.S. Constitution, while conflicting with Fresno’s zoning autonomy under the California Constitution. I request that the Council assess these measures’ legal risks and prioritize voluntary incentives over mandatory regulations.
4. Economic Feasibility Overlooked
The AI’s ambitious goals—expanding shelters, funding wraparound services, and increasing affordable housing—do not account for Fresno’s fiscal constraints, particularly under Proposition 13’s limits on revenue. Without a clear funding plan, these recommendations are impractical and could strain City resources. I suggest a fiscal impact analysis be conducted to align the AI with budgetary realities.
5. Weak Enforcement Mechanisms
Despite noting high rates of disability-based discrimination complaints, the AI relies heavily on education rather than enforcement. The Fair Housing Act and California’s FEHA empower the city to penalize violators, yet no strategies for enhanced code enforcement or litigation support are proposed. I urge the Council to strengthen the AI with proactive enforcement measures to address documented discrimination.
6. Overreliance on Subjective Community
Input The AI’s dependence on surveys and workshops, while valuable, risks prioritizing anecdotal concerns (e.g., NIMBYism) over objective data. HUD expects a data-driven analysis, and this imbalance could weaken the AI’s defensibility. I recommend supplementing community feedback with statistical evidence to validate each impediment.
Proposed Alternative Plan To address these concerns, I propose the following revisions to the AI:
1. Refine Impediments: Limit impediments to those with a clear legal basis under the FHA or FEHA, supported by data showing discriminatory impact on protected classes.
2. Specify Actions: Replace vague recommendations with detailed, funded plans, including timelines and responsible parties, to meet HUD’s AFFH standards.
3. Protect Property Rights: Favor incentives (e.g., tax credits for affordable housing) over mandates like upzoning, ensuring compliance with constitutional protections.
4. Conduct a Fiscal Analysis: Assess the AI’s cost and identify sustainable funding sources, such as leveraging existing HUD grants or public-private partnerships, before adoption.
5. Enhance Enforcement: Add provisions for investigating and penalizing fair housing violations, such as a dedicated task force or increased legal aid funding.
6. Balance Input with Data: Integrate comprehensive statistical analysis (e.g., mortgage denial rates by census tract) alongside community feedback to strengthen the AI’s foundation.
Conclusion: The 2025-2029 AI is a critical opportunity to advance fair housing in Fresno, but its current form risks legal vulnerability and practical failure. I respectfully request that the Council delay adoption pending these revisions and hold an additional public hearing to discuss the amended plan. I am available to provide further input and would appreciate the opportunity to present these concerns at the May 1, 2025, public hearing.
Thank you for your attention to this matter and your commitment to serving Fresno’s residents equitably and responsibly.
[City Response:
1. The AI identifies eight impediments to fair housing choice, the first of which is the lack of quality and affordable housing which was identified as the top barrier to fair housing in the city by survey respondents. This is a significant impediment to fair housing choice when it disproportionately affects protected classes.
As stated in the AI, the disproportionate representation of several protected class groups in low- and middle-income levels can lead to unequal access to housing options and neighborhood opportunities in high-cost housing markets as found in the city of Fresno. Black and Hispanic residents, immigrants, people with disabilities, and seniors often experience additional fair housing barriers when affordable housing is scarce. For instance, individuals with disabilities are disproportionately impacted by substandard housing conditions as indicated in Table 10. Housing problems by race and ethnicity also indicate that Native American and Black households experience housing problems at the highest rates with Native Americans disproportionality experiencing severe housing problems.
Identifying ways to increase the production of affordable housing and improve existing affordable housing stock, as the AI does in Table 26, will aid in addressing the lack of quality and affordable housing that disproportionately impacts protected classes.
2. HUD has terminated the Affirmatively Furthering Fair Housing (AFFH) rule, replacing it with an Interim Final Rule which requires a general commitment that grantees will take active steps to promote fair housing. The City remains committed to ensuring fair housing for all residents and will work to achieve the recommendations outlined in the 2025-2029 Analysis of Impediments.
The recommendations included balance specificity and flexibility to ensure the realistic implementation of the activities.
3. Upzoning would provide opportunities to increase housing supply by allowing new capacity for development of multifamily housing like duplexes and triplexes, particularly in areas of opportunity, which would address the “missing middle” and increase affordability. The recommended activity includes consideration of amendments to upzone, which would include an assessment of legal considerations. The FMC requires all proposed rezones to follow Article 58 which includes district review committee review, ALUC review, a PC hearing, and City Council hearing.
Universal design requirements ensure that accessibility is incorporated from the initial design phase, rather than as an afterthought thereby ensuring that developments are focused on inclusion rather than merely meeting requirements.
4. The recommended activities included in the Analysis of Impediments account for the realities of limited resources. Specifically, rather than expanding shelter operations the recommendation is to continue funding emergency and transitional shelters considering the City’s limited resources for shelter operations. Similarly, the recommendations related to wraparound services specifically acknowledges and addresses the need for additional funding by including the application to future grants to obtain the funding necessary to provide the needed wraparound services. Finally, the recommendation for increasing affordable housing specifically identifies existing funding sources available to the City such as the Local Housing Trust Fund, CDBG, and HOME funds; provides considerations for ways to increase the funding of the Local Housing Trust Fund through mechanisms like housing bonds and development fees; and includes actions that do not require additional funding such as zone code amendments or prioritizing affordable housing when disposing of City-owned land.
5. The City’s Code Enforcement divisions currently provide for the enforcement of housing laws and issue violations as appropriate. Furthermore, the City’s Eviction Protection Program provides legal aid to individuals facing illegal evictions.
Increasing fair housing education for both tenants and landlords help individuals understand their rights and provide a means for reporting instances of discrimination.
6. While data analysis is required and included throughout the Analysis of Impediments, public participation is also an expectation of HUD. Since the Analysis of Impediments is a component of the Consolidated Plan, the citizen participation requirements for the Consolidated Plan apply. Affected people in the community, especially those historically underrepresented, must be included in and participate in the development of the plans. The City’s Analysis of Impediments evaluates input received from the community as a means to support the thorough data analysis conducted.
This comment has been considered and accepted.]
Public Comments Received at Planning Commission
Meetings
Comments Received March 19, 2025:
1. Brunette Harris with H.E.A.T. – Once again we are here, your Annual Action Plan and your other plans that they have, they didn’t have a community meeting, so we want to know what did they come up with these plans from. They had one meeting at Maxie Park, we went, only four people were there. We asked a question, “what happened to the community?” They said, “we did door…” No you didn’t. A lot of people in the community didn’t receive anything. They’re still doing the same thing they’ve been doing. They make an Annual Action Plan, substantial plans, and we have given you what HUD federal guidelines are. So now you putting us in the position where we have to write D.C. because we’re getting sick and tired of it. Now the City needs to be audited because this doesn’t make any sense. We’re tired of it. They’re in our area constantly. You’re building on land that has been…I say it’s right there next to Hyde Park. Nobody seems to go out there and see what’s going on. All that area used to be a dump, they’re digging up crap in the dump. Mr. Criner, if you are aware of southwest Fresno, you know that was a dump in that area. They are building houses over there, they dug it up. We’re tired of it. So now I guess we’re forced to do something we do not want to do, because this doesn’t make any sense. They are not having community meetings, they’re doing basically what they want to do. Now when we came in here that project that you had out there off of North Avenue when those gentlemen came in, Jennifer sent that straight to, we seen it on television, to City Council. There was supposed to have been another meeting and how it went there we don’t know. This is what we get in southwest Fresno. Then they want to get up and stand up and say “oh no, that’s what we did” and when we sit down it’s like we’re not telling the truth. There’s things that we have better to do than to keep running up here to these meetings and telling you guys you’re coming up with things to do in our community and we do not have a say. HUD tells you you have to so now we have to write HUD in both places, San Francisco and Washington D.C. If they take all the fundings from District 1 to District 7, we don’t care, we’re tired. It doesn’t make any sense.
[City Response: An important component of the development of the Draft 2025- 2029 Consolidated Plan involved gathering input from residents regarding housing and community development conditions, needs, and opportunities in Fresno. The City used a variety of approaches to engage the community and receive input including community workshops, focus groups, pop-up events, a community-wide survey, and community needs hearings.
The City hosted six in-person community workshops throughout Fresno on various days and times, and two virtual community workshops to accommodate the varying schedules of the community. A total of 66 participants joined a community workshop.
The City also engaged residents through focus groups facilitated through CASA of Fresno and Madera Counties, County of Fresno Department of Behavioral Health, and Fresno Interdenominational Refugee Ministries. 31 residents participated in a focus group. Additionally, two pop-up engagement activities were held at River Park Farmers Market and Victory Village where over 100 residents were engaged about the Consolidated Plan and Annual Action Plan.
The City also received community input through a 29-question survey focused on housing and community development needs and opportunities, fair housing, and access to opportunity. A total of 237 survey responses were received.
Finally, the Fresno City Council held a public needs hearing on December 12, 2024, to obtain input from the community.
Advertisement of the community workshops and survey included public notice through announcements on the City’s website and social media, the project website, newspaper articles, e-mails to community stakeholders, and door hangers placed at households within one mile of each community location.
This comment has been considered and accepted.]
2. Bobbie with [H.E.A.T.] – I’m just going to spin off with what Brunnett has already stated, is that our main concern is the community. Have the courtesy and the decency is to set up these community meetings so that the community can and should have input. That’s our plight. Include the community. Things are happening and people are saying, “what’s going on?” because they don’t know.
They don’t know what’s going on. We know, but it’s not fair for the community is to come up with all these surprises and then they talk about notifications of 1,000 feet or whatever. You know, by the time all that happen, then people’s homes and things already affected. They have a right according to HUD’s, the federal rules. Let the community have input to say what they. Because it’s not that we don’t want developing but not a surprising thing that you are taking away from the people. That’s our complaint and I just oppose to all of what’s going on and the people are not aware. You can’t keep using the same old behind the door well they really don’t really understand all of what’s going on. That’s a bunch of bull.
People do know, people are educated. And so if you want to insist on making, it seem like that the community is not aware, a lot of it they’re not, but it’s not because they’re not concerned. So, our plight is, we are against what’s going on without the community having input.
[City Response: An important component of the development of the Draft 2025- 2029 Consolidated Plan involved gathering input from residents regarding housing and community development conditions, needs, and opportunities in Fresno. The City used a variety of approaches to engage the community and receive input including community workshops, focus groups, pop-up events, a community-wide survey, and community needs hearings.
The City hosted six in-person community workshops throughout Fresno on various days and times, and two virtual community workshops to accommodate the varying schedules of the community. A total of 66 participants joined a community workshop.
The City also engaged residents through focus groups facilitated through CASA of Fresno and Madera Counties, County of Fresno Department of Behavioral Health, and Fresno Interdenominational Refugee Ministries. 31 residents participated in a focus group. Additionally, two pop-up engagement activities were held at River Park Farmers Market and Victory Village where over 100 residents were engaged about the Consolidated Plan and Annual Action Plan.
The City also received community input through a 29-question survey focused on housing and community development needs and opportunities, fair housing, and access to opportunity. A total of 237 survey responses were received.
Finally, the Fresno City Council held a public needs hearing on December 12, 2024, to obtain input from the community.
Advertisement of the community workshops and survey included public notice through announcements on the City’s website and social media, the project website, newspaper articles, e-mails to community stakeholders, and door hangers placed at households within one mile of each community location.
This comment has been considered and accepted.]
Comments Received April 16, 2025:
1. Brunette Harris with H.E.A.T. – You guys put in that Consolidated Plan that H.E.A.T. had an input through the community. That is a lie, that never happened.
We want it out because there was no community participation in that. And whoever put down there was four people there, their hands should be shaken for even putting four people that attended that meeting at Maxie Park. We are not getting notified. I could care less what people say. They’re not notifying our community. So, there was not any input in the Consolidated Plan. None whatsoever. So, we have a problem with that and you need to get our name out of that.
[City Response: On November 4, 2024, staff held a stakeholder meeting with H.E.A.T. to receive input on the Consolidated Plan and Annual Action Plan.
Table 4 in the Consolidated Plan includes a summary of the comments received during the meeting.
Additionally, the City hosted six in-person community workshops throughout Fresno on various days and times, and two virtual community workshops to accommodate the varying schedules of the community. A total of 66 participants joined a community workshop.
The City also engaged residents through focus groups facilitated through CASA of Fresno and Madera Counties, County of Fresno Department of Behavioral Health, and Fresno Interdenominational Refugee Ministries. 31 residents participated in a focus group. Additionally, two pop-up engagement activities were held at River Park Farmers Market and Victory Village where over 100 residents were engaged about the Consolidated Plan and Annual Action Plan.
The City also received community input through a 29-question survey focused on housing and community development needs and opportunities, fair housing, and access to opportunity. A total of 237 survey responses were received.
Finally, the Fresno City Council held a public needs hearing on December 12, 2024, to obtain input from the community.
Advertisement of the community workshops and survey included public notice through announcements on the City’s website and social media, the project website, newspaper articles, e-mails to community stakeholders, and door hangers placed at households within one mile of each community location
This comment has been considered and accepted.]
2. Bobbie with H.E.A.T. – Im just gunna confirm and support what Brunnette had just said is that it is not a good thing is to indicate anyone to say that a person agrees or was a part of a meeting or anything that you was trying to get as far as your saying that there was a community input. It’s wrong when you print things like that and then you’re gunna indicate people in it. We were at that particular meeting less than fifteen minutes or twenty minutes or so because there were no community there, period. And so, like Brunnette said, you print this we know that a lot of people will probably never see it or read it, but when you present it to whatever you know committee or trying to get fundings its false and then you saying we agree with what you printed in that book, in that consolidated annual book. That is not right and it’s not truth. So, if you gunna vote on or if you’re gunna agree on things, people need to be conscious of what they do because not everybody is gunna say well “I didn’t know it or I didn’t see it.” We will always check and see what’s going on in our community. We can voice our voices and say that we are speaking for but we will continue to accumulate the information and we are gunna read to make sure that our community is gunna be taken care of. Thank you.
[
City Response: On November 4, 2024, staff held a stakeholder meeting with H.E.A.T. to receive input on the Consolidated Plan and Annual Action Plan.
Table 4 in the Consolidated Plan includes a summary of the comments received during the meeting.
This comment has been considered and accepted.]
Public Comments Received at City Council Public
Hearing
Comments Received June 12, 2025: