Lake Forest City Council
May 6, 2025

for their users consistent with the County of Orange and Orange County Operational Area Alert and Warning Plan.

1. Local Administrator
Participating Jurisdictions agree to appoint a designated Local Administrator responsible for leading, coordinating, monitoring and optimizing use of the System at the local level.

Local Administrator shall act as the Jurisdiction’s central point of contact and will work collaboratively with the County Administrator to ensure local use of the system is within MOU and Operating Guidelines.

Local Administrator is responsible for:

1. Contract acquisition if Agency will use the system for non-emergency purposes.

2. Local Agency Mass Notification Operating Procedure development and management.

3. Use compliance: routine monitoring to ensure System is used within the conditions and terms of this document and associated MOU.

4. Access management: Local User account distribution and management, including an annual audit of accounts; annual attestation that all Local Administrators and Local Users are authorized to continue accessing the system.

Record management of MOU(s) and signed Local User certifications.

5. Testing: facilitate routine local System test exercise, document local test results and recommend and execute, as needed, corrective action at the local level.

6. User Testing: verify and document Local Users with Alert and Warning responsibilities are performing monthly tests.

7. Public education campaign: initiate and facilitate public education campaign aimed at making the local community aware of the intended use of the System and individual registration web portal.

8. System support: provide support to Local Users.

9. Providing logins and procedural training to key individuals within their Agency responsible for using the System.

10. Exclusion Lists: provide annually a review of the exclusion list for businesses, phone numbers, and organizations in the Participating Jurisdiction.

11. Training: ensuring Local Users complete security awareness training that covers at a minimum the following areas: proper protection, handling, dissemination, and destruction of confidential information (CI); threats, vulnerabilities, and risks associated with handling of CI; social engineering; system responsibilities and expected behavior; account usage and management – including password creation, protection, and frequency of changes; system usage – allowed vs. prohibited; incident response; physical security; email protection – phishing threats and business account compromise

12. Incident Response: Local Administrator is responsible to immediately notify OCSD of any incidents that could lead to the unauthorized or accidental use, modification, disclosure, or destruction of any information contained within the system.

2. Local User:

County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

Participating Jurisdictions may have an unlimited number of Local Users. Local Users will have access to community member contact records within their Jurisdiction or Service District. Local Users will be authorized and managed by the Local Administrator and may have varied system permissions. For Water Retail Water Agencies, Local Users may use the System to send emergency notifications to the public by using preestablished GIS shape files or the system’s interactive map feature to identify their water users.

Local Users are responsible for obtaining Multi-Factor Authentication (MFA) software and will require MFA software to be functional for access to the System.

If a local user has access to send Alert and Warning messaging to the public then the local user should perform monthly tests including:

1. Logging into AlertOC

2. Sending a test message to one or more contacts (this can be the Alert and Warning User)

3. Checking message receipt to ensure message was delivered County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

VII. AUTHORIZED USE
A. Emergency Public Notifications
Legal restrictions exist related to issuing different types of messages through the System.

All Users are required to know and understand these restrictions. The Form in Attachment B delineates the requirements for each type of message.

As a general principle, the System is to be used when the public is being asked to take some action (e.g. evacuate, prepare to evacuate, shelter in place, boil tap water before drinking, local assistance centers and other follow up information, re-entry to an area after evacuation orders have been lifted or termination of the emergency because the danger has passed).

Use of the System for emergency activity contains two components: (1) the need to disseminate critical, safety-related information to individuals regarding emergency events occurring now, follow up information regarding the event and termination of the emergency event, and (2) communicating with safety-responder staff, volunteers and involved parties about the emergency event.

Emergency Public Notifications are limited to:

1. Imminent or perceived threat to life or property

2. Disaster notifications

3. Evacuation notices

4. Public health emergencies

5. Public safety emergencies

6. Any notification to provide emergency information to a defined community The following criteria should be used to assist with determining the need to issue an alert:

1. Severity. Is there a significant threat to public life and safety?

2. Public Protection. Is there a need for members of the public to take a protective action in order to reduce loss of life or substantial loss of property?

3. Warning. Will providing warning information assist members of the public in making the decision to take proper and prudent action?

4. Timing. Does the situation require immediate public knowledge in order to avoid adverse impact?

5. Geographical area. Is the situation limited to a defined geographical area? Is that area of a size that will allow for an effective use of the system, given the outgoing call capacity?

6. Are other means of disseminating the information inadequate to ensure proper and time delivery of the information?

7. Is the message being sent follow up information to an emergency event in progress? If the answer to ALL of these questions is “Yes”, then an activation of the System for emergency purposes may be warranted.

County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

Illustrations of incidents which may be Emergency Public Notifications are included in Attachment A.

Participating Agencies are authorized to develop pre-established notification lists and messages related to specific types of emergencies. The circumstances for using these lists should be documented within County emergency plans and annexes approved by the Emergency Management Council, and their establishment coordinated with the County Administrator. Such documentation should include which forms of System notification will be used (e.g., opt-in agency data). During emergencies, messages will be coordinated with the Operational Area Emergency Operations Center or OCSD-EMD. These lists may include special populations (e.g. in-home care, schools, etc.) or those susceptible to certain risks (e.g. homes within dam inundation zone). It is the responsibility of the participating Agency to create, maintain and update these lists.

B. Emergency Responder Notifications
Emergency Responder Notifications are limited to:

1. Contacting first responders to advise of an emergency

2. Contacting first responders to report for duty due to an emergency

3. Contacting key staff regarding an emergency or crisis situation

4. Contacting agency employees/DSWs to report at a different time or location (or provide an update) due to an emergency

5. Exercises
Emergency considerations:

1. Notification shall clearly state situation is an emergency

2. Message length shall not exceed 60 seconds

3. Message shall have a call back number specific to the agency issuing the notification.

4. It is highly recommended all messages are recorded using a real voice and not the computer transcriber.

5. It is highly recommended to provide a phone number or website where the public can obtain additional or updated information

6. An all clear notification should be sent when applicable C. Non-Emergency Public Notifications
Non-emergency public notification use is prohibited for any of the following purposes:

1. Any message of commercial nature

2. Any message of a political nature

3. Any non-official business (e.g. articles, retirement announcements, etc.)

4. To send a message to an E911 obtained data source
E911 data is cannot be used for non-emergency use except for testing according to the law California Public Utilities Code (CPUC) sections 2872 and 2891.1 and violators may be subject to criminal enforcement. Any Agency or Jurisdiction in violation of this term may have their use of the System suspended or their individual access revoked.

County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

No Jurisdiction shall use the System for non-emergency public announcements unless a separate contract with the Vendor is established. Cost associated with non-emergency public notifications is the responsibility of the local Jurisdiction. Jurisdictions will be limited to using the self-registering portal entry data only when launching non-emergency messages.

Jurisdictions who contract to use the System for non-emergency activity agree to give precedence to emergency notification call-outs by delaying or terminating non-emergency notification sessions if needed to increase emergency message success. The primary concern for point of failure in this situation is not the System, but the telephone port capacity of local phone providers responsible for delivering calls to community members and businesses.

D. Inter-Department Communication
Each participating Agency and Jurisdiction is authorized to create employee/volunteer and department call lists and pre-recorded messages. Agencies and Jurisdictions may use the System for non-emergency inter-departmental business communication as needed, without cost. It is recommended that individual Agencies identify where this would add value to their operations and establish separate written protocols and procedures for this use. Interdepartmental users will have permission to inter-departmental contact information only and are authorized to use the System solely for inter-departmental communication including but limited to first responder or volunteer call-outs.

VIII. ACTIVATION OF THE SYSTEM
Each Jurisdiction is responsible for launching messages to affected community members and businesses within their Jurisdiction or Service District. • For messages launched by Jurisdictions on their own behalf, Jurisdictions are responsible for identifying and documenting who has the authority to launch messages.
• For messages launched by the County on behalf of Jurisdictions, the County requires the message be authorized by either the City Manager, City Police Chief, City Fire Chief, City Emergency Manager, or by public safety personnel on the incident scene with Incident Commander approval. Exigent circumstances will be evaluated on a case-by-case basis if the preceding individuals are not available.

The County of Orange and Orange County Operational Area Alert and Warning Plan is incorporated by reference. This document delineates the processes for coordinating all alert and warning notifications, including those transmitted using this System.

IX. LIMITATIONS OF THE SYSTEM
Every effort will be made by the County to ensure the System operates in the manner described in the SOP. However there are limitations of technology which may cause the system to fail or provide inconsistent message delivery. Some of these limitations include:
• Cell Phone Disruptions
• Cell Phone Reception Coverage
• Public Safety Power Shutoff events
County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

X. ROUTINE TESTING
Monthly System tests will be conducted to ensure that use of the System in an emergency is optimized and users are familiar with operation. All users should perform monthly message proficiency tests. Users who do not login and perform a message proficiency test at least yearly are subject to removal as a user from the System.

The System will have an annual regional test. This includes testing operational readiness, activation procedures and system effectiveness as well as validating data and system processes. Through the annual test exercise, System administrators and users will be able to observe the mode of operation to augment and refresh System and process knowledge.

Specific test exercise routines, roles, responsibilities and schedule will be detailed in the County of Orange and Operational Area Alert and Warning Plan.

By signing the Mass Notification System MOU, participating Jurisdictions agree to take part in System drills and exercises.

XI. CONFIDENTIALITY AND SECURITY
Through the “Memorandum of Understanding between the County of Orange and Participants for use of Countywide Mass Notification System,” each agency is bound in writing to the confidentiality obligations sufficient to permit agencies to fully perform its obligations under this policy or the vendor agreement. Jurisdictions and Agencies shall be responsible for:

1. Ensuring users have completed an appropriate background check and undergone annual security awareness training.

2. Protecting Confidential Information (CI) contained within the system against accidental or unauthorized use, modification, dissemination, or destruction.

3. Ensuring that users maintain the confidentiality of all user login and password information;

4. Ensuring that users follow the 90 day password expiration limit;

5. Ensuring that users use the service in accordance with all applicable laws and regulations, including those relating to use of personal information;

6. Immediately notifying the County Administrator of any security incident that could lead to the unauthorized access, use, modification, dissemination, or destruction of CI contained within the system.

7. Any breach of the terms of this policy or the vendor agreement by any user; and

8. All communications by users using the service.

XII. COSTS
The County of Orange agrees to fund the System for notifications classified as “emergency use.” The County of Orange also agrees to continue to obtain updated E911 telephone data and geographic maps.

Costs associated with use of the System for non-emergency activity is the responsibility of the local Jurisdiction through separate contract with the Vendor.

XIII. DEFINITIONS
County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

System – All components of the Mass Notification System including hardware, software, access portals, contact data and GIS maps.

Community members – Comprises individuals and businesses.

Emergency - “Emergency” shall include, but not be limited to, instances of fire, flood, storm, epidemic, riots, or disease that threaten the safety and welfare of the individuals and property located within the boundaries of the county and participants’ respective jurisdictions.

XIV. REVISION HISTORY
Revision Date Author Description
April 18, 2008 PMNS Policy
Committee
Document originated
May 19, 2008 PMNS Executive
Review Team
Non-emergency session termination in
Section V., Item C.

June 16, 2008 Teara LeBlanc Exception clause in Section VII, Item A., bullet 2.

May 2010 Vicki Osborn Revision of all sections
June 2012 Raymond Cheung Revision for OCSD transition
May 2013 Raymond Cheung Revision for new vendor contract May 2016 Raymond Cheung Added confidentiality item to Section V., Item C. and allowed non-emergency use in
Section V., Item B. and Section VIII.

June 2021 Harmon “Jay” Ward Revision for new contract
Revision of Sections II, III, IV, V, IX, and XI.

October 2024 Harmon “Jay” Ward Revision for new contract; added User Testing for County and Local Jurisdictions in
Sections VI and X; added City Emergency
Manager as Authorized Requestor in
Section VIII; added Section IX; added
password expiration in Section XI.

County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

XV. ATTACHMENT A – INCIDENT ILLUSTRATIONS
This is a non-exhaustive list provided as examples.

Type of Incident Description Meets
Public
Safety
Criteria
Active Shooter A shooting with armed individual or individuals is occurring in a known area.

Yes
Boil Water
Orders
An unsafe water supply issue requiring the public to boil water before use.

Yes
Building Fire A fire occurring in an urban area requiring evacuation or shelter in place for the immediate area.

Yes
Violent Crimes Violent crimes that just occurred such as robbery, assault, murder, etc.

Yes
Felony Suspect
at Large
Law enforcement is currently searching for a felony
suspect that is suspected to be in a certain area.

Yes
HazMat Hazardous Materials incidents that require a fire/hazmat response and may include evacuations or shelter-inplace orders.

Yes
Health Orders Any public health order made pursuant to County Health Officer recommendations.

Yes
Missing Adult
(920A) with
special circs
12- 17 yrs with decreased mental capacity or medical
condition
Yes
Missing Child
(920C)
12 yrs or younger Yes
Missing Juvenile
(920J)with
special circs
18 yrs and older 12- 17 yrs with decreased mental
capacity or medical condition
Yes
Severe Weather
Related
Weather warnings that forecast an occurring or
imminent threat to public safety or coincide with
protective action recommendations such as voluntary or
mandatory evacuation orders.

Yes
Evacuation or
Shelter-in-Place
Voluntary or mandatory evacuation or shelter-in-place
orders.

Yes
Wildland Fire A fire occurring in a wildland urban interface area requiring immediate evacuation or shelter-in-place.

Yes
Road Closures Unplanned road closures due to an emergency situation.

Yes
Planned Events Road closures due to community events planned in advance.

No
County of Orange and Orange County Operational Area
Countywide Public Mass Notification System
Operating Guidelines

XVI. Attachment B – AlertOC/WEA/EAS Activation Form
Public Mass Notification System
Individual User Agreement

1. __________________________(hereinafter “USER”) is an agent, officer, employee or representative of __________________________, (hereinafter “PARTICIPANT”).

2. PARTICIPANT is a signatory to a Memorandum of Understanding (“MOU”) between with the County of Orange (“COUNTY”) for Use of Countywide Mass Notification System (“SYSTEM”).

3. As an agent, officer, employee or representative of PARTICIPANT, USER has been granted access to the System by PARTICIPANT and is deemed an Individual User under the MOU. USER can have access removed by the Local Administrator for PARTICIPANT at any time.

4. USER understands that as an Individual User, USER may only use the SYSTEM in the manner described in the MOU, the Everbridge GSA Approved End User License Agreement, and in accordance with the requirements of the law.

5. By signing this Individual User Agreement, USER hereby further expressly agrees to the do following things:
a) to maintain the confidentiality of login and password information; b) to use the System in accordance with all applicable laws and regulations, including those relating to use of personal information;
c) to be responsible for any breach of the terms of the Agreement with Everbridge and/or the MOU between PARTICIPANT and COUNTY caused by the USER;
d) to notify the Local Administrator or County Administrator if there is a breach of security caused by the USER e) to maintain the confidentiality of all records and information to which the USER may have access as a result of their access to the System pursuant to all statutory laws relating to privacy and confidentiality that currently exist or exist at any time during the term of this MOU; f) that all information transmitted and the use of the SYSTEM by USER shall be in compliance with California Public Utilities Code section 2872; and
g) to be responsible for notifying the Local Administrator if the USER is no longer an agent, officer, employee, or representative of PARTICIPANT

6. USER also acknowledges having been provided the opportunity to review the GSA Approved End User License Agreement with Everbridge, the Memorandum of Understanding Between the County of Orange and Participants for Use of Countywide Mass Notification System, and California Public Utilities Code section 2872, prior to signing this Individual User Agreement, and hereby agrees to abide by both the letter and intent of those documents.

7. USER may withdraw their consent to terms contained within this Individual User Agreement at any time by notifying PARTICIPANT in writing. USER acknowledges, however, that withdrawing USER’s consent will result in immediate termination of USER’s right and ability to access the SYSTEM.

By signing this Individual User Agreement, USER acknowledges having thoroughly read the foregoing, and hereby consents and agrees to the above terms and conditions.

Dated: __________________ _____________________________________ Signature
_______________________________________
Printed Name
_______________________________________
Email Address

CITY COUNCIL AGENDA REPORT
MEETING DATE: 5/6/2025
DEPARTMENT: Management Services
SUBJECT:

FIRST AMENDMENT TO THE AGREEMENT WITH CROWN FACILITY

SOLUTIONS FOR SPECIAL EVENT JANITORIAL SERVICES AT THE

COMMUNITY CENTER, PERFORMING ARTS CENTER, AND THE

CLUBHOUSE
RECOMMENDED ACTION(S):

1. Approve the First Amendment to the Agreement to Crown Facility Solutions with a compensation amount of $316,000 for special event janitorial maintenance services at the Community Center, Performing Arts Center, and The Clubhouse.

2. Authorize the Mayor to sign, and the City Clerk attest, the First Amendment to the Agreement with Crown Facility Solutions, substantially in the form attached.

EXECUTIVE SUMMARY:

On June 21, 2022, the City Council awarded a three-year agreement, with two optional one-year extensions, to Crown Facilities Solutions with a not-to-exceed compensation amount of $210,000 (“Agreement”) (Attachment 1). Fees associated with the cleaning are paid per rental, with a portion of the fees being a pass-through cost. The pass-through costs were adopted on June 7, 2022. The Agreement is for janitorial services for special event rentals held at the Community Center, Performing Arts Center and The Clubhouse and is effective until June 30, 2025.

Staff recommends the City Council approve the proposed First Amendment to the Agreement with Crown Facility Solutions (“First Amendment”) (Attachment 2).

The proposed First Amendment would extend the term to June 30, 2026, and increase the compensation amount by $106,000. The need for additional funding arises from the proposed term extension as well as an increase in cost based on the Consumer Price Index (“CPI”). In accordance with the CPI-based cost increase mechanism described in the Agreement, the First Amendment would increase all line-item costs by 3.41% or less. The proposed term extension and increased total compensation would allow services to continue under the Agreement through the remaining term without interruption.

BACKGROUND:

On June 21, 2022, the City Council awarded the three-year Agreement to Crown Facilities Solutions in the amount of $210,000. The term of the Agreement is effective through June 30, 2025, and includes two optional one-year extensions based upon performance and subject to City Council approval.

The Agreement includes janitorial services for special event rentals held at the Community Center, Performing Arts Center and The Clubhouse Senior Center.

Cleaning is required for each rental and as determined by staff, with occasional routine cleaning for carpets and floors. Fees associated with the cleaning are paid per rental, with a portion of the fees being a pass-through cost. The passthrough costs were adopted on June 7, 2022.

DISCUSSION:

Staff is proposing a First Amendment to the Crown Valley Solutions Agreement (Attachment 2). The First Amendment increases the compensation by $106,000 for a revised total compensation amount of $316,000. It also extends the term of the Agreement to June 30, 2026, thereby exercising the first of the two optional one-year extensions. The term extension and associated compensation increase are based on an increase to Crown Facilities base fees (increased by CPI), and the City’s projected janitorial needs for the remainder of the current fiscal year and projected needs for Fiscal Year 2025-26. In accordance with the CPI-based cost increase mechanism described in the Agreement, the proposed First Amendment would increase all line-item costs by 3.41% or less.

Vendor Performance Assessment
Pursuant to the City’s Purchasing and Contracting Guidelines, staff is required to complete a vendor performance assessment during a proposed contract amendment. The vendor assessment is a guide to determine if a contract should be amended, renewed, or terminated based on performance in the following categories: performance of scope of services, timeliness, budget performance, and customer service. Utilizing an evaluation form, staff rates the consultant in each category.

Table 2 below provides an overall assessment of the consultant’s performance since work under the original Agreement was initiated. Consistent with the City’s Purchasing and Contracting Guidelines, including the vendor assessment, the contract is eligible for a contract amendment.

Table 2: Vendor Assessment
Crown Facility Solutions
July 1, 2022 – May 6, 2025
Category Assessment
Performance of Scope of
Services
☐Unsatisfied ☐Satisfied ☒Very Satisfied ☐N/A
Timeliness ☐Unsatisfied ☐Satisfied ☒Very Satisfied ☐N/A Budget Performance ☐Unsatisfied ☐Satisfied ☒Very Satisfied ☐N/A Customer Performance ☐Unsatisfied ☐Satisfied ☒Very Satisfied ☐N/A The proposed First Amendment was prepared by the Management Services Department and has been reviewed and approved by the City Attorney as to form. Staff recommend the City Council authorize the proposed First Amendment to the Crown Facility Solutions.

FISCAL IMPACT:

Approval of the recommended action will result in an additional $106,000 in compensation authorized to be paid to Crown Facility Solutions and extend the term of the Agreement by one year to June 30, 2026. Sufficient funds are available in Fiscal Year 2024-25 and will be included in Fiscal Year 2025-26 of the proposed 2025-2027 Operating Budget to cover the costs of the recommended action.

ATTACHMENTS:

1. Agreement with Crown Facility Solutions

2. Proposed First Amendment to the Agreement with Crown Facility Solutions
Initiated By: Victoria Blethen, Recreation Manager
Submitted By: Sean McGovern, Deputy City Manager
Approved By: Debra Rose, City Manager
Attachment 1

Attachment 2

SPECIAL EVENT CUSTODIAL AND JANITORIAL
(2022-042.1)
City of Lake Forest
100 Civic Center Dr.

Lake Forest, CA 92630
Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 City of Lake Forest
First Amendment to Agreement for Maintenance Services
Special Event Custodial and Janitorial
I. PARTIES AND DATE. ..............................................................................

II. RECITALS...............................................................................................

III. TERMS...................................................................................................

IV. SIGNATURES. ........................................................................................

V. EXHIBIT "C" - COMPENSATION..............................................................

Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 Title: Special Event Custodial and Janitorial
3 1. PARTIES AND DATE.

This Agreement is made and entered into this [***INSERT DAY***] day of [***INSERT MONTH***], [***INSERT YEAR***], by and between the City of Lake Forest, a municipal corporation, organized under the laws of the State of California, with its principal place of business at 100 Civic Center Drive, Lake Forest, California 92630 (“City”) and Crown Facility Solutions, a California Corporation (Inc.) , with its principal place of business at 3605 W. MacArthur Blvd, Ste 701, Santa Ana, CA 92704 (“Contractor”). City and Contractor are sometimes individually referred to herein as “Party” and collectively as “Parties.” Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 Title: Special Event Custodial and Janitorial
4 2. RECITALS.

2.1. Agreement
The Parties entered into that certain Agreement for Special Event Custodial and Janitorial Services dated July 1, 2022 (“Agreement”).

2.2. First Amendment
The Parties now desire to amend the Agreement in order to extend the term of the Agreement, increase the total amount of compensation under the Agreement, update the rates of compensation, update vendor information, update the Delivery of Notices, and update City Representative under the Agreement.

Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 Title: Special Event Custodial and Janitorial
5 3. TERMS.

3.1. Term.

Section 3.1.2 of the Agreement is hereby amended in its entirety to read as follows:

The term of this Agreement shall be from July 1, 2022 to June 30, 2026, unless earlier terminated as provided herein. The City shall have the unilateral option, at its sole discretion, to renew this Agreement annually for no more than one (1) additional one-year terms. Contractor shall complete the Services within the term of this Agreement, and shall meet any other established schedules and deadlines.

3.2. Compensation.

Section 3.3.1 of the Agreement is hereby amended in its entirety to read as follows:

Contractor shall receive compensation, including authorized reimbursements, for all Services rendered under this Agreement at the rates set forth in Exhibit “C” attached hereto and incorporated herein by reference. The total compensation shall not exceed THREE HUNDRED SIXTEEN THOUSAND DOLLARS ($316,000.00) without written approval of the City Council or City Manager as applicable. Extra Work may be authorized, as described below, and if authorized, will be compensated at the rates and manner set forth in this Agreement.

3.3. Rates of Compensation/ Schedule of Compensation
Exhibit “C” of the Agreement is hereby amended in to update rates of compensation in the form of EXHIBIT "C" - COMPENSATION to this First Amendment, attached hereto and incorporated herein.

3.4. Delivery of Notices.

Section 3.5.2 of the Agreement is hereby amended as follows:

Contractor: Crown Facility Solutions
3605 W. MacArthur Blvd, Ste 701
Santa Ana, CA 92704
ATTN: Brent P Shears, President & Secretary

3.5. City's Representative.

Section 3.2.4 of the Agreement is hereby amended as follows:

The City hereby designates Sean McGovern, Deputy City Manager, or his/her designee, to act as its representative in all matters pertaining to the administration and performance of this Agreement (“City’s Representative”). City’s Representative shall have the power to act on behalf of the City for review and approval of all products submitted by Contractor but Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 Title: Special Event Custodial and Janitorial
6 not the authority to enlarge the Scope of Work or change the total compensation due to Contractor under this Agreement. The City’s City Manager shall be authorized to act on City’s behalf and to execute all necessary documents which enlarge the Scope of Work or change the Contractor’s total compensation, subject to the provisions contained in Section 3.3 of this Agreement. Contractor shall not accept direction or orders from any person other than the City Manager, City’s Representative or his/her designee.

3.6. Remaining Provisions of Agreement.

Except as otherwise specifically set forth in this First Amendment, the remaining provisions of the Agreement shall remain in full force and effect.

Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 Title: Special Event Custodial and Janitorial
7 4. SIGNATURES.

4.1. SIGNATURES.

CITY OF LAKE FOREST Crown Facility Solutions
By: [AUTHORIZED CITY SIGNATURE]
Scott Voights
Mayor
By: [VENDOR SIGNATURE 1]
Brent P Shears
President
[If Corporation, TWO SIGNATURES,
President OR Vice President AND Secretary
OR Treasurer REQUIRED]
ATTEST:

By: [CITY CLERK SIGNATURE]
City Clerk
By: [VENDOR SIGNATURE 2]
Brent P Shears
Secretary (Corporation or LLC)
APPROVED AS TO FORM:

By: [CITY ATTORNEY SIGNATURE]
Best Best & Krieger LLP
City Attorney
[CONTRACT ADMINISTRATOR APPROVAL]
[PROJECT MANAGER APPROVAL]
[CITY CLERK - INSURANCE APPROVAL]
Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48 Title: Special Event Custodial and Janitorial
8 5. EXHIBIT "C" - COMPENSATION

5.1. EXHIBIT "C" - COMPENSATION
Consultant shall be paid for services in accordance with Section 3.3 of the Agreement and as described above under Exhibit “A” Scope of Services and the not to exceed fee of THREE HUNDRED SIXTEEN THOUSAND DOLLARS ($316,000.00) based on the following schedule:

Sq.

Ft. Capacity Per Cleaning Rate -Original Agreement
Per Cleaning Rate -
First Amendment
(Effective 7/1/2025)
Community Center
1 Banquet Room 2,600 120 $182.00 $188.19
2 Banquet Rooms 5,200 250 $312.00 $322.61
3 Banquet Rooms 7,800 350 $468.00 $483.91
Catering Kitchen 887 5 $88.70 $91.72
Courtyard w/ Fireplace 3,405 150 $272.40 $281.66
Men's/Women's Restroom 1,097 $186.49 $192.83
Clubhouse Senior Center
1 Multipurpose Room 2,000 50 $140.00 $144.76
2 Multipurpose Rooms 4,000 120 $240.00 $248.16
Catering Kitchen 1,102 5 $110.20 $113.95
Patio w/BBQ and Lounge area 1,311 35 $104.88 $108.45
Men's/Women's Restroom 1,000 $170.00 $175.78
Performing Arts Center
Stage 1,510 10 $105.70 $109.29
Theatre seating area 2,569 200 $179.83 $185.94
Lobby Area/Hallway 500 100 $35.00 $36.19
Dressing Room 411 20 $28.77 $29.75
Box Office 123 4 $8.61 $8.90
Mezzanine 450 3 $31.50 $32.57
Men's/Women's Restroom 1,000 $170.00 $175.78
Additional Light Cleaning
(used for multiple day use)
Reduced Rate by 20%
excluding restrooms
Reduced Rate by 20%
excluding restrooms
In the event that this Agreement is renewed pursuant to Section 3.1.2, the rates set forth above may be increased or reduced each year at the time of renewal, but any increase shall not exceed the Consumer Price Index, All Urban Consumers, Los Angeles-Long Beach-Anaheim.

Docusign Envelope ID: 99B576E3-59EE-4188-8C21-4A5DB3885A48

CITY COUNCIL AGENDA REPORT
MEETING DATE: 5/6/2025
DEPARTMENT: Public Works
SUBJECT:

APPROVAL OF AN AGREEMENT WITH SOUTHERN CALIFORNIA EDISON FOR THE SCHEDULE LS-1, OPTION E LIGHT EMITTING DIODE FIXTURE

REPLACEMENT PROGRAM
RECOMMENDED ACTION(S):

1. Approve the Agreement entitled Schedule LS-1 Option E, Energy Efficiency-Light Emitting Diode (“LED”) Fixture Replacement Rate Agreement Form 14-965 with Southern California Edison.

2. Authorize the City Manager to sign the proposed agreement with Southern California Edison.

EXECUTIVE SUMMARY:

The City of Lake Forest has more than 4,000 streetlights in the City and the majority are owned and maintained by Southern California Edison (“SCE”). SCE currently offers a Light Emitting Diode (“LED”) conversion program that would upgrade the majority of the utility-owned streetlights in the City to LED through Schedule LS-1 Option E (“Option E”), Energy Efficient- Light Emitting Diode (LED) Fixture Replacement Rate Agreement (“Agreement”).

Staff recommends the City Council approve the Agreement with SCE to effectuate the LED Fixture replacement program (Attachment 1). Option E would replace the City’s 4,153 High Pressure Sodium Vapor (“HPSV”) streetlights with new, more efficient LED streetlights. The program allows SCE to undertake streetlight replacements with local government concurrence and authorization after which SCE manages the implementation from start to finish. Through the agreement, SCE does not require any up-front investment from the local government, Instead, capital costs are amortized through energy cost saving over a 20-year period with zero interest. During this 20-year period, SCE estimates $204,630 in annual cost savings for the City (Attachment 2). If approved, SCE contractors would begin the project and complete it before the end of the 2025 calendar year.

BACKGROUND:

The majority of the utility-owned streetlights in Lake Forest utilize traditional High Pressure Sodium Vapor (“HPSV”) fixtures. HPSV fixtures are outdated, inefficient, and subject to supply constraints that make their continued use infeasible. Through the LS-1, Option E program, SCE offers to replace HPSV “cobra head” streetlight fixtures with new, more efficient LED light fixtures. Option E allows SCE to undertake the streetlight replacements with local government concurrence and authorization. This would be effectuated through the approval of an Agreement entitled Schedule LS-1 Option E, Energy Efficiency-LED Fixture Replacement Rate Agreement Form 14-965 with Southern California Edison (“Agreement”) (Attachment 1).

DISCUSSION:

The LS-1, Option E program includes a recovery mechanism which recovers the cost of the initial materials installation and materials over 20 years, as approved by the California Public Utilities Commission (“CPUC”). Through the proposed Agreement, SCE does not require any up-front investment from the City. Instead capital costs are amortized through energy cost savings over a 20-year period with zero interest. Savings resulting from the conversion to new, more efficient LED light fixtures would result in cost savings. These savings would then be applied to the City’s costs for streetlights as soon as the replacement efforts are completed. These initial savings are expected to grow following the initial 20 years of the Agreement during which a portion of the savings is used to recover the costs of the upgrade project.

Over the initial 20-year period, SCE estimates that the City would save approximately $204,630 annually for a total savings of $4,092,600 over 20 years (Attachment 2). After the initial 20-year period, SCE estimates annual savings to increase to $281,854. Actual savings are subject to several factors including future electrical rate changes and monthly lease fees for the light poles.

The proposed project would only replace standard non-decorative HPSV fixtures referred to as “cobra head” style lights. LED fixtures are not yet available for the City’s decorative “mission bell” style fixtures located in the Foothill Ranch community. SCE has indicated that LED compatible fixtures in that style would be installed upon availability independent of the LS-1, Option E program.

Staff recommends the City Council approve the Agreement with SCE to effectuate the LED Fixture replacement program (Attachment 1). Should the City Council approve the proposed Agreement, staff would finalize conversion project specifications with SCE, including a determination of the LED color temperature.

LED color temperature, measured in Kelvin (K), defines the appearance of light.

A 3,000K lamp emits a warm, yellowish tone suitable for residential environments and most closely matches the tone of the existing HPSV fixtures. A 4,000K LED produces a cooler, neutral white light, and is currently utilized in the City’s traffic signal safety lights to provide sharper light contrast in signalized roadway intersections. SCE staff recommends an LED color temperature of 3,000K for this conversion project and has indicated the vast majority of SCE’s LS-1, Option E customers opt for that color temperature. If 3,000 K lights are installed staff does not expect any need for glare protection, however any glare shields on existing lights would be reinstalled on the replacement fixture.

If approved, the installation project is anticipated to start September or October 2025 and would be completed by the end of the 2025 calendar year. The final project schedule would be determined based on the availability of the contractor.

The proposed Agreement has been approved as to form by the City Attorney.

Staff recommends the City Council approve the Agreement with SCE to ensure that the City can enroll in the Option E before the program sunsets and to benefit from the lower rates. Should the City decline to participate in the LS-1, Option E program, the City’s lights would eventually be converted to LED on an individual basis when the HPSV bulbs burn out as part of SCE’s regular streetlight maintenance activities compared to a systemwide update of all lights under LS-1, Option E.

FISCAL IMPACT:

If approved, the Agreement would commit the City to a repayment of $1,544,479.20 over 20 years. Costs would be paid through a portion of the energy cost savings resulting from the conversion to LED light fixtures.

ATTACHMENT

1. Schedule LS-1 Option E, Energy Efficiency-Light Emitting Diode (LED) Fixture Replacement Rate Agreement Form 14-965

2. Streetlight Inventory and Savings
Initiated By: Jonathan Poole, Senior Management Analyst Submitted By: Thomas Wheeler, P.E., Director of Public Works/City Engineer Approved By: Debra Rose, City Manager
ATTACHMENT 1
Southern California Edison Original Cal. PUC Sheet No. 57074-E Rosemead, California (U 338-E) Cancelling Cal. PUC Sheet No.

Sheet 1
SCHEDULE LS-1 OPTION E,

ENERGY EFFICIENCY-LIGHT EMITTING DIODE (LED) FIXTURE REPLACEMENT

RATE AGREEMENT
Form 14-965
(To be inserted by utility) Issued by (To be inserted by Cal. PUC) Advice 3241-E R.O. Nichols Date Filed Jun 30, 2015
Decision 14-10-046 Senior Vice President Effective Jun 1, 2016 1P8 Resolution

SOUTHERN CALIFORNIA EDISON COMPANY
SCHEDULE LS-1 OPTION E, ENERGY EFFICIENCY-LIGHT EMITTING DIODE (LED)

FIXTURE REPLACEMENT RATE AGREEMENT
Form 14-965
06/2016
1 This Schedule LS-1 Option E, Energy Efficiency-Light Emitting Diode (LED) Fixture Replacement Rate Agreement (Agreement), effective this day of _,
_(Effective Date), is entered into between Southern California Edison Company (SCE) and ________, an SCE customer taking service on Schedule LS-1 (Applicant), referred to collectively as "Parties," and individually as "Party." This Agreement provides for SCE, at Applicant’s request, to replace the existing street lighting fixtures serving Applicant’s premises with Light Emitting Diode (LED) street lighting fixtures to achieve energy efficiency benefits for Applicant, as set forth in Special Condition 14, Option E, Energy Efficiency-Light Emitting Diode (LED) Fixture Replacement, of Schedule LS-1.

The Parties agree as follows:

1. LED FIXTURES
SCE shall install, own, operate, and maintain LED Fixtures for Applicant as set forth in Exhibit "A" attached hereto and incorporated herein by this reference. The LED Fixtures provided hereunder shall at all times remain the property of SCE.

2. LED FIXTURE REPLACEMENT COSTS

2.1 The replacement costs of the LED Fixtures provided hereunder shall be borne by Applicant.

2.2 Applicant shall pay the charge for the LED Fixtures Replacement rate, which includes an Energy Efficiency Premium Charge (EEPC) and a Base LED Charge, under Option E of Schedule LS-1. Applicant elects Option E in lieu of an upfront, one-time payment of the replacement costs.

2.3 SCE does not guarantee that any energy or bill savings will accrue to Applicant as a result of the LED Fixture replacements.

3. COMMENCEMENT OF SERVICE
The Parties agree that SCE has the right to charge Applicant, and Applicant has an obligation to pay SCE, for the charges set forth in Schedule LS-1, Option E, commencing on the date SCE begins serving the LED Fixtures installed pursuant to this Agreement.

4. TERM AND TERMINATION

4.1 This Agreement shall be effective as of the Effective Date and shall continue for a term of twenty (20) years from the commencement of service as specified in Section 3 above (Term).

4.2 Applicant may terminate this Agreement at any time during the Term upon a thirty (30) - day advance written notice, provided that Applicant, prior to or within the 30-day advance notice period, assigns the Agreement to any New Party In (NPI) that owns, rents or leases the premises served by the street lighting fixtures replaced under this Agreement and will take service under Option E of Schedule LS-1 effective as of the date of termination; otherwise, Applicant shall pay a one-time termination charge equal to the present value of the balance of the EEPC of Option E over the remaining Term. The present value is determined based on SCE’s authorized rate of return on rate base, or discounted rate of

7.90%.

SOUTHERN CALIFORNIA EDISON COMPANY
SCHEDULE LS-1 OPTION E, ENERGY EFFICIENCY-LIGHT EMITTING DIODE (LED)

FIXTURE REPLACEMENT RATE AGREEMENT
Form 14-965
06/2016
2 5. AMENDMENTS; ASSIGNMENTS

5.1 Any changes or amendments to this Agreement must be in writing and must be executed by the Applicant and SCE and, if required, be approved by the California Public Utilities Commission (Commission).

5.2 Applicant shall not assign this Agreement without the prior written consent of SCE; provided, however, that Applicant may assign the Agreement pursuant to the terms and conditions of Section 4.2 above, and the NPI must assume all rights and obligations under this Agreement for the remaining Term. Any assignment and assumption shall be in a form acceptable to SCE.

6. NOTICE
Any notice either Applicant or SCE may wish to provide the other regarding this Agreement must be in writing. Such notice must be either hand-delivered or sent by U.S. certified or registered mail, postage prepaid, to the person designated to receive notice for the other Party below, or to such other address as either may designate by written notice. Notices delivered by hand shall be deemed effective when delivered. Notices delivered by mail shall be deemed effective when received, as acknowledged by the receipt of the certified or registered mailing.

Applicant: SCE:

(Name)

Business Customer Division
(Title) Southern California Edison Company
2244 Walnut Grove Avenue
(Address) Rosemead, CA 91770

(City, State, Zip)

7. NONWAIVER
The failure of either Party to enforce any of the terms and conditions or to exercise any right or privilege in this Agreement shall not be construed as a waiver of any such term and conditions or rights or privileges, and the same shall continue and remain enforce and effect as if no such failure to enforce or exercise had occurred.

8. SEVERABILITY
In the event that any of the provisions, or portions thereof, of this Agreement are held to be unenforceable or invalid by the Commission, or any court of competent jurisdiction, the validity and enforceability of the remaining provisions or any portion thereof shall not be affected.

9. APPLICABLE LAWS, RULES, AND REGULATIONS
This Agreement shall be subject to, and interpreted under the laws, rules, decisions and regulations of the State of California, without regard to its conflict of laws principles, the Commission, and SCE's Commission-approved tariffs.

SOUTHERN CALIFORNIA EDISON COMPANY
SCHEDULE LS-1 OPTION E, ENERGY EFFICIENCY-LIGHT EMITTING DIODE (LED)

FIXTURE REPLACEMENT RATE AGREEMENT
Form 14-965
06/2016
3 10. CALIFORNIA PUBLIC UTILITIES COMMISSION JURISDICTION

10.1 This is a filed form tariff agreement authorized by the Commission for use by SCE. No officer, inspector, solicitor, agent or employee of SCE has any authority to waive, alter, or amend any part of this Agreement except as provided herein or authorized by the Commission. This Agreement is to be used in conjunction with Schedule LS-1 and supplements the terms and conditions of the Applicant's electric service under Schedule LS-1.

10.2 This Agreement shall at all times be subject to such changes or modifications by the Commission as said Commission may, from time to time, direct in the exercise of its jurisdiction.

10.3 Notwithstanding any other provisions of this Agreement, SCE has the right to unilaterally file with the Commission, pursuant to the Commission's rules and regulations, an application for change in rates, charges, classification, service, or rule or any agreement relating thereto.

11. ENTIRE AGREEMENT
This Agreement, including SCE’s Commission-approved tariffs, constitutes the complete agreement and understanding between the Applicant and SCE regarding the LED Fixtures replacement costs.

Prior agreements, representations, understandings, whether expressed or implied, and communications, oral or written, between the Applicant and SCE shall not be construed to be a part of this Agreement.

12. AUTHORIZATION SIGNATURE
In witness whereof, the Parties hereto have caused this Agreement to be signed by their duly authorized representatives.

APPLICANT
BY:

NAME:

TITLE:

DATE SIGNED:

SOUTHERN CALIFORNIA EDISON COMPANY
BY:

NAME:

TITLE:

DATE SIGNED:

Form 14-965
06/2016
4 SOUTHERN CALIFORNIA EDISON COMPANY
EXHIBIT “A”
SCHEDULE LS-1 OPTION E,

ENERGY EFFICIENCY-LIGHT EMITTING DIODE (LED) FIXTURE REPLACEMENT

APPLICANT

CUSTOMER ACCOUNT NO.

SERVICE ACCOUNT NO.

(Additional account numbers/addresses may be attached hereto.)

SERVICE ADDRESS

APPLICANT REQUESTED READY TO SERVE DATE
ASAP

SCE READY TO SERVE DATE
DESCRIPTION OF LED FIXTURES/SCOPE OF WORK: SPECIFY HOW MANY STREET LIGHTING

FIXTURE REPLACEMENTS ARE BEING REQUESTED AND AGREED TO UNDER THIS AGREEMENT AND OTHER RELEVANT DETAILS.

W.O. No(s):

CITY OF LAKE FOREST
1000538200
8004327432
ALL CITY OWNED LS-1 STREETLIGHTS
ATTACHMENT 2
SCE, Confidential Post EEP Template_04.2022.xlsx 10/23/2024

CUSTOMER NAME LAKE FOREST, CITY OF
Customer Number: 1000538200
Estimated Additional Monthly Savings After 20 Years:

CONFIDENTIAL AND/OR PROPRIETARY INFORMATION OF SOUTHERN CALIFORNIA EDISON AND/OR ITS CUSTOMERS OR VENDORS. PUBLIC DISCLOSURE IS RESTRICTED.

Lamp Wattage Lamp Count EEP Per Month*
Estimated Monthly
Savings
50 Watt 11 $1.42 $16
70 Watt 2,509 $1.48 $3,713
100 Watt 877 $1.55 $1,359
150 Watt 436 $1.67 $728
200 Watt 316 $1.93 $610
250 Watt 4 $2.26 $9
400 Watt 0 $2.88 $0
Total 4,153 $6,435
This analysis is provided to help you evaluate your current Southern California Edison (SCE) bill and/or compare your projected bills to other SCE rate options. These results are based on your past usage and/or assumptions about your energy usage and cannot be guaranteed by SCE. This rate analysis may not reflect all of the rate options that are available to you as an SCE customer. Your actual bills will vary from this analysis due to changes to your actual usage and assumptions such as operating hours, the equipment you use, kVAR charges, weather patterns, service voltage, firm service levels, taxes, and added facilities charges. Moreover, the rate options used in this analysis are subject to change by the California Public Utilities Commission (CPUC), which would also alter the outcome of this analysis.

If your current rate schedule becomes unavailable — either by action of the CPUC or because you are no longer eligible to be placed on the rate — you will be notified of your rate options. If you do not select a different applicable rate option at that time, you will be placed on a default rate schedule.

CITY COUNCIL AGENDA REPORT
MEETING DATE: 5/6/2025
DEPARTMENT: City Manager
SUBJECT:

CONSIDERATION OF THE FIVE-YEAR CONSOLIDATED PLAN AND ANNUAL

ACTION PLAN FOR THE CITY'S COMMUNITY DEVELOPMENT BLOCK
GRANT
RECOMMENDED ACTION(S):

1. Conduct a public hearing and approve the Fiscal Year 2025-2030 Consolidated Plan and Fiscal Year 2025-26 Action Plan, and Fiscal Year 2025-2030, and Orange County Regional Assessment of Fair Housing.

2. Authorize staff to submit the approved plans to the U.S. Department of Housing and Urban Development.

EXECUTIVE SUMMARY:

The U.S. Department of Housing and Urban Development (“HUD”) administers the Federal Community Development Block Grant (“CDBG”) Program. CDBG is a formula grant allocated to local governments for the purpose of developing viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities principally for persons of low and moderate-income. To receive this annual grant, the City must submit an Action Plan to HUD by May 15 of each year. The Action Plan outlines how the City will use its CDBG funds to address the goals and objectives delineated in the City’s Five-Year Consolidated Plan (“Consolidated Plan”). The Consolidated Plan sets forth goals and objectives that guide the City’s CDBG funding priorities over a five-year period.

The City’s current 2020-2025 Consolidated Plan will expire on June 30, 2025.

Consequently, the City contracted with Willdan Consulting (“Willdan”), an experienced CDBG consulting firm, to prepare the Fiscal Year (“FY”) 2025-2030 Consolidated Plan and Action Plan for FY 2025-26.

On April 15, staff presented a draft FY 2025-2030 Consolidated Plan and a proposed Expenditure Plan for FY 2025-26 for the City Council’s review and comment (Attachment 1). Staff proposed the draft Expenditure Plan to serve as the foundation for the FY 2025-26 Action Plan. The Expenditure Plan, with estimated expenditures of $781,937, included the anticipated CDBG grant for FY 2025-26 ($479,750), funds carried forward from prior years ($108,765), and the Revolving Loan Carryover ($121,422). Due to the delay in approving the federal 2025 budget, the City will increase or decrease proposed CDBG funding for activities by a percentage based on the final CDBG grant.

Jurisdictions that receive federal assistance have been required to complete an Assessment of Fair Housing (“AFH”) once every five years, consistent with the Consolidated Plan cycle. As a recipient of CDBG funds, Lake Forest satisfies this obligation in part by participating in the preparation of and approving an AFH every five years, coinciding with the approval of the City’s Five-Year Consolidated Plan.

The City Council provided comments on the draft plans and requested the formation of a CDBG Ad-Hoc Committee to review the draft expenditure plan in more detail. As a result of these discussions, the Committee recommended reallocating $50,000 from the proposed BOOST Program to support a Capital Improvement Project for the installation of Audible Pedestrian Signals. The City did not receive comments from the public. Staff recommend the City Council approve the proposed final FY 2025-2030 Consolidated Plan, FY 2025-26 Action Plan, and AFH; and authorize staff to submit the plans to HUD (Attachments 2 and 3).

BACKGROUND:

HUD Requirements/Grant Amount
HUD requires the City to develop a Consolidated Plan and update it every five years in order to participate in the CDBG Program and receive annual funding. In addition, HUD requires the City to adopt an Action Plan each year that outlines how CDBG funds will be used to address the goals and objectives outlined in the Consolidated Plan. The City contracted Wildan through a competitive Request for Proposal process to prepare both plans. The City is required to submit the Consolidated Plan and Action Plan to HUD by May 15, 2025.

To date, HUD has not announced 2025 grant allocations; however, for planning purposes, the City anticipates receiving $479,750 in CDBG funds for FY 2025-26 (representing a reduction from the prior year allocation). In recent years, annual CDBG allocations have been reduced due to federal budgetary restrictions. Of this amount, 15% (i.e., approximately $72,000) can be allocated for public services (i.e., nonprofit organizations that provide a range of services in the community and whose goals align with those identified in the City’s Five-Year Consolidated Plan). Staff published a Notice of Funding Availability (“NOFA”) for the FY 2025-26 program year in the Saddleback Valley News on December 5, 2024, inviting interested parties to submit applications for funding. In addition, staff mailed application packets to all current public service grant sub-recipients inviting applications for FY 2025-26.

Draft Consolidated Plan/Expenditure Plan
On April 15, 2025, staff presented a draft Consolidated Plan and proposed FY 2025-26 CDBG Expenditure Plan to the City Council. The draft Expenditure Plan outlined funding recommendations for FY 2025-26 and was proposed to serve as the foundation for the annual Action Plan (i.e., the first year of the five-year Consolidated Plan). Staff is attaching the staff report for the April 15, 2025, agenda item (Attachment 1) as additional information for the City Council. With regard to the Consolidated Plan, the staff report presented on April 15 outlined the statutory requirements of the plan, the various forms of community outreach undertaken to develop it, and set forth broadly defined goals for the five-year period.

The City Council expressed no comments or requested changes regarding the proposed goals or the overall strategy for the Community Development Block Grant (“CDBG”) program. However, the Council did request the formation of a CDBG Ad-Hoc Committee to review the draft expenditure plan in more detail.

The Ad-Hoc Committee held preliminary discussions on Monday, April 21, and reconvened on Tuesday, April 29, to finalize its recommendations. As a result of these discussions, the Committee recommended reallocating $50,000 from the proposed BOOST Program to support a Capital Improvement Project for the installation of Audible Pedestrian Signals.

Assessment of Fair Housing
For the 2025-2029 program years, Lake Forest agreed to participate in preparation of a regional AFH, and to fund its fair share cost (based on population) of the preparation of the regional AFH, as a joint effort with other Orange County cities and the County of Orange (which administers CDBG funding for additional OC cities).

The City of Santa Ana agreed to serve as the lead agency coordinating the effort, including issuance of a request for proposals ("RFP") and administration of the approved consultant contract. Following the issuance of an RFP and completion of a procurement process with the involvement of multiple cities, the Santa Ana City Council selected MDG Associates, Inc. (“MDG”) as the consultant and authorized execution of an agreement between Santa Ana and MDG.

DISCUSSION:

Proposed Final Consolidated Plan
Staff is presenting the proposed final Consolidated Plan for City Council review and approval (Attachment 2). Staff and Willdan initiated a limited number of changes primarily to reflect updated information used to support the findings and recommended goals. For the most part, the changes involve using “local” data sources, when available, versus the regional data cited in the draft plan and adding clarifying language in certain sections. Staff did not make changes to the proposed goals or strategic plan.

Staff believe the proposed final version reflects the community’s needs and priorities and complies with HUD mandates. The proposed goals are generally consistent with the current Consolidated Plan in that they maintain priority on investing in infrastructure, rehabilitating the City’s existing housing, and providing public services to meet the needs of the City’s low and moderate-income residents.

In addition, the proposed goals take into account the federally mandated services the City must provide in order to continue receiving CDBG funding. As with the current plan, staff’s recommended goals and range of potential programs and projects are broad enough to provide the City flexibility to address community needs over the five-year planning period. In addition, should unforeseen priorities arise, the City can amend the Consolidated Plan to identify new goals that reflect heightened priorities.

FY 2025-26 Action Plan
The Consolidated Plan process also includes the preparation of the first-year Action Plan, which is the annual plan the City prepares pursuant to the goals outlined in the Consolidated Plan. The Action Plan details expenditure allocations and the activities the City will undertake during FY 2025-26. The proposed FY 2025-26 Action Plan is found in Section 6 of the Consolidated Plan (starting on page 112 of Attachment 2).

To date, HUD has not announced 2025 grant allocations; however, for planning purposes, the City anticipates receiving $479,750 in CDBG funds for FY 2025-26 (representing a reduction from the prior year allocation). HUD regulations stipulate that up to 15% of the City’s annual grant may be used for public service programs that provide resources to underserved communities. Based on the awarded grant, approximately $72,000 may be spent on public services (i.e., nonprofit organizations that provide a range of services in the community and whose goals align with those identified in the City’s Consolidated Plan). In addition, 20% of the annual award amount may be used for administrative costs.

Staff’s recommended funding allocations for public service organizations are the same as proposed in the draft Expenditure Plan reviewed by the City Council on April 15, 2025.

Table 1 below summarizes the available funds and proposed expenditures.

Table 1: Draft FY 2025-26 CDBG AAP Funds / Expenditures Available Funds
Anticipated FY 2025-26 CDBG $479,705
Prior Year Carryover $180,765
2024 Revolving Loan $121,422
Total: $781,937
Proposed Allocations
Category % Allocation
Housing Improvements 43 $334,025
Capital Improvement Projects 36 $280,000
Program Administration 12 $95,950
Public Services 9 $71,962
Total: 100 $781,937
Summary
An updated Consolidated Plan and annual Action Plan are required to continue the City’s participation in the CDBG. The attached proposed Consolidated Plan and Action Plan endeavor to balance HUD’s requirement for mandatory elements and the City’s desire to maintain flexibility to address local needs and issues.

The documents are substantially consistent with those reviewed by the City Council on April 15, 2025.

Staff advertised a mandatory 30-day public comment period which ran from March 20, 2025 to April 24, 2025. The City did not receive any comments.

Orange County Assessment of Fair Housing
As discussed in the Executive Summary, all jurisdictions that receive federal assistance have been required to submit an AFH as part of its Consolidated Plan cycle every five years. As a recipient of CDBG funds, Lake Forest satisfies this obligation in part by participating in the preparation of and approving an AFH every five years, coinciding with the approval of the City’s Five-Year Consolidated Plan.

The AFH provides communities an opportunity to assess progress toward the goals of eliminating housing discrimination and promoting access to housing opportunity. A total of six public workshops, including four in person and two virtual, were held to inform Orange County residents about the planned preparation of the AFH, share its goals and objectives, and solicit comments. The proposed AFH is attached for City Council consideration (Attachment 3).

Conclusion
HUD requires the City to adopt the Consolidated Plan and Action Plan at a noticed public hearing. The City published a notice in the Saddleback Valley News on December 5, 2024 stating its intention to present the Consolidated Plan and Action Plan for consideration by the City Council at a meeting on May 6, 2025. Staff recommends the City Council conduct a public hearing. Subject to consideration of any public comments, staff recommends the City Council approve the proposed final Consolidated Plan, Action Plan, and AFH, and authorize staff to submit the plans to HUD.

FISCAL IMPACT:

There is no fiscal impact associated with the recommended action of conducting the public hearing and directing staff to submit the CDBG FY 2025-2030 Consolidated Plan and FY 2025-26 Annual Action Plan to HUD.

ATTACHMENTS:

1. April 15, 2025 Agenda Report

2. Consolidated Plan/Action Plan

3. Orange County Assessment of Fair Housing
Initiated By: Adrian Grijalva, Economic Development/Housing Manager Submitted By: Keith Neves, Assistant City Manager
Approved By: Debra Rose, City Manager
ATTACHMENT 1

CITY COUNCIL AGENDA REPORT
MEETING DATE: 4/15/2025
DEPARTMENT: City Manager
SUBJECT:

DRAFT FISCAL YEAR 2025-2030 CDBG FIVE-YEAR CONSOLIDATED PLAN AND DRAFT FISCAL YEAR 2025-26 EXPENDITURE PLAN
RECOMMENDED ACTION(S):

Review and comment on the draft Fiscal Year 2025-2030 CDBG Five-Year Consolidated Plan and draft Fiscal Year 2025-26 Expenditure Plan.

EXECUTIVE SUMMARY:

The Federal Community Development Block Grant (“CDBG”) Program is administered by the U.S. Department of Housing and Urban Development (“HUD”). CDBG is a formula grant allocated to local governments to develop viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities, principally for persons of low- and moderate-income. To receive this annual grant, the City of Lake Forest (“City”) is required to submit an Annual Action Plan to HUD by May 15 of each year. The Annual Action Plan outlines how CDBG funds will be utilized to address the goals and objectives established in the City’s Five-Year Consolidated Plan (“Consolidated Plan”).

The City’s current 2020-2025 Consolidated Plan will expire on June 30, 2025.

Consequently, the City contracted with Willdan Consulting (“Willdan”), an experienced CDBG consulting firm, to prepare the Fiscal Year (“FY”) 2025-2030 Consolidated Plan. Staff is providing the draft FY 2025-2030 Consolidated Plan (Attachment 1) and the draft FY 2025-26 Expenditure Plan (Attachment 2) for the City’s Council’s review. The draft Expenditure Plan serves as the basis for preparing the FY 2025-26 Annual Action Plan.

The draft Expenditure Plan, with estimated expenditures of $781,937, includes the anticipated CDBG grant for FY 2025-26 ($479,750), funds carried forward from prior years ($180,765), and Revolving Loan Income from 2024 ($121,422).

Staff recommend the City Council provide comment on the draft FY 2025-26 Expenditure Plan and draft FY 2025-2030 Consolidated Plan. Staff will bring the final Action Plan and Consolidated Plan, along with any public comments received, to the City Council for a final review at the May 6, 2025, City Council meeting.

BACKGROUND:

HUD regulations require the City to develop a Consolidated Plan and update the Plan every five years in order to participate in the CDBG Program and receive annual funding. The City contracted with Willdan to prepare the draft FY 2025- 2030 Consolidated Plan and subsequent Annual Action Plan for FY 2025-26. The City selected Willdan through a competitive request for proposal process consistent with the City’s Purchasing and Contracting Guidelines. The firm was selected given its vast technical expertise in preparing Consolidated Plans and Annual Action Plans, and providing CDBG consulting services for various cities throughout California.

In addition, in order to receive funding, HUD requires the City to submit an Action Plan on an annual basis. Willdan is preparing the required FY 2025-26 Draft Action Plan, pursuant to the goals outlined in the Consolidated Plan and based on the draft Expenditure Plan included with this report. The draft Expenditure Plan details proposed funding allocations and activities the City would undertake to address the housing and community development needs and local objectives using the annual CDBG grant, any funds carried forward from prior years, and other housing funds (i.e., loan repayments) anticipated during FY 2025-26 program year.

To date, HUD has not announced 2025 grant allocations; however, for planning purposes, the City anticipates receiving $479,750 in CDBG funds for FY 2025-26 (represents a 5% reduction from the prior year allocation). In recent years, annual CDBG allocations have been reduced due to federal budgetary restrictions. Of this amount, 15% (i.e., approximately $72,000) may be allocated for public services (i.e., nonprofit organizations that provide a range of services in the community and whose goals align with those identified in the City’s Consolidated Plan). In addition, 20% of the annual award amount may be used for administrative costs. The balance is typically utilized for other CDBG-eligible projects, such as the Americans with Disabilities Act (“ADA”) Access Ramp Projects, Audible Pedestrian Signal Projects, Housing Rehabilitation Loans, and Paint Grant Programs. Staff published a Notice of Funding Availability (“NOFA”) for the FY 2025-26 program year in the Saddleback Valley News on December 5, 2024. In addition, staff emailed notices to all current public service grant subrecipient organizations inviting applications for FY 2025-26.

DISCUSSION:

FY 2025-2030 Consolidated Plan
A. Statutory Requirements and Required Plan Components
Preparation of a Five-Year Consolidated Plan is a statutory requirement of the City’s CDBG program. Willdan and staff collaborated to prepare the draft FY 2025-2030 Consolidated Plan. The Plan identifies the City’s overall housing and community development needs and outlines specific goals and objectives that will guide the City’s CDBG funding priorities over a five-year period. In preparing the Consolidated Plan, Willdan evaluated demographic, economic, and housing data. Willdan also reviewed information on affordable housing trends and special needs populations (i.e., homeless and non-homeless). In addition, Willdan consulted with public and private agencies and engaged in citizen participation via an electronic survey.

The housing and demographic data incorporated in the Consolidated Plan were largely obtained from the Comprehensive Housing Affordability Strategy (“CHAS”) developed by the Census Bureau for HUD based on the 2016-2020 American Community Survey (“ACS”). The CHAS and ACS are federallymandated data sources provided by HUD to local jurisdictions submitting required HUD reports (e.g., Consolidated Plans and Action Plans). In addition to the required data sources, staff and Willdan are reviewing the City’s current 2021-2029 Housing Element and will ensure the final version of the Consolidated Plan is consistent with the document.

Overall, the Consolidated Plan includes housing and community development goals and objectives, proposes the continuation of existing programs (e.g., Housing Rehabilitation Loan and Paint Grant Programs) and identifies potential programs and projects that may be undertaken in the five-year planning period (2025-2030). All CDBG expenditures must be consistent with the Consolidated Plan.

FY 2025-26 Action Plan

1. Annual Grant Amount
The Consolidated Plan process also includes the preparation of the first-year Action Plan, which is the annual plan the City prepares pursuant to the goals outlined in the Consolidated Plan. The Action Plan details expenditure allocations and the activities the City will undertake during FY 2025-26.

To date, HUD has not announced 2025 grant allocations; however, for planning purposes, the City anticipates receiving $479,750 in CDBG funds for FY 2025- 2026 (represents a 5% reduction from the prior year allocation). In recent years, annual CDBG allocations have been reduced due to federal budgetary restrictions.

2. Public Service Programs
HUD regulations stipulate that up to 15% of the City’s annual grant may be used for public service programs that provide resources to underserved communities.

Based on the anticipated grant award amount, approximately $71,962 may be spent on public services. As with previous years, the collective amount requested by the applicants exceeds the 15% cap for public service grants.

Staff reviewed all applications with the assistance of Willdan, the City’s CDBG consultant. All applications were reviewed for completeness and evaluated in relation to the goals and objectives listed in the current Consolidated Plan as well as the draft 2025-2030 Consolidated Plan. In formulating draft funding recommendations, staff took into consideration the priorities identified in the “Needs Survey,” consultations with service providers, and the HUD-mandated services.

Staff received a total of six applications from public service organizations which qualify under the public service programs category. After a thorough review and analysis, staff’s draft recommendations for public service grant allocations are provided in Table 1 below.

Table 1: Draft FY 2025-26 CDBG Public Service Grant Recommendations Public Service
Grant Applicant
FY 2024-25
Grant Amount
Requested
Amount
Recommended
Amount
Percent of
Requested
Amount
Age Well Senior
Services, Inc. $7,200 $7,260 $5,000 69%
Boys and Girls
Club N/A $25,000 $12,000 48%
Camino Health
Center $14,100 $15,000 $10,000 67%
Families Forward $18,970 $30,000 $15,962 53%
Family
Assistance
Ministries
$12,300 $20,000 $10,000 50%
South County
Outreach $20,350 $25,000 $19,000 76%
Totals $72,920 $122,260 $71,962 54%
Collectively, public service programs recommended for funding include: food distribution, health care services, before and after-school childcare, and senior services. Given the value of the proposed services to the Lake Forest community, staff recommend funding public service programs at the maximum amount allowed (15% of the grant amount). Funding public services at the maximum rate is consistent with past practice and is a significant factor in advancing the goals outlined in the Consolidated Plan. Due to the delay in approving the federal 2025 budget, the City will increase or decrease proposed funding for activities by a percentage based on the final 2025 CDBG grant.

3. Remaining Grant Allocations and Draft Expenditure Plan HUD also allows the City to allocate a maximum of 20% of the grant for program administration (e.g., salaries, consultant assistance, etc.). The City received an application from the Fair Housing Council of Orange County, a past awardee of CDBG funds. It provides Fair housing services, which are mandatory under HUD regulations and it has historically provided services consistent with the City’s and HUD’s expectations. Fair housing services fall within the Program Administration category. Staff propose that $95,950 be allocated for CDBG program administration ($7,500 for Fair Housing Council of OC and the remainder $88,450 for CDBG Administration). The remaining balance of $311,837 (i.e., grant amount of $479,750 less $71,962 for public services and $95,950 for program administration), may be spent on other CDBG eligible projects such as housing rehabilitation and preservation activities, and public facilities and infrastructure improvements in CDBG-eligible areas. All activities must comply with the City’s Consolidated Plan.

The proposed Expenditure Plan would serve as the basis for preparing the draft Action Plan. If approved by the City Council, the Expenditure Plan would be incorporated into the draft Action Plan and would be presented to the City Council on May 6, 2025, for final adoption and approval. Table 2 below provides an overview of the proposed FY 2025-26 CDBG Expenditure Plan.

Table 2: Overview of FY 2025-26 Draft CDBG Expenditure Plan Estimated Funds Available Estimates
Anticipated FY 2025-26 Grant Amount $479,750
Prior Year Carryover $180,765
2024 Revolving Loan $121,422
Total: $781,937
Category FY 2025-26 Proposed
Allocations
Economic Development
• Boost Program
$50,00
Public Services (Capped at 15%)
• 7 Organizations
$71,962
CDBG Administration (Capped at 20%) $95,950
• Fair Housing Council of OC
• CDBG Administration
($7,500)
($88,450)
Capital Expenditures
• ADA Phase 15
$230,000
Housing & Neighborhood Improvement
• Housing Rehabilitation Loans
• Paint Grants
$334,025
($209,025)
($125,000)
Total: $781,937
HUD allows for CDBG funds to be spent on Economic Development related activities. CDBG-funded economic opportunities provide long-term financial benefits to communities, people’s livelihoods, and personal wealth. The City received an application from Upwards Care Inc. (“Upwards”) to provide services to 13 in-home childcare providers within Lake Forest. CDBG funds would be used to cover part of the salaries and benefits for key staff members, as well as healthcare and payroll taxes. Upwards has secured CDBG funding from cities and counties including but not limited to Cathedral City, Chula Vista, Escondido, Garden Grove, Palo Alto, San Jose, and Tustin, to name a few. Staff is recommending an allocation of $50,000 for this project.

The Expenditure Plan also includes capital projects. These projects serve to preserve and/or enhance public improvements or infrastructure in the community.

CDBG funded improvements must primarily benefit low and moderate-income residents and are typically limited to specific Census Tracts. Exceptions to the focused use of CDBG funding are activities that comply with the American with Disabilities Act (“ADA”). Since FY 2004-2005, the City has utilized a portion of its annual grant to upgrade sidewalk ramps to comply with ADA regulations. The Public Works Department would like to continue the City’s comprehensive program to facilitate access by replacing old ramps with new ones that comply with Federal standards. Staff is recommending an allocation of $230,000 for Phase 15 of the citywide ADA Access Ramp Improvement Project.

Staff also recommend continuing the City’s two housing rehabilitation programs in FY 2025-26: the Housing Rehabilitation Loan Program and the Neighborhood Paint Program. The City Council approved updates to the Policy and Procedures Manual in February 2025, which included increased loan and grant amounts.

Staff is recommending a total allocation of $125,000 for paint grants and $209,025 for loans. These costs are for the loan/grant plus the cost of related administration expenditures.

Summary/Recommendations:

As noted in this report, an updated Five-Year Consolidated Plan and Annual Action Plan are required to be submitted to HUD by the statutory deadline in order to continue the City’s participation in the CDBG program and receive these federal entitlement funds. The attached draft Consolidated Plan and draft Annual Expenditure Plan endeavors to balance HUD’s requirement for mandatory elements and the City’s desire to maintain flexibility to address local needs and issues. At this point in the process, staff is seeking input and comments from the City Council that would be incorporated into the documents. Public comments, if any, will be presented for the City Council’s consideration at the time the final Plans are presented for City Council approval on May 6, 2025.

FISCAL IMPACT:

There is minimal fiscal impact related to the recommended action. Funding for the CDBG Program is provided annually by HUD. The FY 2025-26 CDBG Grant for Lake Forest is unknown at this time. Allocation of the City’s CDBG grant for programs and projects is approved by the City Council as part of the budget adoption process.

ATTACHMENTS:

1. Draft FY 2025-2030 Consolidated Plan

2. Draft FY 2025 Expenditure Plan
Initiated By: Adrian Grijalva, Economic Development/Housing Manager Submitted By: Keith Neves, Assistant City Manager
Approved By: Debra Rose, City Manager
ATTACHMENT 2

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Contents
Executive Summary.......................................................................................................................................1 ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b).........................................................................1 The Process...................................................................................................................................................7 PR-05 Lead & Responsible Agencies 24 CFR 91.200(b).............................................................................7 PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and 91.315(I)..............................8 PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c) .................................................15 Needs Assessment......................................................................................................................................18 NA-05 Overview......................................................................................................................................18 NA-10 Housing Needs Assessment - 24 CFR 91.205 (a,b,c)....................................................................19 NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2)........................................28 NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205 (b)(2)............................31 NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2)..................................34 NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2) .....................................................36 ................................................................................................................................................................77 NA-35 Public Housing – 91.205(b) ..........................................................................................................37 NA-40 Homeless Needs Assessment – 91.205(c)....................................................................................41 NA-45 Non-Homeless Special Needs Assessment - 91.205 (b,d)............................................................46 NA-50 Non-Housing Community Development Needs – 91.215 (f) .......................................................49 Housing Market Analysis.............................................................................................................................51 MA-05 Overview .....................................................................................................................................51 MA-10 Number of Housing Units – 91.210(a)&(b)(2).............................................................................52 MA-15 Housing Market Analysis: Cost of Housing - 91.210(a)...............................................................55 MA-20 Housing Market Analysis: Condition of Housing – 91.210(a)......................................................58 MA-25 Public and Assisted Housing – 91.210(b) ....................................................................................61 Consolidated Plan LAKE FOREST TOC- 2
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MA-30 Homeless Facilities and Services – 91.210(c)..............................................................................63 MA-35 Special Needs Facilities and Services – 91.210(d).......................................................................65 MA-40 Barriers to Affordable Housing – 91.210(e)................................................................................68 MA-45 Non-Housing Community Development Assets – 91.215 (f) ......................................................69 MA-50 Needs and Market Analysis Discussion.......................................................................................75 MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income Households -

91.210(a)(4), 91.310(a)(2).......................................................................................................................80 MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3)...........................................................................84 Strategic Plan ..............................................................................................................................................85 SP-05 Overview.......................................................................................................................................85 SP-10 Geographic Priorities – 91.215 (a)(1)............................................................................................86 SP-25 Priority Needs - 91.215(a)(2).........................................................................................................88 SP-30 Influence of Market Conditions – 91.215 (b)................................................................................91 SP-50 Public Housing Accessibility and Involvement – 91.215(c).........................................................101 SP-55 Barriers to affordable housing – 91.215(h).................................................................................102 SP-60 Homelessness Strategy – 91.215(d)............................................................................................104 SP-65 Lead based paint Hazards – 91.215(i).........................................................................................106 SP-70 Anti-Poverty Strategy – 91.215(j) ...............................................................................................107 SP-80 Monitoring – 91.230 ...................................................................................................................108 Expected Resources..................................................................................................................................109 AP-15 Expected Resources – 91.220(c)(1,2) .........................................................................................109 Annual Goals and Objectives....................................................................................................................112 Projects .................................................................................................................................................115 AP-35 Projects – 91.220(d) ...................................................................................................................115 AP-38 Project Summary ........................................................................................................................116 AP-50 Geographic Distribution – 91.220(f)...........................................................................................123 Consolidated Plan LAKE FOREST TOC- 3
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Affordable Housing ...................................................................................................................................124 AP-55 Affordable Housing – 91.220(g) .................................................................................................124 AP-60 Public Housing – 91.220(h).........................................................................................................125 AP-65 Homeless and Other Special Needs Activities – 91.220(i)..........................................................126 AP-75 Barriers to affordable housing – 91.220(j) .................................................................................128 AP-85 Other Actions – 91.220(k) ..........................................................................................................129 Program Specific Requirements................................................................................................................131 Figures
1: Low- and Moderate-Income Areas
2: Ethnic Concentrations
3: Transit Access
Appendices
Appendix A: SF-424s
Appendix B: Certifications
Appendix C: Citizen Participation Plan
Appendix D: Citizen Participation / Public Comments
Appendix E: Outreach Materials / Survey Results
Appendix F: Proof of Publications / Public Notices
Appendix G: Analysis of Impediments to Fair Housing Choice (AI) Consolidated Plan LAKE FOREST 1
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Executive Summary
ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b)

1. Introduction
The Consolidated Plan is a five-year planning document required by the U.S. Department of Housing and Urban Development (HUD) to be submitted by all participating jurisdictions that receive HUD formula entitlement grant funds. The City of Lake Forest receives Community Development Block Grant (CDBG) entitlement funds annually. This Plan is designed to help participating jurisdictions analyze their housing, community, and economic development needs, so that they can effectively utilize the grant funds allocated each year by HUD. CDBG was created through the Housing and Community Development Act of 1974 to develop viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities, principally for persons of low- and moderate-income. CDBG regulations require that at least 70 percent of all CDBG funds are used to benefit low- and moderateincome residents who are members of households that earn less than 80 percent of Area Median Income (AMI).

As an entitlement jurisdiction, the City must submit the Five-Year Consolidated Plan, as required by HUD, by the due date of “no less than 45 days prior to the start of the grantee's program year start date”. As Lake Forest's fiscal year begins July 1st, this means the Consolidated Plan and each subsequent Annual Action Plan is due to HUD on or around May 15th each year.

The current planning process covering FY 2025-2030 also includes the development of the FY 2025-2026 Action Plan, which is the City’s annual CDBG expenditure plan. The Action Plan details the activities the City will undertake to address housing and community development needs and local objectives using CDBG funds. The City anticipates receiving $479,750 in CDBG funding for Fiscal Year 2025-2026, and roughly the same amount minus a five percent annual decrease over the next five years. Program income is also generated by the repayment of prior funded housing rehabilitation loans which will also be available to undertake eligible housing activities. It is estimated that approximately $300,000 annually of program income from the City’s revolving loan program will be available to support the Housing Rehabilitation Programs.

2. Summary of the objectives and outcomes identified in the Plan Needs Assessment Overview
The Consolidated Plan contains a Needs Assessment and Market Analysis that provide insight into the different levels of need within the community and the market in which grant-funded programs will be implemented. The Needs Assessment incorporates national data from the American Community Survey (ACS) 5-Year Estimates and Comprehensive Housing Affordability Strategy (CHAS) data, in addition to specific local data. Based on this data and input from citizen participation, the Strategic Plan identifies the Consolidated Plan LAKE FOREST 2
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City’s priority needs, including the rationale for establishing allocation priorities and specific measurable goals to be addressed during the five-year period. Regulations governing the CDBG program require that each activity undertaken with CDBG funds meet one of the following three broad national objectives: 1) Benefit people with low- and moderate-income; 2) Aid in the prevention or elimination of slums and blight; 3) Meet an urgent need (such as earthquake, flood, or hurricane relief). Additionally, activities funded must also meet one of HUD’s eligible use categories.

According to HUD’s Consolidated Plan Final Rule, the overall goal of community planning and development programs is to develop viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities principally for low- and moderate-income persons as follows:
• Decent Housing (DH): includes assisting homeless persons to obtain appropriate housing and assisting persons at risk of becoming homeless; retention of the affordable housing stock; and increasing the availability of permanent housing in standard condition and affordable cost to lowincome and moderate-income families, particularly to members of disadvantaged minorities, without discrimination on the basis of race, color, religion, sex, national origin, familial status, or disability. Decent housing also includes increasing the supply of supportive housing, which combines structural features and services needed to enable persons with special needs, including persons with HIV/AIDS and their families, to live with dignity and independence; and providing housing affordable to low-income persons accessible to job opportunities. • A Suitable Living Environment (SL): includes improving the safety and livability of neighborhoods; increasing access to quality public and private facilities and services; reducing the isolation of income groups within a community or geographical area through the spatial de-concentration of housing opportunities for persons of lower-income and the revitalization of deteriorating or deteriorated neighborhoods; restoring and preserving properties of special historic, architectural, or aesthetic value; and conservation of energy resources. • Expanded Economic Opportunities (EO): includes job creation and retention; establishment, stabilization and expansion of small businesses (including micro-businesses); the provision of public services concerned with employment; the provision of jobs involved in carrying out activities under programs covered by this plan to low-income persons living in areas affected by those programs and activities; availability of mortgage financing for low-income persons at reasonable rates using nondiscriminatory lending practices; access to capital and credit for development activities that promote the long-term economic and social viability of the community; and empowerment and self-sufficiency opportunities for low-income persons to reduce generational poverty in federally assisted and public housing.

Outcomes and Priority Needs Established
In addition to meeting one of the General Objective Categories above, HUD requires that project activities funded with entitlement funds also meet one of the following General Outcome Categories:

Availability/Accessibility (1), Affordability (2), or Sustainability (3). Each activity funded will thus have a Consolidated Plan LAKE FOREST 3
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combination of the Objective and Outcome Category listed in the description (i.e. DH-2 would be Decent Housing that is Affordable), which allows for measuring of accomplishments for each of the Consolidated Plan's five years.

During the development of the FY 2025-2030 Consolidated Plan, the following priorities were established as a High Priority Need, with the required Objective and Outcome Category listed in parenthesis and the programs to be funded/implemented are noted by bullet point:
• Priority 1- Affordable Housing (DH-2) [High Need]: Promote, preserve, and assist in the development of affordable housing for low- and moderate- income residents, special needs groups, those at-risk of homelessness, and disproportionately impacted residents. • Priority 2: Community Facilities and Infrastructure (SL-1) [High Need]: Improve and expand facilities and infrastructure that serve low- and moderate- income neighborhoods and residents. • Priority 3: Public Services (SL-1) [High Need]: Provide and improve access to public services for low- and moderate-income persons and those with special needs, as well as prevent and eliminate homelessness.
• Priority 4: Community Preservation Services (SL-3) [High Need]: Provide for the preservation of low- and moderate-income neighborhoods in the target areas. • Priority 5: Economic Development (EO-1) [Moderate Need]: Provide for the economic development needs of low- and moderate-income persons and neighborhood target areas. • Priority 6- Administration and Planning (SL-1) [High Need]: Provide for administration and planning activities to develop housing and community development strategies and programs needed to carry out actions that address identified needs in the Consolidated Plan in accordance with HUD regulations and provide Fair Housing services for all residents.

3. Evaluation of past performance
The City’s CDBG funded programs undertaken over the last two Consolidated Plan Cycles have aided in solving neighborhood and community problems by providing a funding source for underserved needs.

Specifically, Infrastructure Improvement Projects have given low-and moderate-income residential neighborhoods an improved street infrastructure system through ADA curb cuts and ramps and the installation of Audible Pedestrian Signal Push Button lights; public services have helped the City's elderly, youth, homeless, at-risk, victims of domestic violence, and other special needs groups; residents have benefitted from Fair Housing and Tenant/Landlord Counseling Services; residents have been provided affordable housing through an affordable housing acquisition program; the housing stock has been sustained through rehabilitation of deteriorated housing units/lead-based paint testing and abatement; supportive services have been provided to homeless persons/families and/or those at risk of becoming homeless; and the Senior Center was improved with a special allocation of Covid-19 funding.

All of these projects and experiences therein have helped guide the City in choosing the goals and projects for the new Consolidated Plan Cycle. As such, the City will be continuing the priorities and projects from the last plan, as there is still an unmet need due to the limited amount of grant funds received each year.

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It is anticipated that funding received in the next five years will not be sufficient to complete the entire remaining infrastructure projects needed within the low- and moderate-income areas identified in the City's Capital Improvement Plan (CIP). Moreover, affordable housing, public services, fair housing and administration are still High priority needs in the community and will therefore receive continued funding.

As Economic Development is a Medium level priority that has somewhat more restrictive regulations attached to it, it will be included in the Consolidated Plan, but may not be funded with CDBG funds during this cycle. Instead, the City will seek to fund that activity with leveraged resources and will evaluate funding with CDBG should funds become available.

4. Summary of citizen participation process and consultation process City staff encouraged residents and local and regional organizations to participate in the preparation of the FY 2025-2030 Consolidated Plan. There were several opportunities for City residents and agencies/organizations to offer input into the Consolidated Plan process, as noted below:
• The City posted an online Community Needs Survey to solicit the opinion of residents and business owners regarding the City's most pressing needs. The survey was available in English and Spanish. • On January 9, 2025, the City participated in the Orange County 2025-2029 Analysis of Impediments to Fair Housing Workshop, to gather public input on fair housing issues faced by residents, which are incorporated into the Consolidated Plan. • A draft of the Consolidated Plan was made available for a 30-day public comment period from March 20, 2025 to April 24, 2025.
• The City Council discussed the draft Consolidated and Expenditure Plan at its April 15, 2025 meeting to review funding recommendations and applications received. • The Consolidated Plan is scheduled to be adopted by the City Council on May 6, 2025.

A Community Development Needs Survey was made available online through the City’s website from November 1, 2024, through February 28, 2025. There was a total of 238 participants. The survey was available in English and Spanish and responses were mostly received from zip code 92630 (70 percent); 58 percent of the responses were from seniors over 55, which may slightly skew the results. The priority needs and programs established in order of greatest need were as follows:
• Housing Supply/Improvements: Housing for Seniors (Age 62 and older) received the most responses for critical need at 29%, followed by Homebuyer Assistance and Acquisition (for Affordable Housing) at 26% each, and Housing for Small Families at 21%. • Social and Public Service: Mental Health services received the highest number of critical need responses at 33% followed by Healthcare Services at 30% and Childcare Services/Services for Abused and Neglected Children at 28% each.
• Public Infrastructure: Flood Prevention/Drainage, Street Lighting, Water System Improvements, and Residential Street Improvements received the highest number of critical need responses at 34%, 31%, 29%, and 27% respectively.

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• Homeless Services: Mental and Behavioral Health received the most responses at 37% followed by Permanent Housing at 31%, Substance Abuse Programs at 28%, and Homeless Prevention (One-Time Rent/Utilities Assistance) at 27%.
• Community Facilities: Parks and Recreational Facilities received the most critical need responses at 31% followed by Neighborhood Community Centers at 27%, Health Facilities at 23%, and Youth Centers at 19%.

5. Summary of public comments
A summary of public comments received during the planning process can be found in the Citizen Participation section of this Consolidated Plan, as well as in the appendix.

6. Summary of comments or views not accepted and the reasons for not accepting them All comments and input received by the City in the development of the Five-Year Consolidated Plan and Annual Action Plan were accepted and taken into consideration in the development of the Consolidated Plan and Annual Action Plan. There were no comments not accepted.

7. Summary
The primary objective of the CDBG program is to develop viable urban communities by providing decent housing, a suitable living environment, and economic opportunities, principally for persons of low- and moderate-income. Additionally, each activity to be funded with CDBG funds must meet a national objective.

The FY 2025-2030 Five-Year Consolidated Plan will cover five years beginning in FY 2025-2026 and ending in FY 2029-2030. As required by HUD, the Consolidated Plan is prepared using HUD’s electronic template. The template includes over 50 community profile and housing market data tables prepopulated with data from HUD.

The FY 2025-2026 Annual Action Plan is the first of five annual plans in the FY 2025-2030 Consolidated Plan cycle. The Annual Action Plan is the City’s one-year expenditure plan for CDBG funds. The Action Plan identifies the activities the City will undertake during a twelve-month period with CDBG funds to address community needs that support the broad objectives and goals identified in the Consolidated Plan.

To date, HUD has not announced 2025 grant allocations; however, for planning purposes, the City anticipates receiving $479,750 in CDBG funds for FY 2025-2026 (represents a 5% reduction from the prior year allocation). Program income generated by the repayment of prior funded housing rehabilitation loans and prior year uncommitted funds will also be available to undertake eligible housing activities, which is estimated at $180,764.44 (carryover) and $121,422 (2024 Revolving Loan Income). Based on the City's estimated FY 2025-2026 CDBG allocation, the following activities are proposed:

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Program Name Program Description Proposed CDBG
Funding
Public Facility
Improvements/Housing
Examples: Assisted Pedestrian Signal
Pushbuttons and housing rehabilitation loans
and grants
$311,838
(entitlement)
$180,764.44
(carryover)
$121,422 (2024
Revolving Loan
Income)
Public Services Examples: Food distribution, health care services, senior services, and homeless services $71,962 CDBG Program Administration
Program coordination, management, staffing,
monitoring, and reporting; fair housing
education and enforcement services
$95,950

FY 2025-2026 Budget Allocation
Due to the delay in approving the federal 2025 budget, the City will increase or decrease proposed CDBG funding for activities by a percentage based on the final 2025 CDBG grant. Further details can be found in section AP-15 Projects.

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The Process
PR-05 Lead & Responsible Agencies 24 CFR 91.200(b)

1. Describe agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source.

Agency Role Name Department/Agency
CDBG Administrator LAKE FOREST City Manager's Office
Table 1 – Responsible Agencies
Narrative
As shown in Table 1, the City Manager's Office is primarily responsible for the preparation of the Consolidated Plan, Annual Action Plan, Consolidated Annual Performance Review reports required by HUD, as well as the overall administration of CDBG funds.

Consolidated Plan Public Contact Information
The main point of contact for the CDBG Program is:

Adrian Grijalva
Economic Development/Housing Manager
City Manager’s Office
[email protected]
(949) 282-5213
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PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and 91.315(I)

1. Introduction
The consolidated planning process requires jurisdictions to contact and consult with other public and private agencies when developing the Consolidated Plan. The plan must include a summary of the consultation process, including identification of the agencies that participated in the process. Jurisdictions also are required to summarize their efforts to enhance coordination between public and private agencies.

The City sought the input of residents, city departments, non-profit organizations, program beneficiaries and service providers required to create strategic development plans for the city's needs for the 2025- 2030 Consolidated Plan period. A list of these agencies can be found in Table 2.

Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(I)).

To enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies, the City of Lake Forest took the following actions:
• The City Manager's Office, acting as the lead agency, met with various City departments and consulted with outside agencies to gain input on annual needs, enhance coordination of services, prevent duplication of services, and resolve issues within the interagency institutional structure. • The City of Lake Forest collaborates with the County to obtain input on assisted-housing programs. Specifically, the City works with and supports the Orange County Housing Authority’s (OCHA) administration of the Housing Choice Voucher Program, which provides housing subsidies to qualified lower-income renters. Coordination is enhanced by the City’s participation as a member of the OCHA Advisory Committee.
• To strengthen the housing delivery system in the private sector, the City encourages private housing developers to include affordable units in multi-family housing developments within Lake Forest. The City will also continue to cooperate with local nonprofit housing organizations to identify and provide housing opportunities for lower-income households. • Orange County has a broad spectrum of public and nonprofit social service providers that address the needs of the region’s residents. Through the annual CDBG public service grant funding process, City staff can ascertain the type of services City residents require (e.g., senior services, youth services, services for the near homeless and those already homeless), and develop partnerships with local agencies to ensure the delivery of quality services. • The City of Lake Forest has an active economic development program that coordinates business activities and employment programs with community organizations such as the Lake Forest Chamber of Commerce and Orange County Workforce Solutions.

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Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness Coordination of Orange County’s Continuum of Care (OC-CoC) planning process is led by 2-1-1 Orange County and the OC Community Services Department. This nonprofit-public partnership helps ensure comprehensive, regional coordination of efforts and resources to reduce the number of homeless and persons at risk of homelessness throughout Orange County. This partnership serves as the regional coordinator of the year-round CoC planning process and as a catalyst for the involvement of the public and private agencies that make-up the regional homeless system of care.

The City participants in the CoC planning process by providing information regarding the activities it will fund to address local homeless issues. This information is used by the OC-CoC to prepare the regional application to HUD for Homeless Assistance Grant funds. City staff will also expedite certifications of consistency with the Consolidated Plan and other forms of support for the OC-CoC. The City is also a supporter and participant in the biennial Point-In-Time Survey of the region’s homeless.

Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards and evaluate outcomes, and develop funding, policies and procedures for the administration of HMIS The City is not a recipient of Emergency Solutions Grant (ESG) funds; therefore, it does not assist the OCCoC with the determination of ESG allocations nor evaluating the outcomes, or developing policies and procedures for the administration of the regional Homeless Management Information System (HMIS).

2. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdictions consultations with housing, social service agencies and other entities
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Table 2 – Agencies, groups, organizations who participated 1 Agency/Group/Organization Orange County Housing Authority Agency/Group/Organization Type PHA
What section of the Plan was addressed by
Consultation?
Housing Need Assessment
Public Housing Needs
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided data regarding households receiving
HUD rental assistance and regarding
households on the waitlist for housing
assistance
2 Agency/Group/Organization 211 Orange County
Agency/Group/Organization Type Regional organization
Planning organization
What section of the Plan was addressed by
Consultation?
Homelessness Strategy
Homeless Needs - Chronically homeless
Homeless Needs - Families with children
Homelessness Needs - Veterans
Homelessness Needs - Unaccompanied youth
Homeless Management Information System
(HMIS)
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided data regarding regional homeless,
housing/service gaps for homeless, and HMIS
management
3 Agency/Group/Organization Fair Housing Council of Orange County Agency/Group/Organization Type Service-Fair Housing
What section of the Plan was addressed by
Consultation?
Impediments to Fair Housing
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided data regarding fair housing issues in
the community and input on impediments to
fair housing, and assisted in developing action
steps to address impediments to fair housing
4 Agency/Group/Organization Age Well Senior Services
Agency/Group/Organization Type Services-Elderly Persons What section of the Plan was addressed by
Consultation?
Housing Need Assessment
Non-Homeless Special Needs
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How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the housing and
service needs of seniors, including homebound seniors
5 Agency/Group/Organization Families Forward
Agency/Group/Organization Type Services - Housing
Services-homeless
What section of the Plan was addressed by
Consultation?
Homelessness Strategy
Homeless Needs - Families with children
Anti-poverty Strategy
Needs of Low/Mod persons
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the housing and
service needs of homeless families and families
at risk of becoming homeless
6 Agency/Group/Organization Family Assistance Ministry
Agency/Group/Organization Type Services - Housing
Services-homeless
What section of the Plan was addressed by
Consultation?
Homeless Needs - Families with children
Anti-poverty Strategy
Needs of Low/Mod persons
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the housing and
service needs of homeless households and
households at risk of becoming homeless
7 Agency/Group/Organization South County Outreach
Agency/Group/Organization Type Services - Housing
Services-homeless
What section of the Plan was addressed by
Consultation?
Anti-poverty Strategy
Needs of Low/Mod persons
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the needs of lower
income households specifically,
individuals/households at risk of becoming
homeless
8 Agency/Group/Organization Vocational Visions
Agency/Group/Organization Type Services-Persons with Disabilities Consolidated Plan LAKE FOREST 12
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What section of the Plan was addressed by
Consultation?
Non-Homeless Special Needs
Economic development
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the needs of adults
with developmental disabilities, including
developing economic opportunities for this
special needs population
9 Agency/Group/Organization Camino Health Center
Agency/Group/Organization Type Services-Health
What section of the Plan was addressed by
Consultation?
Anti-poverty Strategy
Needs of Low/Mod persons
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the medical/dental
service needs of the community including
homeless individuals
10 Agency/Group/Organization Mercy House Transitional Living Centers Agency/Group/Organization Type Services - Housing
Services-homeless
What section of the Plan was addressed by
Consultation?
Homelessness Strategy
Homeless Needs - Chronically homeless
Homelessness Needs - Veterans
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided input regarding the needs of
chronically homeless individuals
11 Agency/Group/Organization Council On Aging - Orange County Agency/Group/Organization Type Services-Elderly Persons What section of the Plan was addressed by
Consultation?
Non-Homeless Special Needs
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Provided information regarding the housing
and service needs of elderly and disabled
individuals residing in managed care facilities
12 Agency/Group/Organization County of Orange
Agency/Group/Organization Type Other government - County Consolidated Plan LAKE FOREST 13
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What section of the Plan was addressed by
Consultation?
Regional program information
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Various county departments provided
information regarding public health, public
safety, and housing programs
13 Agency/Group/Organization State of California
Agency/Group/Organization Type Other government - State What section of the Plan was addressed by
Consultation?
State program information
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
Various state departments provided
information regarding demographics, public
safety, and economics
14 Agency/Group/Organization Laura's House
Agency/Group/Organization Type Services-Victims of Domestic Violence Services - Victims
What section of the Plan was addressed by
Consultation?
Housing Need Assessment
Homelessness Strategy
Homeless Needs - Families with children
Non-Homeless Special Needs
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
The City consulted with this agency to obtain
data on the number of domestic violence
victims as well as their special needs.

Identify any Agency Types not consulted and provide rationale for not consulting The City consulted with a variety of agencies serving Lake Forest residents and the region. No agency types were explicitly excluded from the consultation process.

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Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan?
Continuum of Care Orange County 211 Provides regional and local point in time homeless survey data, development of the regional 10-Year
Plan to End Homelessness and development of the
regional Discharge Plan
5 Yr. & 1 Yr. PHA
Plan
Orange County Housing
Authority
Identifies OCHA resources to address the housing
needs of lower income renter householders in the
County and the City
City of Lake Forest
2021-2029 Housing
Element
City of Lake Forest Provides City housing priorities and program goals Analysis of
Impediments to Fair
Housing
Orange County HUD
Grantee Cities and the
County of Orange
Countywide document that identifies fair housing
impediments within participating cities and
outlines a plan to address issues
Table 3 – Other local / regional / federal planning efforts Describe cooperation and coordination with other public entities, including the State and any adjacent units of general local government, in the implementation of the Consolidated Plan (91.215(l))
Data from the California Department of Public Health and the Orange County Health Care Agency identifies the percentage of young children with elevated lead blood levels. The City used this data to assess lead-based paint hazards. State agencies were also consulted to obtain updated housing and population information. The County of Orange was contacted to obtain an array of data, including information regarding the number of households receiving rental assistance, homeless count, and other regional data. Local governments also assisted the City with the preparation of the Consolidated Plan.

The Orange County Health Care Agency was consulted regarding the number of Lake Forest residents living with HIV and AIDS and available HOPWA program resources. The City also participated in roundtable meetings with other Orange County CDBG recipients to discuss the preparation of a regional analysis of impediments to fair housing and other regional housing and community needs.

Narrative (optional):

N/A See narratives above.

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PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c)

1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting The City of Lake Forest offered several opportunities for participation and comment throughout the Consolidated Plan preparation process. The City’s Citizen Participation Plan, which is presented in Appendix C, outlines the City’s process to obtain public participation in the development of the Consolidated Plan, Annual Action Plan (AAP), and other facets of the CDBG Program. Action steps include a public hearing before the City Council, which also initiated the 30-day public review of the Consolidated Plan, with the final City Council adoption at a public meeting originally scheduled for May 6, 2025. The notice for the City Council public hearing and a summary of public comments is provided in Appendix D. Public comment and review requirements for adoption of the FY 2025-2030 Orange County Analysis of Impediments to Fair Housing were also undertaken in conjunction with the Consolidated Plan.

The comments received through the citizen participation process are essential to identifying priority needs, as are the results of the Community Needs survey.

Citizen Participation Outreach
Sort Order Mode of Outreach Target of Outreach Summary of response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
1 Newspaper Ad Nontargeted/broad
community
The City published a
Notice of Funding
Availability (NofA) in
the Newspaper on
December 5, 2024.
11 Applications for
funding were
received and the
Proof of Publication
can be found in
Appendix F.

N/A There were no
comments received
that were not
accepted.

N/A
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Sort Order Mode of Outreach Target of Outreach Summary of response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
2 Community Needs
Survey
Nontargeted/broad
community
The FY 2025-2030
Consolidated Plan
Community Survey
was available from
November 2024 to
February 2025.The
City posted a
Community Needs
Survey on its website
and distributed hard
copies to the senior
center and at various
events from
November 2024
through January 31,
2025. 228 responses
were received.

Survey results
received are
included in
Appendix E.

N/A There were no
comments received
that were not
accepted.

N/A
3 Public Meeting Nontargeted/broad
community
Social Service
Providers
The City Council
received a
presentation on the
draft Consolidated
Plan and Expenditure
Plan on April 15, 2025
to review funding
recommendations
and applications
received.

Meeting comments
centered on the
CDBG public service
grant application
process.

N/A There were no
comments received
that were not
accepted.

N/A
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Sort Order Mode of Outreach Target of Outreach Summary of response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
4 Public Meeting Non-English
Speaking - Specify
other language:

Spanish
Nontargeted/broad
community
The City participated
in the South County
Regional AI public
input meeting on
1/9/25.

A summary of the
comments received
can be found in
Appendix G
N/A There were no
comments received
that were not
accepted.

N/A
5 Newspaper Ad Nontargeted/broad
community
Notice regarding the
30-day public review
period and May 6,
2025, Public Hearing
was published on
3/20/25.

A summary of
comments received
can be found in
Appendix C and
Proof of Publication
in Appendix F.

N/A There were no
comments received
that were not
accepted.

N/A
6 Public Hearing Nontargeted/broad
community
The City Council held
a public hearing on
5/06/25 to accept
final public
comments on the
Consolidated Plan,
AAP, and OC-AI, and
authorize submission
of the document to
HUD.

A summary of
comments received
can be found in
Appendix C.

N/A There were no
comments received
that were not
accepted.

N/A
Table 4 – Citizen Participation Outreach
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Needs Assessment
NA-05 Overview
Needs Assessment Overview
The Needs Assessment of the Consolidated Plan identifies the City’s needs as they relate to housing, homelessness, community development, and special needs populations. The housing needs assessment section evaluates household income, tenure (renter or owner), housing cost as a function of household income, disproportionate needs amongst racial and ethnic groups, and public housing needs. The homeless needs assessment examines the sheltered and unsheltered homeless population in San Bernardino County to inform the City’s strategy to address homelessness during the next five years. The non-homeless special needs assessment section evaluates the needs of people who are not homeless, but due to various reasons are in need of services including but not limited to: elderly, frail elderly, severely mentally ill, developmentally disabled, physically disabled, persons with alcohol or other drug addictions, persons with HIV/AIDS and victims of domestic violence. The non-housing community development needs assessment section discusses the need for public facilities, public infrastructure improvements, and public services to benefit low- and moderate-income residents.

From this Needs Assessment, the City will identify those needs with the highest priority, which will form the basis for the Strategic Plan and the programs and projects to be administered during the five-year Consolidated Plan for FY 2025-2030. Information contained in the assessment is gathered through data analysis, consultations, and citizen participation. To assess community needs, the City examined data, held community meetings, conducted a Community Needs Survey, and consulted with local stakeholders.

The Needs Assessment primarily relies on the following sources of data:
• American Community Survey (ACS)(2016-2020 current year estimates) • Comprehensive Housing Affordability Strategy (CHAS data 2016-2020) • 2024 Point- in- Time Homeless Count
• The California Association of Realtors (CAR) website was accessed to obtain information on current market trends and affordability
• The Housing Element and Development Codes were reviewed to provide insight on zoning and land use policies and units at risk of conversion
• Previous Consolidated Plans and other Community Strategic Plans were used to provide supporting data on demographics, City programs, needs, and strategies • Various data requests were sent to County level staff from the Department of Health Services and Housing Authority
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NA-10 Housing Needs Assessment - 24 CFR 91.205 (a,b,c)
Summary of Housing Needs
The following section describes the estimated housing needs projected for the next five-year period for the following categories of persons: extremely low-income, low-income, moderate-income, and middleincome families, renters and owners, elderly persons, persons with disabilities, including persons with HIV/AIDS and their families, single persons, large families, public housing residents, victims of domestic violence, families on the public housing and section 8 tenant-based waiting list, and discuss specific housing problems, including: cost burden, severe cost-burden, substandard housing, and overcrowding (especially large families).

To the extent that any racial or ethnic group has a disproportionately greater need for any income category in comparison to the needs of that category as a whole, an assessment of that specific need is completed. Disproportionately greater need exists when the percentage of persons in a category of need who are members of a particular racial or ethnic group is at least ten percentage points higher than the percentage of persons in the category as a whole.

During the past decade, Lake Forest has experienced moderate population growth. According to data presented in Table 5, the City’s population grew by 6% between 2009 and 2020. In comparison, during roughly the same period, the County’s population grew 2.7, while California’s population grew 6.7%. The 2016-2020 American Community Survey 5-Year Estimates also indicates there was an 8% growth in households and a 24% increase in the median income.

Demographics Base Year: 2009 Most Recent Year: 2020 % Change Population 79,925 84,665 6%
Households 27,045 29,340 8%
Median Income $91,254.00 $112,988.00 24%
Table 5 - Housing Needs Assessment Demographics
Data Source: 2000 Census (Base Year), 2016-2020 ACS (Most Recent Year) Consolidated Plan LAKE FOREST 20
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Number of Households Table
0-30%
HAMFI
>30-50%
HAMFI
>50-80%
HAMFI
>80-100%
HAMFI
>100%
HAMFI
Total Households 3,290 3,075 5,090 3,210 14,680
Small Family Households 1,170 1,315 1,785 1,730 9,180
Large Family Households 195 270 510 305 1,310
Household contains at least one
person 62-74 years of age 985 720 1,180 745 3,280
Household contains at least one
person age 75 or older 710 540 750 185 750
Households with one or more
children 6 years old or younger 355 464 709 550 1,740
Table 6 - Total Households Table
Data
Source:
2016-2020 CHAS
Housing Needs Summary Tables

1. Housing Problems (Households with one of the listed needs) Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total

NUMBER OF HOUSEHOLDS
Substandard
Housing -
Lacking
complete
plumbing or
kitchen
facilities 35 50 50 10 145 0 10 20 0 30
Severely
Overcrowded -
With >1.51
people per
room (and
complete
kitchen and
plumbing) 90 95 105 150 440 0 0 20 15 35
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Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
Overcrowded -
With 1.01-1.5
people per
room (and
none of the
above
problems) 90 110 165 95 460 70 0 185 115 370
Housing cost
burden greater
than 50% of
income (and
none of the
above
problems) 910 705 330 35 1,980 1,345 485 190 65 2,085
Housing cost
burden greater
than 30% of
income (and
none of the
above
problems) 0 460 1,020 380 1,860 105 520 1,225 590 2,440 Zero/negative
Income (and
none of the
above
problems) 55 0 0 0 55 120 0 0 0 120
Table 7 – Housing Problems Table
Data
Source:
2016-2020 CHAS

2. Housing Problems 2 (Households with one or more Severe Housing Problems: Lacks kitchen or complete plumbing, severe overcrowding, severe cost burden) Consolidated Plan LAKE FOREST 22
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Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total

NUMBER OF HOUSEHOLDS
Having 1 or more
of four housing
problems 1,130 950 655 290 3,025 1,410 495 420 190 2,515 Having none of
four housing
problems 295 510 1,410 990 3,205 450 1,115 2,610 1,735 5,910 Household has
negative income,
but none of the
other housing
problems 0 0 0 0 0 0 0 0 0 0
Table 8 – Housing Problems 2
Data
Source:
2016-2020 CHAS

3. Cost Burden > 30%
Renter Owner
0-30%
AMI
>30-50%
AMI
>50-80%
AMI
Total 0-30%
AMI
>30-50%
AMI
>50-80%
AMI
Total

NUMBER OF HOUSEHOLDS
Small Related 510 865 425 1,800 445 335 550 1,330
Large Related 140 130 64 334 55 90 94 239
Elderly 135 170 160 465 759 500 460 1,719
Other 335 189 815 1,339 190 95 380 665
Total need by
income
1,120 1,354 1,464 3,938 1,449 1,020 1,484 3,953
Table 9 – Cost Burden > 30%
Data
Source:
2016-2020 CHAS
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4. Cost Burden > 50%
Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total

NUMBER OF HOUSEHOLDS
Small Related 0 0 530 530 425 165 0 590
Large Related 0 0 60 60 55 90 4 149
Elderly 135 130 45 310 685 150 110 945
Other 0 335 94 429 180 0 0 180
Total need by
income
135 465 729 1,329 1,345 405 114 1,864
Table 10 – Cost Burden > 50%
Data
Source:
2016-2020 CHAS

5. Crowding (More than one person per room)
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total

NUMBER OF HOUSEHOLDS
Single family
households 175 125 200 205 705 70 0 195 115 380
Multiple,
unrelated family
households 10 80 45 20 155 0 0 10 15 25
Other, non-family
households 0 0 35 20 55 0 0 0 0 0
Total need by
income
185 205 280 245 915 70 0 205 130 405
Table 11 – Crowding Information – 1/2
Data
Source:
2016-2020 CHAS
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Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
Households with
Children Present 0 0 0 0 0 0 0 0
Table 12 – Crowding Information – 2/2
Data Source
Comments:

Describe the number and type of single-person households in need of housing assistance.

Data provided by HUD’s Consolidated Plan template for Table 12 above does not provide information for single person households in need of housing assistance. However, the City's Housing Element reported that 21.8% of family households are headed by a single male or single female. There are 1,226 male heads of household with no spouse present and 413 of these households have children under 18. There is a larger number of female householders with no spouse present – 3,378 households or 11.8% of family households – and 1,702 of these female-headed households have children under 18.

Single parent households generally have a higher ratio between their income and their living expenses (that is, living expenses take up a larger share of income than is generally the case in two-parent households). Therefore, finding affordable, decent, and safe housing is often more difficult for single parent and female-headed households. Additionally, single parent and female-headed households have special needs involving access to daycare or childcare, health care, and other supportive services.

Estimate the number and type of families in need of housing assistance who are disabled or victims of domestic violence, dating violence, sexual assault and stalking.

Disabled Households: According to the 2016-2020 ACS data, there are an estimated 5,838 Lake Forest residents with a disability – approximately 7.2% of the City’s population. Federal laws define a person with a disability as "Any person who has a physical or mental impairment that substantially limits one or more major life activities …” Of residents with a disability, 559 (9.6%) are living below the poverty level.

The City’s elderly population has significant levels of disabilities. The ASC estimates 26.3% of Lake Forest seniors, age 65 and over, have a disability. Since seniors have a much higher probability of being disabled, the housing and service needs for persons with disabilities should grow commensurate with senior population growth. Accessibility housing needs of the disabled population, including the elderly, can typically be addressed through housing rehabilitation programs that provided improvements such as ramps, grab bars, wider doorways, and specialized kitchen cabinets.

Victims of Domestic Violence: The National Coalition Against Domestic Violence (NCADV) estimates that nationwide, domestic violence hotlines receive 20,000 calls per day. NCADV also reports that one in three women have experienced rape, physical violence, or stalking by an intimate partner in their lifetime. The Consolidated Plan LAKE FOREST 25
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State of California Department of Justice reports that in 2023, there were 36 calls for assistance related to domestic violence in Lake Forest; however, prior year data from 2014-2023 shows an average of 235 calls per year.

Laura’s House, a leading domestic violence service provider in South Orange County, estimates that only one in seven incidents are reported. Laura’s House also estimates that for each victim of domestic violence that receives shelter and support services, 15 to 20 individuals are turned away from lack of space. The Orange County 2024 Point In Time Survey of the region’s homeless estimates that 10.01% of unsheltered homeless in South Orange County are victims of domestic violence, and 10.40% of sheltered homeless in South Orange County are victims of domestic violence. Victims of domestic violence often face urgent housing needs, requiring safe and confidential shelter to escape abusive situations.

What are the most common housing problems?
According to HUD data from Table 7, the most common housing problems in Lake Forest is housing cost burden. This housing problem impacts both renter and owner households. To a much lesser degree, some households are affected by crowding and substandard housing (as defined by HUD).

Are any populations/household types more affected than others by these problems? Table 9 provides estimates regarding the number of lower-income households impacted by housing cost burden (30% of income toward housing cost).
• Among renter households, extremely low-income senior and low-income large related households are most impacted (49.0% and 48.5%, respectively). • Among owner households, small and large related low-income households are most impacted (62.7% and 65.8% respectively).

Table 10 summarizes information regarding households that pay more than 50% of their income for housing. According to this HUD data, a significant percentage of lower-income households are experiencing severe housing cost burden:
• Among renter households, 68.6% of extremely low-income small renter households are dedicating more than 50% of their income for housing.
• Among owner households, extremely low-income senior households and low-income large households are impacted (46.5% and 60.5% respectively).

As indicated above, few Lake Forest households are impacted by crowded housing. According to Table 11, 1,003 households live in “crowded” housing. HUD’s data indicates that 833 of these households are renters and 170 are owners. When addressing crowding issues, the City is required to utilize the States more liberal occupancy standard, which allows up to 30 people to live in a 1,200 sq./ft. residence. The City’s Code Enforcement program staff reports that approximately 10% of their cases are related to Consolidated Plan LAKE FOREST 26
OMB Control No: 2506-0117 (exp. 09/30/2021)
overcrowding - the most prevalent issue related to crowding in the City is the impact of parking in residential neighborhoods.

According to Table 7, only 165 Lake Forest households are impacted by HUD-defined substandard housing. The City is required to enforce compliance with the California building code, and according to the City’s Code Enforcement staff, substandard housing is not a significant issue in the City. Unpermitted room additions and garage conversions represent the most prevalent types of code violations addressed by City staff.

Describe the characteristics and needs of Low-income individuals and families with children (especially extremely low-income) who are currently housed but are at imminent risk of either residing in shelters or becoming unsheltered 91.205(c)/91.305(c)). Also discuss the needs of formerly homeless families and individuals who are receiving rapid re-housing assistance and are nearing the termination of that assistance
The National Alliance to End Homelessness states that households at risk of homelessness are often very low-income households on a fixed income (such as retired seniors) or marginally employed. Due to limited income and high area housing costs, at risk households are typically severely housing cost burdened. Based on HUD data, 1,945 extremely low-income Lake Forest households dedicate more than 50% of household income for housing (see Table 10). This data indicates that of this figure, senior and small related households comprise 73.3% of the at-risk population.

OCHA reports that as of April 2025, there are 152 Lake Forest households on the waitlist for federal rental assistance.

If a jurisdiction provides estimates of the at-risk population(s), it should also include a description of the operational definition of the at-risk group and the methodology used to generate the estimates:

Extremely low-income households that are experiencing severe housing cost burden are most at risk of becoming homeless. The methodology for estimating the number of households that may be at risk of homelessness is also outlined as follows: Based on the CHAS data in Table 7, 4,065 Households in Lake Forest were experiencing severe cost burden, approximately 98 percent (3,965) are considered low- and moderate-income; earning 0-80 percent of Area Median Income (AMI). Moreover, 2,255 Households (910 renter-households and 1,345 owner-households) are extremely low-income (0-30 percent AMI) and are considered at-risk.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
Specify particular housing characteristics that have been linked with instability and an increased risk of homelessness
The origins of involuntary homelessness are multi-faceted but can be grouped into two general categories:
physiological and economic factors. Examples of physiological factors include physical or mental illness and addiction disorders. Economic factors include the impact of high housing and medical costs. As indicated previously, Lake Forest households with extremely low-incomes and severe housing cost burden have a high risk of becoming homeless. Housing instability encompasses a number of challenges, such as having trouble paying rent, overcrowding, moving frequently, or spending the bulk of household income on housing. The cost of housing as well as the health effects of substandard housing and forced evictions.

Certain populations, such as children who move frequently and people who have spent time in prison, may be more affected by housing instability. Physical or mental illness and addiction disorders, as well as economic factors including the impact of high housing and medical costs impact homelessness. Lack of regular housing, neighborhood characteristics, physical and mental health challenges, elevated rates of childhood and chronic disease, stress, depression, anxiety, and suicide are all characteristics associated with instability and an increased risk of homelessness.

Discussion
According to HUD data provided in the Consolidated Plan template, substandard and crowded housing are not a significant housing problem in Lake Forest; however, housing cost is the most prevalent housing problem. According to the National Alliance to End Homelessness, very low- income households are at a high risk of becoming homeless. Per HUD data, senior and small related households comprise over 70% of the City’s extremely low-income residents that are dedicating more than 50% of their income to maintain their home.

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NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2) Assess the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole.

Introduction
A disproportionate need exists when members of a racial/ethnic group experience housing problems at a rate of 10 percentage points or greater than the proportion of the jurisdiction/income level as a whole.

The following section assesses the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole for the population of low- and moderate-income households.

The four housing problems are:
1) Lacks complete kitchen facilities; 2) Lacks complete plumbing facilities; 3) More than one person per room; and/or 4) Cost Burden greater than 30%.

The housing problems experienced by race/ethnicity are identified in Tables 13-16 below and analyze disproportionate needs by income level.
0%-30% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,650 635 0
White 1,335 365 0
Black / African American 215 95 0
Asian 325 95 0
American Indian, Alaska Native 50 15 0
Pacific Islander 10 10 0
Hispanic 670 50 0
Table 13 - Disproportionally Greater Need 0 - 30% AMI
Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
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OMB Control No: 2506-0117 (exp. 09/30/2021)
30%-50% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,425 650 0
White 1,165 359 0
Black / African American 19 4 0
Asian 415 75 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 0 0
Hispanic 805 60 0
Table 14 - Disproportionally Greater Need 30 - 50% AMI
Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
50%-80% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 3,330 1,765 0
White 1,895 1,245 0
Black / African American 14 65 0
Asian 450 225 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 0 0
Hispanic 845 190 0
Table 15 - Disproportionally Greater Need 50 - 80% AMI
Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
Consolidated Plan LAKE FOREST 30
OMB Control No: 2506-0117 (exp. 09/30/2021)
80%-100% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 1,460 1,750 0
White 805 1,150 0
Black / African American 30 70 0
Asian 205 295 0
American Indian, Alaska Native 15 10 0
Pacific Islander 0 0 0
Hispanic 365 180 0
Table 16 - Disproportionally Greater Need 80 - 100% AMI Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
Discussion
As previously indicated, housing cost burden is the most prevalent housing problem in Lake Forest. Tables 13 through 16 show that regardless of race or ethnicity, a significant number of lower-income Lake Forest households are experiencing a housing problem; however, the data indicates that among extremely lowincome households, while 27 percent of the income category for the jurisdiction as a whole are impacted, Black/African American and Pacific Islanders are disproportionately impacted by housing problems at 77 percent and 100 percent respectively.

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NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205 (b)(2) Assess the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole.

Introduction
A disproportionate need exists when members of a racial/ethnic group experience severe housing problems at a rate of 10 percentage points or greater than the proportion of the jurisdiction/income level as a whole. The following section assesses the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole for the population of low- and moderate-income households.

The ACS defines a “selected condition” as owner- or renter occupied housing units having at least one of the following conditions:
1) lacking complete plumbing facilities; 2) lacking complete kitchen facilities; 3) more than 1.5 occupants per room; and 4) selected monthly housing costs greater than 50 percent of household income.

Tables 17-20 below analyze disproportionate needs by race and income level for severe housing problems. 0%-30% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,540 745 0
White 1,300 400 0
Black / African American 215 95 0
Asian 265 150 0
American Indian, Alaska Native 50 15 0
Pacific Islander 10 10 0
Hispanic 660 65 0
Table 17 – Severe Housing Problems 0 - 30% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over 50%
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OMB Control No: 2506-0117 (exp. 09/30/2021)
30%-50% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 1,445 1,625 0
White 585 940 0
Black / African American 4 19 0
Asian 275 210 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 0 0
Hispanic 560 300 0
Table 18 – Severe Housing Problems 30 - 50% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over 50%
50%-80% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 1,075 4,020 0
White 455 2,685 0
Black / African American 10 69 0
Asian 205 470 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 0 0
Hispanic 400 630 0
Table 19 – Severe Housing Problems 50 - 80% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over 50%
Consolidated Plan LAKE FOREST 33
OMB Control No: 2506-0117 (exp. 09/30/2021)
80%-100% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 480 2,725 0
White 145 1,815 0
Black / African American 0 100 0
Asian 55 450 0
American Indian, Alaska Native 15 10 0
Pacific Islander 0 0 0
Hispanic 244 305 0
Table 20 – Severe Housing Problems 80 - 100% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over 50%
Discussion
Tables 17 through 20 indicate that regardless of race or ethnicity, a significant number of extremely lowincome and very low-income Lake Forest households are experiencing a severe housing problem; however, Black/African American, Asian, and Hispanic households are disproportionately impacted by severe housing problems among the different income categories. In general, at higher income levels, minority populations are not disproportionally impacted by severe housing problems. While 46 percent of the income category for the jurisdiction as a whole are impacted, Black/African American and Pacific Islanders are disproportionately impacted by housing problems at 94 percent and 100 percent respectively.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2) Assess the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole.

Introduction:

HUD defines cost burden as the extent to which gross housing costs, including utility costs, exceeds 30 percent of a given household’s gross income. A household is considered severely cost burdened if gross housing costs, including utility costs, exceeds 50 percent of a household’s gross income. A disproportionate need exists when members of a racial/ethnic group experience cost burden problems at a rate of 10 percentage points or greater than the proportion of the jurisdiction/income level as a whole.

The following section assesses the need of any racial or ethnic group that has disproportionately greater need in comparison to the needs of that category of need as a whole for the population of low and moderate-income households.

Table 21 below analyzes disproportionate needs by race and income level for Cost Burden.

Housing Cost Burden
Housing Cost Burden <=30% 30-50% >50% No / negative
income (not
computed)
Jurisdiction as a whole 18,905 5,805 4,440 185
White 11,935 3,615 2,265 95
Black / African
American 460 50 219 0
Asian 3,190 895 690 75
American Indian,
Alaska Native 45 0 50 0
Pacific Islander 10 0 10 0
Hispanic 2,795 1,090 1,130 14
Table 21 – Greater Need: Housing Cost Burdens AMI
Data
Source:
2016-2020 CHAS
Discussion:

Table 21 shows that that the majority households experiencing overpayment/housing cost burden earn less than 50 percent of the median income, which is similar for all races. As a jurisdiction, households that experience cost burden (pay more than 30 percent or more of their income on housing were identified as follows:

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OMB Control No: 2506-0117 (exp. 09/30/2021)
• 18,905 (65 percent) of all households earn extremely low-income. Disproportionate need is not evident in this group.
• 5,805 (20 percent) of all households earn Very- low- income. There is no disproportionate need evident in this group.
• 4,440 (15 percent) of all households earn above 50 percent of the AMI. Disproportionate need exists for Black/African American (30 percent), American Indian/Alaska Native (53 percent), and Pacific Islander (50 percent).

Consolidated Plan LAKE FOREST 36
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2) Are there any Income categories in which a racial or ethnic group has disproportionately greater need than the needs of that income category as a whole? According to Census data, Hispanics/Latinos make up the largest minority population in Lake Forest (24.5% of the City’s population). Asians represent the second largest minority population (15.7% of the City’s population). Based on HUD data from the above series of tables, Black/African American and Hispanic/Latino households consistently appear to be experiencing housing problems disproportionally to the community as a whole. A notable percentage of Native Americans/ Native Alaskans and Pacific Islanders are also disproportionally impacted by housing problems, but these racial populations comprise a small percentage of the City’s population.

If they have needs not identified above, what are those needs? As previously outlined, housing cost is the prevalent housing problem. This housing problem is found among all income categories and most race/ethnic groups. Based on HUD data and City staff input, crowded and substandard housing are not significant issues in Lake Forest.

Are any of those racial or ethnic groups located in specific areas or neighborhoods in your community?
In general, minority populations reside throughout the City; however, there are eight Census Tracts in the City with minority populations representing more than the County average of 62.3 percent as follows:
• 320.14 BG 3
• 320.27 BG 3
• 524.11 BG 1 BG 2 BG 3
• 524.22 BG 2 BG 5
• 524.23 BG 2 BG 3
• 524.25 BG 1 BG 3
• 524.28 BG 1 BG 2
• 524.30 BG 1 BG 9
Maps demonstrating these Census Tracts are provided as Figure 1: Low- and Moderate-Income Areas, Figure 2: Ethnic Concentrations, and Figure 3: Transit Access in Section MA-50.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-35 Public Housing – 91.205(b)
Introduction
There is no public housing in the City of Lake Forest; however, the Orange County Housing Authority (OCHA) administers the Housing Choice Voucher Program in the City of Lake Forest. The Housing Choice Voucher Program provides rental subsidies to low-income families that spend more than 30% of the gross income on housing costs. The Voucher Program pays the difference between the excess of 30% of the recipient’s monthly income and the federally approved Fair Market Rent (FMR).

The number of vouchers administered by a housing authority constantly fluctuates due to the availability of new vouchers from HUD and changes in housing costs. According to Tables 22-26, OCHA administers 10,825 rental assistance vouchers throughout most of Orange County, which benefit extremely low and low-income families, elderly, disabled, and homeless households. The majority of households are White and Asian, which is reflective of overall County demographics, though Hispanics may be somewhat underrepresented.

Data received from OCHA as of July 2024 indicated that 161 vouchers were leased in Lake Forest, 36 of which were Family Households, 44 were Disabled Households, and 81 were Senior Households. This number increased to 203 as of April 2025. Per the last Consolidated Plan completed in 2020, 88 households were on the waiting list for rental assistance. OCHA opened their waiting list in September 2023 and received 57,000 applications and the number from Lake Forest increased to 152, which illustrates a huge demand for assistance in the County and City.

The data in tables below represent county-wide statistics.

Totals in Use
Program Type
Certificate ModRehabPublic
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of
units
vouchers
in use 0 0 0 10,825 0 10,418 187 207 10
Table 22 - Public Housing by Program Type
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Data
Source:

PIC (PIH Information Center)
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OMB Control No: 2506-0117 (exp. 09/30/2021)
Characteristics of Residents
Program Type
Certificate ModRehabPublic
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Average
Annual
Income 0 0 0 16,476 0 16,470 17,239 15,594
Average
length of stay 0 0 0 8 0 8 0 4
Average
Household
size 0 0 0 2 0 2 1 3
# Homeless at
admission 0 0 0 87 0 5 72 10
# of Elderly
Program
Participants
(>62) 0 0 0 4,926 0 4,884 38 3
# of Disabled
Families 0 0 0 2,163 0 2,075 64 14
# of Families
requesting
accessibility
features 0 0 0 10,825 0 10,418 187 207
# of HIV/AIDS
program
participants 0 0 0 0 0 0 0 0
# of DV
victims 0 0 0 0 0 0 0 0
Table 23 – Characteristics of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center)
Consolidated Plan LAKE FOREST 39
OMB Control No: 2506-0117 (exp. 09/30/2021)
Race of Residents
Program Type
Race Certificate ModRehabPublic
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
White 0 0 0 5,857 0 5,528 139 182 6
Black/African
American 0 0 0 745 0 693 39 10 2
Asian 0 0 0 4,128 0 4,107 4 15 2
American
Indian/Alaska
Native 0 0 0 64 0 60 4 0 0
Pacific
Islander 0 0 0 31 0 30 1 0 0
Other 0 0 0 0 0 0 0 0 0
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 24 – Race of Public Housing Residents by Program Type Data
Source:

PIC (PIH Information Center)
Consolidated Plan LAKE FOREST 40
OMB Control No: 2506-0117 (exp. 09/30/2021)
Ethnicity of Residents
Program Type
Ethnicity Certificate ModRehabPublic
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
Hispanic 0 0 0 1,941 0 1,814 34 87 4
Not
Hispanic 0 0 0 8,884 0 8,604 153 120 6
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 25 – Ethnicity of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center)
Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants on the waiting list for accessible units:

Not applicable. There are no public housing units in Lake Forest.

Most immediate needs of residents of Public Housing and Housing Choice voucher holders Not applicable.

How do these needs compare to the housing needs of the population at large Not applicable.

Discussion
There are no public housing units in Lake Forest.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-40 Homeless Needs Assessment – 91.205(c)
Introduction:

Homeless researchers typically use one of two methods to measure homelessness. One way attempts to count all persons that are homeless on a given day/week (point-in-time counts). The second examines the number of people who are homeless over a given period - period prevalence counts. The Orange County Continuum of Care (OC-CoC) uses the first method for its biennial enumeration of the region’s homeless. To facilitate the enumeration of the homeless and the allocation of limited resources, the OCCoC has geographically divided the County into three Service Planning Areas (SPA). Homeless data from the Point-In-Time Survey (PITS) is provided on a county-wide basis, by SPA, and to a lesser degree, by jurisdiction. Because there is limited data regarding Lake Forest’s homeless population, it is generally assumed that the characteristics of the City’s homeless population are similar to those of the South SPA and Countywide as well. According to the 2024 Point in Time County, there were 7,322 homeless in Orange County as of January 2024; of which there were 641 homeless people in the South Service SPA; 491 unsheltered and 150 sheltered. In Lake Forest, there were 104 homeless identified, all of which were unsheltered.

General demographic information regarding Orange County’s unsheltered homeless population include the following:
• 27% were female, 72% male, and 1% were other non-conforming. • 39% were White, 36% were Hispanic/Latino, 13% were Other Multi, 5% were Black/African American, 4% were Asian, 2% were American Indian/Alaska Native, and 1% were Native Hawaiian/Pacific Islander
• 2% were under the age of 18
• 80 were Veterans
• 146 were Transitional Youth
• 456 were Seniors
• 38% were chronic homeless
• 50% had a substance abuse disorder
• 31% had a physical disability
• 31% had a serious mental illness
• 17% had a developmental disability
• 10% were victims of domestic violence
• 2% were living with HIV/AIDS
Consolidated Plan LAKE FOREST 42
OMB Control No: 2506-0117 (exp. 09/30/2021)
Homeless Needs Assessment
Population Estimate the # of
persons experiencing
homelessness on a
given night
Estimate the
#
experiencing
homelessness
each year
Estimate
the #
becoming
homeless
each year
Estimate the
# exiting
homelessness
each year
Estimate the
# of days
persons
experience
homelessness
Sheltered Unsheltered
Persons in
Households
with Adult(s)
and Child(ren) 0 0 0 0 0 0
Persons in
Households
with Only
Children 0 0 0 0 0 0
Persons in
Households
with Only
Adults 0 0 0 0 0 0
Chronically
Homeless
Individuals 0 0 0 0 0 0
Chronically
Homeless
Families 0 0 0 0 0 0
Veterans 0 0 0 0 0 0
Unaccompanied
Child 0 0 0 0 0 0
Persons with
HIV 0 0 0 0 0 0
Table 26 - Homeless Needs Assessment
Data Source
Comments: 2024 Orange County Point In Time Survey
Indicate if the homeless
population is:

Has No Rural Homeless
If data is not available for the categories "number of persons becoming and exiting homelessness each year," and "number of days that persons experience homelessness," describe these categories for each homeless population type (including chronically homeless Consolidated Plan LAKE FOREST 43
OMB Control No: 2506-0117 (exp. 09/30/2021)
individuals and families, families with children, veterans and their families, and unaccompanied youth):

The OC-CoC conducted a Point-In-Time Survey of Orange County’s homeless as part of a national survey. The January 2024 PITS estimated the County’s homeless population at 7,322 individuals, with 641 in the South SPA, and 104 homeless in Lake Forest. Orange County’s homeless count includes 3,149 sheltered in emergency/transitional housing and 4,173 unsheltered homeless - 150 sheltered and 491 unsheltered in the South SPA. Lake Forest’s homeless are enumerated as 0 sheltered and 104 unsheltered.

Characteristics of the City’s homeless population is provided to the extent the PITS captured information at the city level. If no specific Lake Forest data is available, an estimate is based on the characteristics of the County’s or South SPA’s homeless population.
• Chronic Homeless Individuals: HUD defines a chronically homeless individual as an unaccompanied homeless individual (living in an emergency shelter or is unsheltered) with a disabling condition, who has been continuously homeless for a year or more, or has had at least four episodes of homelessness in the past three years. The 2024 PITS estimates there are 37 sheltered and 216 unsheltered chronically homeless in South County SPA – approximately 33.2% of the subregion's homeless population. Based on this percentage, it is estimated there are 37 chronically homeless in Lake Forest. Since the PITS estimates that 85.4% of the chronic homeless in the South SPA are unsheltered, it is further estimated that 32 of these chronically homeless individuals are unsheltered.
• Chronically Homeless Families and Families with Children: The 2024 PITS identifies 53 homeless persons in “families” in Lake Forest - 36 individuals are sheltered, and 17 are unsheltered. The PITS provides no data regarding chronically homeless families; however, among unsheltered homeless individuals, approximately one-third report they become homeless for the first time in the past 12 months.
• Veterans and their Families: The County’s 2024 PITS found four veterans among Lake Forest unsheltered homeless.
• Unaccompanied Youth: The 2024 PITS did not estimate “unaccompanied children” (as requested in Table 26); however, the homeless survey estimated the number of youth households, i.e., adults between the ages of 18 and 24 – Transitional Age Youth. The 2024 PITS identified four homeless Transitional Age Youth in the City.
• HIV/AIDS: The 2024 PITS estimated that 0.8% of homeless adults in the South SPA are living with HIV/AIDS. Based on this percentage, it is likely there is one Lake Forest homeless individual is living with HIV/AIDS.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
Nature and Extent of Homelessness: (Optional)
Race: Sheltered: Unsheltered (optional)
White 0 0
Black or African American 0 0
Asian 0 0
American Indian or Alaska
Native 0 0
Pacific Islander 0 0
Ethnicity: Sheltered: Unsheltered (optional)
Hispanic 0 0
Not Hispanic 0 0
Data Source
Comments: See above
Estimate the number and type of families in need of housing assistance for families with children and the families of veterans.

OCHA provided the City with information regarding Lake Forest households that submitted applications for rental assistance in 2023, the last time OCHA accepted applications. During the last Consolidated Plan, OCHA reported there were 88 Lake Forest households on the waitlist for housing assistance. Of this number, 31 were households with children, 24 were senior households (age 62 and older), and 36 of applicants indicate they were disabled. Because homeless veterans are provided a priority for rental housing assistance, OCHA staff indicated there are no veteran households on the waitlist; however, OCHA reported 15 veteran households currently receive federal rental assistance. OCHA estimates it will take approximately three years to work through the existing waitlist.

Describe the Nature and Extent of Homelessness by Racial and Ethnic Group.

As previously reported, the 2024 PITS estimates 79.1% of the South SPA’s homeless are racially White,

9.5% Black/African American, 8.3% “multi-racial or other,” 1.6% Asian, 1.2% Native Hawaiian/Pacific Islander, and 0.5% American Indian/Alaska Native. An estimated 27.3% are Hispanic/Latino. It is reasonable to assume Lake Forest’s homeless population mirrors the racial and ethnic composition of the South SPA.

Describe the Nature and Extent of Unsheltered and Sheltered Homelessness.

The 2024 Orange County homeless survey reports there are 0 sheltered and 104 unsheltered homeless in Lake Forest.

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Discussion:

The 2024 Point-In-Time survey of Orange County’s homeless estimates there are 104 homeless in Lake Forest – none are sheltered, and all 104 are unsheltered. To a large extent, the characteristics of the homeless in Lake Forest mirrors those of the County’s South SPA homeless population, as reported in the 2024 PITS. The 2024 homeless survey also assessed the number of homeless seniors. The survey indicates there are four unsheltered homeless seniors in Lake Forest. According to regional service providers, homelessness among seniors is a growing issue.

Throughout the country homelessness has become an increasing problem. Factors contributing to the rise in homelessness include a lack of housing affordable to low- and moderate-income persons, increases in the number of persons whose income fall below the poverty level, reductions in subsidies to the poor, drug/alcohol abuse, and the deinstitutionalization of the mentally ill. The County suffers from a severe lack of affordable housing for both renters and buyers. The inability of homeless people to afford housing is compounded by the limited employment and entitlement options available to homeless people. With limited working skills, homeless people earn only modest wages. Moreover, cutbacks in federal assistance programs also play a critical part in the plight of the homeless. This has been particularly true with public assistance programs, where benefit levels have not kept pace with the cost of living.

Those who are at-risk of homelessness are those who are experiencing extreme difficulty maintaining housing and have no reasonable alternatives of obtaining subsequent housing. Contributing factors putting people at-risk include eviction, loss of income, low-income, disability, unaffordable increase in the cost of housing, discharge from an institution without subsequent housing in place, irreparable damage or deterioration to residence, and fleeing from family violence.

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NA-45 Non-Homeless Special Needs Assessment - 91.205 (b,d) Introduction:

HUD requires that the Consolidated Plan include a review of relevant data regarding the housing needs of persons that have special supportive housing needs, but who are not homeless. Certain segments of the population, such as elderly, disabled, victims of domestic violence, and persons with HIV/AIDS may experience conditions that make it difficult for them to access affordable housing. Physical or medical conditions, space or supportive service requirements, income, or other factors may impede a household’s ability to obtain decent and affordable housing. This section briefly describes the characteristics of some of the special needs populations in Lake Forest.

Describe the characteristics of special needs populations in your community:

Special need populations are identified as the elderly, disabled, victims of domestic violence, and persons with HIV/AIDS. Characteristics are identified below.

What are the housing and supportive service needs of these populations and how are these needs determined?
Elderly/Frail Elderly: According to the U.S. Census Bureau, 12.4% of Lake Forest residents are age 65 and older (2013-2017 ACS). This population is often impacted by limited mobility, increased health complications, and fixed income. Common service needs for the elderly include transportation and inhome services. Per HUD’s housing needs data (Tables 9 and 10), 1,749 lower-income elderly households are experiencing housing cost burden – 1,030 are experiencing severe housing cost burden. As of November 2019, OCHA provides housing assistance to 83 senior Lake Forest households - 24 senior Lake Forest households are on OCHA’s housing assistance waitlist.

Persons with Disabilities: According to the 2013-2017 ACS, approximately 7.2% of Lake Forest’s population has one or more disabilities. Federal laws define a person with a disability as "Any person who has a physical or mental impairment that substantially limits one or more major life activities...” Examples of disabilities include hearing, mobility, and visual impairments, chronic alcoholism, and mental illness. As of November 2019, OCHA provides housing assistance to 123 disabled Lake Forest households - 36 disabled Lake Forest households are on the housing assistance waitlist. The Regional Center is a nonprofit that coordinates services for individuals with developmental disabilities. They offer services ranging from housing and self-determination programs to job training and placement.

Victims of Domestic Violence: Domestic violence is displayed in many forms; intimidation, physical assault, sexual assault, and other abusive behavior that is part of a pattern of control by a partner against another. Nationwide it is estimated that one in three women and one in seven men experience some form of domestic violence by an intimate partner. The California Department of Justice reports that in 2018, 272 domestic violence calls for assistance were reported in Lake Forest. For these individuals, temporary safe housing is vital. The 2019 PITS estimates that in the South SPA, 11.3% of homeless adults Consolidated Plan LAKE FOREST 47
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are victims of domestic violence - 25% are unsheltered. Housing and support options are available for victims of domestic violence.

Persons with HIV/AIDS: Persons with HIV/AIDS are considered a special needs group due to their need for health care and supportive services. Persons with HIV/AIDS may also face bias and misunderstanding about their illness that may affect their access to housing. Furthermore, these households may also have special needs in that they may have trouble balancing their incomes with medical expenses due to their illness, putting them at-risk of becoming homeless.

The Orange County Health Care Agency estimated that as of 2024, there were 113 people living with HIV in in Lake Forest. Demographic data regarding the characteristics of this group include the following:
• Gender: 95 were male, 16 were female
• Race/Ethnicity: 50 were Hispanic, 44 were White, and 11 were Asian • Age: 40 were age 56 and older and all other age categories had approximately 20 people Several service providers are available to help special needs populations. Safety net services allow special needs populations to save limited financial resources on items such as transportation, after-school care, and food/clothing. Additionally, fair housing enforcement and rental assistance vouchers are valuable housing resources for special needs populations. The service and housing needs of special needs populations were determined by the input of community stakeholders, government agencies, and service providers.

Discuss the size and characteristics of the population with HIV/AIDS and their families within the Eligible Metropolitan Statistical Area:

Persons with HIV/AIDS are considered a special needs group due to their need for health care and supportive services. Persons with HIV/AIDS may also face bias and misunderstanding about their illness that may affect their access to housing. Furthermore, these households may also have special needs in that they may have trouble balancing their incomes with medical expenses due to their illness, putting them at-risk of becoming homeless.

No HIV/AIDS-dedicated housing is located in Lake Forest; however, the AIDS Services Foundation has a motel program that will allow those with HIV/AIDS facing homelessness to stay in motels throughout the region for a limited time. The following HIV/AIDS housing resources are available to residents on a countywide basis:
• Aid Services Foundation has 18 beds in its transitional housing program • Gerry House has six beds in their six-month transitional housing recovery program with set-aside beds for those with HIV/AIDS
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If the PJ will establish a preference for a HOME TBRA activity for persons with a specific category of disabilities (e.g., persons with HIV/AIDS or chronic mental illness), describe their unmet need for housing and services needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2) (ii)) The City does not receive HOME funds.

Discussion:

A percentage of the City’s population has special needs that may require unique housing options and services. These special needs groups include senior and frail elderly, the disabled, victims of domestic violence, and persons with HIV/AIDS. While housing and service programs are available to these special needs populations, additional resources may be needed to address individual needs.

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NA-50 Non-Housing Community Development Needs – 91.215 (f) Describe the jurisdiction’s need for Public Facilities:

Based on responses to the City’s community needs survey, improving parks and recreation facilities are priorities. The City is addressing this community priority, as evident by the recent completion of a new community center and senior center, and the construction of new sports and recreation facilities. A comprehensive needs assessment of the City’s parks was recently completed, which identified improvements for the community’s parks, including new playground equipment, improvements to courts and fields, and installing/upgrading landscaping and other facilities such as restrooms.

Whenever the City contemplates improvements to public facilities, it must consider the implications of compliance with the American with Disabilities Act. Public agencies, such as the City, are required under the American with Disabilities Act of 1990 (ADA) to perform “self-evaluations” of their current facilities relative to the accessibility requirements of the ADA. Under this law, the City must have a plan to make public facilities ADA accessible. The City has developed a Transition Plan that details which public facilities do not meet current ADA requirements. Some of the improvements identified in the Transition Plan may be addressed with CDBG funding.

How were these needs determined?
2025 Consolidated Plan Community Survey and city staff.

Describe the jurisdiction’s need for Public Improvements:

Top issues identified by the community in the 2025 Consolidated Plan Community Survey include water/sewer system improvements, residential street improvements, and sidewalk improvements.

Water, sewer, and storm water infrastructure and services are provided by other public agencies or special districts, and may not be CDBG-eligible. Budget consideration may be given to other identified priorities such as residential streets and sidewalks improvements within CDBG-eligible areas. The City’s ADA Transition Plan also identifies numerous curb ramps that need upgrading to current ADA standards.

How were these needs determined?
2025 Consolidated Plan Community Survey and city staff.

Describe the jurisdiction’s need for Public Services:

Based on responses to the 2025 Consolidated Plan Community Survey, health and youth services are identified as highly needed. Other need priorities include senior services and childcare. Among homeless services, outreach, mental/behavioral health services, homelessness prevention, and emergency shelter are ranked as the highest needs.

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How were these needs determined?
2025 Consolidated Plan Community Survey and consultation with local service providers.

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Housing Market Analysis
MA-05 Overview
Housing Market Analysis Overview:

The purpose of the Market Analysis is to provide a clear picture of the City’s housing market, including the significant characteristics of housing supply, housing conditions, and cost. The Housing Market Analysis, in conjunction with the Needs Assessment, will provide the basis for the Strategic Plan to identify programs and projects to be funded and administered as part of the CDBG program.

Most of the data tables in this section are populated by default with data from the Comprehensive Housing Affordability Strategy (CHAS), the special tabulation of housing data produced by the Census Bureau for HUD. Additional data is derived from the American Community Survey (ACS) and other updated sources. The Market Analysis will also examine barriers to affordable housing, including impediments to fair housing choice.

Based on the data reviewed in the Needs Assessment and the following Market Analysis, several characteristics of the City’s housing market have indicated that affordable housing is a key issue in the City. As such, the City has given this Need a High Priority level in the Consolidated Plan. Currently there is a large need for homes to accommodate small families and alleviate the significant overcrowding occurring that is disproportionately impacting those low- and moderate-income residents. As the City’s population continues to age, there may be less pressure on the housing market for larger homes and greater need for smaller, more affordable homes, since only 13 percent of the housing stock is made up of efficiencies and one-bedrooms. Additionally, there are very limited ownership opportunities for these smaller units (2%) that would benefit seniors and single households; thus, balance will be needed when approving development projects.

In the last decade, the City has continued to pursue affordable housing development; however, the lack of monetary resources available to create new affordable housing units of adequate size and lack of current inventory, housing affordability and overcrowding problems for Small Families will continue to be a challenge to the community during the period of the FY 2025-2030 Consolidated Plan.

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MA-10 Number of Housing Units – 91.210(a)&(b)(2)
Introduction
HUD defines a housing unit as a house, an apartment, or a single room, occupied as a separate living quarter, or if vacant, intended for occupancy as a separate living quarter. This section of the Consolidated Plan will assess the housing characteristics of the City’s housing supply, including unit type and tenure, age, condition, affordability, and availability.

Based on data from Table 27, Lake Forest’s housing stock is primarily comprised of one-unit structures (approximately 73%). The data further shows the City has a total of 30,750 housing units with a small number of mobile homes that represent 4% of the housing stock.

According to Table 28, the majority (70.1%) of the City’s housing units are owner-occupied, and 29.9% are renter-occupied. However, based on bedroom mix, ownership is very limited for smaller households, as All residential properties by number of units
Property Type Number %
1-unit detached structure 17,165 56%
1-unit, attached structure 5,280 17%
2-4 units 1,565 5%
5-19 units 4,040 13%
20 or more units 1,545 5%
Mobile Home, boat, RV, van, etc 1,155 4%
Total 30,750 100%
Table 27 – Residential Properties by Unit Number
Data Source: 2016-2020 ACS
Unit Size by Tenure
Owners Renters
Number % Number %
No bedroom 60 0% 385 4%
1 bedroom 475 2% 2,550 29%
2 bedrooms 3,840 19% 3,220 37%
3 or more bedrooms 16,280 79% 2,540 29%
Total 20,655 100% 8,695 99%
Table 28 – Unit Size by Tenure
Data Source: 2016-2020 ACS
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Describe the number and targeting (income level/type of family served) of units assisted with federal, state, and local programs.

The City’s 2021–2029 Housing Element identified 398 affordable housing in the City distributed within several housing developments. The affordability covenants for several of these developments have expired; however, an updated listed of assisted units is available:
• AFH Affordable Housing Condo: 1 unit for lower-income families • SCO Transitional Housing Condo: 8 units for lower-income families • Madrid Transitional Housing Condo: 2 units for lower-income families • Saguaro Apartments: 3 units for lower-income families • Arroyo at Baker Ranch: 187 units for lower-income families • Mountain View Apartments: 70 units for lower-income families • The Meadows Senior Apartments: 64 units for lower-income seniors Provide an assessment of units expected to be lost from the affordable housing inventory for any reason, such as expiration of Section 8 contracts.

Of the 264 affordable units listed in the 2021-2029 Housing Element, affordable housing covenants have expired on 253 units. Affordable housing covenants on eight (transitional) units will expire between 2022 and 2026.

Does the availability of housing units meet the needs of the population? The Southern California Association of Governments (SCAG) undertakes a Regional Housing Needs Assessment (RHNA) to quantify the anticipated need for housing within a five-county region. California General Plan law requires the City to have land zoned to accommodate its fair share of the regional housing need as calculated by SCAG. The goal of the RHNA is to ensure an equitable distribution of housing among jurisdictions within SCAG’s region so that every community provides for a mix of housing for all economic segments. The housing allocation targets are not building requirements; instead, they are planning goals for each community to accommodate through appropriate planning policies and land use regulations. Allocation targets are intended to assure that adequate sites and zoning are made available to address anticipated housing demand during the planning period. The distribution of housing needs by income category for each jurisdiction is adjusted to avoid an overconcentration of lower-income households in any community. For the current planning period (2021 through 2029), the City’s RHNA allocation is 2,727 new housing units.

According to a recent article in the Orange County Register, “California needs between 1.8 million and 3.5 million new homes by 2025. To get there, cities and counties would have to approve two to four times the number of homes they’ve been permitting in the past few years. But instead of approving more homes, almost every California city and county is falling behind its state-mandated housing goal….” [“California needs more housing, but 97% of cities and counties are failing to issue enough RHNA Consolidated Plan LAKE FOREST 54
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permits.” Published December 9, 2019, O.C. Register.] According to this article, the City is not on track to issue sufficient housing construction permits to meet current RHNA goals. State and SCAG planners are in the process of establishing RHNA goals for jurisdictions for the next planning cycle. These goals are yet to be finalized. Once established, the City will evaluate options to comply with applicable State requirements.

HUD data from Table 9 estimates that 7,026 lower-income Lake Forest households have a housing cost burden. Based on the current supply of housing units, there appears to be a gap of housing units affordable to many residents, especially lower-lower income households.

Describe the need for specific types of housing:

As previously outlined in the Housing Needs Assessment, housing costs in the region and specifically the City, present an issue for many households regardless of income, size, or tenure. Among lower-income households, senior and small related households appear to be experiencing housing costs challenges at a higher rate.

Discussion
The City’s housing stock is comprised primarily of single units. State and regional planners have established goals for all jurisdictions to create an environment to allow for the creation of housing that is affordable to different income levels. While the City has encouraged the development of many housing units, there appears to be a need for additional units, particularly affordable to lower-income households.

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MA-15 Housing Market Analysis: Cost of Housing - 91.210(a) Introduction
It is reported that the median home sales price in Orange County in December 2019 was $840,000 – the second highest on record. [“Buyer competition fuels 16% jump in Southern California house sales.” Orange County Register, published January 17, 2020.] The rise in home sales prices has been driven by low interest rates and a low supply of available housing units. According to Zillow.com, in January 2020, the median home sales price in Lake Forest was $736,702, a 40.5% increase from the 2015 median value listed in Table 29. With respect to rents, Zillow reports the median Lake Forest list rent in January 2020 was $3,100.

Cost of Housing
Base Year: 2009 Most Recent Year: 2020 % Change
Median Home Value 524,400 682,700 30%
Median Contract Rent 1,619 2,009 24%
Table 29 – Cost of Housing
Data Source: 2000 Census (Base Year), 2016-2020 ACS (Most Recent Year) Rent Paid Number %
Less than $500 365 4.2%
$500-999 155 1.8%
$1,000-1,499 525 6.0%
$1,500-1,999 3,350 38.6%
$2,000 or more 4,290 49.4%
Total 8,685 100.0%
Table 30 - Rent Paid
Data Source: 2016-2020 ACS
Housing Affordability
Number of Units affordable to
Households earning
Renter Owner
30% HAMFI 335 No Data
50% HAMFI 510 565
80% HAMFI 3,900 1,220
100% HAMFI No Data 2,854
Total 4,745 4,639
Table 31 – Housing Affordability
Data Source: 2016-2020 CHAS
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Monthly Rent
Monthly Rent ($) Efficiency (no
bedroom)
1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom
Fair Market Rent 2,200 2,344 2,783 3,769 4,467
High HOME Rent 1,826 1,958 2,352 2,708 3,001
Low HOME Rent 1,381 1,479 1,776 2,051 2,288
Table 32 – Monthly Rent
Data Source: HUD FMR and HOME Rents
Is there sufficient housing for households at all income levels? Based on HUD data tables above, it appears there is a limited supply of housing units affordable to lower income households. With a median home price of $736,702 and a current median list rent of $3,100, it is evident there is an insufficient supply of affordable housing for households at most income levels. The 2019-20 Community Indicators, produced by the Orange County Business Council, concludes a minimum annual income of $110,160 is needed to purchase an entry-level home in Orange County (estimated at $680,000). This income requirement exceeds the average annual salary of many occupations, such as retail sales clerks, secretaries, computer programmers, elementary school teachers, and nurses. The 2019-20 Community Indicators also finds that “To afford a median-prices one-bedroom apartment in 2019, an Orange County resident would need to make $31.38 per hour – equivalent to an annual income of $66,310… A minimum wage worker in Orange County would have to work 105 hours a week to afford a one-bedroom apartment, 131 hours to afford a two-bedroom unit, and 183 hours to afford a threebedroom.” [2019-20 Orange County Community Indicators, page 54-58.] How is affordability of housing likely to change considering changes to home values and/or rents?
The California Association of Realtors reports that current economic trends indicate a continued strong housing market in Orange County. Contributing economic indicators include low inflation, low unemployment, low-interest rates, and high consumer confidence. In response to a perceived affordable housing crisis in the State, as 2019 came to an end, the State legislature passes a series of housing bills aimed at easing the housing crisis. Measures such as AB 1482 will limit annual rent increases to 5% and requires landlords to have “just cause” when evicting a tenant. Other bills open the door for building additional housing units by right and allowing higher densities in certain transit districts. These enacted housing bills will most likely change the State, regional, and local housing market; however, both intended and unintended consequences of these bills remain to be understood.

How do HOME rents / Fair Market Rent compare to Area Median Rent? How might this impact your strategy to produce or preserve affordable housing? Consolidated Plan LAKE FOREST 57
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The City of Lake Forest is not a participating jurisdiction in HUD’s HOME program; however, HUD’s current rent limits for the program are listed in Table 32. Based on a comparison of these rent levels to rents listed on certain on-line housing services, it is evident that significant subsidies or other concessions would be necessary to create units that are affordable to lower-income households.

Discussion
Orange County remains one of the nation’s most expensive housing markets. Data indicates that median home sales prices and monthly rents are out of reach of many lower-income and moderate-income households. Current economic trends also indicate housing costs will likely remain out of reach of many of the region’s residents. The State of California has taken legislative action to address a growing housing shortage; however, the future impacts of this legislation are unknown.

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MA-20 Housing Market Analysis: Condition of Housing – 91.210(a) Introduction
Assessing housing conditions in a City can provide the basis for developing policies and programs to maintain and preserve the quality of life. Deteriorating housing conditions depress property values and can discourage reinvestment in a community. Consequently, maintaining or improving housing conditions is often an important goal for cities.

Describe the jurisdiction's definition of "standard condition" and "substandard condition but suitable for rehabilitation":

Substandard Condition: A dwelling unit that contains a condition that endangers the life, limb, health, property, safety, or welfare of the public or the occupants. The conditions that make a property a substandard unit are defined in the California Health & Safety Code Section 17920.3.

Substandard Condition but suitable for Rehabilitation: For purposes of the CDBG program, this term means that the cost of remedying all substandard conditions plus the current value of the property does not exceed the after-rehabilitation value of the property.

Housing Problems: As defined by HUD:

1. Lack of complete kitchen or plumbing facilities

2. More than one person per room

3. Cost burden greater than 30%
Condition of Units
Condition of Units Owner-Occupied Renter-Occupied
Number % Number %
With one selected Condition 6,120 30% 4,690 54%
With two selected Conditions 90 0% 515 6%
With three selected Conditions 10 0% 0 0%
With four selected Conditions 0 0% 0 0%
No selected Conditions 14,430 70% 3,480 40%
Total 20,650 100% 8,685 100%
Table 33 - Condition of Units
Data Source: 2016-2020 ACS
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Year Unit Built
Year Unit Built Owner-Occupied Renter-Occupied
Number % Number %
2000 or later 1,780 9% 1,090 13%
1980-1999 9,915 48% 4,485 52%
1950-1979 8,870 43% 3,100 36%
Before 1950 85 0% 20 0%
Total 20,650 100% 8,695 101%
Table 34 – Year Unit Built
Data Source: 2016-2020 CHAS
Risk of Lead-Based Paint Hazard
Risk of Lead-Based Paint Hazard Owner-Occupied Renter-Occupied Number % Number %
Total Number of Units Built Before 1980 8,955 43% 3,120 36% Housing Units build before 1980 with children present 2,860 14% 1,935 22% Table 35 – Risk of Lead-Based Paint
Data Source: 2016-2020 ACS (Total Units) 2016-2020 CHAS (Units with Children present) Vacant Units
Suitable for
Rehabilitation
Not Suitable for
Rehabilitation
Total
Vacant Units
Abandoned Vacant Units
REO Properties
Abandoned REO Properties
Table 36 - Vacant Units
Data Source: 2005-2009 CHAS

UPDATED INFORMATION
There are limited data sources regarding vacant units and REO properties within the City. Based on data from the State of California Department of Labor, as of January 1, 2019, the City’s housing vacancy rate is

3.7% (approximately 1,100 units). Based on information from RealtyTrac, in December 2019, there were 28 properties in Lake Forest that were in some stage of foreclosure (default, auction or bank owned).

Need for Owner and Rental Rehabilitation
Estimated Number of Housing Units Occupied by Low or Moderate Income Families with LBP Hazards
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For determining the number of housing units with lead-based paint, the age of the housing stock is the critical variable. Since 1978, the federal government has prohibited the use of lead-based paint on residential property; however, national studies estimated that 75% of all residential structures built before 1978 contain lead-based paint (LBP). However, not all units with LBP present a hazard. Only testing for lead in dust, soil, deteriorated paint, chewable paint surfaces, friction paint surfaces, or impact paint surfaces will provide information about hazards. Overall, these conditions are not prevalent in Lake Forest.

According to the data in Table 35, approximately 47% of the City’s housing stock (12,663 units) was built before 1980 and may contain LBP. Most impacted by lead hazards are children under six years of age. HUD data estimates there are 4,380 housing units in the City with children present, that may have a lead-based paint issue. The State of California and the County of Orange Department of Public Health report that in 2018, 1.02% of 32,426 children under age six that were screened for blood lead levels (BLL), had a BLL over 4.5 micrograms of per deciliter (µg/dL). (4.5 µg/d is the BLL level the Center for Disease Control and Prevention (CDC) considers “high”). The most recent data regarding elevated BLL for Lake Forest children less than age six is from 2012. In 2012, the CDC reports that 13 of 737 children tested had BLL greater than 4.5 µg/d. This data is not specific to lead-based paint; nonetheless, the data indicate that elevated blood lead among the City’s young children is not a significant issue. Regardless, the City will take proactive action to educate parents of the developmental issues to young children associated with lead and will address lead-based paint hazards as part of its housing rehabilitation programs.

Discussion
In general, Lake Forest’s housing stock is well maintained and in good to excellent condition; however, it is important to note that a significant percentage of the housing stock is over 30 years old. After 30 years, homes may begin to require substantial maintenance and even extensive rehabilitation (e.g., roof, electrical, plumbing). Additionally, some residences constructed before 1978 may have lead-based paint hazards.

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MA-25 Public and Assisted Housing – 91.210(b)
Introduction
The City of Lake Forest does not own or operate any public housing units.

Totals Number of Units
Program Type
Certificate Mod-Rehab Public
Housing
Vouchers
Total Project -based Tenant -based Special Purpose Voucher Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units vouchers
available 9,925 879 1,669 0
# of accessible units
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 37 – Total Number of Units by Program Type
Data Source: PIC (PIH Information Center)
Describe the supply of public housing developments:

Describe the number and physical condition of public housing units in the jurisdiction, including those that are participating in an approved Public Housing Agency Plan:

Not applicable
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Public Housing Condition
Public Housing Development Average Inspection Score
Table 38 - Public Housing Condition
Describe the restoration and revitalization needs of public housing units in the jurisdiction:

Not applicable
Describe the public housing agency's strategy for improving the living environment of lowand moderate-income families residing in public housing:

Not applicable
Discussion:

The City of Lake Forest does not own or operate any public housing units.

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MA-30 Homeless Facilities and Services – 91.210(c)
Introduction
As previously discussed, the OC-CoC conducts a biennial point in time count and survey of the region’s homeless. The 2024 Point-In-Time Survey also includes an inventory of homeless shelter resources. Information presented in Table 39 identifies homeless shelter beds in Lake Forest.

Facilities and Housing Targeted to Homeless Households
Emergency Shelter Beds Transitional
Housing Beds
Permanent Supportive Housing
Beds
Year Round Beds
(Current & New)
Voucher /
Seasonal /
Overflow Beds
Current & New Current & New Under
Development
Households with Adult(s) and
Child(ren) 0 0 35 0 0
Households with Only Adults 0 0 0 0 0
Chronically Homeless Households 0 0 0 0 0
Veterans 0 0 0 0 0
Unaccompanied Youth 0 0 0 0 0
Table 39 - Facilities and Housing Targeted to Homeless Households Data Source Comments:

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Describe mainstream services, such as health, mental health, and employment services to the extent those services are use to complement services targeted to homeless persons The City of Lake Forest does not provide direct services for the homeless; however, it does fund nonprofit agencies that provide housing and support services for homeless Lake Forest residents. Case managers at these service agencies work closely with clients to identify appropriate mainstream services available to them and guide them through the qualification process. Examples of mainstream services include veterans housing vouchers, veteran medical services, MediCal/Medicare, SSI, and general relief.

List and describe services and facilities that meet the needs of homeless persons, particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth. If the services and facilities are listed on screen SP-40 Institutional Delivery Structure or screen MA-35 Special Needs Facilities and Services, describe how these facilities and services specifically address the needs of these populations.

As indicated in Table 39, the OC-CoC identifies 35 transitional housing beds in Lake Forest. These shelter beds are reserved for homeless families.

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MA-35 Special Needs Facilities and Services – 91.210(d) Introduction
HUD requires that the Consolidated Plan describe, to the extent information is available, facilities, and services that are available assist persons who are not homeless but that have special needs.

Including the elderly, frail elderly, persons with disabilities (mental, physical, developmental), persons with alcohol or other drug addictions, persons with HIV/AIDS and their families, public housing residents and any other categories the jurisdiction may specify, and describe their supportive housing needs
Senior and Frail Elderly: There are several skilled nursing and residential care facilities located in Lake Forest. According to the California Department of Social Services Community Licensing Division, there are 805 residential care beds in 47 facilities in Lake Forest. The bulk of these facilities are six-bed facilities operating in residential neighborhoods. There are no subsidized senior housing units in the City; however, there are two complexes that offer 57 and 64 affordable senior housing units respectively.

Group Homes/Quarters: The State reports that as of January 2025, there are 515 Lake Forest residents living in group housing. Examples of group housing included homes for the mentally disabled and physically disabled, seniors, and those recovering from substance addiction. In recent years some recovery homes have had negative impacts on residential neighborhoods. Due to current federal and state regulations, the City’s ability to take specific enforcement action is limited; nonetheless, the City continues to seek different avenues to address and mitigate some of the neighborhood impacts caused by problematic operators.

HIV/AIDS Housing: As previously outlined, there are no shelters or permanent housing units for persons with HIV/AIDS in Lake Forest.

Public Housing Residents: There is no public housing in Lake Forest. As of April 2025, a total of 203 households in Lake Forest are receiving a rental housing voucher or certificate from OCHA.

Describe programs for ensuring that persons returning from mental and physical health institutions receive appropriate supportive housing
In Lake Forest, while not necessarily receiving CDBG funding, several programs and resources are available throughout the city to assist individuals transitioning from mental health facilities into supportive housing.

Here are some key services:
• 2-1-1 Orange County: A 24/7 helpline that connects people to services like housing, healthcare, food, and mental health support.

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• Lake Forest Homeless Engagement and Resources Team (LFHEART): Provides access to shelter, mental health care, legal help, housing referrals, and other support for people experiencing homelessness.
• Lake Family Resource Center: Supports survivors of domestic violence with rent assistance, counseling, safety planning, and legal advocacy. Orange County Rescue Mission: Offers transitional housing, food, job training, mental health services, and addiction recovery program tailored for veterans, families, youth, victims of domestic violence, and victims of sex trafficking. • Collaboration with organizations like: Age Well Senior Services, Camino Family Health Center, Families Forward, Families Assistance Ministries, and South County Outreach to provide housing assistance, employment opportunities, mental health services, and basic necessities. • Collaboration with the County of Orange to offer various housing assistance programs including:
o Housing Choice Voucher Program: assists low-income individuals and families with rental housing.
o Affordable Housing Developments including:
 The Arroyo at Baker Ranch: A 189-unit affordable family apartment community.  Portola Senior Apartments: A 57-unit affordable housing project for seniors aged 62 and older.
 Mountain View Apartments: A 71-unit affordable housing project currently under construction.
 The Meadows Senior Affordable Apartments: A 65-unit complex, including 64 senior affordable units and one manager’s unit.

These resources aim to provide comprehensive support for individuals transitioning from mental health facilities, ensuring access to appropriate housing and essential services in Lake Forest.

Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals.

91.315(e)
The City will continue to support various local organizations each year of the Consolidated Plan that provide services to persons with special needs. Agencies funded will depend on applications received annually through the City's NoFA. For the first year of the plan, the following service providers will be funded:
• Age Well Senior Services
• Boys & Girls Club of Laguna Beach
• Camino Health Services
• Fair Housing Council of OC
• Families Forward
• Family Assistance Ministry
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• South County Outreach
The City will also continue to support the efforts of OCHA to obtain additional housing vouchers and certificates for disabled, elderly, and other special needs households. Additionally, as new housing opportunities are designed and developed, the City will work with developers to ensure accessible units are incorporated into projects as required by federal and state regulations.

For entitlement/consortia grantees: Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals. (91.220(2))
The City does not receive HOME funds either directly as an entitlement or indirectly through a consortium.

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MA-40 Barriers to Affordable Housing – 91.210(e)
Negative Effects of Public Policies on Affordable Housing and Residential Investment Lake Forest's Housing Element for the 2021-2029 planning period identifies several constraints to affordable housing development. Key constraints include:

1. Limited Availability of Residential Land: Lake Forest has largely developed its residentially designated lands, with future residential development primarily limited to recycling existing units and completing infill development. While the city's sphere of influence contains substantial vacant land suitable for new development, additional residential development is planned in areas like Portola Hills and Foothill Ranch, which may not be immediately accessible for affordable housing projects.

2. High Development Standards: The city's mixed-use zoning regulations, designed to encourage residential development, impose certain standards that could be seen as constraints. For example, the Mixed-Use 43 (MU 43) district allows a maximum density of 43 dwelling units per net acre and a maximum Floor Area Ratio (FAR) of 1.2:1, with building heights limited to 65 feet. While these standards aim to promote development, they may not fully align with the affordability objectives of the Housing Element.

3. Infrastructure and Service Constraints: Ensuring that adequate infrastructure and services are available to support new affordable housing developments can be a constraint. The Housing Element Sites Inventory Regulations require that residential developments on rezone sites permit at least 16 units, with a minimum residential density of 20 dwelling units per net acre. This density requirement may necessitate significant infrastructure enhancements, posing challenges to affordability.

4. Market Constraints: The broader housing market in Orange County, characterized by high land and construction costs, poses challenges to developing affordable housing in Lake Forest. These market conditions can make it difficult for developers to produce housing that is affordable to low- and moderateincome households without substantial subsidies.

Addressing these constraints requires a multifaceted approach, including revising zoning regulations to allow for greater residential densities, ensuring that infrastructure improvements are cost-effective, and exploring financial incentives to make affordable housing projects more viable.

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MA-45 Non-Housing Community Development Assets – 91.215 (f) Introduction
According to the data from Table 40, the top business sectors in Lake Forest are Education and Health Care Services Professional, Scientific, Management Services Arts, Entertainment, Accommodations Retail Trade, accounting for 57 percent of workers.

Data from Table 41, shows the City has a workforce of 47,845 individuals, which is an increase of 4,345 from the last Plan. The unemployment rate of 4.88% is a slight decrease from the last Plan, which reported an unemployment rate of 5.63%; however, the unemployment rate for young adults is significantly higher at 17.51%. Major sectors include Management, business and finance, Sales and office, and Service occupations (Table 42). The majority of workers can get to work in less than an hour, with only 7 percent reporting a longer commute (Table 43). Workers are mostly well educated with only 6 percent being less than a high school graduate and 82 percent having some type of college education (Table 44). When looking at the data in Table 45 (level of educational attainment by age), it appears that approximately 23% of the City’s seniors have less than a college education, which would indicate more of a burden on their already fixed incomes. Most of these seniors probably don’t have a pension and rely on social security.

As shown in Table 46, median earnings for those with high school equivalent or less are less than $63,000 per year.

Economic Development Market Analysis Business Activity
Business by Sector Number of
Workers
Number of
Jobs
Share of
Workers
%
Share of
Jobs
%
Jobs less
workers
%
Agriculture, Mining, Oil & Gas Extraction 230 95 1 0 0
Arts, Entertainment, Accommodations 5,026 4,387 12 12 -1 Construction 2,193 3,252 5 9 3
Education and Health Care Services 6,237 3,253 15 9 -7
Finance, Insurance, and Real Estate 3,591 3,714 9 10 1
Information 1,357 563 3 2 -2
Manufacturing 3,939 4,767 10 13 3
Other Services 1,308 1,410 3 4 1
Professional, Scientific, Management
Services 5,958 6,702 15 18 3
Public Administration 0 0 0 0 0
Retail Trade 4,059 3,170 10 8 -2
Transportation and Warehousing 950 214 2 1 -2
Wholesale Trade 2,683 3,349 7 9 2
Total 37,531 34,876 -- -- --
Table 40 - Business Activity
Data
Source:
2016-2020 ACS (Workers), 2020 Longitudinal Employer-Household Dynamics (Jobs) Consolidated Plan LAKE FOREST 70
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Labor Force
Total Population in the Civilian Labor Force 47,845
Civilian Employed Population 16 years and
over 45,505
Unemployment Rate 4.88
Unemployment Rate for Ages 16-24 17.51
Unemployment Rate for Ages 25-65 3.34
Table 41 - Labor Force
Data Source: 2016-2020 ACS
Occupations by Sector Number of People
Management, business and financial 17,570
Farming, fisheries and forestry occupations 1,215
Service 4,365
Sales and office 10,045
Construction, extraction, maintenance and
repair 2,085
Production, transportation and material
moving 1,450
Table 42 – Occupations by Sector
Data Source: 2016-2020 ACS
Travel Time
Travel Time Number Percentage
< 30 Minutes 25,388 63%
30-59 Minutes 11,809 29%
60 or More Minutes 2,904 7%
Total 40,101 100%
Table 43 - Travel Time
Data Source: 2016-2020 ACS
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Education:

Educational Attainment by Employment Status (Population 16 and Older) Educational Attainment In Labor Force
Civilian Employed Unemployed Not in Labor
Force
Less than high school graduate 2,330 205 1,085
High school graduate (includes
equivalency) 4,565 205 1,410
Some college or Associate's degree 11,315 630 2,385
Bachelor's degree or higher 19,860 570 3,730
Table 44 - Educational Attainment by Employment Status
Data Source: 2016-2020 ACS
Educational Attainment by Age
Age
18–24 yrs 25–34 yrs 35–44 yrs 45–65 yrs 65+ yrs
Less than 9th grade 200 230 435 1,010 475
9th to 12th grade, no diploma 410 690 515 735 355
High school graduate, GED, or
alternative 1,685 1,355 1,335 3,495 1,860
Some college, no degree 2,685 2,845 2,210 5,205 2,495
Associate's degree 440 1,035 800 2,235 1,075
Bachelor's degree 990 4,370 4,145 7,285 3,070
Graduate or professional degree 50 1,680 2,770 3,945 2,150 Table 45 - Educational Attainment by Age
Data Source: 2016-2020 ACS
Educational Attainment – Median Earnings in the Past 12 Months Educational Attainment Median Earnings in the Past 12 Months Less than high school graduate 60,706
High school graduate (includes equivalency) 63,010
Some college or Associate's degree 88,662
Bachelor's degree 135,120
Graduate or professional degree 191,934
Table 46 – Median Earnings in the Past 12 Months
Data Source: 2016-2020 ACS
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Based on the Business Activity table above, what are the major employment sectors within your jurisdiction?
According to Table 40, three major business activity sectors account for 41% of total “workers” and 37% of total “jobs.”
• Professional, Scientific, Management Services – 15% of Workers and 15% of Jobs • Education and Health Care Services – 14% of Workers and 11% of Jobs • Arts, Entertainment, Accommodations – 12% of Workers and 11% of Jobs Other leading business sectors include manufacturing, retail, and finance, insurance, and real estate. This data corresponds with the profile of several of the City’s top employers.

Describe the workforce and infrastructure needs of the business community:

The City has established an aggressive economic development program to attract and retain employers to the community. A City webpage provides comprehensive information regarding the City’s economic development program. Infrastructure improvements to support the expansion or revitalization of business and industrial centers are incorporated into the City’s Capital Improvement Budget. In addition to improvements to roads, parkways, and storm drains, the City may explore the feasibility of installing a high-speed fiber-optic network. A fiber internet uses fiber-optic lines, which are cables made of bundled strands of glass. Each glass strand acts as a conduit for light signals that relay digital code from one end to the other at the speed of light. This technology allows for internet speeds far beyond DSL and cable because each fiber-optic line can carry multiple signals at top speeds simultaneously.

Describe any major changes that may have an economic impact, such as planned local or regional public or private sector investments or initiatives that have affected or may affect job and business growth opportunities during the planning period. Describe any needs for workforce development, business support or infrastructure these changes may create.

The City has a strong commitment to fostering job creation and retention for Lake Forest businesses. The City demonstrates this commitment via the Growing and Retaining Our Workforce (GROW) program. The economic impacts of the Coronavirus pandemic remain unknown, however recent news reports indicate significant unemployment in most sectors of the local, state, and national labor markets. In response, the City allocated CDBG-Coronavirus (CDBG-CV) funds authorized by the CARES Act of 2020, for a small business assistance program. A portion of regular CDBG funds may be allocated on a short-term basis to assist local businesses create or retain jobs for lower-income individuals.

How do the skills and education of the current workforce correspond to employment opportunities in the jurisdiction?
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The Orange County Business Council 2020 Orange County Workforce Indicators Report provides a detailed overview of the region’s economy. The report identifies economic changes caused by new technologies and how new technology is transforming the workforce, the local economy, and the overall business climate of Orange County. Of all the trends that may impact the workplace, the report indicates, “Artificial Intelligence (AI) has the greatest transformative potential.” Furthermore, “While new technologies will likely create more jobs than it replaces in the long term, the labor market may face disruptions and widening skills gaps in the short term…. Soft skills will be the key to navigate this transformative period.” The report loosely defines soft skills as the ability to work well in a group and demonstrate the “kind of creativity exhibited by writers and painters.” Effective leadership, communication, and time management are critical soft skills. According to the Business Council report, “These skills… will likely prove to be some of the most defensible skills in an era of increasing automation ... they will survive long after many technical skills become obsolete.”
The Workforce Indicators Report further outlines that educators can prepare tomorrow’s workers by helping students focus on non-automatable skills and activities such as creative, critical thinking, and teamwork. “Education itself will have to expand into more of a lifelong process rather than just a degree or certificate. As technology and other changes continue to transform jobs, workers will need to constantly develop and refine skills in order to keep up.” This workforce report provides examples of how major corporations are finding it more efficient and cost-effective to retrain workers to develop the skills necessary for the future rather than dismissing “redundant” positions and hiring new workers with the required skills.

According to HUD data, the City has a well-educated, professional workforce. Lake Forest’s population seems well matched for the region’s economy; however, HUD data and recent studies of the Orange County workforce also indicate that a significant percentage of the City’s workforce is employed outside of the city limits. Table 43 estimates that 39% of the City’s workforce commute time exceeds 30 minutes. A primary goal of the City’s economic development initiatives is to create and keep jobs in the City to achieve a better housing-jobs balance and create a vibrant and diverse local economy.

Describe any current workforce training initiatives, including those supported by Workforce Investment Boards, community colleges and other organizations. Describe how these efforts will support the jurisdiction's Consolidated Plan.

According to the 2020 Orange County Business Council’s Workforce Indicators Report, community colleges are playing a critical role in helping Orange County businesses expand. “Community colleges are able to adapt to the needs of a rapidly changing labor market much more quickly than their four-year counterparts, making them essential to many cutting-edge industries.” Furthermore, Orange County’s community colleges provides students with resources and knowledge to learn skills tailored explicitly for certain careers allowing them to find jobs they are already familiar with, thus reducing the likelihood of unemployment or underemployment. Examples of “Career Education” programs offered at local colleges include Information and Communication Technology, Process Technology, Energy Efficiency and Consolidated Plan LAKE FOREST 74
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Renewables, and Science and Medical Technology. The county’s universities will continue at the vanguard of research and innovation, which fuels the region’s economy.

Does your jurisdiction participate in a Comprehensive Economic Development Strategy (CEDS)? No
If so, what economic development initiatives are you undertaking that may be coordinated with the Consolidated Plan? If not, describe other local/regional plans or initiatives that impact economic growth.

Discussion
Lake Forest will continue to support and promote local business attraction and retention, thereby fostering job creation and retention, and coordinating these efforts with job training and placement programs to provide expanded economic opportunities for its low- to moderate-income residents. In response to significant unemployment resulting from the Coronavirus CDBG funds may be allocated on a short-term basis to assist local businesses create or retain jobs for lower-income individuals.

The State of California Employment Development Department reported the unemployment rate for Lake Forest as of December 31, 2024, was 3.5%, this is significantly lower than the 8.2% reported during the last Consolidated Plan.

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MA-50 Needs and Market Analysis Discussion
Are there areas where households with multiple housing problems are concentrated? (include a definition of "concentration")
Housing problems impact low- and moderate- income households disproportionately, compared to higher income households; thus, areas with concentrations of low- and moderate-income households are likely to have high rates of housing problems.

An area of low- and moderate-income concentration is usually defined as a census tract or block group in which the number of low-income persons (defined as persons earning 50 percent or less of the County median income) exceeds 51 percent of the total number of persons. However, the City of Lake Forest is an exception grantee per HUD guidelines and this percentage is 49.9 percent.

Per the 2020 ACS, there are 14 Census Tract block groups considered to be low- and moderate-income, of which eight have high concentrations of over ten percentage points of the overall City percentage as follows:

Tract Blockgroup Lowmod Lowmod_pct
032047 1 775 68.90%
052411 1 1,130 51.50%
052424 1 1,085 66.40%
032014 2 1,025 71.90%
052410 2 400 66.10%
052411 2 1,095 70.60%
052422 2 525 51.50%
052423 2 1,425 61.40%
032014 3 2,055 89.20%
032027 3 975 67.20%
032029 3 835 49.90%
052410 3 1,070 54.50%
052425 4 1,325 56.30%
Total 13,720
Are there any areas in the jurisdiction where racial or ethnic minorities or low-income families are concentrated? (include a definition of "concentration") Maps illustrating areas of the City with minority concentrations are illustrated in Figure 2. -income. A comparison of these maps indicates there is some concentration of minority populations, lower-income residents, and housing cost burden.

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What are the characteristics of the market in these areas/neighborhoods? As evident from Figure 2, Census Tracts with a percentage of ethnic concentrations are mostly situated in the City’s southwest section. Figure 1 illustrates that this section of the City also has a concentration of CDBG-eligible Block Groups.

Are there any community assets in these areas/neighborhoods? Communities within the identified Census Tracts are primarily residential. Local and regional retail and commercial businesses the residents of this area, including El Toro Road - the City’s primary commercial core. Neighborhood amenities include community parks and middle and elementary schools.

Neighborhood schools support several programs that serve lower-income children with supplemental meals and after-school recreation and tutoring programs.

Are there other strategic opportunities in any of these areas? City planners will examine current land uses within the identified Census Tracts to identify potential opportunities to develop new housing and other amenities to improve the overall quality of life for existing area residents.

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MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income Households - 91.210(a)(4), 91.310(a)(2)
Describe the need for broadband wiring and connections for households, including low- and moderate-income households and neighborhoods.

Since 2008, the California Emerging Technology Fund (CETF), in partnership with the state, has tracked internet adoption across California. The 2023 Statewide Digital Equity Survey, conducted with the University of Southern California, reveals continued growth in broadband adoption, particularly among historically disadvantaged groups. However, significant digital equity challenges persist. Notably, the following percentages of key demographics remain unconnected: Non-English Speaking (14.8%), Low Income (13.0%), Rural (10.8%), 60 or Older (9.2%), Reported Disability (8.7%), Veteran (7.7%), Women (6.6%), and LGBTQIA+ (6.6%).

The 2023 Statewide Digital Equity Survey identified cost as the primary barrier to broadband adoption in California. The state's average monthly broadband cost of $83.60 aligns with national figures, such as the FCC's $82.40. However, Orange County's average of $91.50 is significantly higher, ranking second among the counties surveyed. For low-income households, broadband expenses consume an estimated 3.3% of disposable income, exceeding the FCC's recommended 2%. This financial strain underscores the importance of programs like the Affordable Connectivity Program (ACP). Despite this need, ACP awareness in Orange County is only 36.8%. Specific to the City of Lake Forest, the following ACP data has been identified for eligible households: 18% of Total Households in the City of Lake Forest are eligible for ACP Enrollment. Of those households 58% are currently enrolled in the program (858 Households Enrolled out of 42 Households ACP Eligible).

According to ISP Reports, the following internet providers in Lake Forest are ranked amongst the highest rated in the State of California:

1. AT&T

2. Cox Communications

3. T-Mobile Home Internet

4. Verizon
Based on various data sources, including FCC data, Cox Communications is the fastest internet provider in the City of Lake Forest. However, AT&T has the most affordable internet plan options available for broadband services in the City.

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Source: California Interactive Broadband Map – Median Household Income as of 12/31/2021 Consolidated Plan LAKE FOREST 82
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Source: California Interactive Broadband Map – Fixed Consumer Served Status as of 12/31/2021 Consolidated Plan LAKE FOREST 83
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Source: California Interactive Broadband Map –Consumer Fixed Downstream Availability as of 12/31/2021 Describe the need for increased competition by having more than one broadband Internet service provider serve the jurisdiction.

Increased competition among internet providers is crucial to delivering both higher-quality and more affordable broadband. This is vital for closing the digital divide, particularly for those with limited or no internet access. The high cost of broadband, exemplified by Orange County's average of $91.50 per month (compared to the FCC's report national average cost for broadband estimated at $82.40), is a significant barrier. Promoting competition amongst providers in the City of Lake Forest can result in lower broadband internet service costs, directly addressing the primary reason for households' lack of connectivity amongst low-income households in the City. This is important given that financial assistance to assist with overcoming such barriers can become scarce as funding sources are shifted to address other priorities. An example of this is the recent pause in 2024 to the Affordable Connectivity Program (ACP). Despite the program’s success, funding was significantly reduced causing the program to temporarily stop accepting applications from eligible households. With rising costs for goods and services, it is important to continue to drive competition to ensure households have a healthy amount of service options and prices available to choose from.

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MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3)
Describe the jurisdiction’s increased natural hazard risks associated with climate change.

The City’s current General Plan includes a Safety and Noise Element, which contains an assessment of specific natural hazards such as flooding and wildland fires. • Flooding: There are several water streams and creeks that traverse the City. The potential for flooding in semiarid environments such as Orange County is increased due to the variation and unpredictability in the amount and intensity of rainfall. Portions of the City are subject to inundation from a 100-year flood. Development within the 100-year floodplain is prohibited in floodways unless the development will not obscure flows or increase flood levels. • Wildland Fires: Lake Forest is subject to both wild and urban fires. The eastern portion of the City is adjacent to the Cleveland National Forest, which is considered a high fire hazard area. The regional natural vegetation is highly prone to wildfire – a hazard that can be exacerbated by prolonged drought.

Describe the vulnerability to these risks of housing occupied by low- and moderate-income households based on an analysis of data, findings, and methods.

The City’s General Plan includes a public safety plan that aims to “reduce the risk of death, injury, property damage, economic loss, and harm due to natural and manmade disasters.” Through this document, the City has developed policies to address natural hazards such as flooding and fire. • Develop and maintain an emergency preparedness plan, which will coordinate with the regional plan. The emergency preparedness plan will direct the City’s response to emergencies stemming from various types of disasters.
• Continue to participate in the National Flood Insurance Program. • Reduce the risk of wildland fire through fuel modification programs, especially where natural vegetation interfaces with urban development.

The City is currently updating the General Plan. The 2040 General Plan will provide updates to the City’s current planning documents, and will include policies and goals related to “Climate Change and Resiliency Planning.” The goal of this planning process is to ensure the City is “A well-prepared community where risks to life, property, the economy, and the environment resulting from climate change, including extreme weather events, are minimized.” The Climate Change and Resiliency Plan has the potential to impact all residents regardless of income.

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Strategic Plan
SP-05 Overview
Strategic Plan Overview
The Strategic Plan is the centerpiece of the City of Lake Forest’s 2025–2030 Consolidated Plan. The Strategic Plan identifies the programs and projects the City will undertake or consider during the five-year Consolidated Plan cycle. In addition to identifying resources, goals, and objectives to implement housing and community development activities, the Strategic Plan has several sub-strategies, including addressing homeless issues, overcoming barriers to affordable housing, and program/project monitoring efforts.

The City’s overall objective for the CDBG program mirrors the HUD’s program objective: to create a viable community by providing decent housing, a suitable living environment, and economic opportunities, principally for persons of low- and moderate-income. To this end, the following Consolidated Plan goals have been established based on the consultation and analysis process:
• Improve or expand the supply of housing affordable to lower-income households • Provide or improve public infrastructure and facilities that benefit low- and moderate-income neighborhoods and residents
• Provide or improve access to public social services for low- and moderate-income persons and persons with special needs
• Provide a continuum of housing and supportive services for the homeless and the near-homeless • Provide financial assistance to create or preserve employment opportunities for lower-income residents
• Provide program administration and planning activities needed to carry out actions that address needs identified in the Consolidated Plan, including fair housing services to address local impediments to fair housing
All programs and projects are subject to the availability of CDBG funds and the City’s annual budget adoption process.

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SP-10 Geographic Priorities – 91.215 (a)(1)
Geographic Area
Table 47 - Geographic Priority Areas
1 Area Name: CDBG TARGET AREAS
Area Type: Local Target area
Other Target Area Description:

HUD Approval Date:
% of Low/ Mod:

Revital Type: Other
Other Revital Description: INFRASTRUCTURE

IMPROVEMENTS
Identify the neighborhood boundaries for this target area.

Include specific housing and commercial characteristics of this target area.

How did your consultation and citizen participation process help you to identify this neighborhood as a target area?
Identify the needs in this target area.

What are the opportunities for improvement in this target area? Are there barriers to improvement in this target area?
2 Area Name: Citywide
Area Type: Citywide
Other Target Area Description: Citywide
HUD Approval Date:
% of Low/ Mod:

Revital Type:

Other Revital Description:

Identify the neighborhood boundaries for this target area.

Include specific housing and commercial characteristics of this target area.

How did your consultation and citizen participation process help you to identify this neighborhood as a target area?
Identify the needs in this target area.

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What are the opportunities for improvement in this target area? Are there barriers to improvement in this target area?
General Allocation Priorities
Describe the basis for allocating investments geographically within the jurisdiction (or within the EMSA for HOPWA)
CDBG funds will be allocated on a citywide basis for activities that primarily benefit qualified low- and moderate-income households (i.e., limited-clientele activities). Other activities such as public improvements will be limited to eligible areas (see Figure 1), except for ADA related improvements, which may be carried out on a much broader basis.

The City does not receive Housing Opportunities for Persons With AIDS (HOPWA) funds.

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SP-25 Priority Needs - 91.215(a)(2)
Priority Needs
Table 48 – Priority Needs Summary
1 Priority Need
Name
Affordable Housing
Priority Level High
Population Extremely Low
Low
Moderate
Geographic Areas
Affected
Citywide
Associated Goals Affordable Housing
Description Loans, grants, and other forms of subsidies to improve or expand the City's supply of housing affordable to lower-income households Basis for Relative
Priority
Needs analysis and public input
2 Priority Need
Name
Public Improvements
Priority Level High
Population Moderate
Non-housing Community Development
Geographic Areas
Affected

CDBG TARGET AREAS
Citywide
Associated Goals Infrastructure and Facility Improvements Description Installation of new or rehabilitation of existing public infrastructure and public facility improvements
Basis for Relative
Priority
Needs analysis, City department consultation, and public input 3 Priority Need
Name
Public Services
Priority Level High
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Population Extremely Low
Low
Moderate
Other
Geographic Areas
Affected
Citywide
Associated Goals Public Social Services
Description Social service programs that assistance to low- and moderate-income residents (may include fair housing services)
Basis for Relative
Priority
Needs Assessment, service providers input, and public input 4 Priority Need
Name
Homeless Support Services and Housing
Priority Level High
Population Chronic Homelessness
Individuals
Families with Children
Geographic Areas
Affected
Citywide
Associated Goals Homeless Continuum of Care
Description Housing and support services for the homeless and the near-homeless Basis for Relative
Priority
Needs Assessment, service providers input, and public input 5 Priority Need
Name
Economic Opportunities
Priority Level High
Population Moderate
Geographic Areas
Affected
Citywide
Associated Goals Economic Opportunities
Description Grants and other forms of assistance to create or expand for employment opportunities for lower-income individuals
Basis for Relative
Priority
Response to COVID-19 pandemic
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6 Priority Need
Name
Administration and Planning
Priority Level High
Population Other
Geographic Areas
Affected
Citywide
Associated Goals Program Administration
Description Program oversight and coordination, including fair housing services Basis for Relative
Priority
HUD required.

Narrative (Optional)
Impediments to Fair Housing: The Fair Housing Act of 1968 requires HUD and its program participants to administer housing and urban development programs in a manner that does not discriminate directly or indirectly based on race, color, religion, sex, national origin, age, familial status, or disability. The Fair Housing Act not only prohibited discrimination in housing-related activities and transactions but also requires entities to affirmatively further fair housing. The Analysis of Impediments (AI) to Fair Housing Choice is the primary policy document utilized by HUD grantees for this purpose. HUD encourages jurisdictions to consult with one another and initiate metropolitan-wide planning to address impediments to fair housing choice.

During the past Consolidated Plan cycles, the City participated in the development of a multi-jurisdictional AI. For the 2025-2029 AI cycle, Lake Forest has joined with other Orange County cities and the County of Orange to develop a county-wide AI. The 2025-2029 Orange County AI evaluates existing demographic data, past fair housing enforcement activity for each partner community, mortgage lender data, and existing housing and land use public policies. Based on an extensive analysis of this data, and the input of residents, a list of impediments to fair housing choice for the participating jurisdictions have been developed. A corresponding set of action steps to address these barriers have also been prepared. The 2025-2029 Orange County AI is incorporated into the Consolidated Plan in Appendix G.

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SP-30 Influence of Market Conditions – 91.215 (b)
Influence of Market Conditions
Affordable
Housing Type
Market Characteristics that will influence
the use of funds available for housing type
Tenant Based
Rental Assistance
(TBRA)
NA – CDBG can not be used for this type of activity.

TBRA for NonHomeless Special
Needs
NA – CDBG can not be used for this type of activity.

New Unit
Production
CDBG typically cannot be used for this type of activity; however, funds can be used for certain pre-development costs or off-site public improvements. The Needs Assessment and the Housing Market Analysis indicate there is a shortage of housing units affordable to lower-income households; however, due to the size of the City’s annual CDBG allocation, it is unlikely funds will be used for this purpose. A substantial amendment to the Consolidated Plan may be necessary if future funding is allocated for this type of activity.

Rehabilitation Based on the data provided in the Needs Assessment and the Market Analysis, the City’s housing stock is generally in good condition; however, there is a need for rehabilitating a portion of the City’s older housing stock.

Acquisition,
including
preservation
According to data provided in the Needs Assessment, 1,945 extremely lowincome households experience severe housing cost burden. Based on this data, the City could consider utilizing housing resources to improving the City’s older residential properties as a means of expanding housing opportunities for lower income households.

Table 49 – Influence of Market Conditions
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SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2) Introduction
Fluctuations in annual CDBG allocations make it difficult to determine anticipated resources for a fiveyear period; however, based on recent allocations, the City expects to receive approximately $475,000 annually in CDBG funding, for a five-year total of $2,375,000. The City uses CDBG funds for housing preservation activities, public improvements, public services, and administrative costs. In addition, approximately $450,000 of program income will be generated annually from the Housing Rehabilitation Loan Program loan payoffs for an additional $2,250,000 dedicated for housing activities through the revolving loan fund.

The City will receive $479,750 in CDBG funds for Fiscal Year 2025-2026. Additional resources for the year include prior year carryover funds totaling $180,764 and program income in the amount of $460,598.79 received during the fiscal year generated by the repayment of previously funded housing rehabilitation loans. Both amounts vary from year to year. The City anticipates that the County of Orange will continue to administer the federal rental assistance program in Lake Forest, assisting approximately 200 households per year. The City will continue efforts to leverage CDBG funds with other federal, state, and local funds.

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Anticipated Resources
Program Source
of
Funds
Uses of Funds Expected Amount Available Year 1 Expected Amount
Available
Remainder
of ConPlan
$
Narrative
Annual Description
Allocation:
$
Program
Income: $
Prior Year
Resources:
$
Total:
$
CDBG public
-
federal
Acquisition
Admin and
Planning
Economic
Development
Housing
Public
Improvements
Public
Services $479,750 $127,329 $180,764
$
$787,843.44 $3,503,887
Annual
CDBG
allocation,
prior year
funds, and
estimated
revolving
loan
resources
Table 50 - Anticipated Resources
Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied The City has identified other resources that may be available to carry out activities that address the goals of the Consolidated Plan:
• OCHA reports that as of April 2025, 203 Lake Forest households receive rental assistance. The City anticipates that OCHA will provide rental assistance to 200 Lake Forest households annually over the five-year Consolidated Plan cycle.
• The City does not have an inclusionary housing program; however, the Housing Element indicates the City will encourage developers to include a minimum of 15% affordable units within their housing projects. As an alternative, developers may pay an in-lieu fee instead of constructing affordable units within their development. The City will negotiate an agreement with a developer to ensure units are built, or the in-lieu fee is collected.

CDBG does not require matching funds.

If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan The City of Lake Forest Housing Authority holds assets formerly held by the Lake Forest Redevelopment Agency. As of April 2025, there are limited assets remaining, no physical property is owned.

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Discussion
Funding resources to implement the City’s Consolidated Plan are limited. The City anticipates that fluctuations in CDBG funding will continue. HUD has begun to invest additional resources into housing assistance vouchers and certificates, and OCHA has aggressively pursued these new resources. The City will support OCHA’s efforts to secure new rental assistance resources. As other resources (e.g., Housing Authority) become available, the City will explore opportunities to expend these funds to support the goals and objectives of the Consolidated Plan.

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SP-40 Institutional Delivery Structure – 91.215(k)
Explain the institutional structure through which the jurisdiction will carry out its consolidated plan including private industry, non-profit organizations, and public institutions.

Responsible Entity Responsible Entity
Type
Role Geographic Area
Served
Orange County Housing
Authority
PHA Public Housing Jurisdiction
LAKE FOREST Government Economic
Development
Homelessness
Ownership
Planning
Rental
neighborhood
improvements
public facilities
public services
Jurisdiction
County of Orange Government Economic
Development
Homelessness
Non-homeless special
needs
Planning
Region
Orange County
Continuum of Care
Regional organization Homelessness Region
Table 51 - Institutional Delivery Structure
Assess of Strengths and Gaps in the Institutional Delivery System The City of Lake Forest works with a wide range of public and community-based organizations to address the social service needs of the community. The institutional structure utilized to administer the CDBG program includes the following:
• The City’s Community Development Department serves as the lead agency for coordination of the Five-Year Consolidated Plan, Annual Action Plans, the Consolidated Annual Performance and Evaluation Report (CAPER), compliance review of CDBG-funded projects, and the Orange County AI.
• The City’s Public Works Department administers capital improvement (infrastructure and facility) projects, including CDBG-funded activities.

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• The City contracts with the Fair Housing Council of Orange County to provide fair housing services.
• The City works in partnership with the Orange County Housing Authority to provide rental assistance to lower-income renters.
• The City works with an extensive network of local social service providers to assist the homeless, households at risk of homelessness, special needs populations, and lower-income residents.
• The City’s economic development plan engages the local business community and employers to expand business opportunities in the City, which, in turn, generates employment opportunities for residents at all income levels.

Availability of services targeted to homeless persons and persons with HIV and mainstream services
Homelessness Prevention
Services
Available in the
Community
Targeted to
Homeless
Targeted to People
with HIV
Homelessness Prevention Services
Counseling/Advocacy X X
Legal Assistance
Mortgage Assistance
Rental Assistance X X
Utilities Assistance X
Street Outreach Services
Law Enforcement
Mobile Clinics
Other Street Outreach Services X
Supportive Services
Alcohol & Drug Abuse
Child Care X
Education
Employment and Employment
Training X
Healthcare X

HIV/AIDS
Life Skills X X
Mental Health Counseling
Transportation
Other
Table 52 - Homeless Prevention Services Summary
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Describe how the service delivery system including, but not limited to, the services listed above meet the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) Service providers are available to assist Lake Forest residents that are at risk of becoming homeless and that are homeless. Based on the idea that it is less expensive and disruptive to keep a household housed in place, the primary focus of the City’s homeless strategy is to support the provision of safety net services for community residents. These services include assessment and case management, supplemental food, limited financial assistance for rent or utilities, and reduced cost childcare and medical services. Safety net services enable households at risk of homelessness to redirect limited income toward maintaining their housing.

For those who are homeless, the City has established relationships with housing and service providers that accept referrals from the City. These agencies can address the immediate, interim, and long-term housing needs of the homeless, and provide critical support services.

Describe the strengths and gaps of the service delivery system for special needs population and persons experiencing homelessness, including, but not limited to, the services listed above As indicated above, the City has developed a strong relationship with local nonprofit agencies that provide a variety of services to residents, including individuals with special needs and the homeless. The main weakness in the City’s service delivery system stems from limited financial resources. Additional issues include service and facility gaps in the continuum of care and service overlap.

Provide a summary of the strategy for overcoming gaps in the institutional structure and service delivery system for carrying out a strategy to address priority needs The Orange County Continuum of Care has designed and implemented a Coordinated Entry System (CES) for people experiencing homelessness or that are at risk of homelessness. The objective of the CES is to more effectively and efficiently help people who are homeless to secure housing and, consequently, achieve a measurable reduction in regional homelessness. As part of this effort, the OC-CoC has adopted a policy of shifting investment away from transitional housing and investing in permanent supportive housing and rapid re-housing. To the extent resources are available, the City supports the efforts of the OC-CoC to use limited resources as effectively as possible.

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SP-45 Goals Summary – 91.215(a)(4)
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome Indicator
1 Affordable Housing 2025 2029 Affordable Housing Citywide Affordable Housing CDBG:
$2,250,000
Homeowner Housing
Rehabilitated:
40 Household Housing Unit
2 Infrastructure and
Facility
Improvements
2025 2029 Non-Housing
Community
Development
CDBG
TARGET
AREAS
Citywide
Public
Improvements
CDBG:
$625,000
Public Facility or Infrastructure
Activities other than
Low/Moderate Income
Housing Benefit:
7500 Persons Assisted
3 Public Social
Services
2025 2029 Non-Homeless
Special Needs
Low & Moderateincome Households
Citywide Public Services CDBG:
$200,000
Public service activities other
than Low/Moderate Income
Housing Benefit:
8000 Persons Assisted
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Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome Indicator
4 Homeless
Continuum of Care
2025 2029 Homeless Citywide Homeless Support
Services and
Housing
CDBG:
$175,000
Public service activities other
than Low/Moderate Income
Housing Benefit:
2500 Persons Assisted
Tenant-based rental
assistance / Rapid Rehousing:
50 Households Assisted
Homelessness Prevention:
250 Persons Assisted
5 Economic
Opportunities
2025 2029 Non-Housing
Community
Development
Citywide Economic
Opportunities
CDBG:
$100,000
Businesses assisted:
50 Businesses Assisted
6 Program
Administration
2025 2029 Administration Citywide Administration and
Planning
CDBG:
$450,000
Other:
450 Other
Table 53 – Goals Summary
Goal Descriptions
1 Goal Name Affordable Housing
Goal
Description
Improve or expand the supply of housing affordable to lower-income households Consolidated Plan LAKE FOREST 100
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2 Goal Name Infrastructure and Facility Improvements
Goal
Description
Improve and expand public infrastructure and facilities that benefit low- and moderate-income neighborhoods and residents
3 Goal Name Public Social Services
Goal
Description
Provide or improve access to public social services for low- and moderate-income persons and persons with special needs
4 Goal Name Homeless Continuum of Care
Goal
Description
A continuum of housing and supportive services for the homeless and the near-homeless 5 Goal Name Economic Opportunities
Goal
Description
Grants and other forms of assistance to create or expand for employment opportunities for lower-income individuals 6 Goal Name Program Administration
Goal
Description
Provide administration and planning activities to carry out actions that address identified needs in the Consolidated Plan, including fair housing services to address local impediments to fair housing Estimate the number of extremely low-income, low-income, and moderate-income families to whom the jurisdiction will provide affordable housing as defined by HOME 91.315(b)(2)
The City is not a participating jurisdiction in the HOME program.

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SP-50 Public Housing Accessibility and Involvement – 91.215(c) Need to Increase the Number of Accessible Units (if Required by a Section 504 Voluntary Compliance Agreement)
The City of Lake Forest does not own or operate public housing units.

Activities to Increase Resident Involvements
Not applicable
Is the public housing agency designated as troubled under 24 CFR part 902? N/A
Plan to remove the ‘troubled’ designation
Not applicable
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SP-55 Barriers to affordable housing – 91.215(h)
Barriers to Affordable Housing
Barriers to affordable housing exist in the form of governmental regulations and market factors. Barriers or impediments to affordable housing are caused when there is little incentive to develop affordable housing due to excessive development costs and/or the lack of community commitment. The City has little control over market factors such as the cost and availability of financing. Public policy and community issues potentially affect the cost of all development projects through the design and implementation of land use ordinances, fees, and development standards. While these policies constrain residential development to some extent, they are necessary to support other public policies. Cities also often require developers to provide on-site and off-site improvements necessary to serve their projects. The City of Lake Forest 2021–2029 Housing Element concludes that building codes and development standards in Lake Forest are not substantially different from those of most other cities in Orange County.

Land and construction costs are also key market factors that may serve as a barrier to affordable housing.

The City has no influence over materials and labor costs. Land represents one of the most significant costs of new housing. The City’s Housing Element points out that despite generally poor economic conditions, land prices throughout Orange County remain high relative to other regions in California and pose a significant challenge to the development of affordable housing by the private market. Because per unit land cost is directly affected by density, one way to affect this cost is to develop at higher densities that allow the cost to be spread across more units, thus reducing the total price. The City Zoning Code allows development at up to 43 units per acre in the R2 district. Another factor that may serve to address the high cost of developing affordable housing is the availability of government funding to subsidize a portion of the development cost. The elimination of California redevelopment in February 2012 directly impacted a primary funding source of the City of Lake Forest for subsidizing the cost of affordable housing.

Strategy to Remove or Ameliorate the Barriers to Affordable Housing Affordable housing development faces several challenges, including the cost of construction, financing, and development regulations. The 2013–2021 Housing Element notes that the City can encourage and facilitate affordable housing through financial assistance, removal of regulatory constraints, and administrative support. It offers the following actions to promote affordable housing production with limited available funding.
• The City will monitor new neighborhood developments for compliance with development agreements that include an Affordable Housing Implementation Plan. • The City will collaborate with affordable housing developers to identify potential sites, write letters of support to help secure governmental and private-sector funding, and offer technical assistance related to the application of State density bonus provisions. • Work with developers on a case-by-case basis to provide State-mandated regulatory concessions and incentives to assist with the development of affordable and senior housing. State-mandated Consolidated Plan LAKE FOREST 103
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regulatory concessions and incentives could include but are not limited to, density bonuses, parking reductions, fee reductions or deferral, expedited permit processing, and modified or waived development standards.
• If available, provide financial subsidies to help reduce the cost of development in exchange for the reservation of units for lower-income households.

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SP-60 Homelessness Strategy – 91.215(d)
Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
The City collaborates with nonprofit partners to conduct homeless outreach in the community. Service providers will evaluate the service and housing needs of individuals to facilitate the transition to permanent housing and independent living. Local service providers tie into the regional Coordinated Entry System established by the OC-CoC, which determines the vulnerability of homeless individuals and prioritizes access to housing and services for those most at risk. This need-assessment system is designed to “facilitate exits from homelessness to stable housing in the most rapid manner given available resources.” The City has a Community outreach Specialist that works closely with the Orange County Sheriff’s Department Homeless Outreach Team. The former helps coordinate services with the Orange County Health Care Agency, homeless advocacy groups, and other nonprofits to offer resources and services to the homeless and chronic homeless.

Addressing the emergency and transitional housing needs of homeless persons As Table 39 indicates, there are 35 transitional shelter beds located in the City. These shelter beds are the result of past City allocations of CDBG and redevelopment funds to nonprofits to assist with the acquisition of housing units. These units continue to provide much needed interim housing opportunities for homeless families with children. The City will continue to support local nonprofit agencies that provide emergency and transitional housing for the region’s homeless. The City supports agencies such as Family Assistance Ministries (FAM), Families Forward, and South County Outreach. FAM offers a continuum of housing, including emergency and transitional housing for families with children. Families Forward and South County Outreach offer interim housing programs for homeless families that have been stabilized and are transitioning into independent living. Additionally, the City will participate in regional efforts to explore options and opportunities to develop a South SPA year-round emergency shelter and homeless resources center.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again.

According to current HUD directives, the OC-CoC has established a coordinated entry system whereby a homeless individual or family seeking shelter and services is directed to a streamlined system that facilitates access to appropriate housing and services. The system screens applicants for eligibility for services, such as homelessness prevention, emergency shelter, rapid rehousing, permanent supportive housing, and other interventions. The needs and strengths of each household are assessed to determine Consolidated Plan LAKE FOREST 105
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which interventions will be most effective and appropriate, while also prioritizing people for assistance based on the severity of their needs. Homeless service providers presently supported by the City will be critical players in housing and servicing the City’s homeless population via the coordinated entry system.

Help low-income individuals and families avoid becoming homeless, especially extremely lowincome individuals and families who are likely to become homeless after being discharged from a publicly funded institution or system of care, or who are receiving assistance from public and private agencies that address housing, health, social services, employment, education or youth needs
As indicated previously, the City homeless strategy is rooted in the proposition that it is less expensive and disruptive for a household to remain sheltered in their existing home than to be rehoused. To this end, the City uses public resources, such as CDBG, to support agencies that provide a variety of safety net services that may help prevent households from becoming homeless. Examples of safety net services include food banks, rent/utility assistance, and subsidized childcare services. The City will also participate in regional homeless planning efforts, including the OC-CoC’s Discharge Plan, which will aim to prevent individuals that are leaving institutions such as jails, prisons, and hospitals from becoming homeless.

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SP-65 Lead based paint Hazards – 91.215(i)
Actions to address LBP hazards and increase access to housing without LBP hazards The Residential Lead-Based Paint (LBP) Hazard Reduction Act of 1992 (Title X) changed the federal approach to addressing LBP by increasing the emphasis on the prevention of childhood lead poisoning through housing-based strategies.

Lake Forest has implemented its lead-based paint reduction strategy as part of the City’s Housing Rehabilitation programs. All application packets for the City’s Housing Rehabilitation programs include a notice to educate residents about the health dangers of lead and encourages screening of children for elevated blood lead levels. Additionally, before using federal funds to improve a property, a unit must be screened for lead-based paint. If lead-based paint is identified, the hazards must be addressed per federal requirements. The use of lead-based paint is prohibited in newly constructed units.

How are the actions listed above related to the extent of lead poisoning and hazards? The City will continue to act as necessary to reduce lead-based paint hazards per HUD regulations. As outlined above, housing units improved via the City’s housing rehabilitation programs are tested for leadbased paint, and the hazard is removed as necessary to comply with federal regulations.

How are the actions listed above integrated into housing policies and procedures? The City will comply with lead-based requirements as part of the administration of the CDBG program.

The City’s Housing Rehabilitation programs’ policies and procedures aim to reduce the risk of lead-based paint poisoning, especially among young children.

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SP-70 Anti-Poverty Strategy – 91.215(j)
Jurisdiction Goals, Programs and Policies for reducing the number of Poverty-Level Families According to the U.S. Census Bureau, 7.4% of the City’s population is living below the poverty level. The Census Bureau also reports that 7.4% of Lake Forest residents age 65 and older live in poverty, as are 9.3% of children age 18 years and younger.

The City has identified several activities and services it can implement to help combat poverty:
• Support rental assistance programs provided by OCHA for very low-income renters, especially for senior and disabled households, and households with children. • Continue to support homeless prevention services for individuals presently housed but are at risk of losing their residence.
• Assist those already homeless in need of emergency shelter, transitional housing, rapid rehousing, or permanent supportive housing.
• Support public services that provide a social safety net for lower-income individuals. • Continue to implement housing rehabilitation programs for lower-income homeowners, especially senior households.
• Assist agencies that provide employment training for low- and moderate-income residents. • Support programs that aid the anti-poverty strategy, such as CalWorks and the Orange County Workforce Investment Board.

How are the Jurisdiction poverty reducing goals, programs, and policies coordinated with this affordable housing plan
The activities delineated above are tied directly to the goals and objectives of the City’s Consolidated Plan. Safety net services can provide households living in poverty with extra resources that may allow them to maintain or improve their overall financial situation. Furthermore, expanding or preserving the City’s supply of affordable housing will provide new housing opportunities to lower-income households at affordable prices, which is consistent with the housing goals of the Consolidated Plan.

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SP-80 Monitoring – 91.230
Describe the standards and procedures that the jurisdiction will use to monitor activities carried out in furtherance of the plan and will use to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements
The City of Lake Forest Community Development Department has the responsibility for overall program monitoring and compliance. Staff monitors all CDBG funded agencies and City departments to ensure compliance with applicable regulations and to ensure timely implementation of all activities. The program staff conducts an on-site monitoring visit of each subrecipient biennially. The City also ensures compliance with all Federal and City contracting regulations, including procurement, Federal Labor Standards, equal opportunity (Minority Business Enterprise and Women Business Enterprise), and Section

3. While construction projects are underway, on-site compliance interviews with the workers are conducted. Additionally, the program Staff ensures compliance with the U.S. Office of Management and Budget (OMB) requirements for conducting single audits, as well as compliance with HUD reporting requirements for accomplishment in the Integrated Disbursement and Information System (IDIS).

The City of Lake Forest will continue to reach out to small businesses and minority and women-owned businesses when conducting procurements for supplies, equipment, construction, and services for CDBGfunded activities.

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Expected Resources
AP-15 Expected Resources – 91.220(c)(1,2)
Introduction
Fluctuations in annual CDBG allocations make it difficult to determine anticipated resources for a five-year period; however, based on recent allocations, the City expects to receive approximately $475,000 annually in CDBG funding, for a five-year total of $2,375,000. The City uses CDBG funds for housing preservation activities, public improvements, public services, and administrative costs. In addition, approximately $450,000 of program income will be generated annually from the Housing Rehabilitation Loan Program loan payoffs for an additional $2,250,000 dedicated for housing activities through the revolving loan fund.

The City will receive $479,750 in CDBG funds for Fiscal Year 2025-2026. Additional resources for the year include prior year carryover funds totaling $180,764 and program income in the amount of $127,329 received during the fiscal year generated by the repayment of previously funded housing rehabilitation loans. Both amounts vary from year to year. The City anticipates that the County of Orange will continue to administer the federal rental assistance program in Lake Forest, assisting approximately 200 households per year. The City will continue efforts to leverage CDBG funds Consolidated Plan LAKE FOREST 110
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with other federal, state, and local funds.

Anticipated Resources
Program Source of
Funds
Uses of Funds Expected Amount Available Year 1 Expected Amount
Available
Remainder of
ConPlan
$
Narrative Description
Annual
Allocation: $
Program
Income: $
Prior Year
Resources:
$
Total:
$
CDBG public -
federal
Acquisition
Admin and
Planning
Economic
Development
Housing
Public
Improvements
Public Services $479,750.00 $127,329.00 180,764.44 $787,843.44 $3,503,887.00 Annual CDBG allocation, prior year
funds, and estimated revolving loan
resources
Table 54 - Expected Resources – Priority Table
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Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied The City has identified other resources that may be available to carry out activities that address the goals of the Consolidated Plan:
• OCHA reports that as of April 2025, 203 Lake Forest households receive rental assistance. The City anticipates that OCHA will provide rental assistance to 200 Lake Forest households annually over the five-year Consolidated Plan cycle.
• The City does not have an inclusionary housing program; however, the Housing Element indicates the City will encourage developers to include a minimum of 15% affordable units within their housing projects. As an alternative, developers may pay an in-lieu fee instead of constructing affordable units within their development. The City will negotiate an agreement with a developer to ensure units are built, or the in-lieu fee is collected.

CDBG does not require matching funds.

If appropriate, describe publically owned land or property located within the jurisdiction that may be used to address the needs identified in the plan The City of Lake Forest Housing Authority holds assets formerly held by the Lake Forest Redevelopment Agency. As of April 2025, there are limited assets remaining, no physical property is owned.

Discussion
Funding resources to implement the City’s Consolidated Plan are limited. The City anticipates that fluctuations in CDBG funding will continue. HUD has begun to invest additional resources into housing assistance vouchers and certificates, and OCHA has aggressively pursued these new resources. The City will support OCHA’s efforts to secure new rental assistance resources. As other resources (e.g., Housing Authority) become available, the City will explore opportunities to expend these funds to support the goals and objectives of the Consolidated Plan.

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Annual Goals and Objectives
AP-20 Annual Goals and Objectives
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome
Indicator
1 Affordable Housing 2025 2029 Affordable Housing Citywide Affordable Housing CDBG:
$450,000
Homeowner Housing
Rehabilitated: 15
Household Housing
Unit
2 Public Social
Services
2025 2029 Non-Homeless
Special Needs
Low & Moderateincome Households
Citywide Public Services CDBG:
$71,900
Public service
activities other than
Low/Moderate
Income Housing
Benefit:2,729
Persons Assisted
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Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome
Indicator
3 Homeless
Continuum of Care
2025 2029 Homeless Citywide Homeless Support
Services and
Housing
CDBG:
$49,200
Public service
activities other than
Low/Moderate
Income Housing
Benefit: 2,400
Persons Assisted
Homelessness
Prevention: 97
Persons Assisted
4 Economic
Opportunities
2025 2029 Non-Housing
Community
Development
Citywide Economic
Opportunities
CDBG:
$50,000
Businesses assisted:
10 Businesses
Assisted
5 Program
Administration
2025 2029 Administration Citywide Administration and
Planning
CDBG:
$95,950
Other: 34 Other
6 Community
Facilities and
Infrastructure
2025 2029 Community
Facilities and
Infrastructure
Target
Areas
Community
Facilities and
Infrastructure
CDBG:
$230,000
Other: 8,500 Other
Table 55 – Goals Summary
Consolidated Plan LAKE FOREST 114
OMB Control No: 2506-0117 (exp. 09/30/2021)
Goal Descriptions
1 Goal Name Affordable Housing
Goal
Description
Loans and grants to improve owner-occupied housing or expand the supply of housing affordable to lower-income households
2 Goal Name Public Social Services
Goal
Description
Provide or improve access to public social services for low- and moderate-income persons and persons with special needs
3 Goal Name Homeless Continuum of Care
Goal
Description
A continuum of supportive and housing services for the homeless and households at risk of homelessness 4 Goal Name Economic Opportunities
Goal
Description
Grants and other forms of assistance to create or expand for employment opportunities for lower-income individuals 5 Goal Name Program Administration
Goal
Description
CDBG program oversight and coordination including fair housing services 6 Goal Name Community Facilities and Infrastructure
Goal
Description
Improve/upgrade public infrastructure & facilities
Consolidated Plan LAKE FOREST 115
OMB Control No: 2506-0117 (exp. 09/30/2021)
Projects
AP-35 Projects – 91.220(d)
Introduction
The activities to be undertaken during FY 2025-2026 are summarized below. All activities identified are expected to be completed by June 30, 2026.

Projects
# Project Name
1 CDBG Administration
2 Housing Rehabilitation Loans
3 Paint Program Grants
4 Age Well Senior Services
5 Camino Health Center
6 Fair Housing Council of OC
7 Families Forward
8 Family Assistance Ministry
9 South County Outreach
10 ADA Ramp Improvements Phase 15
11 Boys & Girls Club of Laguna Beach
12 Upwards
Table 56 – Project Information
Consolidated Plan LAKE FOREST 116
OMB Control No: 2506-0117 (exp. 09/30/2021)
Describe the reasons for allocation priorities and any obstacles to addressing underserved needs The City recognizes that special needs populations (i.e., seniors, disabled, and households with extremely low-income) are more likely to become homeless because they have limited income or other issues that require supportive housing or services; therefore, the City considers supportive services a high priority.

The City anticipates that the greatest obstacle to meeting the underserved needs of these special needs populations will be a lack of financial resources for both supportive services and housing. A common need reported by service providers is affordable housing. Increasing rents, and reductions to the Housing Choice Voucher Program and other housing programs, can impact the City's ability to support affordable housing opportunities for extremely low- and very low-income households.

AP-38 Project Summary
Project Summary Information
1 Project Name CDBG Administration
Target Area Citywide
Goals Supported Program Administration
Needs Addressed Administration and Planning
Funding CDBG: $88,450
Description CDBG program oversight and coordination
Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
N/A
Location Description 100 Civic Center, Lake Forest CA (City Hall) Planned Activities CDBG program oversight and coordination, including public service grant management, preparation of reports, and IDIS management Consolidated Plan LAKE FOREST 117
OMB Control No: 2506-0117 (exp. 09/30/2021)
2 Project Name Housing Rehabilitation Loans
Target Area Citywide
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $209,025
Description Housing rehabilitation loans for owner-occupied housing units Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
10 low- and moderate-income households
Location Description Citywide
Planned Activities Loans to rehabilitate owner-occupied housing units funded with entitlement funds and program income received during the year
3 Project Name Paint Program Grants
Target Area Citywide
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $125,000
Description Grants to assist homeowners in painting the exterior of their home Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
5 low- and moderate-income homeowners
Location Description Citywide
Planned Activities Grants to homeowners to paint the exterior of their home Consolidated Plan LAKE FOREST 118
OMB Control No: 2506-0117 (exp. 09/30/2021)
4 Project Name Age Well Senior Services
Target Area Citywide
Goals Supported Public Social Services
Needs Addressed Public Services
Funding CDBG: $5,000
Description Meals on Wheels
Target Date 6/30/2025
Estimate the number and type of families that
will benefit from the proposed activities
100 Seniors and frail elderly
Location Description Citywide
Planned Activities Case management and in-home support services for home-bound seniors and frail elderly
5 Project Name Camino Health Center
Target Area Citywide
Goals Supported Public Social Services
Needs Addressed Public Services
Funding CDBG: $10,000
Description Low-cost medical services
Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
2,400 Individuals
Location Description 22481 Aspen St., Suite A, Lake Forest CA Planned Activities Reduced cost medical services for low- and moderate-income persons Consolidated Plan LAKE FOREST 119
OMB Control No: 2506-0117 (exp. 09/30/2021)
6 Project Name Fair Housing Council of OC
Target Area Citywide
Goals Supported Public Social Services
Needs Addressed Public Services
Funding CDBG: $7,500
Description Program Administration
Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
34 households
Location Description Citywide
Planned Activities Fair housing outreach, education, and enforcement services to address impediments to fair housing.
7 Project Name Families Forward
Target Area Citywide
Goals Supported Homeless Continuum of Care
Needs Addressed Homeless Support Services and Housing
Funding CDBG: $15,962
Description Support services for at-risk and homeless families with children Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
27 Individuals At-Risk Homeless
Location Description Citywide
Consolidated Plan LAKE FOREST 120
OMB Control No: 2506-0117 (exp. 09/30/2021)
Planned Activities Case management for homeless families with children and families with children that are at risk of becoming homeless
8 Project Name Family Assistance Ministry
Target Area Citywide
Goals Supported Homeless Continuum of Care
Needs Addressed Homeless Support Services and Housing
Funding CDBG: $10,000
Description Housing and services for households at risk of homelessness or that are homeless Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
50 lower-income individuals
Location Description Citywide
Planned Activities Case management, supportive services and rent/utility assistance for lower-income residents at risk of eviction or termination of utility services. 9 Project Name South County Outreach
Target Area Citywide
Goals Supported Affordable Housing
Needs Addressed Public Services
Funding CDBG: $19,000
Description Homelessness prevention assistance
Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
20 At-Risk Homeless individuals
Consolidated Plan LAKE FOREST 121
OMB Control No: 2506-0117 (exp. 09/30/2021)
Location Description 7 Whatney St. B, Irvine, CA
Planned Activities Foodbank services, including case management - services also include emergency rent and utility assistance to prevent eviction or termination of services 10 Project Name ADA Ramp Improvements Phase 15
Target Area Citywide
Goals Supported Program Administration
Needs Addressed Public Improvements
Funding CDBG: $230,000
Description ADA Ramp Improvements Phase 15 will include curb cuts and ramp installation in the eligible areas.

Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
Approximately 8,500 disabled residents.

Location Description Throughout the city at street intersections, as necessitated by conditions and current federal standards.

Planned Activities Implement improvements to comply with current ADA regulations. 11 Project Name Boys & Girls Club of Laguna Beach
Target Area Citywide
Goals Supported Public Social Services
Needs Addressed Public Services
Funding CDBG: $12,000
Description Childcare services
Target Date 6/30/2026
Consolidated Plan LAKE FOREST 122
OMB Control No: 2506-0117 (exp. 09/30/2021)
Estimate the number and type of families that
will benefit from the proposed activities
After School childcare for 32 low-income families.

Location Description Mountain View, 24551 Raymond Way, Lake Forest, CA 92630 Planned Activities After school childcare.
12 Project Name Upwards
Target Area Citywide
Goals Supported Economic Development
Needs Addressed Economic Development
Funding CDBG: $50,000
Description Micro-Enterprise Technical Assistance and Job Training for Childcare Service Providers.

Target Date 6/30/2026
Estimate the number and type of families that
will benefit from the proposed activities
10 Businesses to be served
Location Description Various
Planned Activities Micro-Enterprise Technical Assistance and Job Training for Childcare Service Providers.

Consolidated Plan LAKE FOREST 123
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-50 Geographic Distribution – 91.220(f)
Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed For FY 2025-2026, CDBG funds will support activities on a citywide basis, that is, for households that are income-eligible or eligible due to a unique characteristic (e.g., adults with disabilities and seniors) regardless of where they live in Lake Forest.

Geographic Distribution
Target Area Percentage of Funds
CDBG TARGET AREAS 28
Citywide 72
Table 57 - Geographic Distribution
Rationale for the priorities for allocating investments geographically The City does not allocate CDBG funds on a geographic basis; instead, funding is allocated in a manner that best meets the needs of lower income households regardless of where they reside in the City. The City prioritizes the use of its CDBG funding for the preservation of housing that is affordable to lowerincome households (via rehabilitation), and that helps prevent homelessness or assist those already homeless. These activities are carried out on a citywide basis.

CDBG-funded infrastructure and facility improvements are usually located within Low- and ModerateIncome areas as identified by HUD (see Figure 1 LMA Map). Some infrastructure/facility improvement projects may be undertaken in areas outside of Low- and Moderate-Income areas. Such projects are typically limited to those that address ADA regulations.

Discussion
CDBG funds will fund programs that serve lower-income Lake Forest residents regardless of where they live. For FY 2025-2026, CDBG funds will benefit residents on a citywide basis, with the exception of the ADA Ramp Improvement project that will benefit primarily low- and moderate-income residential areas.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
Affordable Housing
AP-55 Affordable Housing – 91.220(g)
Introduction
Although the Consolidated Plan and Action Plan focus on affordable housing needs of the community, the City's only HUD funding source is CDBG. HUD regulations prohibit the use of CDBG for the construction of new housing; however, the City will allocate funds to preserve existing housing that is affordable to lower-income homeowners.

One Year Goals for the Number of Households to be Supported Homeless 0
Non-Homeless 0
Special-Needs 0
Total 0
Table 58 - One Year Goals for Affordable Housing by Support Requirement One Year Goals for the Number of Households Supported Through Rental Assistance 0
The Production of New Units 0
Rehab of Existing Units 0
Acquisition of Existing Units 0
Total 0
Table 59 - One Year Goals for Affordable Housing by Support Type Discussion
The 2025-2026 Action Plan allocates CDBG public to a local agency that will provide transitional housing to an estimated 11 individual. The City's CDBG-funded affordable housing strategy is to maintain the affordable housing stock through housing rehabilitation programs and supporting rental assistance programs like the Housing Choice Voucher (administered by the OCHA). The City anticipates eight homeowners will participate in the City’s housing rehabilitation program, and 200 Lake Forest renter households will receive rental assistance during FY 2025-2026.

Consolidated Plan LAKE FOREST 125
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-60 Public Housing – 91.220(h)
Introduction
The City of Lake Forest does not own or operate public housing.

Actions planned during the next year to address the needs to public housing Not applicable
Actions to encourage public housing residents to become more involved in management and participate in homeownership
Not applicable
If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance
Not applicable
Discussion
The City of Lake Forest does not own or operate public housing.

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OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-65 Homeless and Other Special Needs Activities – 91.220(i) Introduction
The City recognizes the importance of assisting the homeless and near-homeless with a continuum of care approach that not only addresses a homeless person’s immediate shelter needs, but also provides access to transitional and permanent housing, support services, and employment opportunities to break the cycle of homelessness.

Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
The City collaborates and relies on nonprofit partners to reach out to homeless persons (especially unsheltered persons). The City will allocate CDBG funds to four agencies that will provide services for homeless individuals. Each agency has an outreach component used to engage and assess clients Addressing the emergency shelter and transitional housing needs of homeless persons In past years, the City used CDBG funds to assist nonprofits in acquiring eight condominium units located in the community to provide transitional housing. For FY 2025-2026, Families Forward’s “Housing Program” is recommended for CDBG funding. This program offers interim (i.e., transitional) housing for up to 25 individuals (i.e., families with children). The City did not receive any requests for emergency shelter programs.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again
The Orange County Continuum of Care coordinates a system that incorporates several evidence-based practices, including a Housing First approach that involves moving persons directly from the streets into permanent housing accompanied by home-based supportive services. This approach has been effective with chronically homeless persons and families.

In past years Lake Forest used CDBG and local redevelopment funding to expand permanent housing opportunities for the formerly homeless. In 2015, the City’s Housing Authority (former redevelopment agency) sold a four-unit apartment to Families Forward. These units provide permanent housing Consolidated Plan LAKE FOREST 127
OMB Control No: 2506-0117 (exp. 09/30/2021)
opportunities for lower-income households, including formerly homeless families.

In addition to Rapid Rehousing, the OC-CoC will address the housing needs of homeless households with unique situations. The Family Redirection Program aims to keep homeless families with children off the streets by prioritizing shelter and housing resources for families. HUD has also significantly increased the number of rental assistance vouchers for homeless Veterans (i.e., Veterans Affairs Supportive Housing or VASH vouchers). In addition to receiving rental assistance, veterans with a history of severe mental health illness, substance use disorder, or physical disabilities receive case management and appropriate support services from the Department of Veterans Affairs. Currently, 486 VASH vouchers are in place throughout Orange County (13 in Lake Forest). For unaccompanied youth, there are several residential/supportive services programs available in Orange County designed specifically for youths. Services offered include crisis intervention, drug abuse counseling, and case management.

The City will not allocate FY 2025-2026 CDBG funds for rapid rehousing or permanent supportive housing.

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs
For FY 2025-2026, the City will allocate CDBG funds to Family Assistance Ministry and South County Outreach for an array of services to assist the near-homeless and those already homeless. These agencies operate food bank programs, which provide an entry point into the regional CoC. Program applicants undergo an assessment by case managers who determine if additional services are needed and who will make appropriate referrals. CDBG resources are used by these agencies to assist households who are at risk of eviction or the termination of utilities due to financial hardships, especially in the post-COVID-19 environment. The City will also continue to participate in regional homeless planning efforts, including the OC CoC’s Discharge Plan, which aims to prevent individuals from leaving institutions such as jails and hospitals, from becoming homeless.

Discussion
The programs identified above to address the needs of homeless persons indicate that serving the homeless is a complex issue requiring a network of service providers. The City will allocate CDBG resources to support a network of agencies that will address the needs of the community’s homeless and those at risk of becoming homeless.

Consolidated Plan LAKE FOREST 128
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-75 Barriers to affordable housing – 91.220(j)
Introduction:

The Strategic Plan provides detailed information regarding barriers to affordable housing and actions to overcome these barriers. The efforts to address these barriers during FY 2025-2026 are summarized below.

Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment
Affordable housing development faces several challenges, including the cost of construction, financing, and development regulations. The 2013–2021 Housing Element notes that the City can encourage and facilitate affordable housing through financial assistance, removal of regulatory constraints, and administrative support. It offers the following actions to promote affordable housing production with limited available funding.
• The City will monitor new neighborhood developments for compliance with development agreements that include an Affordable Housing Implementation Plan. • The City will collaborate with affordable housing developers to identify potential sites, write letters of support to help secure governmental and private-sector funding, and offer technical assistance related to the application of State density bonus provisions. • Work with developers on a case-by-case basis to provide State-mandated regulatory concessions and incentives to assist with the development of affordable and senior housing. State-mandated regulatory concessions and incentives could include but are not limited to, density bonuses, parking reductions, fee reductions or deferral, expedited permit processing, and modified or waived development standards.
• If available, provide financial subsidies to help reduce the cost of development in exchange for the reservation of units for lower-income households.

Discussion:

The Strategic Plan includes an extensive narrative regarding barriers to affordable housing and actions the City can take to mitigate identified obstacles to the development of affordable housing. As outlined above, the City provides an expedited development review process for affordable housing projects to help reduce holding costs and the overall cost of development. The City has little control over market forces such as the cost of land, building materials, and labor. If resources are available, the City may provide gap financing to help reduce overall development costs as an incentive to develop affordable housing. There are no growth limit initiatives in Lake Forest.

Consolidated Plan LAKE FOREST 129
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-85 Other Actions – 91.220(k)
Introduction:

There are several constraints to meeting the needs of low-income residents; the primary obstacle is a lack of funding to address all needs adequately. Demand for services has forced many nonprofits to reduce services at a time when governmental entities are also decreasing resources. In response to the level of need, the City has maintained its commitment to utilize and leverage resources efficiently and effectively to meet priority community needs.

Actions planned to address obstacles to meeting underserved needs The City recognizes that special needs populations face challenges due to low income, the unique conditions that they face, and that they are more likely to become homeless as a result of these factors.

Special needs populations often require unique housing and supportive services. The City considers supportive services and housing for special needs populations as a high priority. In FY 2025-2026, the City will fund public service agencies that assist underserved populations such as the homeless, seniors, the disabled, and low-income families with children.

Actions planned to foster and maintain affordable housing The City's strategies related to CDBG-funded affordable housing efforts are focused on maintaining the housing stock through its housing rehabilitation programs, supporting rental assistance programs like the Housing Choice Voucher, and helping to ensure individuals have access to housing free of discrimination due to race, gender, disability, and other personal or household characteristics.

Actions planned to reduce lead-based paint hazards
As previously discussed, the Residential Lead-Based Paint (LBP) Hazard Reduction Act of 1992 changed the federal strategy to addressing LBP by increasing the emphasis on the prevention of childhood lead poisoning through housing-based approaches. For example, lead-based paint hazard reduction as an eligible activity in the City’s housing rehabilitation programs.

All application packets for the City’s housing rehabilitation programs include a notice to educate residents about the health dangers of lead and encourage screening of children for elevated blood-lead levels. Additionally, before the use of federal funds, housing units are screened for lead-based paint. Housing units identified with lead-based paint hazards are treated, so the lead-based paint is abated per current federal requirements. The use of lead-based paint is prohibited in newly constructed units.

Actions planned to reduce the number of poverty-level families The City will leverage limited CDBG funds to address the needs of poverty-level families by partnering with Consolidated Plan LAKE FOREST 130
OMB Control No: 2506-0117 (exp. 09/30/2021)
nonprofit agencies that primarily focus services to these households. Specifically, the City will fund programs that provide safety net services such as food banks, limited financial assistance to prevent eviction, low-cost medical and dental care, and fair housing education/enforcement services.

Actions planned to develop institutional structure
The City of Lake Forest will continue efforts to eliminate institutional gaps and enhance coordination of programs with all segments of the community. For example, the City will partner with nonprofit entities to deliver public services. City departments will continue to work together to evaluate programs and projects that may be funded in whole or in part with CDBG funds that address priority needs. The City will assist OCHA by participating in the Cities Advisory Committee – a quarterly meeting of cities and OCHA to discuss issues related to federal rental housing assistance and general housing issues. As a member of the OC-CoC Community Forum, the City will continue to provide information to the regional CoC as it prepares the County’s annual Continuum of Care Homeless Assistance grant application. The City will also continue to participate in the development of the County’s Ten-Year Plan to end chronic homelessness and the regional discharge plan.

Actions planned to enhance coordination between public and private housing and social service agencies
The City will continue to participate in regional coordination of services by participating in the Cities Advisory Committee - the quarterly meeting of cities and OCHA to discuss issues related to federal rental housing assistance and as a member of the OC-CoC Community Forum. On an annual basis, the City meets with service providers to discuss service needs and ways to improve service to residents. Another example of enhanced coordination is the preparation of the county-wide Analysis of Impediments to Fair Housing. The City participated in the development of this document, which required significant jurisdictional coordination.

Discussion:

As previously outlined, HUD regulations require that the City prepare an Analysis of Impediments to Fair Housing choice (Al) every five years. In addition to identifying impediments, the AI includes a strategy to overcome barriers and action steps to implement on an annual basis. The City reports AI accomplishments in the annual year-end report. The City of Lake Forest joined other Orange County jurisdictions to fund the preparation of a county-wide AI. The AI evaluates existing demographic data, past fair housing enforcement activity for each partner community, mortgage lender data, and existing housing and land use public policies. Based on an analysis of this data, plus the input of residents, a list of impediments to fair housing choice for the County has been developed. A corresponding set of action steps to address these barriers has also been prepared. A summary of the of 2025-2029 Orange County AI is incorporated into the Consolidated Plan as Appendix G – the entire AI is available for review on the City’s website. The specific action steps the City will take during FY 2025-2026 to address impediments to fair housing can also be found in Appendix G.

Consolidated Plan LAKE FOREST 131
OMB Control No: 2506-0117 (exp. 09/30/2021)
Program Specific Requirements
AP-90 Program Specific Requirements – 91.220(l)(1,2,4)
Introduction:

The program-specific requirements that apply to the City are those for the CDBG program.

Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 0

2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0

3. The amount of surplus funds from urban renewal settlements 0

4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0

5. The amount of income from float-funded activities 0
Total Program Income: 0
Other CDBG Requirements

1. The amount of urgent need activities 0

2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income. Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this Annual Action Plan. 80.50% The City will meet the 70% low- and moderate-income Overall Benefit requirement for the use of CDBG funds over each of the five Consolidated Plan program years, and specifically for current Program Year 2025. Approximately 19.5% of available CDBG funds (minus administration), may be used for Urgent Need activities; however, no such need has been determined at this time.

1. If applicable to a planned HOME TBRA activity, a description of the preference for persons with special needs or disabilities. (See 24 CFR 92.209(c)(2)(i) and CFR 91.220(l)(2)(vii)).

N/A the City does not receive HOME funds.

Consolidated Plan LAKE FOREST 132
OMB Control No: 2506-0117 (exp. 09/30/2021)
Appendix - Alternate/Local Data Sources
1 Data Source Name
Vacant Units
List the name of the organization or individual who originated the data set.

City of Lake Forest
Provide a brief summary of the data set.

Information regarding vacant properties
What was the purpose for developing this data set?
Provide information regarding vacant properties
How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
Data limited to City of Lake Forest
What time period (provide the year, and optionally month, or month and day) is covered by this data set? 2021-2029 Housing Element
What is the status of the data set (complete, in progress, or planned)? Complete.
2 Data Source Name
OC Continuum of Care
List the name of the organization or individual who originated the data set.

OC-211
Provide a brief summary of the data set.
2024 Orange County homeless Point-In-Time Survey
What was the purpose for developing this data set?
Homeless survey
How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
Countywide with some local data
What time period (provide the year, and optionally month, or month and day) is covered by this data set? January 2024
What is the status of the data set (complete, in progress, or planned)? Complete

OMB Number: 4040-0004
Expiration Date: 11/30/2025
* 1. Type of Submission: * 2. Type of Application:
* 3. Date Received: 4. Applicant Identifier:
5a. Federal Entity Identifier: 5b. Federal Award Identifier:

6. Date Received by State: 7. State Application Identifier:
* a. Legal Name:
* b. Employer/Taxpayer Identification Number (EIN/TIN): * c. UEI:
* Street1:

Street2:
* City:

County/Parish:
* State:

Province:
* Country:
* Zip / Postal Code:

Department Name: Division Name:

Prefix: * First Name:

Middle Name:
* Last Name:

Suffix:

Title:

Organizational Affiliation:
* Telephone Number: Fax Number:
* Email:
* If Revision, select appropriate letter(s):
* Other (Specify):

State Use Only:

8. APPLICANT INFORMATION:
d. Address:
e. Organizational Unit:
f. Name and contact information of person to be contacted on matters involving this application:

Application for Federal Assistance SF-424
Preapplication
Application
Changed/Corrected Application
New
Continuation
Revision
USA: UNITED STATES
* 9. Type of Applicant 1: Select Applicant Type:

Type of Applicant 2: Select Applicant Type:

Type of Applicant 3: Select Applicant Type:
* Other (specify):
* 10. Name of Federal Agency:

11. Catalog of Federal Domestic Assistance Number:

CFDA Title:
* 12. Funding Opportunity Number:
* Title:

13. Competition Identification Number:

Title:

14. Areas Affected by Project (Cities, Counties, States, etc.):
* 15. Descriptive Title of Applicant's Project:

Attach supporting documents as specified in agency instructions.

Application for Federal Assistance SF-424
Add Attachments Delete Attachments View Attachments
Add Attachment Delete Attachment View Attachment
* a. Federal
* b. Applicant
* c. State
* d. Local
* e. Other
* f. Program Income
* g. TOTAL
.

Prefix: * First Name:

Middle Name:
* Last Name:

Suffix:
* Title:
* Telephone Number:
* Email:

Fax Number:
* Signature of Authorized Representative: * Date Signed:

18. Estimated Funding ($):

21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001) ** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency specific instructions.

Authorized Representative:

Application for Federal Assistance SF-424
* a. Applicant
Attach an additional list of Program/Project Congressional Districts if needed. * b. Program/Project
* a. Start Date: * b. End Date:

16. Congressional Districts Of:

17. Proposed Project:

Add Attachment Delete Attachment View Attachment
a. This application was made available to the State under the Executive Order 12372 Process for review on b. Program is subject to E.O. 12372 but has not been selected by the State for review. c. Program is not covered by E.O. 12372.

Yes No
Add Attachment Delete Attachment View Attachment
** I AGREE
* 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.) * 19. Is Application Subject to Review By State Under Executive Order 12372 Process? If "Yes", provide explanation and attach

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EQUAL HOUSING

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Orange County i 25-29 Regional AFH
Acknowledgements
Special thanks to all individuals and organizations that contributed to the planning process, including, but not limited to, the following:

The individuals and organizations (including Equus Workforce Solutions, Project Hope Alliance, Alianza Translatinx, Human Options, Illumination Foundation, The Eli Home, The Cambodian Family, and Orange County Families Forward) who attended the in-person and virtual community meetings.

The organizations that participated in the stakeholder interviews and focus groups, including Fair Housing Council of Orange County, Fair Housing Foundation, Orange County Families Forward, Orange County United Way, Family Assistance Ministry, The HUB OC, National Core, NeighborWorks Orange County, Thomas House Family Shelter, Domus Development, Dayle McIntosh Center, CalOptima, and Assistance League of Orange County.

Staff from all jurisdictions that participated in the planning effort, with additional thanks to staff from:
• The Cities of Costa Mesa, La Habra, and Santa Ana, for hosting in-person community meetings.
• The County of Orange and the Cities of Anaheim, Aliso Viejo, Buena Park, Fountain Valley, Fullerton, Irvine, Laguna Niguel, Mission Viejo, San Clemente, Santa Ana, and Rancho Santa Margarita for advertising the in-person and virtual community meetings through various channels.
• The City of Santa Ana, which served as lead agency responsible for coordinating the development of this report.

Document Version
Last updated: March 27, 2025
Orange County ii 25-29 Regional AFH
Cover Photo Credit
The cover photograph for this report was provided courtesy of C&C Development. The photograph features Terraces at Santiago in the City of Santa Ana’s Station District.

Terraces at Santiago is an award-winning 36-unit urban infill transit-oriented multifamily affordable rental housing development featuring a mix of two-, three-, and five-bedroom apartments. In keeping with surrounding neighborhoods, this property was designed with Spanish/Santa Barbara architectural influences. Exterior detailing accents include wrought iron, decorative gables, wall sconces, decorative arches, decorative wood rafter rails, decorative painted wood shutters, and recessed stucco elements with wrought iron lattice.

The building is LEED Gold Certified.

Orange County iii 25-29 Regional AFH
Table of Contents
I. Executive Summary.............................................................................................................. 1 II. Community Participation Process ...................................................................................... 3 A. Stakeholder Consultation................................................................................................. 3 B. Community Meetings ....................................................................................................... 3 III. Fair Housing Analysis ........................................................................................................... 6 A. Demographic and Housing Summary ............................................................................ 6 B. Segregation/Concentration and Integration ................................................................ 38 C. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)............................... 60 D. Disparities in Access to Opportunity............................................................................. 66

1. Education ..................................................................................................................... 66

2. Employment ................................................................................................................ 80

3. Transportation ............................................................................................................. 92

4. Access to Low Poverty Neighborhoods ................................................................... 99

5. Access to Environmentally Healthy Neighborhoods ............................................ 112

6. Disability and Access ................................................................................................ 120

7. Patterns in Disparities in Access to Opportunity ................................................... 124 E. Disproportionate Housing Needs................................................................................ 129 F. Local and State Policies and Practices Impacting Fair Housing .............................. 143 IV. Fair Housing Issues and Action Plan .............................................................................. 146 A. Orange County Urban County ..................................................................................... 146

1. Unincorporated Orange County .............................................................................. 149

2. Brea............................................................................................................................. 156

3. Cypress....................................................................................................................... 159

4. Dana Point.................................................................................................................. 161

5. La Palma..................................................................................................................... 165

6. Laguna Beach ............................................................................................................ 170

7. Laguna Hills ............................................................................................................... 174

8. Laguna Woods ........................................................................................................... 179 Orange County iv 25-29 Regional AFH

9. Los Alamitos .............................................................................................................. 182

10. Placentia..................................................................................................................... 184

11. San Juan Capistrano................................................................................................. 189

12. Seal Beach ................................................................................................................. 191

13. Stanton....................................................................................................................... 193

14. Villa Park .................................................................................................................... 194

15. Yorba Linda................................................................................................................ 196 B. Aliso Viejo ...................................................................................................................... 199 C. Anaheim......................................................................................................................... 201 D. Buena Park ..................................................................................................................... 206 E. Costa Mesa .................................................................................................................... 209 F. Fountain Valley .............................................................................................................. 213 G. Fullerton ......................................................................................................................... 215 H. Garden Grove ................................................................................................................ 225 I. Huntington Beach ......................................................................................................... 228 J. Irvine............................................................................................................................... 229 K. La Habra ......................................................................................................................... 240 L. Laguna Niguel ............................................................................................................... 244 M. Lake Forest..................................................................................................................... 249 N. Mission Viejo.................................................................................................................. 251 O. Newport Beach.............................................................................................................. 253 P. Orange............................................................................................................................ 255 Q. Rancho Santa Margarita............................................................................................... 258 R. San Clemente ................................................................................................................ 261 S. Santa Ana....................................................................................................................... 264 T. Tustin.............................................................................................................................. 268 U. Westminster................................................................................................................... 272 Orange County 1 25-29 Regional AFH
I. Executive Summary
The Assessment of Fair Housing (AFH) provides communities an opportunity to assess their progress toward the goals of eliminating housing discrimination and promoting access to housing opportunity for both current and future residents. Jurisdictions that receive funding from the U.S. Department of Housing and Urban Development (HUD), including Community Development Block Grant (CDBG), HOME Investment Partnerships Program (HOME), and Emergency Solutions Grant (ESG) funds, complete an AFH at least once every five years, consistent with the Consolidated Plan cycle, as part of their obligations under the Housing and Community Development Act of 1974 and the CranstonGonzalez National Affordable Housing Act.

As a fair housing planning document, the AFH facilitates HUD grantee compliance with statutory and regulatory requirements to affirmatively further fair housing. Affirmatively furthering fair housing entails taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. The duty to affirmatively further fair housing applies to all activities and programs within a jurisdiction related to housing and urban development.

This AFH is a collaborative effort among the following jurisdictions:
• Orange County and the Urban County Program participating cities of Brea, Cypress, Dana Point, La Palma, Laguna Beach, Laguna Hills, Laguna Woods, Los Alamitos, Placentia, San Juan Capistrano, Seal Beach, Stanton, Villa Park, and Yorba Linda. • The HUD Entitlement Cities of Aliso Viejo, Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, Irvine, La Habra, Laguna Niguel, Lake Forest, Mission Viejo, Newport Beach, City of Orange, Rancho Santa Margarita, San Clemente, Santa Ana, Tustin, Westminster.

To prepare the AFH, jurisdictions first must identify fair housing issues. A fair housing issue refers to a condition within a specific geographic area that restricts fair housing choice or limits access to opportunity. Fair housing issues may include ongoing local or regional segregation/concentration or lack of integration, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, disproportionate housing needs, and evidence of discrimination or violations of civil rights law or regulations related to housing.

To identify fair housing issues, HUD recommends that jurisdictions gather and analyze data. For this AFH, the jurisdictions analyzed data on the following topics:
• Demographics
• Segregation or Concentration/Integration
• Racially and/or Ethnically Concentrated Areas of Poverty • Disparities in Access to Opportunity
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• Housing Needs
• Discrimination Complaints
The data utilized in the analysis are from the U.S. Census Bureau American Community Survey (ACS), HUD’s AFFH Data and Mapping Tool, the California Department of Housing and Community Development (HCD) AFFH Data Viewer 2.0, housing discrimination complaint data provided by HUD’s Office of Fair Housing and Equal Opportunity (FHEO), and information gathered through the community participation process (described below).

The ACS data utilized in the assessment are from the 2018-2022 five-year estimates, which were the most current data across all participating jurisdictions at the time the analysis was conducted.

After analyzing the data and identifying fair housing issues, jurisdictions then must identify contributing factors. A contributing factor is any condition that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues. For each fair housing issue and its contributing factors, jurisdictions must then develop fair housing goals. A fair housing goal is a specific, meaningful action that can reasonably be expected to create meaningful positive change that affirmatively furthers fair housing by increasing fair housing choice or reducing disparities in access to opportunity.

For the contributing factors and fair housing goals in this AFH, the jurisdictions built upon the extensive work they have already done preparing their most recent Housing Elements, which cover an eight-year planning period. As part of the state-mandated Housing Element, California jurisdictions must conduct a fair housing assessment that includes an analysis of fair housing issues, identification of factors that create and/or contribute to those issues, and development of goals and meaningful actions to affirmatively further fair housing.

Progress toward reaching the goals identified in the Housing Element must then be periodically reported to the state.

A summary of the fair housing issues, significant contributing factors, and fair housing goals for each jurisdiction can be found in Section IV of this AFH.

Orange County 3 25-29 Regional AFH
II. Community Participation Process
To develop the AFH, information was also gathered from residents, housing professionals, and service providers. Incorporating information from these sources is important for ensuring that the AFH reflects community needs and knowledge that may not be discernible from other data sources. The community participation process for this AFH involved the following efforts:

A. Stakeholder Consultation
Four one-on-one interviews, and two focus groups were conducted during January and February 2025 with organizations that provide fair housing services and/or housing and services to protected class groups throughout the County. The interviews and focus group sessions discussed the fair housing issues frequently encountered by the organizations, the underlying causes for those issues, and ongoing efforts currently to address them.

Participants also discussed additional actions their organizations would recommend.

Invitations to participate in the stakeholder consultation activities were sent to approximately 78 organizations identified by the jurisdictions involved in the planning process. Fourteen organizations, as well as staff from two of the participating jurisdictions, participated in these consultations, including: Fair Housing Council of Orange County, Fair Housing Foundation, Orange County Families Forward, Orange County United Way, Family Assistance Ministry, The HUB OC, National Core, NeighborWorks Orange County, Thomas House Family Shelter, Domus Development, City of Garden Grove, City of Lake Forest, Dayle McIntosh Center, CalOptima, and Assistance League of Orange County. Information gathered through these consultations is incorporated throughout this report.

B. Community Meetings
A total of six community meetings were held in March 2025 to gather public input on the fair housing issues impacting residents of Orange County, and the factors that create, contribute to, perpetuate, or increase the severity of those issues. These meetings included two virtual meetings and four in-person meetings held at the dates, times, and locations listed below.

In-person community meetings:
• March 5, 2025, from 10:30 a.m. – 11:30 a.m. at Santa Ana City Council Chamber, 22 Civic Center Plaza, Santa Ana, CA 92701
• March 5, 2025, from 6:30 p.m. – 7:30 p.m. at Santa Ana City Council Chamber, 22 Civic Center Plaza, Santa Ana, CA 92701
• March 6, 2025, from 10:30 a.m. – 11:30 a.m. at La Habra City Hall, Festival Room, 110 E. La Habra Boulevard, La Habra, CA 90631
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• March 6, 2025, from 6:30 p.m. – 7:30 p.m. at Costa Mesa City Hall, Community Room, 77 Fair Drive, Costa Mesa, CA 92626
Virtual community meetings:
• March 7, 2025, at 6:00 p.m., via Microsoft Teams
• March 13, 2025, at 1:00 p.m., via Microsoft Teams
Outreach to advertise the community meetings included the following efforts:
• City of Anaheim notified the 250 members of their Homeless Collaborative and community stakeholders.
• City of Aliso Viejo posted a copy of the notice to their City website and shared on social media and city newsletters.
• City of Buena Park posted the public notice on the City website and City Hall bulletin board.
• City of Fountain Valley posted the public notice on the City website • City of Fullerton published the public notice in the Fullerton Observer newspaper, placed the notice on the City of Fullerton website, and placed copies of the notice at various public facilities and libraries as well as over 25 affordable housing sites. • City of Irvine sent copies of the notice to subrecipient partners and other interested parties.
• City of Laguna Niguel posted the public notice on the City website and social media channels.
• City of Mission Viejo posted the public notice on the City website. • City of San Clemente posted the public notice on the City website. • City of Santa Ana published the public notice for the public meetings in six languages (English, Spanish, Vietnamese, Korean, Chinese, and Arabic) including the following publications: Orange County Register, La Opinion, Nguoi Viet Daily News, Korea Times, World Journal, and Beirut Times.
• City of Rancho Santa Margarita posted the public notice on bulletin boards outside City Hall, OCFA Station 45, and Trabuco Canyon Water District. • County of Orange sent information regarding the virtual community meetings to community centers in the unincorporated areas of the County.

A total of fifteen individuals participated in these meetings to share their knowledge on fair housing issues and contributing factors in Orange County. These included representatives from the following organizations: Equus Workforce Solutions, Project Hope Alliance, Alianza Translatinx, Human Options, Illumination Foundation, The Eli Home, The Cambodian Family, Orange County Families Forward, City of Fountain Valley, and City of Buena Park. Information gathered through these meetings is incorporated throughout this report.

Orange County 5 25-29 Regional AFH
Orange County 6 25-29 Regional AFH
III. Fair Housing Analysis
A. Demographic and Housing Summary
Table 1 – Demographics, shows demographic information for the population of Orange County overall, the Orange County Urban County jurisdictions0F 1 , the participating HUD
Entitlement Cities, and the region1F
2 . These data are from the Census Bureau’s 2018-2022
American Community Survey 5-year Estimates. Table 2 – Demographic Trends, shows similar data over time, dating back to 1990. These tables indicate the following:

Population
Orange County has a population of 3,175,227. The largest cities in the County are Anaheim (population 347,111), Santa Ana (population 311,379), and Irvine (population 304,527). The Urban County population is 585,178.

Race/Ethnicity
Orange County’s population is majority-minority; however, the largest population group is White (38.46%). Hispanic residents comprise the second largest population group (33.93%), followed by Asian American and Pacific Islanders (AAPI), who make up 21.77% of the County population. African Americans account for 1.54% of the County population.

Compared to the region, Orange County has a higher proportion of White and AAPI residents, and a smaller proportion of Hispanic and Black residents.

Among the participating HUD Entitlement Cities, in comparison to the County overall:
• The Urban County, Aliso Viejo, Costa Mesa, Huntington Beach, Laguna Niguel, Lake Forest, Mission Viejo, Newport Beach, Rancho Santa Margarita, and San Clemente have a significantly higher2F
3 proportion of White residents.
• Anaheim, La Habra, and Santa Ana have a significantly higher proportion of Hispanic residents.
• Buena Park, Fountain Valley, Garden Grove, Irvine, and Westminster have a higher proportion of AAPI residents.

Since 1990, the County population has become more diverse, transitioning from a White majority in 1990 to a majority-minority population today. The number of White residents in 1 The Orange County Urban County comprises the County unincorporated area, twelve (12) cities with populations under 50,000 (participating cities) and two (2) cities, Placentia and Yorba Linda, with populations over 50,000 (metropolitan cities).
2The region is defined by HUD as the Los Angeles-Long Beach-Anaheim Metropolitan Statistical Area (MSA), which comprises Los Angeles and Orange counties.
3 For this analysis, “significantly higher” means that the percentage of residents of a particular race/ethnicity in a city is at least 10% higher than the percentage of residents of the same race/ethnicity in the County overall.

Orange County 7 25-29 Regional AFH
the County declined each decade, while the number of Hispanic and AAPI residents grew.

The number of Black residents increased between 1990-2010 but declined over the past decade. These same trends are generally shared with the region and across the Urban County and HUD Entitlement Cities, with the following exceptions:
• In the region, the Black population has been declining since 2000. • In Aliso Viejo, the population of all racial/ethnic groups, including White, has increased in each decade.
• In Costa Mesa, Garden Grove, Huntington Beach, and Newport Beach, the AAPI population has declined over the last decade.
• In Fountain Valley and Garden Grove, the Black population has been declining since 2000.
• In Irvine, the White and Black populations have been increasing since 2000, in addition to growing Hispanic and AAPI populations.
• In La Habra, the Black population continued to grow after 2010. • In Laguna Niguel and Lake Forest, the White population increased during the 1990s before declining over the subsequent decades, and the Black population has continued to grow over the last decade.
• In Rancho Santa Margarita, the White population increased during the 1990s before declining over the last two decades.
• In San Clemente, the White population grew between 1990-2010, before shrinking slightly over the last decade; and the AAPI population fell over the last decade. • In Santa Ana, the Black population has been falling since 1990, and the Hispanic population has been declining since 2000.
• In Tustin, the Black population has been declining since 1990.

National Origin
Orange County has a foreign-born population of 937,254 (29.52% of the total population3F 4 ).

The primary countries of origin for the foreign-born population are Mexico (9.17%) and Vietnam (4.69%).

In the region, 32.52% of the population is foreign born, which is slightly higher than in Orange County.

Among the participating HUD Entitlement Cities, in comparison to the County overall:
• Huntington Beach, Laguna Niguel, Newport Beach, Orange, and San Clemente have significantly lower percentages of foreign-born residents. 4 Source: U.S Census Bureau, 2018-2022 American Community Survey 5-Year Estimates, Table B05006 Orange County 8 25-29 Regional AFH
• Garden Grove, Irvine, Santa Ana, and Westminster have significantly higher percentages of foreign-born residents. In these cities, the main countries of origin for the foreign-born population are:
o Garden Grove: Vietnam and Mexico
o Irvine: China (excluding Taiwan), Korea, and India
o Santa Ana: Mexico and Vietnam
o Westminster: Vietnam and Mexico
Since 1990, the County’s foreign-born population has increased in each decade, with the most dramatic increase occurring during the 1990s. In comparison, • The foreign-born population in the region grew between 1990-2010 and has been declining since 2010.
• The foreign-born population has declined in the following jurisdictions:
o The Urban County, Anaheim, La Habra, Orange, and San Clemente, where the foreign-born population has been declining since 2010.
o Costa Mesa and Santa Ana, where the foreign-born population has been declining since 2000. However, in Santa Ana, foreign-born residents still make up approximately half of the total population.
• In Irvine, the foreign-born population has continued to grow rapidly, nearly doubling since 2010.

Limited English Proficiency
Individuals who have Limited English Proficiency (LEP) are those who primarily speak a language other than English and speak English “less than very well.” In Orange County, there are 539,484 LEP individuals4F
5 , which is equal to approximately 16.99% of the
population. The primary languages spoken by the LEP population in the County are Spanish (11.72%) and Vietnamese (3.45%).

In the region, 21.95% of the population is LEP, which is slightly higher than in Orange County.

Among the participating HUD Entitlement Cities, in comparison to the County overall:
• Aliso Viejo, Newport Beach, and San Clemente, have significantly lower percentages of LEP residents.
• Anaheim, Buena Park, Garden Grove, Santa Ana, and Westminster have significantly higher percentages of LEP residents. In these cities, the primary languages spoken by the LEP population are:
o Anaheim: Spanish and Vietnamese
5 Source: U.S Census Bureau, 2018-2022 American Community Survey 5-Year Estimates, Table S1601 Orange County 9 25-29 Regional AFH
o Buena Park: Spanish and Korean
o Garden Grove:Vietnamese and Spanish
o Santa Ana: Spanish and Vietnamese
o Westminster:Vietnamese and Spanish
Between 1990-2010, the County’s LEP population increased. Since 2010, the County’s LEP population has declined, though it remains well above the 1990 LEP population. In comparison:
• The LEP population in the region grew during the 1990s but has been declining since 2000.
• The LEP population has grown each decade since 1990, including since 2010, in the Urban County jurisdictions, Aliso Viejo, Fountain Valley, Irvine, Laguna Niguel, Lake Forest, Mission Viejo, Rancho Santa Margarita, and Westminster. • The LEP population has been declining since 2000 in Anaheim, Costa Mesa, Huntington Beach, and Santa Ana.
• In Garden Grove, Newport Beach, and San Clemente, the LEP population declined between 2000-2010, but has increased since 2010.

Age
Approximately 63.2% of the Orange County population is between the ages of 18 and 64;

15.38% are aged 65 and older, and 21.42% are younger than 18. The age distribution of the population in the region is similar. In comparison to the County overall, the Urban County, Laguna Niguel, Mission Viejo, and Newport Beach all have slightly older populations, with over one-fifth of their population aged 65 and older.

Since 1990, the County’s population has been getting older. Currently, the County’s population has a smaller proportion of the population (when compared to 1990) in both the “Under 18” and “18-64” year-old age categories, and a higher proportion of the population in the “65+” age category. The same general trend is evident in the region and all other jurisdictions, except for Aliso Viejo, where the percentage of the population under age 18 has increased, and the percentage of the population aged 65 and older has decreased, since 1990.

Families with Children
In Orange County, approximately 41.56% of families have children. This is slightly higher than the region, where 40.02% of families have children. Among the participating HUD Entitlement Cities, in comparison to the County overall:
• Aliso Viejo and Tustin have significantly higher percentages of families with children (52.06% and 52.64%, respectively), and in Irvine, over half (50.45%) of families have children.

Orange County 10 25-29 Regional AFH
• Laguna Niguel, Huntington Beach, Newport Beach, and Westminster have the lowest percentages of families with children, although the percentages are not significantly lower than those for the County overall.

The percentage of families with children in the County is lower today than it was in 1990, when 48.04% of families had children. This is also true in the region and the other jurisdictions, with the following exceptions:
• Aliso Viejo, Newport Beach, and Tustin, where the current percentage of families with children is higher than it was in 1990.

Table 1 – Demographics
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 11 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 12 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 13 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 14 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 15 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 16 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 17 25-29 Regional AFH
Table 1 – Demographics (continued)
Note 2: 10 most populous places of birth and languages at the jurisdiction level may not be the same as the 10 most populous at the Region level, and are thus labeled separately.

Note 3: Data Sources: LEP Language data from U.S. Census Bureau, 2011-2015 American Community Survey 5-Year Estimates; All other data from U.S. Census Bureau, 2018-2022 American Community Survey 5- Year Estimates.

Note 1: All % represent a share of the total population within the jurisdiction or region, except family type, which is out of total families.

Orange County 18 25-29 Regional AFH
Table 2 – Demographic Trends
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Table 2 – Demographic Trends (continued)
Orange County 20 25-29 Regional AFH
Table 2 – Demographic Trends (continued)
Orange County 21 25-29 Regional AFH
The following paragraphs describe housing patterns, including tenure, cost burden, and the location of renters and owners.

Tenure
Table 3 - Housing Tenure, shows data on housing tenure for the region, Orange County, the Orange County Urban County jurisdictions, and each HUD Entitlement City. These data are from the 2018-2022 American Community Survey 5-Year Estimates. This table indicates the following:

In Orange County overall, the homeownership rate is 56.5%. This is higher than the homeownership for the region, which is 48.7%. Among the jurisdictions, • The following have a comparable homeownership rate (within five percentage points of the County’s rate)
o Aliso Viejo
o Buena Park
o Fullerton
o Garden Grove
o Huntington Beach
o La Habra
o Newport Beach
o Orange
o Westminster
• The following jurisdictions have a homeownership rate that is lower than the homeownership rate for the County overall by at least five percentage points, indicating a higher percentage of households are renters:
o Anaheim
o Costa Mesa
o Irvine
o Santa Ana
o Tustin
• The following jurisdictions have a homeownership rate that is higher than the County overall by at least five percentage points:
o The Urban County jurisdictions
o Fountain Valley
o Laguna Niguel
o Lake Forest
o Mission Viejo
o Rancho Santa Margarita
o San Clemente
Orange County 22 25-29 Regional AFH
Table 3 – Housing Tenure
Orange County 23 25-29 Regional AFH
Cost Burden
Table 4 – Cost Burden shows data on housing cost burden for the region, Orange County, the Orange County Urban County, and each HUD Entitlement City. These data are from the 2018-2022 American Community Survey 5-Year Estimates. Cost burden is defined as spending more than 30% of monthly gross income on housing-related costs. This table presents the following:

In Orange County overall, over half (53.2%) of all renters are cost burdened. The rate is significantly lower for homeowners (30.3%). These rates are comparable to the experience of owners and renters across the region. Among the jurisdictions, • The following have a comparable rate of cost burdened renters (within five percentage points of the County’s rate)
o The Urban County jurisdictions
o Aliso Viejo
o Buena Park
o Costa Mesa
o Fullerton
o Garden Grove
o Huntington Beach
o Irvine
o Laguna Niguel
o La Habra
o Mission Viejo
o Orange
o Rancho Santa Margarita
o Santa Ana
o Westminster
• The following jurisdictions have a renter cost-burden rate that is lower than the rate for the County overall by at least five percentage points:
o Newport Beach
o San Clemente
• The following jurisdictions have a renter cost-burden rate that is higher than the rate for the County overall, by at least five percentage points, meaning a higher percentage of renters in these jurisdictions are cost burdened compared to the County overall:
o Anaheim
o Fountain Valley
o Lake Forest
o Tustin
Orange County 24 25-29 Regional AFH
Table 4 – Cost Burden
Orange County 25 25-29 Regional AFH
Location of Renters and Owners
Map 1 – Housing Tenure. is a series of maps showing the distribution of renter households in the region, and in northern, central, and southern Orange County. These maps were produced by California HCD to facilitate the fair housing planning process 5F 6 . On the maps,
the darker shaded areas have a higher proportion of renter households. These maps reflect the following:
• In Orange County overall, renters are concentrated in the north, west, and central parts of the County. Moving east and south from the border with Los Angeles County, a higher percentage of housing units are owner-occupied.

Within the participating jurisdictions, there are concentrations of renter-occupied and owner-occupied housing in the following areas:
• In the Orange County Urban County jurisdictions there are relatively few areas with a high percentage of renter households, with the exceptions of Placentia, which has high concentrations of renter households in the southwest corner of the city and in parts of the city near CSU-Fullerton; and Los Alamitos, which has a high concentration of renters in the neighborhood north of Joint Forces Training Base Los Alamitos and west of Lexington Drive. Conversely, there are various parts of the Urban County jurisdictions with relatively high concentrations of owner households, including Yorba Linda and the unincorporated area to the east of Yorba Linda, North Tustin, Seal Beach (outside the Naval Weapons Station), Rossmoor, Villa Park, Orange Park Acres, and Northwest Brea.
• In Aliso Viejo there is a relatively high percentage of renter households south of SR73 between Aliso Viejo Parkway and Woodfield Park, and a relatively high percentage of owner households along the southern and western edges of city, south of SR-73 and west of Pacific Park Drive and Wood Canyon Drive.
• In Anaheim there are relatively high percentages of renter households in the Census Tracts north of SR-91 in Northeast Anaheim; between the Convention Center and I5, and around Angel Stadium, in the southeastern part of the city; and in the Census Tract south of I-5 bounded by Lincoln Avenue and Brookhurst Street, in the northwestern part of the city. There is a relatively high percentage of owner households in Anaheim Hills.
• In Buena Park there is a relatively high percentage of renters in the Census Tracts just north of I-5.
6 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing Orange County 26 25-29 Regional AFH
• In Costa Mesa there are relatively high concentrations of renter households north of SR-55 in the downtown area, and west of Orange Coast College; and there is a relatively high percentage of owner households north of Adams Avenue. • In Fountain Valley there are relatively high percentages of owner households in the neighborhoods south of Talbert Avenue and west of Brookhurst Street, and in the neighborhood just to the west of Mile Square Regional Park. • In Fullerton there are relatively high percentages of renter households in and around CSU Fullerton and along Highland Ave between SR-91 and Orangethorpe Avenue (adjacent to the Fullerton Metrocenter shopping mall); and there are relatively high percentages of owner households in Census Tracts between CSU Fullerton and Brea Boulevard, and between Harbor Boulevard and the Robert E. Ward Nature Preserve. • In Garden Grove, there is a relatively high percentage of owner households in West Garden Grove, compared to the rest of the city.
• In Huntington Beach there are high percentages of owner households in the eastern half of the city, as well as in the area surrounding the Huntington Club country club. • In Irvine there are relatively high percentages of renter households in the southwestern part of the city—specifically in the Census Tracts west of Harvard Ave, around San Remo Park, and north of UC Irvine in University Town Center; and near the I-5/I-405 interchange—specifically in the Census Tracts encompassing the Irvine Medical and Science Complex, the Irvine Spectrum Center, and East Irvine. • In La Habra there are a relatively high percentage of owner households in the neighborhoods south of SR-90 and west of Euclid St.
• In Laguna Niguel there are relatively high percentages of owner households in the southeast corner of the city (bordering San Juan Capistrano and Dana Point), adjacent to the El Niguel County Club, and in the neighborhoods between Crown Valley Pkwy and Alicia Pkwy.
• In Lake Forest there are relatively high percentages of owner households in the northeast of the city (to the north of SR-24) and in the southwest of the city (south of Trabuco Rd and west of Ridge Route Dr).
• In Mission Viejo there are relatively high percentages of owner households throughout the city, with some renters located in the southern part of the city. • In Newport Beach there is a relatively high percentage of owner households in the Newport Coast community, and a relatively high percentage of renters around the Newport Beach Country Club.
• In the City of Orange there are relatively high percentages of renter households in the southwestern corner of the city, west of SR-57 and I-5, and relatively high percentages of owner households in the eastern half of the city. • In Rancho Santa Margarita there is a relatively high percentage of owner households throughout the city, with some renters located in the neighborhoods just to the east of SR-241 between Antonio Pkwy and Santa Margarita Pkwy.

Orange County 27 25-29 Regional AFH
• In San Clemente there is a relatively high percentage of renter households in the neighborhoods south of Max Berg Plaza Park, and relatively high percentages of homeowners in a number of neighborhoods to the north and northwest. • In Santa Ana there are relatively high percentages of renter households in the downtown area and in the neighborhoods southeast of downtown. • In Tustin there are relatively high percentages of renter households in the neighborhoods adjacent to SR-55 south of I-5, and relatively high percentages of owner households in the northeast part of the city.
• In Westminster there are relatively high percentages of renters in the neighborhoods just north and south of Westminster Blvd between Hoover St. and Beach Blvd.

Map 1 – Housing Tenure – Region
Source: California HCD, AFFH Data Viewer
Orange County 28 25-29 Regional AFH
Map 1 – Housing Tenure – North Orange County
Source: California HCD, AFFH Data Viewer
Orange County 29 25-29 Regional AFH
Map 1 – Housing Tenure – Central Orange County
Source: California HCD, AFFH Data Viewer
Orange County 30 25-29 Regional AFH
Map 1 – Housing Tenure – South Orange County
Source: California HCD, AFFH Data Viewer
Orange County 31 25-29 Regional AFH
The following analysis describes the demographics of residents of publicly supported housing.

Table 5 – Publicly Supported Households by Race/Ethnicity, provides the demographics of residents of different types of publicly support housing programs, including Public Housing, Project-Based Section 8, Other Multifamily, and the Housing Choice Voucher (HCV) Program. This table shows that, in Orange County:
• The majority of publicly supported housing is provided through the HCV Program (over 20,000 households with HCVs countywide). Additionally, there are approximately 4,000 units in Project-based Section 8 properties and approximately 100 units in Other Multifamily properties. There are no Public Housing units in the County.
• A significant portion of households with HCVs are headed by an AAPI individual (41.16%), followed by households headed by a White individual (25.32%), then Hispanic-headed households (21.12%), and then Black households (7.06%). • Project-based Section 8 units have a similar racial composition to the HCV Program overall; however, the percentages of households headed by AAPI and White individuals are higher (47.11% and 33.06% respectively), and households headed by Hispanic and Black individuals are lower (15.19% and 1.77% respectively).

Within the participating jurisdictions, the racial/ethnic composition of publicly supported housing units varies:
• In the Orange County Urban County jurisdictions, the racial/ethnic composition of households in the HCV Program and in Project-based Section 8 units matches the County overall, with the one exception being that the number of AAPI and White households in Project-based Section 8 units are equal (each comprise 36.75% of those units).
• In Aliso Viejo, the only publicly supported housing available is through the HCV Program. Two-thirds of households using HCVs in the city are White. • In Anaheim, there are Project-based Section 8 developments in addition to households using HCVs. In the Project-based Section 8 units, the majority of households are AAPI. In the HCV Program, Hispanic households make up the largest single group of voucher recipients, followed by AAPI and White households. • In Buena Park, the overwhelming majority of households in Project-based Section 8 units are AAPI. In the HCV Program, approximately one-third of households are Hispanic, 25% AAPI, 25% White, and nearly one-fifth of households are Black. • In Costa Mesa, the majority of households in both Project-based Section 8 housing and the HCV Program are White, and there are no Black households in Project-based Section 8 units.

Orange County 32 25-29 Regional AFH
• In Fountain Valley, the majority of households in both Project-based Section 8 housing and the HCV Program are AAPI, and there are no Black households in Project-based Section 8 units.
• In Fullerton, nearly all of the households in Project-based Section 8 units are AAPI and the majority of households in Other Multifamily program units are White. In the HCV Program, White and Hispanic families each make up approximately one-third of households, and Black and AAPI families each make up approximately 14% of households.
• In Garden Grove, a large majority of households in both Project-based Section 8 housing and the HCV Program are AAPI (over 80% in each program). • In Huntington Beach, over 50% of households in Project-based Section 8 units are AAPI and around one-third are White. In the HCV Program, over 40% of households are White and around one-third are AAPI.
• In Irvine, White households are the majority in Project-based Section 8 and Other Multifamily program units and are the largest share of households in the HCV Program (46.76%). In the HCV Program, Black households are the second largest racial/ethnic group, comprising approximately one-fifth of households. • In La Habra, Hispanic households are the majority of HCV Program participants. The second largest racial/ethnic group is White households, who comprise 25% of households in the program. In Project-based Section 8 units, Hispanic, White, and AAPI each comprise approximately one-third of households. • In Laguna Niguel, the majority of households in both Project-based Section 8 housing and the HCV Program are White.
• In Lake Forest, the majority of households in the HCV Program are White. There are no other types of publicly supported housing in the city. • In Mission Viejo, the majority of households in the HCV Program are White. There are no other types of publicly supported housing included in the HUD-provided data. (However, per the City’s Housing Element and other local sources, there are various publicly supported housing developments in the city.)
• In Newport Beach, the majority of households in both Project-based Section 8 housing and the HCV Program are White.
• In Orange, White and Hispanic households each comprise a slightly more than 40% of households in Project-based Section 8 units, and approximately one-third of households in the HCV Program. AAPI households make up around 25% of households in the HCV Program.
• In Rancho Santa Margarita, the majority of households in the HCV Program are White. There are no other types of publicly supported housing in the city. • In San Clemente, the majority of households in both Project-based Section 8 housing and the HCV Program are White.

Orange County 33 25-29 Regional AFH
• In Santa Ana, the majority of households in Project-based Section 8 units and in the HCV Program are AAPI. The second largest racial/ethnic group in each of these programs is Hispanic households.
• In Tustin, the majority of households in Project-based Section 8 units are AAPI (over 70%) and approximately one-fifth are White. In the HCV Program, Hispanic households are the largest group (38%), followed by White households (33%). • In Westminster, AAPI households are the majority in both Project-based Section 8 units and in the HCV Program.

Orange County 34 25-29 Regional AFH
Table 5 – Publicly Supported Households by Race/Ethnicity Los Angeles-Long Beach-Anaheim, CA MSA
Housing Type # % # % # % # %
Public Housing 653 6.67% 2,696 27.54% 6,055 61.84% 374 3.82% Project-Based Section 8 9,108 23.49% 6,733 17.37% 10,666 27.51% 12,058 31.10% Other Multifamily 1,706 32.43% 450 8.55% 1,173 22.30% 1,909 36.29% HCV Program 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Total Households 1,741,265 40.51% 332,330 7.73% 1,458,220 33.92% 666,628 15.51% 0-30% of AMI 242,025 29.00% 96,395 11.55% 355,100 42.55% 122,168 14.64% 0-50% of AMI 425,645 28.94% 149,340 10.16% 661,570 44.99% 203,018 13.81% 0-80% of AMI 682,980 30.49% 208,645 9.31% 990,690 44.22% 310,058 13.84% Orange County, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 1,362 33.06% 73 1.77% 626 15.19% 1,941 47.11% Other Multifamily 71 68.27% 8 7.69% 10 9.62% 6 5.77%
HCV Program 5,776 25.32% 1,610 7.06% 4,819 21.12% 9,390 41.16% Total Households 537,517 51.84% 16,903 1.63% 241,657 23.30% 186,863 18.02% 0-30% of AMI 63,893 40.68% 2,935 1.87% 52,308 33.30% 34,051 21.68% 0-50% of AMI 119,885 41.29% 5,251 1.81% 102,916 35.45% 55,867 19.24% 0-80% of AMI 206,268 43.82% 8,396 1.78% 160,512 34.10% 85,187 18.10% Orange County Urban County
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 154 36.75% 11 2.63% 96 22.91% 154 36.75% Other Multifamily 21 87.50% 0 0.00% 3 12.50% 0 0.00%
HCV Program 729 31.81% 164 7.16% 420 18.35% 969 42.30%
Total Households 123,567 64.87% 3,074 1.61% 30,302 15.91% 29,493 15.48% 0-30% of AMI 14,141 57.02% 339 1.37% 5,608 22.61% 4,234 17.07% 0-50% of AMI 27,749 57.61% 644 1.34% 10,983 22.80% 7,883 16.36% 0-80% of AMI 46,897 59.09% 1,298 1.64% 17,045 21.48% 12,551 15.82% Aliso Viejo, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 0 0.00% 0 0.00% 0 0.00% 0 0.00% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 109 66.09% 17 10.60% 23 13.90% 14 8.60%
Total Households 12,570 67.58% 380 2.04% 2,120 11.40% 2,830 15.22% 0-30% of AMI 960 67.37% 85 5.96% 100 7.02% 205 14.39%
0-50% of AMI 1,675 66.07% 180 7.10% 195 7.69% 385 15.19% 0-80% of AMI 3,540 65.98% 250 4.66% 555 10.34% 770 14.35% Anaheim, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 58 21.48% 14 5.19% 51 18.89% 146 54.07% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 1,273 26.52% 430 8.96% 1,788 37.25% 1,290 26.89% Total Households 36,390 36.39% 2,688 2.69% 41,509 41.51% 17,464 17.46% 0-30% of AMI 5,410 26.79% 670 3.32% 10,364 51.32% 3,345 16.56% 0-50% of AMI 10,610 27.99% 1,214 3.20% 19,969 52.68% 5,429 14.32% 0-80% of AMI 17,010 28.83% 1,723 2.92% 30,514 51.72% 8,554 14.50% Buena Park, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 13 11.40% 1 0.88% 5 4.39% 95 83.33% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 174 24.25% 127 17.65% 232 32.25% 184 25.54% Total Households 7,540 32.34% 835 3.58% 7,705 33.05% 6,830 29.29% 0-30% of AMI 885 21.74% 250 6.14% 1,545 37.96% 1,300 31.94% 0-50% of AMI 1,820 22.28% 315 3.86% 3,590 43.94% 2,270 27.78% 0-80% of AMI 3,180 25.68% 515 4.16% 5,020 40.53% 3,440 27.78% White Black Hispanic Asian or Pacific Islander
Race/Ethnicity
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
White Black Hispanic
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
Asian or Pacific Islander
Note 3: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Note 1: Data Sources: Decennial Census, APSH, and CHAS; accessed through the HUD AFFH Tool, Table 6, Version AFFHT0006, Released July 10, 2020.

Note 2: Numbers presented are numbers of households not individuals.

Orange County 35 25-29 Regional AFH
Table 5 – Publicly Supported Households by Race/Ethnicity (continued) Costa Mesa, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 69 65.09% 0 0.00% 19 17.92% 18 16.98% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 376 57.17% 23 3.50% 107 16.24% 149 22.64%
Total Households 25,230 61.75% 695 1.70% 10,105 24.73% 3,870 9.47% 0-30% of AMI 3,720 54.35% 105 1.53% 2,380 34.77% 480 7.01% 0-50% of AMI 6,395 51.45% 175 1.41% 4,680 37.65% 955 7.68% 0-80% of AMI 10,960 53.71% 285 1.40% 6,955 34.08% 1,800 8.82% Fountain Valley, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 10 14.29% 0 0.00% 1 1.43% 59 84.29% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 99 19.23% 6 1.21% 44 8.55% 363 70.42%
Total Households 10,409 55.16% 175 0.93% 2,166 11.48% 5,794 30.70% 0-30% of AMI 1,305 49.25% 0 0.00% 227 8.57% 1,015 38.30% 0-50% of AMI 2,299 51.26% 25 0.56% 472 10.52% 1,539 34.31% 0-80% of AMI 4,214 52.51% 70 0.87% 1,036 12.91% 2,529 31.51% Fullerton, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 5 5.00% 0 0.00% 1 1.00% 94 94.00% Other Multifamily 38 79.17% 3 6.25% 5 10.42% 2 4.17%
HCV Program 264 38.23% 96 13.99% 232 33.64% 95 13.71%
Total Households 20,005 44.40% 1,448 3.21% 11,890 26.39% 10,615 23.56% 0-30% of AMI 3,305 37.49% 344 3.90% 2,835 32.16% 2,100 23.82% 0-50% of AMI 5,515 37.14% 434 2.92% 5,350 36.03% 3,205 21.58% 0-80% of AMI 9,305 38.61% 789 3.27% 8,375 34.75% 4,965 20.60% Garden Grove, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 34 13.28% 3 1.17% 4 1.56% 215 83.98% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 133 4.98% 35 1.30% 219 8.24% 2,270 85.23%
Total Households 14,254 29.92% 592 1.24% 13,550 28.44% 18,417 38.66% 0-30% of AMI 2,160 20.26% 165 1.55% 3,100 29.08% 5,054 47.42% 0-50% of AMI 3,865 20.48% 204 1.08% 6,200 32.86% 8,244 43.69% 0-80% of AMI 7,080 23.55% 303 1.01% 10,125 33.68% 12,043 40.06% Huntington Beach, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 133 35.00% 4 1.05% 41 10.79% 200 52.63% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 461 42.58% 50 4.61% 166 15.36% 399 36.88%
Total Households 53,650 71.15% 753 1.00% 10,855 14.40% 8,114 10.76% 0-30% of AMI 5,730 60.89% 115 1.22% 2,140 22.74% 1,220 12.96% 0-50% of AMI 11,035 62.66% 183 1.04% 3,905 22.17% 2,105 11.95% 0-80% of AMI 20,055 65.89% 323 1.06% 6,110 20.08% 3,205 10.53% Irvine, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 428 59.03% 24 3.31% 42 5.79% 231 31.86% Other Multifamily 12 52.17% 5 21.74% 2 8.70% 4 17.39%
HCV Program 682 46.76% 282 19.34% 246 16.84% 243 16.67% Total Households 45,515 50.61% 1,800 2.00% 6,788 7.55% 33,230 36.95% 0-30% of AMI 6,055 45.27% 230 1.72% 1,145 8.56% 5,260 39.33% 0-50% of AMI 9,580 46.56% 510 2.48% 1,939 9.42% 7,670 37.28% 0-80% of AMI 16,010 49.11% 625 1.92% 2,959 9.08% 11,750 36.04% White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
Note 3: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Note 1: Data Sources: Decennial Census, APSH, and CHAS; accessed through the HUD AFFH Tool, Table 6, Version AFFHT0006, Released July 10, 2020.

Note 2: Numbers presented are numbers of households not individuals.

Orange County 36 25-29 Regional AFH
Table 5 – Publicly Supported Households by Race/Ethnicity (continued) Note 3: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Note 1: Data Sources: Decennial Census, APSH, and CHAS; accessed through the HUD AFFH Tool, Table 6, Version AFFHT0006, Released July 10, 2020.

Note 2: Numbers presented are numbers of households not individuals.

Orange County 37 25-29 Regional AFH
Table 5 – Publicly Supported Households by Race/Ethnicity (continued) Rancho Santa Margarita, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 0 0.00% 0 0.00% 0 0.00% 0 0.00% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 87 62.31% 21 14.87% 24 17.06% 6 4.50%
Total Households 11,890 69.59% 285 1.67% 2,674 15.65% 1,855 10.86% 0-30% of AMI 1,095 66.57% 0 0.00% 440 26.75% 60 3.65%
0-50% of AMI 1,855 61.22% 50 1.65% 805 26.57% 215 7.10% 0-80% of AMI 3,525 65.58% 65 1.21% 1,295 24.09% 355 6.60% San Clemente, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 52 73.24% 0 0.00% 9 12.68% 9 12.68% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 100 72.35% 5 3.82% 26 18.61% 6 4.62%
Total Households 19,495 79.56% 130 0.53% 3,264 13.32% 965 3.94% 0-30% of AMI 1,820 67.16% 20 0.74% 605 22.32% 35 1.29%
0-50% of AMI 3,980 70.76% 20 0.36% 1,264 22.47% 65 1.16% 0-80% of AMI 6,420 72.62% 55 0.62% 1,809 20.46% 225 2.55% Santa Ana, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 44 5.47% 9 1.12% 202 25.12% 462 57.46% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 191 10.86% 69 3.89% 537 30.49% 958 54.41%
Total Households 12,430 16.55% 899 1.20% 50,935 67.83% 9,959 13.26% 0-30% of AMI 1,570 8.63% 159 0.87% 13,565 74.59% 2,745 15.09% 0-50% of AMI 3,405 9.76% 299 0.86% 26,460 75.88% 4,400 12.62% 0-80% of AMI 6,150 11.63% 529 1.00% 39,210 74.16% 6,440 12.18% Tustin, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 20 19.42% 0 0.00% 10 9.71% 73 70.87% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 192 33.12% 86 14.95% 219 37.88% 79 13.70%
Total Households 10,485 40.69% 604 2.34% 7,710 29.92% 6,084 23.61% 0-30% of AMI 1,480 39.31% 160 4.25% 1,465 38.91% 589 15.64% 0-50% of AMI 2,660 34.08% 240 3.07% 3,535 45.29% 1,134 14.53% 0-80% of AMI 4,595 34.93% 375 2.85% 5,965 45.34% 1,874 14.25% Westminster, CA
Housing Type # % # % # % # %
Public Housing 0 0.00% 0 0.00% 0 0.00% 0 0.00%
Project-Based Section 8 3 3.03% 0 0.00% 1 1.01% 95 95.96% Other Multifamily 0 0.00% 0 0.00% 0 0.00% 0 0.00%
HCV Program 122 5.13% 21 0.87% 103 4.33% 2,131 89.46%
Total Households 9,270 34.01% 203 0.74% 5,165 18.95% 12,121 44.47% 0-30% of AMI 1,595 22.62% 14 0.20% 1,195 16.95% 4,154 58.92% 0-50% of AMI 2,800 23.64% 24 0.20% 2,260 19.08% 6,599 55.71% 0-80% of AMI 4,685 27.38% 79 0.46% 3,630 21.22% 8,397 49.08% White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
Note 3: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Note 1: Data Sources: Decennial Census, APSH, and CHAS; accessed through the HUD AFFH Tool, Table 6, Version AFFHT0006, Released July 10, 2020.

Note 2: Numbers presented are numbers of households not individuals.

White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
White Black Hispanic Asian or Pacific Islander
Orange County 38 25-29 Regional AFH
B. Segregation/Concentration and Integration
The following analysis describes segregation/concentration levels, identifies the racial/ethnic groups that experience the highest levels of segregation/concentration, and explains how these levels and patterns have changed over time.

Table 6 – Racial/Ethnic Dissimilarity Trends, displays how segregated/concentrated or integrated various racial/ethnic groups are in the region, the Orange County Urban County, and the HUD Entitlement Cities using a Dissimilarity Index, which is calculated using data from the 2010 Decennial Census. The Dissimilarity Index measures the degree to which two groups are evenly distributed across a geographic area and is commonly used for assessing residential segregation/integration between two groups. Dissimilarity index values indicate the following:
• Values between 0 and 39 generally indicate high integration (low segregation/concentration)
• Values between 40 and 54 generally indicate moderate segregation/concentration • Values between 55 and 100 generally indicate a high level of segregation/concentration
Please note two key shortcomings of these data:

1. The data only measure segregation between Black and White, Hispanic, and White, and AAPI and White residents. As a result, no conclusions can be drawn regarding segregation among Black, Hispanic, and AAPI residents.

2. The data measure segregation only within each jurisdiction and do provide insights into racial/ethnic segregation across jurisdictional boundaries.

Table 6 shows that, in the region, there are high levels of segregation between Black and White residents and between Hispanic and White residents, and there is moderate segregation between AAPI and White residents. Since 1990, segregation between Black and White residents has declined, while segregation between Hispanic/White and AAPI/White has increased.

In Orange County the following jurisdictions are highly integrated, indicating low levels of segregation/concentration among the groups analyzed:
• The Urban County jurisdictions – While segregation levels are higher compared to 1990, they have trended downward since 2000 for Black/White and Hispanic/White residents.
• Aliso Viejo – Since 1990, concentrations of Hispanic and AAPI residents have been increasing but remain low.

Orange County 39 25-29 Regional AFH
• Anaheim – Segregation levels between Black/White and AAPI/White have been increasing since 1990. Segregation level between Hispanic/White were high in 2000 but have since declined.
• Buena Park – Segregation levels have increased since 1990 but remain low. • Fountain Valley – Since 1990, segregation levels between Hispanic/White and between AAPI/White have been increasing but remain low. • Fullerton – Segregation level between AAPI/White is increasing but remains low. • Garden Grove – Segregation levels have increased since 1990 but remain low. • Huntington Beach – Segregation level between Black/White increased between 2000-2010 but remains low.
• Irvine – Segregation levels between the groups analyzed decreased between 2000- 2010.
• La Habra – Since 1990, segregation between Black/White residents has increased, though remains low, and segregation between Hispanic/White and between AAPI/White has decreased.
• Laguna Niguel – Between 1990-2010, concentrations of Black and Hispanic residents increased, though remain low.
• Lake Forest – Between 1990-2010, segregation between Hispanic/White and between AAPI/White increased, though remains low.
• Mission Viejo – Between 1990-2010, concentration of Hispanic residents increased, though remains low.
• Newport Beach – Between 1990-2010, segregation between Hispanic/White and between AAPI/White increased, though remains low.
• Orange – Between 1990-2010, segregation between AAPI/White increased, though remains low.
• Rancho Santa Margarita – Concentration by race/ethnic group has increased since 1990 but remains low.
• Westminster – Segregation levels have increased since 1990 but remain low.

In Orange County the following jurisdictions have moderate levels of segregation between at least two of the racial groups analyzed (no jurisdictions in the County have high levels of segregation):
• Costa Mesa –There is moderate segregation between Hispanic and White residents.

Segregation levels declined slightly between 2000-2010 but remain moderate. • Santa Ana –There is moderate segregation between Hispanic and White residents, and between AAPI and White. Segregation levels between Hispanic/White residents declined slightly between 2000-2010 but remain moderate. Since 1990, segregation between AAPI/White residents has increased.
• Tustin – There is moderate segregation between Hispanic and White residents.

Segregation levels declined between 2000-2010 but remain moderate.

Orange County 40 25-29 Regional AFH
Table 6 - Racial/Ethnic Dissimilarity Trends
Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 55.32 55.50 54.64 30.48 36.54 35.55 1.79 6.49 8.90 Black/White 72.75 68.12 65.22 32.90 35.33 34.07 15.82 12.66 11.59 Hispanic/White 60.12 62.44 62.15 36.26 42.43 39.52 0.19 14.88 15.67 Asian or Pacific Islander/White 43.46 46.02 45.77 32.65 36.76 37.16 0.31 4.86 7.94 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 29.33 31.57 31.56 18.17 22.07 21.40 29.84 36.88 34.33 Black/White 22.16 25.87 27.69 21.76 23.51 25.25 30.17 27.07 27.67 Hispanic/White 38.77 40.24 38.70 26.64 33.21 30.85 34.52 45.33 41.88 Asian or Pacific Islander/White 13.23 17.28 21.53 11.56 13.87 16.44 30.36 31.94 30.59 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 14.25 22.27 23.54 25.53 31.16 30.52 25.05 31.79 32.16 Black/White 27.24 27.57 26.28 30.60 31.84 26.53 22.19 23.11 23.45 Hispanic/White 21.64 28.33 29.59 33.72 39.98 38.28 27.67 32.64 33.20 Asian or Pacific Islander/White 13.85 22.12 23.58 30.41 33.48 35.24 27.45 34.97 33.98 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 21.11 23.44 21.58 16.49 21.55 18.01 28.18 26.72 24.14 Black/White 21.45 19.99 24.20 42.99 27.84 19.37 12.56 13.25 19.36 Hispanic/White 28.10 33.37 30.09 21.98 22.79 17.88 33.93 30.96 28.59 Asian or Pacific Islander/White 22.86 20.11 18.25 18.18 22.57 18.73 40.48 38.69 36.53 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 9.17 12.98 16.34 9.39 15.38 17.28 13.67 15.17 15.75 Black/White 13.82 22.75 16.24 12.43 12.16 9.52 18.03 20.63 16.83 Hispanic/White 13.34 20.76 22.79 15.72 26.10 27.63 12.26 18.75 20.96 Asian or Pacific Islander/White 13.37 12.68 13.82 8.84 11.06 13.46 20.00 16.83 13.98 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 13.20 15.04 17.04 23.75 24.25 22.59 5.43 12.26 14.07 Black/White 21.92 19.85 15.96 24.17 24.63 24.89 7.18 12.64 13.35 Hispanic/White 14.33 18.29 18.21 30.31 29.99 26.95 5.73 19.52 23.13 Asian or Pacific Islander/White 22.99 23.74 25.92 19.44 22.28 22.53 6.70 8.56 9.55 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend 1990 Trend 2000 Trend 2010 Trend Non-White/White 21.89 25.93 16.76 47.77 49.28 46.49 26.33 36.73 32.93 Black/White 13.86 19.08 14.93 36.53 27.91 25.15 42.49 35.11 29.02 Hispanic/White 27.16 32.90 23.71 53.09 53.61 50.00 31.13 48.20 42.54 Asian or Pacific Islander/White 14.66 14.76 16.56 43.10 46.77 46.87 19.20 17.74 19.76 Racial/Ethnic Dissimilarity Index 1990 Trend 2000 Trend 2010 Trend Non-White/White 24.58 28.05 31.59
Black/White 11.56 14.18 17.62
Hispanic/White 30.31 29.74 31.83
Asian or Pacific Islander/White 23.15 29.73 34.65
Lake Forest, CA
Note 1: Data Source: Decennial Census, accessed through the HUD AFFH Tool, Table 3, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Westminster, CA
Rancho Santa Margarita, CA
San Clemente, CA Santa Ana, CA Tustin, CA
Orange, CA
Mission Viejo, CA
Newport Beach, CA
Los Angeles-Long Beach-Anaheim, CA MSA Aliso Viejo, CA
Anaheim, CA Buena Park, CA Costa Mesa, CA
Orange County Urban County
Garden Grove, CA
Huntington Beach, CA Irvine, CA La Habra, CA
Laguna Niguel, CA
Fountain Valley, CA Fullerton, CA
Orange County 41 25-29 Regional AFH
The following analysis identifies areas with relatively high segregation/concentration and integration and indicates the predominant groups living in each area.

Race/Ethnicity
Map 2 – Racial/Ethnic Concentration, is a series of maps showing racial/ethnic concentrations in the region, and in northern, central, and southern Orange County. These maps are published by California HCD using methodology from the Othering & Belonging Institute, which combines various measures of segregation and integration (including a dissimilarity index), and uses data from 2020. On these maps, dark red indicates areas where people of color (POC) experience high levels of segregation/concentration; green indicates areas where White residents experience high levels of segregation/concentration; yellow indicates areas that are racially/ethnically integrated.

Map 3 – Predominant Population by Race/Ethnicity, is a series of maps showing the predominant racial/ethnic group by Census Tract in the region, and in northern, central, and southern Orange County. The colors indicate different racial/ethnic groups, and the relative strength of the shading indicates the extent to which one group is dominant over the next most populous group (with darker shading indicating a higher concentration of that racial/ethnic group). These maps were created by California HCD using 2017-2021 ACS data, to facilitate fair housing planning. 6F
7 Collectively, the maps illustrate that in Orange County overall, there are areas of high POC segregation/concentration in the central and northern parts of the County (including the cities of Santa Ana, Westminster, Garden Grove, Anaheim, and Fullerton), and there are areas of high White segregation/concentration along the entire coast (including Seal Beach, Huntington Beach, Newport Beach, Laguna Beach, Dana Paint, Capistrano Beach, and San Clemente) and in the southern part of the County (including Mission Viejo, Aliso Viejo, Laguna Niguel, and Rancho Santa Margarita).

Within each participating jurisdiction, there are areas of high segregation/integration in the following locations:
• In the Orange County Urban County jurisdictions,
o There are areas of high White segregation in Dana Point, Laguna Beach, Laguna Hills, Laguna Woods, the unincorporated areas east of Rancho Santa Margarita, North Tustin, Seal Beach, Yorba Linda, northern Placentia, Villa Park, and Orange Park Acres.
o There are areas of high POC segregation in Stanton (which are predominantly Hispanic or AAPI), Cypress (which are predominantly AAPI), northern Yorba 7 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing Orange County 42 25-29 Regional AFH
Linda (which are predominantly AAPI), La Palma (which are predominantly AAPI), and San Juan Capistrano (which is predominantly Hispanic). o There are areas of integration including the Atwood neighborhood in Placentia, which is predominantly Hispanic; Brea just northwest of the SR90/SR-57 interchange, which is a predominantly Hispanic area; and in Los Alamitos, in the neighborhood north of Joint Forces Training Base Los Alamitos and west of Lexington Drive, which is predominantly Hispanic. • In Aliso Viejo, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration (which are predominantly White) in the northern and eastern parts of the city. • In Anaheim, the map shows integrated areas in Southeast Anaheim (where Hispanic residents are the predominant group), in western Anaheim west of Brookhurst Street (where Hispanic residents are the predominant group in many neighborhoods, and AAPI residents are the predominant group in a few others), and in the neighborhoods between Modjeska Park and Palm Lane Park in the Hermosa Village community (where Hispanic residents are the predominant group). The map shows another integrated area in Northeast Anaheim, to the north of SR-91. However, this is primarily an industrial/commercial area. The city also has neighborhoods of high POC segregation, including the neighborhoods north of downtown and along SR91, and neighborhoods south of downtown and adjacent to Disneyland. These areas are predominantly Hispanic. The Anaheim Hills area demonstrates a high White segregation.
• In Buena Park, most of the city is considered an area of low-medium segregation with the exception of the following areas: the northeast corner of the city is considered an area of high POC segregation and is predominantly AAPI; the neighborhood between I-5, Artesia Boulevard, Beach Boulevard, and the Los Angeles County border is also considered an area of high POC segregation, and is predominantly Hispanic; and the neighborhoods south of Boisseranc Park between Dale Street and the nurseries, is considered a racially integrated area. • In Costa Mesa, the neighborhoods between downtown and the Costa Mesa Country Club are areas of high POC segregation, with a predominantly Hispanic population.

The neighborhoods in East Side Costa Mesa (east of SR-55 and south of Mesa Drive) are all areas of high White segregation, as are the neighborhoods north of the Country Club and the neighborhoods between Estancia High School and Canyon Park.
• In Fountain Valley, the majority of Census Tracts are considered areas of high POC segregation, and many have a predominantly AAPI population (particularly north of Warner Avenue). The neighborhoods surrounding the intersection of Magnolia Street and Ellis Avenue in the city’s southwest, and between Brookhurst Street and Ward Street south of I-405, are considered areas of high White segregation.

Orange County 43 25-29 Regional AFH
• In Fullerton, there are various neighborhoods that are considered racially integrated, including in the area around CSU Fullerton and extending west to Fullerton College, and in the southwest area of the city. There are also areas considered to have high POC segregation, including most of the neighborhoods west of Harbor Boulevard and north of Malvern Avenue, which are predominantly AAPI areas. • In Garden Grove, the majority of the city is considered an area of high POC segregation except for West Garden Grove. In West Garden Grove, the residential neighborhoods west of Knott Street are considered areas of high White segregation.

East of Knott Street is primarily industrial and commercial land uses. In the high POC segregation areas, AAPI residents are the predominant group west of 9th Street and Hispanic residents are the predominant group east of there. • In Huntington Beach, most of the city’s neighborhoods are predominantly White, with the exception of one Census Tract in the center of the city that is predominantly Hispanic.
• In Irvine, there are a number of Census Tracts considered to be areas of high POC segregation, some of which are predominantly AAPI and others are predominantly White. These areas include the neighborhoods between I-405 and UC Irvine, the Westpark community north of I-405, the neighborhoods between Como Channel and I-5, and the Northwood community north of I-5. There are also areas of high White segregation in Irvine, including the neighborhood bounded by Turtle Rock Drive the area surrounding the Strawberry Farms Golf Club, the Woodbridge community north of I-405, and the neighborhood west of the Oak Creek Golf Club. Please note that data was unavailable for many parts of the city, as indicated by the grey shading. • In La Habra, there are various neighborhoods considered to have high POC segregation, including neighborhoods in the center of the city north of Guadalupe Park and between Idaho Street to the west and Sonora High School to the east. These neighborhoods are predominantly Hispanic. The city also has two racially integrated areas, one that extends across its border to the west (between SR-90 and the railroad tracks) and another that extends across its border to the south (south of SR-90 and east of Euclid St).
• In Laguna Niguel, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration (which are predominantly White) in the northeastern and eastern parts of the city. • In Lake Forest, most of the city’s neighborhoods have a predominantly White population. There are predominantly Hispanic neighborhoods in the southeast corner of the city, along El Toro Road, and the northwest corner of the city is predominantly AAPI.
• In Mission Viejo, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration in the southern, northern, and western parts of the city.

Orange County 44 25-29 Regional AFH
• In Newport Beach, the entire city is classified as an area of high White segregation. • In Orange, most of the city to the north and east of Villa Park is considered an area of high White segregation, and most of the city to the south and west of Villa Park is considered an area of low-medium POC segregation. In the low-medium segregation areas, the neighborhoods are predominantly Hispanic west of Glassel Street with a high concentration of Hispanic residents in the neighborhoods north of Walnut Avenue. The neighborhoods between Glassel Street and SR-55 are predominantly White, and the neighborhoods east of SR-55 and south of Villa Park are predominantly Hispanic. There is one area in the city that is considered integrated. This area lies to the south of Villa Park and runs south along Santiago Creek and east along the northside of Chapman Avenue toward El Modena. • In Rancho Santa Margarita, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration (which are predominantly White) in the neighborhoods east of SR-241 between Antonio Parkway and Santa Margarita Parkway.
• In San Clemente, the majority of the city is considered an area of high White concentration, with the exception of one Census Tract encompassing neighborhoods north and east of Max Berg Plaza Park, which is classified as low-medium concentration with a predominantly White population.
• In Santa Ana, the majority of the city is considered an area of high POC segregation and has a predominantly Hispanic population except for the Riverview West community which is predominantly AAPI. There are some areas of low-medium POC segregation in the city, including the neighborhoods north of I-5, Floral Park, West Floral Park, Fisher Park, Morrison/Eldridge Park, Riverglen, Casa de Santiago, and neighborhoods south of Warner Avenue.There is one integrated area in the southern part of the city between Segerstrom High School and the Bristol Place Shopping Mall, where White residents are the predominant group.
• In Tustin, there are racially integrated neighborhoods just to the north of I-5. These are surrounded by neighborhoods of low-medium segregation that are a mix of predominantly White, Hispanic, and AAPI.
• In Westminster, the majority of the city is considered an area of high POC segregation and has a predominantly AAPI population with a few exceptions. The northwestern corner of the city, between I-405 and Bolsa Chica Road is an area of high White segregation. Across I-405 from those neighborhoods is an integrated area with a predominantly Hispanic population (west of Edwards Avenue). This area includes mobile home parks near the intersections of SR-22 and I-405.

Orange County 45 25-29 Regional AFH
Map 2 – Racial/Ethnic Concentration – Region
Source: California HCD, AFFH Data Viewer
Orange County 46 25-29 Regional AFH
Map 2 – Racial/Ethnic Concentration – North Orange County Source: California HCD, AFFH Data Viewer
Orange County 47 25-29 Regional AFH
Map 2 – Racial/Ethnic Concentration – Central Orange County Source: California HCD, AFFH Data Viewer
Orange County 48 25-29 Regional AFH
Map 2 – Racial/Ethnic Concentration – South Orange County Source: California HCD, AFFH Data Viewer
Orange County 49 25-29 Regional AFH
Map 3 – Predominant Population by Race/Ethnicity – Region Source: California HCD, AFFH Data Viewer
Orange County 50 25-29 Regional AFH
Map 3 – Predominant Population by Race/Ethnicity – North Orange County Source: California HCD, AFFH Data Viewer
Orange County 51 25-29 Regional AFH
Map 3 – Predominant Population by Race/Ethnicity – Central Orange County Source: California HCD, AFFH Data Viewer
Orange County 52 25-29 Regional AFH
Map 3 – Predominant Population by Race/Ethnicity – South Orange County Source: California HCD, AFFH Data Viewer
The following analysis compares the locations of publicly supported housing with the areas of concentration.

Map 4 - Publicly Supported Housing, is a series of maps showing the location of federaland state-subsidized housing in the region, and in northern, central, and southern Orange County. These maps were created by California HCD to facilitate fair housing planning, using data from California Housing Partnership7F
8 . On the maps, the size of each dot
correlates to the number of publicly-supported housing units in an area—larger dots indicate higher numbers of units. The shading of the Census Tracts indicates the percentage of renter occupied housing units in that Tract that are supported by a HCV, including both tenant-based and project-based vouchers. The darker shading indicates higher percentages of vouchers.

The locations of publicly supported housing on these maps align with the areas of segregation and integration on Map 2 (Racial/Ethnic Segregation/Integration), in the following places:
8 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing Orange County 53 25-29 Regional AFH
• In the Orange County Urban County jurisdictions,
o There is overlap between the location of publicly supported housing, including a high rate of voucher use, and areas of high POC segregation in the following places:
▪ Cypress – in the neighborhood around King Elementary School, in the north of the city.
▪ Placentia – in the southwest corner of the city
▪ Stanton – throughout the city
▪ San Juan Capistrano – in the Census Tract that encompasses the interchange between I-5 and the Ortega Highway (SR-74)
o There is overlap between areas without any publicly supported housing and either low HCV use or no data on HCV use, and areas of high White segregation, the following places:
▪ Rossmoor, Seal Beach, North Tustin, Villa Park, Orange Park Acres, North Laguna Hills, Laguna Woods, and Dana Point
• In Aliso Viejo, there are publicly supported units and higher percentages of units with vouchers in the south of city, which is an area of high White concentration. • In Anaheim, there are multiple publicly supported housing developments downtown and north of downtown, which are high POC segregation areas. The map also shows a concentration of vouchers in the high POC segregation area between Santa Ana River and Orangethorpe Avenue, east of Anaheim Canyon Metrolink station and west of Imperial Highway (SR-90). However, this is largely a commercial/industrial area with few housing units. In the western part of the city, around Western High School, there is also a cluster of publicly supported housing developments in a racially integrated area.
• In Buena Park, most publicly supported housing units are located in between I-5 and the Artesia Freeway (SR-91), which is a low-medium segregation area like most of the city.
• In Costa Mesa, the largest number of publicly supported housing units and the highest concentration of vouchers is in high POC segregation area located downtown and west of downtown.
• In Fountain Valley, the location of publicly supported housing units and highest concentrations of vouchers mirrors the high POC segregation areas. • In Fullerton, publicly supported housing units are mostly clustered in the center of the city, which is a low-medium segregation area.
• In Garden Grove, there are lots of publicly supported housing units in the center of city along Garden Grove Boulevard, which is a high POC segregation area.

There are no publicly supported housing units in West Garden Grove, which is an area of high White segregation.

Orange County 54 25-29 Regional AFH
• In Huntington Beach, the map shows publicly supported housing units located in the center of the city. Local data identify affordable housing projects distributed broadly across the city.
• In Irvine, the high POC segregation areas north of I-405 overlap with the location of publicly supported housing units. In other parts of the city where there is high voucher use and multiple publicly supported housing developments, there is no segregation data available.
• In La Habra, publicly supported housing units are located in the city’s center and north neighborhoods, which are all low-medium or high POC segregation areas. • In Laguna Niguel, the map shows one public supported housing development (near the intersection of Pacific Park Drive and La Paz Road) and a small concentration of voucher use in northwest part of city, which is a low-medium concentration area. City staff report that another development in the western part of the City also receives vouchers.
• In Lake Forest, there are publicly supported housing units in the northwest, near the intersection of SR-241 and Alton Parkway.There are a smaller number of units in the south of the city, along El Toro Road.
• In Mission Viejo, the map shows two publicly supported housing developments in the southern part of the city. One of these developments, in the southeast, aligns with a low-medium concentration area. City staff report that there are additional publicly supported housing developments that are not reflected in the HUD-provided data.
• In Newport Beach, there are two publicly supported housing developments (one east and one west of Newport Center), both of which are in high White segregation areas.
• In Orange, all publicly supported housing units and households with vouchers are located to the west and south of Villa Park (which are low-medium segregation areas). There are no units or vouchers in use to the east of Villa Park, where it is a high White segregation area.The largest publicly supported housing development (biggest blue dot) is in the integrated area to the south of Villa Park, running south along Santiago Creek and east along the northside of Chapman Avenue towards El Modena.
• In Rancho Santa Margarita, there are no publicly supported housing units. There are some vouchers in use in the northeast part of the city that is a low-medium concentration area
• In San Clemente, there is a cluster of publicly supported housing units in the lowmedium concentration area north and east of Max Berg Plaza Park. • In Santa Ana, a significant number of publicly supported housing units are located downtown and southeast of downtown, both of which are high POC segregation areas. There is a higher concentration of vouchers, as well as some publicly Orange County 55 25-29 Regional AFH
supported housing units, west of the Santa Ana River, which is also a high POC segregation area.
• In Tustin, there is a large concentration of publicly supported housing units in the south. Segregation data for this area are unavailable; however, according to Map 3 (Predominant Population by Race/Ethnicity) the population is predominantly AAPI. • In Westminster, the location of publicly supported housing units and areas with highest concentration of vouchers aligns with the high POC segregation areas in the central part of the city. There are no publicly supported housing units, and fewer vouchers in use, in the western parts of the city that are high White segregation, racially integrated, and low-medium segregation areas.

Map 4 - Publicly Supported Housing – Region
Source: California HCD, AFFH Data Viewer
Orange County 56 25-29 Regional AFH
Map 4 - Publicly Supported Housing – Region (HCV Only)
Source: California HCD, AFFH Data Viewer
Orange County 57 25-29 Regional AFH
Map 4 - Publicly Supported Housing – North Orange County Source: California HCD, AFFH Data Viewer
Orange County 58 25-29 Regional AFH
Map 4 - Publicly Supported Housing – Central Orange County Source: California HCD, AFFH Data Viewer
Orange County 59 25-29 Regional AFH
Map 4 - Publicly Supported Housing – South Orange County Source: California HCD, AFFH Data Viewer
The following analysis describes the public or private policies or practices, demographic shifts, economic trends, or other factors that may have caused or contributed to the patterns described above (including siting decisions of private or publicly supported housing or the location of residents using Housing Choice Vouchers).

Broadly speaking, the patterns of residential segregation/concentration by race – both between and within jurisdictions in Orange County and across the United States – are due, in part, to:
• Historic practices of redlining and legal racial segregation, which created many of the residential patterns that still exist today.
• Local land use and zoning laws that have perpetuated patterns of racial segregation, some of which remain in place, while others which have been removed but continue to have lasting effects.
• Market factors, including the high cost of land and existing housing throughout Orange County, constrain the development of new affordable housing and limit access for families to existing housing.

Orange County 60 25-29 Regional AFH
• Discrimination in the private housing market, including source-of-income discrimination, driven in part by a lack of knowledge of state and federal fair housing laws and regulations, which in turn limits housing mobility. • There are numerous ethnic enclaves of Hispanic, Vietnamese, Chinese, and other groups throughout Orange County. These enclaves provide a sense of community and a social network that may help newcomers preserve their cultural identities.

However, these active choices should not obscure the significant impact of structural barriers to fair housing choice and discrimination.

Through the stakeholder consultations and community meetings, it was also reported that segregation/concentration patterns in the County are due to:
• In addition to landlord resistance to renting to HCV Program participants, the gap between HCV subsidy amounts and housing costs further inhibits HCV Program participants from accessing housing in higher cost (and higher opportunity) areas. • Lack of housing mobility for some minority groups based on a lack of credit history coupled with high demand for affordable housing across the County, which permits landlords and property management companies to prioritize applicants based on credit history.

Detailed lists of the public or private policies or practices, demographic shifts, economic trends, and other factors that have caused or contributed to segregation/concentration in each of the jurisdictions are included in Section IV.

C. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) The following analysis identifies R/ECAPs and/or groupings of R/ECAP tracts.

HUD defines racially or ethnically concentrated areas of poverty (R/ECAPs) as Census Tracts that meet both of the following criteria:
• a non-White population of 50 percent or more, and
• a poverty rate that exceeds 40% or a poverty rate that is three or more times the average Tract poverty rate for the metropolitan area, whichever threshold is lower.

The analysis in this report uses a measure of segregation and concentrated poverty created by the California Tax Credit Allocation Committee (TCAC) and California HCD. The TCAC/HCD Opportunity Map’s poverty concentration and racial segregation filter aligns with HUD's R/ECAP methodology but is designed to more effectively reflect the level of racial and ethnic diversity in many parts of California. This measure uses the following criteria to define Census Tracts as “High Segregation and Poverty” areas:
• Tracts and rural block groups where at least 30 percent of the population is living below the poverty level (note that college and graduate students are removed from Orange County 61 25-29 Regional AFH
the poverty calculation in the filter in Census Tracts where they comprise at least 25% of the population); and
• Tracts that have a Location Quotient (LQ) higher than 1.25 for Black, Hispanic, Asian, or all people of color. The LQ measures relative segregation by calculating how much more segregated a Census Tract is relative to a larger area (in this case, the County).

Compared to the measure used by HUD (which is an absolute threshold of nonWhite population in a Census Tract), this measure better captures inequality operating on individuals at the neighborhood level.

Map 5 – High Segregation and Poverty Areas, indicates racially or ethnically concentrated areas of poverty in Orange County (note that the only R/ECAP areas are located in the central part of the County). This map was created by California HCD to facilitate fair housing planning, using the TCAC/HCD Opportunity Map data. This map shows R/ECAPs in the following areas:
• Placentia – in the southwestern corner of the city, south of Orangethorpe Avenue • Anaheim – northeast of Disneyland, along Ball Road and I-5 • Garden Grove – in the northern part of the city to between Brookhurst Street and Gilbert Street, north of Chapman Avenue
• Santa Ana – covering multiple Census Tracts in the downtown • Costa Mesa – on the west side of downtown and the area southwest of downtown (between Newport Avenue (SR-55) and Placentia Avenue, south of 19th Street).

Orange County 62 25-29 Regional AFH
Map 5 – High Segregation and Poverty Areas – Central Orange County Source: California HCD, AFFH Data Viewer
The following analysis describes and identifies the predominant protected classes residing in R/ECAPs, and how these demographics compare with the overall demographics of the area.

To identify the predominant protected classes residing in R/ECAPs and compare them to the overall demographics of the surrounding areas, we look at the areas designated as “High Segregation and Poverty” on Map 5 (High Segregation and Poverty Areas) in relation to the demographic information on Map 3 (Predominant Population by Race/Ethnicity). The analysis finds that R/ECAPs in Orange County are predominantly Hispanic. Specifically, • In Placentia, the R/ECAP Tract is predominantly Hispanic, as are the neighborhoods to the west and south in Fullerton and Anaheim. The neighborhoods to the east are predominantly White.
• In Anaheim, the R/ECAP Tract is predominantly Hispanic, as are all the surrounding neighborhoods.
• In Costa Mesa, the R/ECAP area is predominantly Hispanic, as are the adjacent neighborhoods to the north and west. The Census Tracts to the east, across Newport Avenue, are all predominantly White.
• In Garden Grove, the R/ECAP Tract is predominantly Hispanic and is surrounded by Census Tracts that are predominantly AAPI.

Orange County 63 25-29 Regional AFH
• In Santa Ana, the R/ECAP Tracts are predominantly Hispanic, as are all the surrounding neighborhoods.

The following analysis describes how R/ECAPs align with the location of publicly supported housing.

Map 6 - Publicly Supported Housing and R/ECAPs, shows the location of public-supported housing in Orange County in comparison to the location of the R/ECAPs (outlined in red).

This map shows no overarching patterns between the location of publicly supported housing and R/ECAPs.
• In Placentia, the R/ECAP area is home to one public housing development of 50-100 units, and between 5-15% of renter-occupied units in the Tract utilize a voucher— which is similar to other Tracts in the city.
• In Anaheim, there are no publicly supported housing units in the R/ECAP Tract, and fewer than 5% of renter-occupied units in the R/ECAP Tract utilize a voucher. • In Costa Mesa, the largest publicly supported housing development in the city is located on the northern boundary of the R/ECAP area. There is no data on voucher usage in the Tract.
• In Garden Grove, 15-30% of renter-occupied units in the R/ECAP tract utilize a voucher, which is similar to a number of other non-R/ECAPTracts in the city. There are no publicly supported housing developments in the R/ECAP Tract. • In Santa Ana, fewer than 5% of renter-occupied housing units in the R/ECAP areas utilize a voucher; however, there are various publicly supported housing developments within the boundaries of the R/ECAP area.

Orange County 64 25-29 Regional AFH
Map 6 - Publicly Supported Housing and R/ECAPs
Source: Created by authors using map from California HCD, AFFH Data Viewer Orange County 65 25-29 Regional AFH
The following analysis describes the public or private policies or practices, demographic shifts, economic trends, or other factors that may have caused or contributed to the patterns described above.

In the most recent Housing Elements prepared and adopted by each jurisdiction, the following factors were identified that contribute to the existence of R/ECAPs in these jurisdictions.

In Placentia:
• Lack of affordable housing, which limits housing mobility. • Limited participation in the Housing Choice Voucher Program. • Land use and development practices that constrain affordable housing development.
• Private discrimination in housing, due in part to a lack of fair housing knowledge and enforcement.

In Anaheim:
• Historic practices of redlining and legal racial segregation have created many of the residential patterns that still exist today. Additionally, the high cost of land and existing housing in Anaheim (and throughout Orange County) are significant constraints to the development of new affordable housing and access for families to existing housing.

In Costa Mesa:
• Housing discrimination, which limits mobility for families. • Lack of affordable housing due to both governmental and market constraints.

In Garden Grove:
• Lack of affordable, accessible housing in a range of unit sizes, due to high land and development costs in the region, public opposition to new development, and land use and zoning laws.
• Housing discrimination, which limits mobility for families. • Limited access to financial services.
• Lack of meaningful language access for individuals with limited English proficiency. • Lack of private investment in specific neighborhoods.

In Santa Ana:
• Lack of fair housing education and outreach.
• Lack of affordable housing.

Orange County 66 25-29 Regional AFH
D. Disparities in Access to Opportunity
The following paragraphs analyze disparities in access to opportunity for education, employment, transportation, poverty, environmentally healthy neighborhoods, disability and access, and patterns in any disparities to access to opportunity.

1. Education
Table 6 – Opportunity Indicators by Race/Ethnicity (below), includes a School Proficiency Index, which measures the proximity various racial/ethnic groups have, based on where they live, to neighborhoods with high-performing schools. School proficiency is measured using school-level data on the performance of 4th grade students on state exams. The index is based on a range of 0 to 100, with higher scores indicating better proximity to highperforming schools.

Table 6 shows the following disparities in access to neighborhoods with high-performing schools in each of the participating jurisdictions:
• In the region, there are significant disparities in access to neighborhoods with high performing schools. Access is lowest for Black and Hispanic residents, and highest for White and AAPI residents. Access is especially low for Black residents living below the Federal Poverty Level (FPL).
• In the Orange County Urban County jurisdictions, Hispanic residents have the least access to neighborhoods with high-performing schools, and this disparity is even more pronounced for Hispanic residents living below the FPL. Compared to the region, access is better across all groups and there are smaller disparities between groups.
• In Aliso Viejo, access to neighborhoods with high-performing schools is high for all groups and there is little disparity between race/ethnic groups. • In Anaheim, access to neighborhoods with high-performing schools is relatively low for all groups in the city and there are significant racial/ethnic disparities. Hispanic residents have the least access, followed by Native American and Black residents.

Access also tends to be worse for residents living below the FPL, with Hispanic residents living below the FPL having the least access to neighborhoods with highperforming schools. • In Buena Park, Hispanic and Black residents have less access to neighborhoods with high-performing schools than other groups, and this disparity is even greater for Hispanic residents living below the FPL. Residents in the city have better access to neighborhoods with high-performing schools than their counterparts regionwide, and there are fewer disparities in access by race/ethnicity when compared to the region.
• In Costa Mesa, Hispanic residents have less access to neighborhoods with highperforming schools than other groups, and this disparity is even greater for Hispanic Orange County 67 25-29 Regional AFH
residents living below the FPL. Generally, residents in the city have better access to neighborhoods with high-performing schools than their counterparts regionwide, and there are fewer disparities in access by race/ethnicity when compared to the region.
• In Fountain Valley, access to neighborhoods with high-performing schools is high for all groups, with little disparity between race/ethnic groups, except for Native Americans living below the FPL, who have relatively poor access. • In Fullerton, access to neighborhoods with high performing schools is comparable to the region, with relatively low access and evidence of racial/ethnic disparities.

Hispanic residents have the least access, followed by Native American and Black residents.
• In Garden Grove, Hispanic residents have less access than other groups to neighborhoods with high-performing schools, though these disparities are less pronounced than in the region as a whole.
• In Huntington Beach, Hispanic and Black residents have less access than other groups to neighborhoods with high-performing schools, and these disparities are more pronounced for residents living below the FPL.
• In Irvine, access to neighborhoods with high-performing schools is high for all groups.
• In La Habra, access to neighborhoods with high-performing schools is relatively low for all groups and there is little disparity between race/ethnic groups. • In Laguna Niguel, access to neighborhoods with high-performing schools is high for all groups.
• In Lake Forest, access to neighborhoods with high-performing schools is moderately high for all groups, though residents living below the federal FPL have less access to these types of neighborhoods. Hispanic residents living below the federal FPL, in particular, have the least access compared to other groups. • In Mission Viejo, access to neighborhoods with high-performing schools is moderately high for all groups and there is little disparity between groups. • In Newport Beach, access to neighborhoods with high-performing schools is high for all groups.
• In Orange, there are some disparities in access to neighborhoods with highperforming schools, with Black and Hispanic residents having less access than other groups. These disparities are less pronounced than in the region overall—this is because, Hispanic, Black, and Native American residents of Orange have better access to these kinds of neighborhoods than their counterparts in the region overall, while White and AAPI residents of Orange have less access. • In Rancho Santa Margarita, access to neighborhoods with high-performing schools is high for all groups.

Orange County 68 25-29 Regional AFH
• In San Clemente, access to neighborhoods with high-performing schools is moderately high for all groups with few disparities between groups. • In Santa Ana, access to neighborhoods with high-performing schools is relatively low for all groups and there are significant disparities between race/ethnic groups.

Hispanic and Native American residents have the least access to neighborhoods with high-performing schools.
• In Tustin, Hispanic and Native American residents living below the FPL have significantly less access to neighborhoods with high-performing schools than other groups.
• In Westminster, access to neighborhoods with high-performing schools is moderately high for all groups and there is little disparity between groups.

Orange County 69 25-29 Regional AFH
Table 6 – Opportunity Indicators by Race/Ethnicity
Los Angeles-Long Beach-Anaheim, CA MSA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 65.19 68.03 67.43 77.63 73.13 54.59 21.35 Black, Non-Hispanic 36.07 33.82 35.34 87.25 79.02 40.72 11.92 Hispanic 35.53 39.72 35.73 86.48 77.78 43.70 12.36
Asian or Pacific Islander, Non-Hispanic 55.03 61.94 57.64 85.13 75.98 51.11 13.13 Native American, Non-Hispanic 48.40 50.70 48.58 81.04 75.36 45.88 17.68 Population below federal poverty line
White, Non-Hispanic 53.66 60.62 59.62 83.19 78.51 56.98 18.46 Black, Non-Hispanic 24.12 28.03 26.41 88.34 81.07 36.90 11.74 Hispanic 25.05 33.70 29.50 89.09 80.94 44.63 10.63
Asian or Pacific Islander, Non-Hispanic 45.45 57.59 51.41 88.58 80.61 52.88 11.05 Native American, Non-Hispanic 33.63 39.10 36.05 84.43 78.22 47.65 16.22 Orange County Urban County, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 76.48 81.89 74.59 60.92 67.05 46.96 24.39 Black, Non-Hispanic 69.50 75.53 68.16 74.64 71.50 44.07 15.23 Hispanic 58.20 67.52 59.65 75.35 73.08 45.50 15.65
Asian or Pacific Islander, Non-Hispanic 69.64 76.68 67.46 77.05 70.10 43.85 13.93 Native American, Non-Hispanic 68.87 73.43 68.92 69.65 69.78 46.01 19.49 Population below federal poverty line
White, Non-Hispanic 68.31 77.99 69.03 62.05 71.85 49.98 24.26 Black, Non-Hispanic 57.08 70.54 60.65 74.14 71.46 42.77 13.74 Hispanic 40.26 56.48 46.97 79.38 77.74 45.63 12.87
Asian or Pacific Islander, Non-Hispanic 59.82 72.84 58.95 82.14 75.35 40.98 10.57 Native American, Non-Hispanic 59.71 78.50 58.72 80.71 75.06 48.72 12.85 Aliso Viejo, CA CDBG
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 86.40 83.80 89.60 25.37 76.58 67.81 44.39 Black, Non-Hispanic 85.66 83.41 89.02 26.10 79.11 67.21 44.13 Hispanic 84.11 84.55 88.33 26.59 79.32 68.55 43.87
Asian or Pacific Islander, Non-Hispanic 87.35 84.31 89.76 24.91 75.76 67.91 44.68 Native American, Non-Hispanic 86.17 83.12 88.93 26.36 79.02 67.87 44.33 Population below federal poverty line
White, Non-Hispanic 82.37 81.49 87.38 28.15 80.65 67.31 43.92 Black, Non-Hispanic 96.00 90.96 92.00 20.00 71.00 68.85 44.00 Hispanic 87.11 86.95 88.83 25.18 80.76 67.92 44.61
Asian or Pacific Islander, Non-Hispanic 79.67 82.36 87.60 28.86 79.35 68.30 43.19 Native American, Non-Hispanic 89.00 73.76 91.00 20.00 71.00 64.40 46.00 Anaheim, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 57.74 51.16 55.99 86.30 72.67 43.78 11.42 Black, Non-Hispanic 42.85 39.66 45.37 89.16 78.00 36.96 8.52 Hispanic 36.00 27.30 39.83 90.59 79.51 50.51 7.89
Asian or Pacific Islander, Non-Hispanic 49.75 44.50 50.68 87.98 75.45 37.02 9.49 Native American, Non-Hispanic 44.95 36.79 46.32 89.37 77.46 48.18 8.95 Population below federal poverty line
White, Non-Hispanic 45.90 40.49 46.79 89.04 77.96 42.96 9.09 Black, Non-Hispanic 31.74 34.14 37.42 89.65 79.84 31.61 7.85 Hispanic 29.41 22.31 35.78 91.71 81.27 52.65 7.32
Asian or Pacific Islander, Non-Hispanic 45.63 44.33 47.94 88.35 76.64 30.85 9.12 Native American, Non-Hispanic 28.04 34.19 30.87 92.22 79.80 57.77 8.38 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; and NATA; all accessed through the HUD AFFH Tool, Table 12, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Orange County 70 25-29 Regional AFH
Table 6 – Opportunity Indicators by Race/Ethnicity (continued) Buena Park, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 60.45 68.12 55.62 88.37 74.04 32.63 5.85 Black, Non-Hispanic 46.36 56.49 50.18 88.38 76.06 36.64 5.75 Hispanic 45.66 56.38 48.40 87.86 75.87 38.65 5.61
Asian or Pacific Islander, Non-Hispanic 55.66 65.85 56.16 88.51 74.65 34.48 5.98 Native American, Non-Hispanic 54.49 66.44 52.73 88.12 74.89 31.49 5.74 Population below federal poverty line
White, Non-Hispanic 53.80 63.19 53.10 88.01 75.46 34.13 5.82 Black, Non-Hispanic 34.70 61.54 49.56 89.06 79.09 51.37 6.30 Hispanic 36.05 49.35 44.29 87.95 77.28 40.67 5.51
Asian or Pacific Islander, Non-Hispanic 52.60 62.69 52.02 88.88 76.16 33.32 5.99 Native American, Non-Hispanic 66.17 70.34 82.13 88.84 71.20 32.56 6.92 Costa Mesa, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 60.10 72.71 73.56 89.69 81.33 83.04 28.03 Black, Non-Hispanic 55.04 70.24 69.80 90.47 83.27 83.47 25.72 Hispanic 40.06 60.53 56.72 90.42 83.05 78.57 30.24
Asian or Pacific Islander, Non-Hispanic 61.51 71.28 73.20 90.57 82.88 87.44 22.65 Native American, Non-Hispanic 53.54 70.81 68.03 90.49 82.74 81.69 28.26 Population below federal poverty line
White, Non-Hispanic 53.85 69.80 68.91 90.07 82.43 80.51 28.58 Black, Non-Hispanic 61.70 78.78 82.00 91.46 84.89 87.37 19.50 Hispanic 33.36 56.69 51.57 90.56 83.60 78.70 31.40
Asian or Pacific Islander, Non-Hispanic 55.36 71.81 73.29 90.38 83.08 84.52 24.46 Native American, Non-Hispanic 50.53 67.96 56.06 91.85 77.66 85.70 19.03 Fountain Valley, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 72.99 77.95 66.97 88.74 72.84 63.54 10.36 Black, Non-Hispanic 63.35 74.50 64.34 89.00 77.04 67.34 9.23 Hispanic 61.51 73.48 61.11 89.32 76.51 64.27 9.44
Asian or Pacific Islander, Non-Hispanic 68.19 74.62 62.14 88.86 73.78 61.25 9.43 Native American, Non-Hispanic 71.09 77.77 66.67 88.24 73.04 61.75 9.83 Population below federal poverty line
White, Non-Hispanic 73.72 79.47 71.04 88.66 70.86 60.63 12.98 Black, Non-Hispanic 59.12 85.62 60.95 89.98 80.00 64.77 7.03 Hispanic 62.05 75.52 64.05 88.78 73.78 52.61 10.82
Asian or Pacific Islander, Non-Hispanic 64.02 71.44 61.18 88.82 76.72 64.70 8.84 Native American, Non-Hispanic 25.00 58.70 39.00 91.00 79.00 33.65 9.00 Fullerton, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 62.61 56.65 61.50 87.07 76.65 55.54 8.66 Black, Non-Hispanic 49.62 47.75 52.52 88.60 79.69 50.90 7.95 Hispanic 42.72 39.02 45.92 88.92 79.56 48.09 7.72
Asian or Pacific Islander, Non-Hispanic 59.92 66.82 67.55 86.58 74.57 45.70 8.74 Native American, Non-Hispanic 52.94 46.15 50.35 88.41 78.82 50.79 7.98 Population below federal poverty line
White, Non-Hispanic 55.56 50.27 55.74 89.34 80.78 56.42 8.27 Black, Non-Hispanic 36.98 38.56 45.43 90.92 83.87 43.50 7.52 Hispanic 37.93 36.39 41.66 89.84 80.77 46.43 7.60
Asian or Pacific Islander, Non-Hispanic 59.46 64.03 66.38 88.24 78.20 51.50 8.57 Native American, Non-Hispanic 66.11 42.19 54.89 87.14 77.59 36.66 7.59 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; and NATA; all accessed through the HUD AFFH Tool, Table 12, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Orange County 71 25-29 Regional AFH
Table 6 – Opportunity Indicators by Race/Ethnicity (continued) Garden Grove, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 51.61 62.62 46.45 89.02 75.00 36.85 5.30 Black, Non-Hispanic 41.29 55.63 41.33 89.90 78.05 34.48 5.93 Hispanic 38.31 49.57 38.53 90.25 78.44 36.49 6.55
Asian or Pacific Islander, Non-Hispanic 36.53 57.58 38.40 89.26 78.09 26.41 6.31 Native American, Non-Hispanic 42.49 57.15 40.82 89.84 77.88 33.27 6.01 Population below federal poverty line
White, Non-Hispanic 43.98 59.78 40.82 89.70 77.12 33.92 5.82 Black, Non-Hispanic 31.36 52.83 42.46 88.39 77.73 22.40 6.08 Hispanic 33.96 47.89 37.29 90.91 80.88 38.03 6.46
Asian or Pacific Islander, Non-Hispanic 34.39 57.31 37.26 89.10 78.63 24.49 6.43 Native American, Non-Hispanic 25.46 59.54 38.35 90.71 82.88 20.33 5.55 Huntington Beach, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 73.22 76.09 73.40 86.19 75.11 39.88 27.16 Black, Non-Hispanic 66.28 64.48 68.38 86.93 77.62 44.20 22.24 Hispanic 56.39 62.72 61.50 86.96 78.62 46.28 19.14
Asian or Pacific Islander, Non-Hispanic 70.78 72.77 69.79 85.78 74.36 43.09 23.36 Native American, Non-Hispanic 69.29 73.74 70.28 86.49 76.42 41.44 25.86 Population below federal poverty line
White, Non-Hispanic 70.07 73.38 72.99 86.92 77.44 38.84 27.86 Black, Non-Hispanic 46.90 56.51 58.56 88.62 80.11 43.69 17.85 Hispanic 42.73 56.09 51.58 87.45 81.23 47.75 14.39
Asian or Pacific Islander, Non-Hispanic 61.40 65.76 67.00 86.92 78.76 42.40 23.92 Native American, Non-Hispanic 72.02 78.94 63.69 86.00 64.39 36.61 26.65 Irvine, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 75.51 91.83 85.86 86.03 75.70 82.98 24.62 Black, Non-Hispanic 71.46 90.47 85.50 87.62 77.90 85.02 24.34 Hispanic 71.82 91.30 84.30 87.17 77.18 84.06 24.32
Asian or Pacific Islander, Non-Hispanic 74.27 91.74 86.27 86.36 76.01 81.99 24.03 Native American, Non-Hispanic 73.19 91.00 86.39 86.51 77.19 85.15 24.45 Population below federal poverty line
White, Non-Hispanic 74.06 91.44 81.96 88.76 79.32 87.44 26.01 Black, Non-Hispanic 70.68 91.56 89.17 86.53 76.94 79.65 24.23 Hispanic 72.33 89.99 77.69 89.76 80.78 89.91 26.12
Asian or Pacific Islander, Non-Hispanic 75.04 93.12 76.85 88.34 80.05 88.66 27.79 Native American, Non-Hispanic 75.05 92.63 64.82 92.82 83.98 89.60 26.21 La Habra, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 54.95 45.37 49.14 85.13 74.94 24.60 9.57 Black, Non-Hispanic 51.87 41.91 49.43 85.67 76.39 21.77 9.50 Hispanic 49.15 38.57 41.33 85.10 76.65 25.54 9.56
Asian or Pacific Islander, Non-Hispanic 63.20 44.08 62.32 84.33 71.22 22.13 9.44 Native American, Non-Hispanic 51.76 43.96 45.26 84.53 75.07 26.27 9.56 Population below federal poverty line
White, Non-Hispanic 56.10 47.10 49.00 84.46 74.26 24.56 9.48 Black, Non-Hispanic 52.83 41.39 42.26 87.37 77.76 28.47 9.43 Hispanic 46.12 36.01 37.54 85.25 76.92 28.33 9.70
Asian or Pacific Islander, Non-Hispanic 52.15 40.10 53.86 86.17 73.95 25.19 9.48 Native American, Non-Hispanic 53.40 39.69 33.09 88.64 77.34 23.54 9.00 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; and NATA; all accessed through the HUD AFFH Tool, Table 12, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Orange County 72 25-29 Regional AFH
Table 6 – Opportunity Indicators by Race/Ethnicity (continued) Laguna Niguel, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 76.15 78.68 81.92 20.01 65.30 24.83 44.29 Black, Non-Hispanic 75.53 78.56 81.05 20.78 66.76 27.40 43.54 Hispanic 74.16 77.79 80.90 21.60 68.64 26.05 42.93
Asian or Pacific Islander, Non-Hispanic 76.21 79.74 81.58 21.17 67.10 30.29 43.17 Native American, Non-Hispanic 73.38 78.54 81.49 20.46 66.97 23.45 45.40 Population below federal poverty line
White, Non-Hispanic 76.39 77.56 79.65 20.30 66.57 26.91 43.73 Black, Non-Hispanic 71.95 74.35 89.13 22.25 72.54 11.92 43.47 Hispanic 75.89 78.28 79.36 21.25 67.62 30.40 44.20
Asian or Pacific Islander, Non-Hispanic 75.56 80.73 75.10 23.52 71.49 42.28 41.54 Native American, Non-Hispanic N/a N/a N/a N/a N/a N/a N/a Lake Forest, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 76.36 72.36 81.64 32.24 69.42 71.33 42.33 Black, Non-Hispanic 73.27 69.65 81.67 32.34 70.96 72.67 42.25 Hispanic 67.04 66.07 76.36 31.35 73.18 70.57 39.94
Asian or Pacific Islander, Non-Hispanic 73.63 72.58 82.39 32.16 69.56 73.34 42.56 Native American, Non-Hispanic 75.43 68.97 79.14 32.03 71.55 69.17 41.59 Population below federal poverty line
White, Non-Hispanic 70.42 68.73 79.06 32.70 72.03 71.31 41.04 Black, Non-Hispanic 80.40 60.52 86.90 25.18 69.16 38.16 45.46 Hispanic 63.26 57.73 67.26 26.85 71.64 76.10 35.45
Asian or Pacific Islander, Non-Hispanic 61.70 65.12 73.73 35.90 75.46 69.11 39.66 Native American, Non-Hispanic 27.00 62.47 60.00 31.00 85.00 71.40 34.00 Mission Viejo, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 81.64 76.96 76.49 20.23 60.25 21.34 46.11 Black, Non-Hispanic 79.61 72.77 76.94 20.85 64.05 27.65 45.55 Hispanic 77.56 73.46 73.81 20.70 64.44 27.95 44.61
Asian or Pacific Islander, Non-Hispanic 80.69 77.17 77.29 20.55 60.53 22.69 45.63 Native American, Non-Hispanic 79.23 74.24 74.50 21.07 62.03 22.20 46.25 Population below federal poverty line
White, Non-Hispanic 80.70 78.05 76.43 20.42 61.66 22.41 46.10 Black, Non-Hispanic 70.69 76.42 81.54 21.23 69.77 27.61 43.31 Hispanic 73.93 74.29 66.28 20.00 66.08 35.01 41.77
Asian or Pacific Islander, Non-Hispanic 74.62 76.39 81.02 20.31 65.65 30.45 42.20 Native American, Non-Hispanic N/a N/a N/a N/a N/a N/a N/a Newport Beach, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 81.31 90.17 82.88 86.59 75.16 90.40 41.36 Black, Non-Hispanic 78.86 89.72 81.85 86.92 76.61 90.54 40.65 Hispanic 79.04 88.93 81.76 86.93 76.81 89.82 40.55
Asian or Pacific Islander, Non-Hispanic 84.48 91.60 85.94 83.05 68.64 89.19 38.80 Native American, Non-Hispanic 79.22 88.29 81.86 88.35 78.06 91.17 40.73 Population below federal poverty line
White, Non-Hispanic 78.99 89.20 83.30 87.76 78.81 90.38 43.27 Black, Non-Hispanic 78.71 86.38 78.21 89.58 85.43 87.99 48.46 Hispanic 82.46 87.75 81.41 88.28 77.88 89.87 41.76
Asian or Pacific Islander, Non-Hispanic 84.34 88.97 82.79 88.43 76.05 92.09 39.15 Native American, Non-Hispanic 77.00 89.17 88.00 93.00 85.00 95.55 40.00 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; and NATA; all accessed through the HUD AFFH Tool, Table 12, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Orange County 73 25-29 Regional AFH
Table 6 – Opportunity Indicators by Race/Ethnicity (continued) Orange, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 59.85 60.76 61.19 87.39 72.03 69.31 10.04 Black, Non-Hispanic 52.12 48.57 51.47 89.40 77.99 78.41 8.77 Hispanic 48.30 50.65 52.77 88.89 76.83 76.42 9.01
Asian or Pacific Islander, Non-Hispanic 59.06 58.78 59.94 87.51 72.50 67.82 9.94 Native American, Non-Hispanic 54.37 55.48 56.10 88.33 74.75 73.95 9.39 Population below federal poverty line
White, Non-Hispanic 57.04 52.92 58.45 89.18 76.75 78.49 9.16 Black, Non-Hispanic 32.85 42.16 41.19 83.58 78.05 89.55 9.52 Hispanic 45.47 53.35 53.02 89.09 76.93 73.57 9.08
Asian or Pacific Islander, Non-Hispanic 52.82 43.86 48.07 89.57 79.90 81.30 8.42 Native American, Non-Hispanic 64.21 51.31 53.78 90.52 79.37 86.78 8.55 Rancho Santa Margarita, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 87.82 84.08 87.29 19.01 61.49 12.75 54.08 Black, Non-Hispanic 85.22 82.80 86.30 20.39 66.64 13.57 53.73 Hispanic 84.08 80.19 85.16 21.29 69.41 11.83 54.01
Asian or Pacific Islander, Non-Hispanic 86.50 84.59 87.52 19.55 63.25 12.85 53.44 Native American, Non-Hispanic 86.05 82.04 86.50 20.09 66.32 11.54 53.88 Population below federal poverty line
White, Non-Hispanic 83.99 77.97 85.14 20.86 67.77 9.82 54.55 Black, Non-Hispanic N/a N/a N/a N/a N/a N/a N/a
Hispanic 79.71 72.25 79.75 22.39 74.90 7.51 54.71
Asian or Pacific Islander, Non-Hispanic 92.08 91.03 89.00 16.53 50.91 17.71 53.51 Native American, Non-Hispanic N/a N/a N/a N/a N/a N/a N/a San Clemente, CA CDBG
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 76.02 73.91 77.79 15.18 58.61 30.53 54.50 Black, Non-Hispanic 75.72 74.47 77.50 15.14 58.28 33.23 53.99 Hispanic 64.41 66.23 74.88 16.13 64.05 28.18 54.33
Asian or Pacific Islander, Non-Hispanic 77.00 75.99 77.85 14.57 56.60 36.23 53.93 Native American, Non-Hispanic 70.21 72.47 77.11 16.20 60.72 31.36 54.49 Population below federal poverty line
White, Non-Hispanic 72.53 69.89 77.05 15.87 60.90 29.70 54.94 Black, Non-Hispanic 33.81 63.97 69.04 14.71 67.68 30.34 53.00 Hispanic 64.44 65.67 75.42 15.59 64.76 30.60 54.22
Asian or Pacific Islander, Non-Hispanic 75.99 79.46 77.89 13.66 59.13 42.42 53.36 Native American, Non-Hispanic 69.92 82.92 81.47 13.38 53.61 35.91 53.08 Santa Ana, CA
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 43.58 40.95 48.31 92.62 80.95 74.89 10.29 Black, Non-Hispanic 37.22 34.86 40.19 92.78 81.04 67.18 10.60 Hispanic 27.34 28.45 33.05 92.92 80.41 62.17 11.06
Asian or Pacific Islander, Non-Hispanic 37.32 41.90 37.03 92.43 79.82 52.24 10.44 Native American, Non-Hispanic 30.92 33.84 37.35 92.65 79.81 61.51 10.65 Population below federal poverty line
White, Non-Hispanic 36.59 35.69 45.31 92.55 81.75 72.63 10.59 Black, Non-Hispanic 30.40 34.66 39.64 91.94 82.25 76.57 10.44 Hispanic 22.21 27.00 30.56 93.36 82.18 60.87 10.98
Asian or Pacific Islander, Non-Hispanic 36.22 40.88 35.66 92.11 80.53 46.13 10.05 Native American, Non-Hispanic 22.28 21.56 35.82 93.35 79.06 60.67 11.72 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; and NATA; all accessed through the HUD AFFH Tool, Table 12, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Orange County 74 25-29 Regional AFH
Table 6 – Opportunity Indicators by Race/Ethnicity (continued) By comparing the School Proficiency Index in Table 6 to the demographic data in Table 1 (Demographics), a pattern emerges showing that cities where all residents have access to neighborhoods with high-performing schools, have a lower percentage of Hispanic residents than the County overall. In other words, Hispanic residents are concentrated in cities with fewer high-performing schools. Specifically, in the following cities, the School Proficiency Index is 70 or higher for every racial/ethnic group, and the percentage of the population that is Hispanic is lower than the countywide percentage of 33.93%:
• Aliso Viejo, where the School Proficiency Index is over 83 for all groups, and 20.02% of the population is Hispanic.
• Fountain Valley, where the School Proficiency Index is over 73 for all groups, and

17.08% of the population is Hispanic.
• Irvine, where the School Proficiency Index is over 90 for all groups, and 11.24% of the population is Hispanic.
• Laguna Niguel, where the School Proficiency Index is over 77 for all groups, and

16.10% of the population is Hispanic.
• Mission Viejo, where the School Proficiency Index is over 72 for all groups, and

19.67% of the population is Hispanic.

Tustin, CA CDBG
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 63.67 71.61 73.97 89.66 78.12 75.92 12.00 Black, Non-Hispanic 49.37 60.11 64.18 92.75 83.81 83.31 10.82 Hispanic 44.93 51.70 59.55 93.52 85.08 86.73 9.74
Asian or Pacific Islander, Non-Hispanic 54.59 67.08 73.12 90.92 80.48 78.28 12.30 Native American, Non-Hispanic 58.55 62.31 69.02 91.12 81.54 81.61 10.47 Population below federal poverty line
White, Non-Hispanic 50.82 67.17 68.54 92.03 82.78 82.13 11.15 Black, Non-Hispanic 53.03 52.08 60.97 93.61 85.87 88.59 9.55 Hispanic 33.68 38.03 51.91 95.23 88.33 88.99 8.87
Asian or Pacific Islander, Non-Hispanic 51.22 62.44 67.76 91.95 82.30 84.23 11.07 Native American, Non-Hispanic 21.99 34.26 62.35 95.29 87.57 92.46 8.78 Westminster, CA CDBG
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-Hispanic 49.67 72.09 47.64 86.39 76.49 42.87 6.57 Black, Non-Hispanic 40.88 69.65 44.06 86.96 78.34 40.93 6.86 Hispanic 35.08 63.82 39.25 87.10 78.73 37.10 6.50
Asian or Pacific Islander, Non-Hispanic 35.42 65.32 39.47 87.81 79.49 29.74 7.51 Native American, Non-Hispanic 43.72 69.82 44.55 87.26 77.82 41.17 6.24 Population below federal poverty line
White, Non-Hispanic 42.88 69.22 42.57 86.90 77.90 37.35 6.79 Black, Non-Hispanic 32.08 67.37 41.25 85.75 77.20 41.57 7.92 Hispanic 32.07 60.97 36.24 86.89 78.84 40.17 5.44
Asian or Pacific Islander, Non-Hispanic 31.20 62.98 38.17 87.91 80.04 31.20 7.13 Native American, Non-Hispanic 37.94 63.01 34.15 89.90 81.79 23.92 8.00 Note 1: Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; and NATA; all accessed through the HUD AFFH Tool, Table 12, Version AFFHT0006, Released July 10, 2020.

Note 2: Refer to the Data Documentation for details (www.hudexchange.info/resource/4848/affh-data-documentation).

Orange County 75 25-29 Regional AFH
• Newport Beach, where the School Proficiency Index is over 88 for all groups, and

10.47% of the population is Hispanic.
• Rancho Santa Margarita, where the School Proficiency Index is over 80 for all groups, and 20.41% of the population is Hispanic.

Map 7 – Education Score, is a series of maps showing the TCAC/HCD Opportunity Map’s Education Composite Score for north, central, and south Orange County, and the region.

These maps were created by California HCD to facilitate fair housing planning, using the TCAC/HCD Opportunity Map data8F
9 . The Education Composite Score for a particular Census Tract is based on four indicators, all of which are based on enrollment-weighted averages of the three schools closest to the tract’s center point 9F 10:
• Math and Reading Proficiency, where “Proficiency” is the percentage of students performing at grade-level in the 4th grade.
• High School Graduation Rate, which is calculated using California Department of Education data on the percent of students who graduate in four years. • Student Poverty, which is measured as the percentage of students that do not receive free and reduced-price lunch.

A tract’s composite score is determined by whether it falls above or below the median (50th percentile) tract or block group value within each region. Each indicator that falls above the regional median adds one point to the final score. On the maps, the categories equal the following scores:
• Highest: >3-4
• High: >2-3
• Moderate: >1-2
• Low: 0-1
These maps, along with Map 3 showing the predominant race/ethnicity in each area, show the following relationship between residency patterns and proximity to proficient schools by race/ethnicity:
• In the County overall,
o Cities in the central County have the lowest education scores, indicating that residents in these areas are less likely to live near high quality schools. Areas in the southern County, along the coast, and in the unincorporated areas in the north and east parts of the County, have the highest education scores. 9 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 10 Detailed descriptions of the methodology used to measure each indicator can be found on the CTAC website, https://www.treasurer.ca.gov/ctcac/opportunity.asp
Orange County 76 25-29 Regional AFH
Low education score areas generally correspond to areas where the population is predominantly Hispanic.
• In the Orange County Urban County jurisdictions,
o Brea and Los Alamitos have high education scores and are predominantly White in most but not all areas.
o Cypress has high education scores and a predominantly AAPI and White population.
o La Palma has high education scores and a predominantly AAPI population o Yorba Linda, Villa Park, Orange Park Acres, North Tustin, unincorporated areas of the County, Laguna Woods, Laguna Beach, and Laguna Hills, all have the highest education scores and are predominantly White.
o Dana Point has a mix of education scores, all areas are predominantly White. o Placentia has low education scores in the southeast, which align with the predominantly Hispanic neighborhoods.
o San Juan Capistrano has low education score areas that are a mix of predominantly Hispanic and predominantly White neighborhoods. • In Aliso Viejo, all neighborhoods in the city have the highest education score and are predominantly White.
• In Anaheim, most of the city’s neighborhoods have low education scores and are predominantly Hispanic. The exception is Anaheim Hills, which is both predominantly White, and has the highest education scores. • In Buena Park, there are neighborhoods with low education scores in the city’s center and southeast, which are also areas of predominant Hispanic population. • In Costa Mesa, the southwest quarter of the city has low education scores. This area is a mix of predominantly Hispanic neighborhoods in and around downtown, and predominantly White neighborhoods to the west.
• In Fountain Valley, almost all of the city’s neighborhoods have high education scores.

These neighborhoods are a mix of predominantly White and AAPI. • In Fullerton, neighborhoods in the south of the city have low education scores and are also the areas with the highest concentrations of Hispanic residents. • In Garden Grove, the neighborhoods with low education score areas in the east are predominantly Hispanic, and the neighborhoods with low education scores in the northwest are predominantly Hispanic and AAPI.
• In Huntington Beach, the neighborhoods with the highest education scores correlate to areas that are predominantly White, which is most of the city. One area of the city with low education scores has a predominantly Hispanic population. • In Irvine, neighborhoods across the city have the highest education score. These neighborhoods are a mix of predominantly White and AAPI.

Orange County 77 25-29 Regional AFH
• In La Habra, neighborhoods with low education scores are located in the center and eastern part of the city, which are also the areas with the highest concentrations of Hispanic residents.
• In Laguna Niguel, all neighborhoods have high education scores and are predominantly White.
• In Lake Forest, all neighborhoods have high education scores and most are predominantly White, except in the southeastern corner of the city, along El Toro Road, which is predominantly Hispanic.
• In Mission Viejo, all neighborhoods have high education scores, and most are predominantly White except in the southern part of the city. • In Newport Beach, all neighborhoods have high education scores and are predominantly White.
• In Orange, neighborhoods in the western half of the city have low education scores and are predominantly Hispanic. The neighborhoods with the highest education scores are in the eastern half of the city. The high education score areas north and west of Villa Park are predominantly White, and the high education score areas south and west of Villa Park are predominantly Hispanic.
• In Rancho Santa Margarita, all neighborhoods have high education scores and are predominantly White.
• In San Clemente, all neighborhoods have high education scores and are predominantly White.
• In Santa Ana, neighborhoods with low education score areas comprise most of the city, and are areas where population is predominantly Hispanic. • In Tustin, the neighborhoods with low education scores are predominantly Hispanic and White, and the neighborhoods with the highest education scores are predominantly AAPI.
• In Westminster, there is a mix of moderate, high, and highest education score areas.

There is one part of the city with low education scores, in the north. This area is predominantly Hispanic.

Orange County 78 25-29 Regional AFH
Map 7 – Education Score – Region
Source: California HCD, AFFH Data Viewer
Map 7 – Education Score – North Orange County
Source: California HCD, AFFH Data Viewer
Orange County 79 25-29 Regional AFH
Map 7 – Education Score – Central Orange County
Source: California HCD, AFFH Data Viewer
Map 7 – Education Score – South Orange County
Source: California HCD, AFFH Data Viewer
Orange County 80 25-29 Regional AFH

2. Employment
Table 6 includes a Jobs Proximity Index, which measures the physical distance between where residents of different races/ethnicities live and the location of jobs. A higher index value indicates better access to employment opportunities. Table 6 also includes a Labor Market Index, which measures the unemployment rate, labor-force participation rate, and percentage of the population aged 25 and above with at least a bachelor’s degree, by neighborhood. A higher index value indicates that residents live in a neighborhood with higher labor force participation and human capital.

Table 6 shows the following regarding disparities in access to neighborhoods close to jobs and with high labor force participation and human capital in each of the participating jurisdictions:
• In the region, there are significant disparities in both the Jobs Proximity and the Labor Market Index. The Jobs Proximity Index is the lowest for Black residents, especially those living below FPL. It is also low for Hispanic residents. White residents are most likely to live in neighborhoods close to jobs.The Labor Market Index is lowest for Black and Hispanic residents, especially those living below FPL, and highest for White residents. Generally, the Labor Market Index is lower for individuals living below FPL.
• In the Orange County Urban County jurisdictions, there is relatively low access to neighborhoods close to jobs for all races/ethnicities, with no large disparities between groups. Compared to the region, residents of all races/ethnicities have better access to neighborhoods with high labor force participation and human capital. However, there are disparities between racial/ethnic groups, with Hispanic residents having significantly less access than other groups, and White residents having more access.
• In Aliso Viejo, access to neighborhoods with high labor force participation and human capital is high for all races/ethnicities, with no large disparities between groups. This is also true for access to neighborhoods close to jobs. On both indices, the city performs significantly better than the region overall. • In Anaheim, there are significant disparities in access to neighborhoods close to jobs, and with high labor force participation and human capital. Hispanic residents have the least access to neighborhoods with high labor force participation and human capital. Black and AAPI residents have the least access to neighborhoods close to jobs. On both indices, the city is comparable to the region overall, with lowto-moderate scores and significant disparities between groups. • In Buena Park, there is relatively low access to neighborhoods close to jobs for all races/ethnicities, with no large disparities between groups. Compared to the region, residents of all races/ethnicities have less access to neighborhoods close to jobs.

There is moderate access to neighborhoods with high labor force participation and Orange County 81 25-29 Regional AFH
human capital, with slight disparities between races/ethnicities—Hispanic residents have the least access to these neighborhoods. Compared to the region, access is higher for Hispanic and Black residents in the city.
• In Costa Mesa, access to neighborhoods close to jobs is high for all races/ethnicities, with only slight disparities—Hispanic residents have the least access. Access to neighborhoods with high labor force participation and human capital is also high for all races/ethnicities, but with significant disparities between races/ethnicities—again Hispanic residents have the least access. On both indices, the city performs better than the region overall for all racial/ethnic groups.
• In Fountain Valley, access to neighborhoods close to jobs, and with high labor force participation and human capital, is relatively high for all groups except for Native American residents living below the FPL, who have very low index values for each measure.
• In Fullerton, all race/ethnicities have moderate access to neighborhoods close to jobs, with slight disparities between groups—AAPI residents have the least access of any group. Regarding access to neighborhoods with high labor force participation and human capital, there are some disparities between groups (with Hispanic residents having the least access), and index values for Hispanic, Black, and AAPI residents are higher than their counterparts regionwide. • In Garden Grove, access to neighborhoods close to jobs is low for all groups, with some disparities between groups—AAPI residents have the least access. Compared to the region, all groups in Garden Grove have less access. Access to neighborhoods with high labor force participation and human capital is also relatively low for all groups in the city, with slight disparities between races/ethnicities. Access is lowest for Hispanic and AAPI residents. Compared to the region, the Labor Market Index in the city is higher for Black and Hispanic residents, and lower for all others. • In Huntington Beach, access to neighborhoods close to jobs is relatively low for all groups, with few disparities between races/ethnicities. Overall, groups in the city have better access to neighborhoods with high labor force participation and human capital; however, there are large disparities between groups. Hispanic residents, and especially those living below the FPL, have the least access to these neighborhoods. • In Irvine, access to neighborhoods close to jobs and with high labor force participation and human capital is high for all groups (and higher than the region).

The only significant disparities are for Black residents living below FPL, who have less access to neighborhoods close to jobs, and Native American residents living below FPL, who have less access to neighborhoods with high labor force participation and human capital.
• In La Habra, access to neighborhoods close to jobs is very low for all groups, with no disparities between groups. There are disparities, however, in access to neighborhoods with high labor force participation and human capital. Hispanic Orange County 82 25-29 Regional AFH
residents and Native American residents living below FPL have the least access of all groups. Compared to region, Hispanic, Black and AAPI residents in the city have more access, while White residents have less access.
• In Laguna Niguel, access to neighborhoods close to jobs is lower than the region for all groups, with little disparity between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups, with little disparity between groups.
• In Lake Forest, access to neighborhoods close to jobs is relatively high, and higher than region, for all groups. There is very little disparity between groups, except for Black residents below FPL, who have very low access to neighborhoods close to jobs. Access to neighborhoods with high labor force participation and human capital is higher than in the region for all groups, with little disparity except for Hispanic, AAPI, and Native American residents living below FPL, all of whom have significantly less access.
• In Mission Viejo, access to neighborhoods close to jobs is low for all groups, with no disparities between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups, with little disparity except for Hispanics living below FPL, for whom access is relatively low compared to other city residents but is still higher than in the region.
• In Newport Beach, access to neighborhoods close to jobs, and neighborhoods with high labor force participation and human capital, is high for all groups, with very little disparity between groups.
• In Orange, access to neighborhoods close to jobs is higher than the region, but there are some disparities—access is lowest for AAPI and White residents. There are also disparities in access to neighborhoods with high labor force participation and human capital. Black and Hispanic residents overall, and Black and AAPI residents living below FPL have the least access. However, access is higher for all groups (except White residents), in comparison to the region.
• In Rancho Santa Margarita, access to neighborhoods close to jobs is very low for all groups, with no disparities between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups, with some disparities—Hispanic residents living below FPL have the least access. • In San Clemente, access to neighborhoods close to jobs is low for all groups, with very little disparity between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups (and higher than in the region), with some disparity—namely, Hispanic residents living below FPL have less access. • In Santa Ana, access to neighborhoods close to jobs is higher for all groups than in region, with some disparities—access is lowest for AAPI residents, especially those living below FPL. Access to neighborhoods with high labor force participation and human capital is lower than in the region for all groups except Black residents, and Orange County 83 25-29 Regional AFH
there are significant disparities in access—Hispanic residents have the least access, and access is also lower for individuals living below FPL in each racial/ethnic group. • In Tustin, access to neighborhoods close to jobs is higher for all groups than in region, with some disparities between races/ethnicities—White residents have the least access. Access to neighborhoods with high labor force participation and human capital is higher than in the region, with some disparities—Hispanic residents have the least access, and access is also lower for individuals living below FPL in each racial/ethnic group.
• In Westminster, there are disparities in access to neighborhoods close to jobs by race/ethnicity. Native American residents living below FPL, and AAPI residents, have the least access. There are some disparities in access to neighborhoods with high labor force participation and human capital by race/ethnicity—Native American residents living below FPL and Hispanic and AAPI residents overall, have less access.

Compared to the region, access in the city is slightly better for Black and Hispanic residents, worse for all other groups.

The following analysis describes how a person’s place of residence affects their ability to obtain a job.

Map 8 – Economic Score, is a series of maps showing the TCAC/HCD Opportunity Map’s Economic Composite Score for north, central, and south Orange County, and the region.

These maps were created by California HCD to facilitate fair housing planning, using the TCAC/HCD Opportunity Map data10F
11 . The Economic Composite Score for a particular Census Tract is based on four indicators11F
12:
• Poverty Rate – Measured as the percentage of the Tract residents who live above 200 percent of the FPL (the 200 percent threshold is used to account for the higher cost of living in California compared to other regions of the United States). • Adult Education Rate – Measured as the percentage of adults aged 25 years and older in each Tract, who have earned at least a bachelor’s degree. • Employment Rate- Measured as the percentage of individuals in each Tract ages 20 to 64 who are employed in either the civilian labor force or the armed forces. • Home Value – Measured as the median home value (dollars) of owner-occupied housing units in each tract.
11 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 12 Detailed descriptions of the methodology used to measure each indicator can be found on the CTAC website, https://www.treasurer.ca.gov/ctcac/opportunity.asp
Orange County 84 25-29 Regional AFH
The composite score for each Tract is determined by whether it falls above or below the median (50th percentile) tract or block group value within each region. On the map, a higher numerical score indicates more positive economic outcomes.

These maps show the following relationship between residency patterns and economic outcomes, including employment:
• Countywide, there is a similar pattern to the education scores, with cities in the central County tending to have lower economic scores than cities and unincorporated areas along the coast and in the southern, northern, and eastern parts of the County. Low score areas generally correspond to areas where the population is predominantly Hispanic of AAPI, whereas the high score areas correspond to predominantly White areas.
• In the Orange County Urban County jurisdictions,
o There are generally good economic outcomes in Cypress, Yorba Linda, North Tustin, La Palma, Los Alamitos, unincorporated areas east of Yorba Linda, Brea, North Tustin, Orange Park Acres, Villa Park, Seal Beach (except for the Tract where Leisure World, a retirement community, is located), Rossmoor, Laguna Beach, Dana Point, Ladera Ranch, and Capistrano Beach. o There is a mix of economic outcomes in the following places:
▪ Placentia, where there are lower economic scores in the southwest corner of the city, which is predominantly Hispanic.
▪ Laguna Woods and North Laguna Hills, which are predominantly White and have lower economic scores.
▪ San Juan Capistrano, where there are lower economic scores in the Census Tract that encompasses the interchange between I-5 and the Ortega Highway (SR-74), which is also a high POC segregation area and predominantly Hispanic.
• In Aliso Viejo, neighborhoods across the city have high economic scores, are predominantly White, and are mostly areas of high White concentration. • In Anaheim, neighborhoods with lower economic scores include neighborhoods considered to be areas of high POC segregation, including those north of downtown and along SR-91, and south of downtown and adjacent to Disneyland. These areas are predominantly Hispanic. Conversely, Anaheim Hills has high economic scores and is predominantly White.
• In Buena Park, the neighborhoods between I-5 and SR-91 have the lowest economic scores in the city. These areas are predominantly Hispanic. The northeastern corner of the city, which is predominantly AAPI, has the highest economic scores in the city. • In Costa Mesa, the neighborhoods in and surrounding downtown, on the west side of Newport Boulevard have the lowest economic scores. These are also areas that are predominantly Hispanic.

Orange County 85 25-29 Regional AFH
• In Fountain Valley, neighborhoods across the city have high economic scores. • In Fullerton, there is a general north/south divide between areas with higher and lower economic scores. The southeastern neighborhoods, which are predominantly Hispanic, have the lowest economic scores, while the northern half of the city, predominantly White and AAPI neighborhoods, have the highest economic scores. • In Garden Grove, economic scores are moderate north of Garden Grove Freeway (SR-22) and are higher in West Garden Grove. Economic scores are generally lower south of SR-22.
• In Huntington Beach, neighborhoods across the city have high economic scores. • In Irvine, neighborhoods across the city have high economic scores except in the area surrounding UC Irvine, and in the neighborhoods east of the intersections of SR-133 and I-5—these are predominantly AAPI.
• In La Habra, the areas with the lowest economic scores are the same areas with high POC segregation, including the neighborhoods in the center of the city north of Guadalupe Park and between Idaho Street to the west and Sonora High School to the east. These neighborhoods are predominantly Hispanic. • In Laguna Niguel, neighborhoods across the city have high economic scores, are predominantly White, and are mostly areas of high White concentration. • In Lake Forest, neighborhoods across the city have high economic scores except for in the southeastern corner, which is a predominantly Hispanic area. • In Mission Viejo, neighborhoods across the city have high economic scores, are predominantly White, and are primarily areas of high White concentration. • In Newport Beach, neighborhoods across the city have high economic scores, are predominantly White, and are all areas of high White segregation. • In Orange, neighborhoods across the city have good economic scores. The best economic scores are in the neighborhoods north and east of Villa Park, where the population is predominantly White and classified as an area of high White segregation. The neighborhoods with lower economic scores are located west of Glassel Street and north of Walnut Avenue, which is a predominantly Hispanic area. • In Rancho Santa Margarita, neighborhoods across the city have high economic scores, are predominantly White, and are generally areas of high White concentration.
• In San Clemente, neighborhoods across the city have high economic scores, are predominantly White, and are primarily areas of high White concentration. • In Santa Ana, there are neighborhoods with low economic scores in much of the central and western parts of the city, which correspond to the areas of high POC segregation and are predominantly Hispanic, except for the Riverview West community, which is predominantly AAPI. Neighborhoods with higher economic scores are in the northern and southern parts of the city, which are areas of lowmedium segregation.

Orange County 86 25-29 Regional AFH
• In Tustin, all neighborhoods have good economic scores except for one neighborhood south of I-5 and west of SR-55, adjacent to Santa Ana. This is also a predominantly Hispanic area and is classified as an area of high POC segregation. • In Westminster, economic scores are lowest in the central part of the city, in the neighborhoods south of Westminster Boulevard, east of Hoover Street, and north of Bolsa Avenue. These are all areas of predominantly AAPI population.

Map 8 – Economic Score – Region
Source: California HCD, AFFH Data Viewer
Orange County 87 25-29 Regional AFH
Map 8 – Economic Score – North Orange County
Source: California HCD, AFFH Data Viewer
Orange County 88 25-29 Regional AFH
Map 8 – Economic Score – Central Orange County
Source: California HCD, AFFH Data Viewer
Orange County 89 25-29 Regional AFH
Map 8 – Economic Score – South Orange County
Source: California HCD, AFFH Data Viewer
The following analysis describes the groups that are least successful in accessing employment.

Table 7 - Labor Force Participation and Unemployment, shows 2018-2022 ACS data on labor force participation rates and unemployment rates in the region and Orange County, for the overall population and by race/ethnicity, disability status, and sex. The table shows that:
• Orange County has lower unemployment rates than the region for every group measured in the table, except for Pacific Islanders.
• Labor force participation rates are generally higher in Orange County than the region, except for White individuals (lower in the County than the region) and Asian individuals (same rate in County and region).
• Similar to the region overall, Black individuals have the highest unemployment rate in Orange County. In the County, Pacific Islanders have the second highest unemployment rate.

Orange County 90 25-29 Regional AFH
Table 7 – Labor Force Participation and Unemployment
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 65.00% 6.60% 65.60% 5.40% 75.30% 3.80% Race/Ethnicity
White, Non-Hispanic 63.40% 6.30% 62.80% 5.10% 75.50% 3.50% Black 60.70% 10.40% 70.60% 7.70% 84.90% 8.90%
Hispanic 67.60% 6.60% 70.70% 5.50% 78.00% 3.00%
Asian 62.70% 5.30% 62.70% 5.10% 71.00% 3.00%
Pacific Islander 66.40% 7.00% 68.70% 7.30% 100.00% 0.00% Native American 66.20% 7.90% 70.60% 5.20% 100.00% 0.00% Sex (population 20 to 64 years)
Male 84.10% 6.10% 85.90% 4.70% 91.10% 2.90%
Female 72.80% 6.50% 73.50% 5.40% 79.00% 4.10%
Disability Status
With any disability 46.80% 13.30% 51.00% 10.80% 68.50% 2.90% Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 67.40% 5.40% 69.00% 5.40% 73.20% 5.00% Race/Ethnicity
White, Non-Hispanic 62.70% 5.00% 61.40% 6.40% 71.20% 5.00% Black 72.30% 9.30% 77.70% 3.30% 91.60% 5.90%
Hispanic 70.80% 5.40% 72.40% 5.00% 76.50% 5.80%
Asian 64.20% 4.70% 70.90% 5.00% 64.10% 2.60%
Pacific Islander 66.80% 2.50% 63.30% 33.50% 92.80% 2.80% Native American 73.70% 4.10% 67.80% 18.30% 72.90% 3.70% Sex (population 20 to 64 years)
Male 86.20% 4.70% 87.00% 5.60% 89.50% 4.00%
Female 73.90% 5.50% 77.00% 4.90% 78.50% 5.00%
Disability Status
With any disability 47.50% 13.40% 50.10% 13.70% 57.80% 11.50% Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 61.80% 6.00% 65.40% 6.90% 64.30% 5.80% Race/Ethnicity
White, Non-Hispanic 57.40% 6.90% 60.40% 6.60% 59.70% 6.70% Black 70.50% 27.80% 63.10% 17.80% 57.80% 0.00%
Hispanic 72.90% 3.90% 71.10% 6.60% 72.90% 4.90%
Asian 62.10% 5.10% 63.60% 6.90% 59.60% 6.40%
Pacific Islander 65.20% 20.40% 83.50% 0.00% 65.60% 13.00% Native American 66.00% 0.00% 73.20% 8.30% 78.70% 5.90%
Sex (population 20 to 64 years)
Male 83.30% 7.40% 85.00% 5.50% 83.30% 5.00%
Female 75.30% 4.80% 71.80% 7.50% 74.00% 5.80%
Disability Status
With any disability 37.40% 12.10% 52.00% 10.50% 46.40% 10.70% Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 66.30% 5.40% 65.60% 5.50% 66.20% 5.50% Race/Ethnicity
White, Non-Hispanic 63.80% 5.10% 66.90% 6.30% 63.50% 4.70% Black 80.90% 13.10% 73.10% 5.20% 63.40% 9.80%
Hispanic 75.70% 5.70% 68.10% 5.50% 74.10% 3.00%
Asian 63.40% 5.40% 63.40% 4.50% 69.40% 9.60%
Pacific Islander 77.70% 6.40% 79.30% 0.60% 93.10% 0.00% Native American 56.00% 4.00% 65.20% 4.00% 89.70% 0.00%
Sex (population 20 to 64 years)
Male 85.70% 5.50% 83.10% 4.10% 86.70% 4.30%
Female 77.40% 4.60% 70.10% 6.40% 75.00% 6.80%
Disability Status
With any disability 53.80% 13.00% 54.10% 11.20% 37.80% 10.50% Note 1: Data Sources: U.S. Census Bureau, 2018-2022 American Community Survey 5-Year Estimates Garden Grove, CA
Huntington Beach, CA Irvine, CA Laguna Niguel, CA
Los Angeles-Long Beach-Anaheim, CA MSA Orange County, CA Aliso Viejo, CA Anaheim, CA Buena Park, CA Costa Mesa, CA
Fountain Valley, CA Fullerton, CA
Orange County 91 25-29 Regional AFH
Table 7 – Labor Force Participation and Unemployment (continued) Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 68.30% 7.20% 69.20% 5.00% 63.60% 4.40% Race/Ethnicity
White, Non-Hispanic 63.60% 7.60% 67.20% 5.20% 60.30% 4.70% Black 76.00% 3.60% 54.70% 3.50% 71.10% 2.80%
Hispanic 71.20% 7.70% 75.20% 5.50% 71.50% 3.20%
Asian 65.30% 4.30% 67.50% 3.30% 66.20% 5.00%
Pacific Islander 100.00% 0.00% 60.70% 0.00% 89.50% 0.00% Native American 57.70% 0.00% 94.90% 0.00% 72.80% 0.00%
Sex (population 20 to 64 years)
Male 88.90% 6.20% 88.90% 4.30% 88.60% 3.50%
Female 76.60% 7.50% 73.80% 5.00% 75.10% 4.60%
Disability Status
With any disability 49.80% 15.90% 57.30% 7.50% 53.90% 3.70% Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 62.40% 4.10% 66.10% 4.70% 74.30% 3.30% Race/Ethnicity
White, Non-Hispanic 60.50% 4.70% 64.00% 4.00% 73.60% 3.00% Black 54.80% 0.00% 60.90% 5.60% 82.10% 1.60%
Hispanic 76.80% 2.70% 69.20% 5.40% 80.20% 3.80%
Asian 57.50% 0.80% 64.90% 3.10% 72.70% 3.40%
Pacific Islander 100.00% 0.00% 59.60% 0.00% 100.00% 0.00% Native American 65.40% 0.00% 76.50% 0.00% 95.00% 21.60% Sex (population 20 to 64 years)
Male 88.70% 3.80% 82.30% 4.20% 92.90% 3.50%
Female 68.60% 3.90% 75.60% 4.20% 77.10% 2.20%
Disability Status
With any disability 60.30% 10.40% 52.40% 5.10% 62.10% 5.20% Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 63.10% 5.30% 66.70% 5.50% 69.00% 5.90% Race/Ethnicity
White, Non-Hispanic 61.90% 5.80% 59.90% 3.90% 65.90% 7.30% Black 71.50% 0.00% 70.50% 6.60% 74.00% 8.00%
Hispanic 70.70% 4.70% 68.50% 5.30% 72.50% 6.50%
Asian 52.20% 3.90% 61.70% 7.40% 67.80% 4.00%
Pacific Islander 30.90% 0.00% 42.10% 24.90% 63.50% 14.80% Native American 100.00% 0.00% 70.00% 6.40% 68.20% 0.00% Sex (population 20 to 64 years)
Male 85.40% 4.80% 85.00% 4.90% 89.70% 4.40%
Female 71.60% 5.30% 71.60% 5.20% 75.80% 6.50%
Disability Status
With any disability 52.60% 4.40% 51.70% 9.60% 51.40% 11.20% Labor Force
Participation Rate
Unemployment rate
Population 16 years and over 59.90% 7.50%
Race/Ethnicity
White, Non-Hispanic 58.00% 5.80%
Black 71.40% 3.80%
Hispanic 66.60% 9.00%
Asian 57.40% 7.20%
Pacific Islander 36.30% 25.60%
Native American 47.60% 15.40%
Sex (population 20 to 64 years)
Male 82.10% 7.20%
Female 71.20% 7.60%
Disability Status
With any disability 42.10% 12.90%
Note 1: Data Sources: U.S. Census Bureau, 2018-2022 American Community Survey 5-Year Estimates Orange, CA Rancho Santa Margarita, CA
San Clemente, CA Santa Ana, CA Tustin, CA
Westminster, CA
La Habra, CA Lake Forest, CA Mission Viejo, CA
Newport Beach, CA
Orange County 92 25-29 Regional AFH

3. Transportation
This analysis describes any disparities in access to transportation related to costs and access to public transit by protected class groups.

Table 6 includes a Transit Index, which measures the likelihood that residents will utilize public transportation. Higher index values indicate better access to public transit in a neighborhood. Table 6 also includes a Low Transportation Cost Index, which measures the cost of transportation in a neighborhood. Higher index values indicate lower transportation costs. Transportation costs may be low in a neighborhood due to better access to public transportation, or to the density of housing, services, and employment, or contributing factors.

Table 6 shows the following regarding disparities in access to transit and to neighborhoods with low transportation costs in each of the participating jurisdictions:
• In the region, access to transit and access to neighborhoods with low transportation costs are relatively high for all groups, though there are significant disparities between racial/ethnic groups. Both indices are lowest for White residents and highest for Black residents and are higher across all groups for individuals living below the FPL.
• In the Orange County Urban County jurisdictions, access to transit is slightly lower for all groups compared to the region but is still relatively high. There are also significant disparities, with AAPI residents having the best access, and White residents having the least access. Access is slightly higher across groups for people living below the FPL. Access to neighborhoods with low transportation costs is lower for all groups compared to the region overall but is still relatively high. There are some disparities between groups, with Hispanic residents having the best access, and White residents having the least access. Access is slightly higher across groups for people living below the FPL, except for Hispanic residents living below the FPL who have similar access to the overall Hispanic population. • In Aliso Viejo, access to transit is low for all groups, and lowest for Black and Native American residents living below the FPL. Access to neighborhoods with low transportation costs is relatively high for all groups, with small disparities between groups—access is lowest for Black and Native American residents living below the FPL.
• In Anaheim, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Buena Park, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Costa Mesa, access to transit and access to neighborhoods with low transportation costs are high for all groups.

Orange County 93 25-29 Regional AFH
• In Fountain Valley, access to transit and access to neighborhoods with low transportation costs are high for all groups. Black residents living below the FPL have the highest access to neighborhoods with low transportation costs. • In Fullerton, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Garden Grove, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Huntington Beach, access to transit and access to neighborhoods with low transportation costs are high for all groups. Native American residents living below the FPL have relatively low access to neighborhoods with low transportation costs, compared to other groups in city and the region.
• In Irvine, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In La Habra, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Laguna Niguel, access to transit is low for all groups. Access to neighborhoods with low transportation costs is slightly lower for residents of the city in comparison to the region.
• In Lake Forest, access to transit is low for all groups, and lowest for Black and Hispanic residents living below the FPL. Access to neighborhoods with low transportation costs is slightly lower for residents of the city in comparison to the region.
• In Mission Viejo, access to transit is low for all groups. Access to neighborhoods with low transportation costs is slightly lower for residents of the city in comparison to the region.
• In Newport Beach, access to transit is high for all groups. Access to neighborhoods with low transportation costs is comparable to the region for most groups, except for AAPI residents in the city, who have less access than other groups and compared to the region.
• In Orange, access to transit is high for all groups and slightly better than access in the region. Access to neighborhoods with low transportation costs is relatively high for all groups and is comparable to the region as a whole. • In Rancho Santa Margarita, access to transit is low for all groups. Access to neighborhoods with low transportation costs is also lower in the city compared to the region, and there are significant racial/ethnic disparities. AAPI residents living below the FPL have significantly lower access than other groups. • In San Clemente, access to transit is low for all groups, and access to neighborhoods with low transportation costs is also lower in the city compared to the region. There are some racial/ethnic disparities in access to neighborhoods with low Orange County 94 25-29 Regional AFH
transportation costs—Native American residents living below the FPL line, and AAPI residents of all income levels, have less access compared to other groups. • In Santa Ana, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Tustin, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Westminster, access to transit and access to neighborhoods with low transportation costs are high for all groups.

The following analysis describes how a person’s place of residence affects their access to transportation.

Map 9 – High Quality Transit Areas, is a series of maps showing the areas of north, central, and south Orange County, and the region, that have access to “high quality” public transit, defined as having scheduled frequencies of 15 minutes or less. These maps were created by California HCD to facilitate fair housing planning, using data from the California Department of Transportation (Caltrans) 12F
13 . On the maps, the outlined areas are those within
half a mile of a transit stop that is served by public transit with scheduled frequencies of 15 minutes or less.

These maps show the following relationship between a person’s place of residence and access to transportation:
• Countywide, high quality transit areas (HQTAs) are concentrated in central County cities, and there are no HQTAs in the southern or northeast parts of the County. • In the Orange County Urban County jurisdictions, there are HQTAs in the following places
o In Brea, there is a HQTA in the center of city, overlapping with the racially integrated Census Tract that has a predominantly Hispanic population. o In Cypress, there is a HQTA on the southern edge of the city. o In Stanton, HQTAs cover the entire city.
o In Seal Beach, there are HQTAs along Seal Beach Boulevard north of US-1. o In Rossmoor, the southeastern corner of the city is a HQTA, along Seal Beach Boulevard.
o In Los Alamitos, the northern edge of the city is part of an HQTA. o In Laguna Woods, the eastern half of the city is a HQTA, along El Toro Rd. o In Laguna Hills, the part of the city adjacent to the HQTAs in Laguna Woods and Lake Forest is a HQTA.
13 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing Orange County 95 25-29 Regional AFH
o The following areas have no HQTAs: Placentia, Yorba Linda, unincorporated areas east of Yorba Linda, La Palma, Villa Park, Orange Park Acres, El Modena, North Tustin, Laguna Beach, Dana Point, Capistrano Beach, San Juan Capistrano, Ladera Ranch, and North Laguna Hills
• In Aliso Viejo, there are no HQTAs
• In Anaheim, there are HQTAs in the western part of city along Beach Boulevard; in the central and southern part of city along Harbor Boulevard and Katella Avenue, including the Anaheim Regional Transportation Intermodal Center near Angel Stadium; and in the eastern part of the city near the Anaheim Canyon Metrolink station. These areas overlap with both high POC segregation areas and racially integrated areas.
• In Buena Park, there are HQTAs in the eastern half of city, along Beach Boulevard and La Palma Avenue.
• In Costa Mesa, HQTAs cover most of the city’s area except for the high White segregation areas in the northwest (the neighborhoods north and west of the Country Club) and in East Side Costa Mesa (east of SR-55 and south of Mesa Drive), which do not have HQTAs.
• In Fountain Valley, there are no HQTAs
• In Fullerton, there are HQTAs in downtown Fullerton and up to Fullerton College, including the area around the Metrolink station.
• In Garden Grove, there are HQTAs south of SR-22, in West Garden Grove, and in the eastern part of the city. There are no HQTAs in the city’s north-central area. • In Huntington Beach, most of the city is not a HQTA.There is one HQTA around the intersection of Main Street and Pacific Coast Highway (US-1). • In Irvine, there are HQTAs located near UC Irvine and John Wayne Airport, and the Irvine Medical and Science Complex. The majority of the city does not have HQTAs. • In La Habra, the western half of the city is a HQTA. In the eastern half of the city, which is a high POC segregation area and has a concentration of predominantly Hispanic neighborhoods, there are no HQTAs
• In Laguna Niguel, there are no HQTAs except in a small area in the northeast corner along Crown Valley Parkway, adjacent to Mission Viejo.
• In Lake Forest, most of the city is not a HQTA. There are two HQTAs in the city: one in Foothill Ranch, north of SR-241(around Towne Center); and the other in the city’s southeastern corner along El Toro Rd (which is a predominantly Hispanic area). • In Mission Viejo, most of the city does not have HQTAs. There are two HQTAs in the city: one in the southern part, along Crown Valley Parkway (which is a low-medium concentration area with a predominantly Hispanic population); and the other in the northern part of the city, around the intersections of Santa Margarita Parkway with Los Alisos Boulevard and Marguerite Parkway (which are low-medium concentration areas with predominantly White populations) Orange County 96 25-29 Regional AFH
• In Newport Beach, there are HQTAs just south of Costa Mesa and around the Civic Center. Much of the city does not have HQTAs.
• In Orange, there are HQTAs downtown, in the neighborhoods west and northwest of downtown, and along the westside of Costa Mesa Freeway (SR-55) north of Katella Avenue. There are no HQTAs east of the Costa Mesa Freeway. • In Rancho Santa Margarita, there are no HQTAs
• In San Clemente, there are no HQTAs
• In Santa Ana, most of the city is covered by HQTAs, except for northeast and southeast corners.
• In Tustin, most of the city does not have HQTAs.There are two HQTAs in the following areas: one HQTA is in the racially integrated neighborhoods just to the north of I-5, in and around downtown; the other HQTA is in South Tustin, around the Metrolink train station.
• In Westminster, most of the city is considered a HQTA, with the exception of the western and southeastern areas.

Map 9 – High Quality Transit Areas – Region
Source: California HCD, AFFH Data Viewer
Orange County 97 25-29 Regional AFH
Map 9 – High Quality Transit Areas – North Orange County Source: California HCD, AFFH Data Viewer
Orange County 98 25-29 Regional AFH
Map 9 – High Quality Transit Areas – Central Orange County Source: California HCD, AFFH Data Viewer
Orange County 99 25-29 Regional AFH
Map 9 – High Quality Transit Areas – South Orange County Source: California HCD, AFFH Data Viewer

4. Access to Low Poverty Neighborhoods
The following analysis describes any disparities in exposure to poverty by protected class groups.

Table 6 includes a Low Poverty Index, which measures the level of poverty in a neighborhood. Higher index values indicate less exposure to poverty in a neighborhood.

Table 6 shows the following regarding disparities in access to low-poverty neighborhoods in each of the participating jurisdictions:
• In the region, there are significant disparities in access to low-poverty neighborhoods. Hispanic and Black residents have the least access, and White residents have the most access. Individuals living below the FPL also have less access to low-poverty neighborhoods, compared to the overall population. • In the Orange County Urban County jurisdictions, access to low-poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL. However, there are significant disparities in access.

Hispanic residents have the least access. White residents have the most access.

Individuals living below the FPL also have less access to low-poverty neighborhoods, compared to the overall population.

Orange County 100 25-29 Regional AFH
• In Aliso Viejo, access to low-poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In Anaheim, there are significant disparities in access to low-poverty neighborhoods.

Hispanic residents have the least access. White residents have the most access.

Individuals living below the FPL also have less access to low-poverty neighborhoods, compared to the overall population. Compared to the region, White, AAPI, and Native American residents of the city have less access to low-poverty neighborhoods; and Black residents of the city have better access. • In Buena Park, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale because Hispanic, Black, and Native American residents in the city have better access than their counterparts in the region. Access in the city is lowest for Hispanic and Black residents, and highest for White residents. Individuals living below the FPL have less access across all groups, except for Native American residents.
• In Costa Mesa, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale due to the fact that all groups, except for White residents, in the city have better access than their counterparts in the region as a whole. Access in the city is lowest for Hispanic residents and highest for AAPI residents. Individuals living below the FPL have less access across all groups, except for Black residents
• In Fountain Valley, all residents have relatively good access to low-poverty neighborhoods compared to the region. There are some disparities by race/ethnicity, with Hispanic residents, and Native American residents living below the FPL, having the least access.
• In Fullerton, all residents have relatively good access to low-poverty neighborhoods compared to the region. There are some disparities by race/ethnicity, with Hispanic residents, including those living below the FPL, and Black residents living below the FPL, having the least access.
• In Garden Grove, there are significant disparities in access to low-poverty neighborhoods. AAPI and Hispanic residents have the least access. White residents have the best access. The population living below the FPL has less access across all groups. Compared to the region, disparities in the city are less pronounced due to lower index values for White and AAPI residents in the city, and higher index values for all other groups in the city, as compared to values in the region. • In Huntington Beach, all residents have relatively good access to low-poverty neighborhoods compared to the region. There are some disparities by race/ethnicity, with Hispanic residents having the least access and White residents having the most access. Individuals living below the FPL have less access across all groups, except for Native American residents.

Orange County 101 25-29 Regional AFH
• In Irvine, access to low-poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In La Habra, access to low-poverty neighborhoods is higher for all groups compared to the region, except for White residents. There are significant disparities in access to low-poverty neighborhoods by race/ethnicity. Hispanic residents have the least access. AAPI residents overall have the most access, however, the AAPI population living below the FPL has significantly less access compared to the overall AAPI population in the city.
• In Laguna Niguel, access to low-poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In Lake Forest, access to low-poverty neighborhoods is higher for all groups compared to the region. However, some racial/ethnic disparities exist, with Hispanic residents having the least access. For the population living below the FPL, access is much lower for Native American residents compared to any other group, access is lower for AAPI residents compared to the overall AAPI population, and access is higher for Black residents compared to the overall Black population. • In Mission Viejo, access to low-poverty neighborhoods is higher for all groups compared to the region. However, some disparities exist for individuals living below the FPL, with Black residents living below the FPL having less access than other groups in the city (though still with better access compared to the region). • In Newport Beach, access to low-poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In Orange, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale because all groups, except for White residents, in the city have better access than their counterparts in the region as a whole. Hispanic residents in the city have the least access to low-poverty neighborhoods. Additionally, Black residents living below the FPL have significantly lower access.
• In Rancho Santa Margarita, access to low-poverty neighborhoods is higher for all groups compared to the region, and there is little racial/ethnic disparity. For the population living below the FPL, racial/ethnic disparities are larger, mainly because the AAPI population below the FPL has the most access to low-poverty neighborhoods of any group in the city.
• In San Clemente, access to low-poverty neighborhoods is higher for all groups compared to the region. However, some racial/ethnic disparities exist, with Hispanic residents experiencing the least access. Disparities are larger for the population Orange County 102 25-29 Regional AFH
living below the FPL, with Black residents living below the FPL having the least access in the city.
• In Santa Ana, there are significant disparities in access to low-poverty neighborhoods. Hispanic residents have the least access overall, and White residents have the most access overall. For the population living below the FPL, access is lower across all groups. Compared to the region, all groups in the city have less access to low-poverty neighborhoods, except for Black residents, who have access comparable to the region overall.
• In Tustin, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale due to the fact that Hispanic, Black, and Native American residents in the city have higher access relative to the region, and White and AAPI residents have lower access relative to region. In the city, Hispanic residents have the lowest access. For the population living below the FPL, there are also significant disparities. Access to low-poverty neighborhoods is lowest for Native American and Hispanic residents living below the FPL, and access for White residents living below the FPL is significantly lower than access for the overall White population.
• In Westminster, access to low poverty neighborhoods is lower than in the region for all groups, except for Black residents, and there are significant racial/ethnic disparities. Hispanic and AAPI residents have the least access, overall. For the population living below the FPL, access is lower across all groups and is lowest for AAPI residents.

Map 10 – Poverty Status, is a series of maps showing the percent of households, by Census Tract, living below the FPL in north, central, and south Orange County, and in the region.

These maps were created by California HCD to facilitate fair housing planning, using data from the U.S. Census Bureau American Community Survey, 2017-2021 5-Year Estimates13F 14 .

These maps show the following relationship between an individual’s place of residence and their exposure to poverty:
• Countywide, higher poverty areas are in the central County cities, whereas the areas along the coast, in the south, and in the northeast are low poverty areas. • In the Orange County Urban County jurisdictions, there are high poverty areas (i.e., with poverty rates above 20%) in the following places:
o In Placentia, in the southwest corner of the city, which is a high POC segregation area that is predominantly Hispanic.
o In Stanton, in the neighborhoods on the south side of Katella Avenue and on the eastside of Beach Boulevard north of Katella Avenue. 14 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing Orange County 103 25-29 Regional AFH
o In San Juan Capistrano, there is one tract between Camino Del Avion, Del Obispo Street, and Alipaz Street, which has a poverty rate over 20% and is predominantly Hispanic.
• In Aliso Viejo, all Census Tracts have a poverty rate below 20%. • In Anaheim, the highest poverty area is located downtown north of Lincoln Avenue (in a predominantly Hispanic area). There are other areas of concentrated poverty south and west of downtown, which are also predominantly Hispanic. The areas of lowest poverty are downtown south of Lincoln Avenue, east of downtown (including the racially integrated areas), in Northeast Anaheim, and in Anaheim Hills. • In Buena Park, all Census Tracts have a poverty rate below 20%. • In Costa Mesa, all Census Tracts have a poverty rate below 20%. • In Fountain Valley, all Census Tracts have a poverty rate below 20%. • In Fullerton, there are high poverty areas in the southeast (predominantly Hispanic, low-medium segregation areas) and surrounding CSU Fullerton (likely due to the presence of college students).
• In Garden Grove, there are high poverty areas in the industrial area in West Garden Grove, in the Census Tract between Brookhurst Street and Gilbert Street north of Chapman Avenue (a low-medium segregation area that is predominantly Hispanic), and in the Census Tract in between SR-22 and Garden Grove Boulevard west of Gilbert Street (a high POC segregation area that is predominantly AAPI). • In Huntington Beach, all Census Tracts have a poverty rate below 20%. • In Irvine, the highest poverty area is surrounding UC Irvine (likely due to the presence of college students). There is also a high poverty area west of San Diego Creek north of I-405. This is primarily an industrial/commercial area encompassing the Irvine Business Complex.
• In La Habra, all Census Tracts have a poverty rate below 20%. • In Laguna Niguel, all Census Tracts have a poverty rate below 20%. • In Lake Forest, all Census Tracts have a poverty rate below 20%. • In Mission Viejo, all Census Tracts have a poverty rate below 20%. • In Newport Beach, all Census Tracts have a poverty rate below 20%. • In Orange, all Census Tracts have a poverty rate below 20%, and all neighborhoods east of Villa Park have poverty rates below 10%.
• In Rancho Santa Margarita, all Census Tracts have a poverty rate below 20%. • In San Clemente, all Census Tracts have a poverty rate below 20%. • In Santa Ana, high poverty areas are concentrated in downtown and southeast of downtown where land use is primarily industrial and commercial, and in western Santa Ana, specifically the Census Tract northwest of the intersection of McFadden Avenue and Harbor Boulevard, where Kona Kai Mobile Home Park is located. All of these areas are high POC segregation areas with predominantly Hispanic populations.

Orange County 104 25-29 Regional AFH
• In Tustin, all Census Tracts have a poverty rate below 20%. • In Westminster, there are high poverty areas between Edwards Street and Beach Boulevard along Westminster Boulevard, and south of Bolsa Avenue west of Bushard Street. These areas are high POC segregation areas with predominantly AAPI populations.

Map 10 – Poverty Status – Region
Source: California HCD, AFFH Data Viewer
Orange County 105 25-29 Regional AFH
Map 10 – Poverty Status – North Orange County
Source: California HCD, AFFH Data Viewer
Orange County 106 25-29 Regional AFH
Map 10 – Poverty Status – Central Orange County
Source: California HCD, AFFH Data Viewer
Orange County 107 25-29 Regional AFH
Map 10 – Poverty Status – South Orange County
Source: California HCD, AFFH Data Viewer
Table 8 - Poverty by Race/Ethnicity and National Origin, shows data from the 2018-2022 ACS on poverty rates by race/ethnicity and national origin, for the region, Orange County, the Urban County jurisdictions, and the HUD Entitlement Cities. The table shows the following:
• Countywide, the poverty rate is lower than region for all groups except AAPI residents (who have a poverty rate comparable to the region). There are significant racial/ethnic disparities. The Black poverty rate is highest and is nearly double the White poverty rate, and the foreign-born population is more likely to live below poverty than the native-born population.
• In the Orange County Urban County jurisdictions, the poverty rate is lower than the County overall. Similar to the County overall, the Black poverty rate is highest and is nearly double the White poverty rate, and the foreign-born population is more likely to live below poverty than the native-born population. • In Aliso Viejo, the overall poverty rate is lower than the County. Similar to the County, the foreign-born population is more likely to live below poverty than the native-born population. (Note that the Black and Native American populations may be too small for the sample data to be accurate.)
• In Anaheim, the overall poverty rate is higher than the County and is comparable to the region poverty rate. Black and Hispanic residents have the highest poverty rates.

Orange County 108 25-29 Regional AFH
Similar to the County overall, the foreign-born population is more likely to live below poverty than the native-born population.
• In Buena Park, the overall poverty rate is lower than in the County. Similar to the County overall, Black residents have the highest poverty rate. • In Costa Mesa, the overall poverty rate is similar to the County and there are much larger racial/ethnic disparities. The Black poverty rate in the city is over 20%, which is nearly three times as high as the White poverty rate and double the AAPI poverty rate. Similar to the County overall, the foreign-born population is more likely to live below poverty than the native-born population.
• In Fountain Valley, the overall poverty rate is lower than the County. Similar to the County, the foreign-born population is more likely to live below poverty than the native-born population. (Note that the Black and Native American populations may be too small for the sample data to be accurate.)
• In Fullerton, the overall poverty rate is higher than the County and is comparable to the region poverty rate, and there are much larger racial/ethnic disparities than in the County overall. The Black poverty rate is over 22%, which is almost three times higher than the White and AAPI poverty rates. The Hispanic poverty rate is above 17%, which is more than double the White and AAPI rates. Similar to the County overall, the foreign-born population is more likely to live below poverty than the native-born population. (Note that the Native American population may be too small for the sample data to be accurate.)
• In Garden Grove, the overall poverty rate is higher than the County and is comparable to the region poverty rate. There are relatively small disparities by race/ethnicity, with Black residents experiencing the highest poverty rates, and foreign-born residents more likely to live below the FPL than native-born residents. • In Huntington Beach, the overall poverty rate is lower than the County and the foreign-born population is much more likely to live below poverty than the nativeborn population. (Note that the Native American population may be too small for the sample data to be accurate.)
• In Irvine, the overall poverty rate is higher than the County and is comparable to the region poverty rate. Black, Hispanic, and AAPI residents experience similar poverty rates, which are all higher than the poverty rate for White residents. Foreign-born residents are more likely to live below the FPL than native-born residents. • In La Habra, the overall poverty rate is similar to the County. Foreign-born residents more likely to live below the FPL than native-born residents, and Hispanic residents have a higher poverty rate than other groups. (Note that the Black and Native American populations may be too small for the sample data to be accurate.) • In Laguna Niguel, the overall poverty rate is lower than the County. However, there are disparities between groups. Hispanic residents have the highest poverty rate in Orange County 109 25-29 Regional AFH
the city, and foreign-born residents are more likely to live below the FPL than nativeborn residents. • In Lake Forest, the overall poverty rate is lower than in the County. However, there are disparities between groups. Hispanic residents have the highest poverty rate in the city, and foreign-born residents are more likely to live below the FPL than nativeborn residents. • In Mission Viejo, the overall poverty rate is lower than the County. The data show the Black poverty rate to be much higher than other racial/ethnic groups, however the population size may be too small for the data to be accurate. • In Newport Beach, the overall poverty rate is lower than the County. Unlike the County overall, foreign-born residents in the city are less likely to live below the FPL than native-born residents. Poverty rates for Black, AAPI, and Native American residents are the highest. However, note that the Black and Native American populations may be too small for the sample data to be accurate. • In Orange, the overall poverty rate is similar to the County. In the city, Native American and Hispanic residents have the highest poverty rates, and foreign-born residents are more likely to live below the FPL than native-born residents. • In Rancho Santa Margarita, the overall poverty rate is lower than the County.The data show the Native American poverty rate to be much higher than other racial/ethnic groups, however the population size may be too small for the data to be accurate.
• In San Clemente, the overall poverty rate is lower than the County and foreign-born residents are more likely to live below the FPL than native-born residents. The data show the Black poverty rate to be much higher than other racial/ethnic groups, however the population size may be too small for the data to be accurate. • In Santa Ana, the overall poverty rate is higher than the County but lower than the region poverty rate. Black residents have the highest poverty rate (nearly 20%). • In Tustin, the overall poverty rate is higher than the County but lower than the region poverty rate. Hispanic residents have the highest poverty rate (nearly double the White poverty rate), and foreign-born residents are more likely to live below the FPL than native-born residents.
• In Westminster, the overall poverty rate is higher than the County and the region.The Black poverty rate is over 20% and more than double the White poverty rate. The AAPI poverty rate is over 18% and is also more than double the White poverty rate.

Foreign-born residents are more likely to live below the FPL than native-born residents. (Note that the Native American population may be too small for the sample data to be accurate.)
Orange County 110 25-29 Regional AFH
Table 8 – Poverty by Race/Ethnicity and National Origin Orange County 111 25-29 Regional AFH
Table 8 – Poverty by Race/Ethnicity and National Origin (continued) Orange County 112 25-29 Regional AFH

5. Access to Environmentally Healthy Neighborhoods
The following analysis describes any disparities in access to environmentally healthy neighborhoods by protected class groups.

Table 6 includes an Environmental Health Index, which captures the potential exposure to harmful toxins in a neighborhood. Higher index values indicate less exposure to harmful toxins, and therefore better environmental quality, in a neighborhood.

Table 6 shows the following regarding disparities in access to environmentally healthy neighborhoods in each of the participating jurisdictions:
• In the region, there is relatively low access to environmentally healthy neighborhoods for all groups, and racial/ethnic disparities exist. Access to environmentally healthy neighborhoods is highest access for White residents, and lowest for Black residents followed by Hispanic and AAPI residents. Access is lower for all groups living below the FPL, with the least access experienced by Hispanic residents living below the FPL.
• In the Orange County Urban County jurisdictions, there is relatively low access to environmentally healthy neighborhoods for all groups, and racial/ethnic disparities exist. Access to environmentally healthy neighborhoods is highest access for White residents, and lowest for AAPI residents followed by Black and Hispanic residents.

Access is lower for all groups living below the FPL, except for White residents who have comparable access to the overall population.
• In Aliso Viejo, there is relatively high access to environmentally health neighborhoods for all groups compared to the region, and no racial/ethnic disparities.
• In Anaheim, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Buena Park, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Costa Mesa, residents have better access to environmentally healthy neighborhoods than residents of the region, but access is still low.There are some racial/ethnic disparities in access. Overall, AAPI residents have the least access to environmentally healthy neighborhoods, and Hispanic residents have the best access. For the population living below the FPL, Black and Native American residents have the least access.
• In Fountain Valley, there is very poor access to environmentally friendly neighborhoods for all residents compared to the region. There are small disparities in access for the population living below the FPL. Specifically, Black residents living below the FPL have the least access.

Orange County 113 25-29 Regional AFH
• In Fullerton, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Garden Grove, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity. • In Huntington Beach, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still fairly low and there are some racial/ethnic disparities. Access to environmentally healthy neighborhoods is lowest for Hispanic residents, and even more so for Hispanic residents living below the FPL.
• In Irvine, residents have better access to environmentally healthy neighborhoods than those of the region, but access is still low for all groups regardless of race/ethnicity.
• In La Habra, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Laguna Niguel, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited for all groups regardless of race/ethnicity.
• In Lake Forest, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited and there are some disparities among the population living below the FPL—specifically, Native American residents living below the FPL have the least access. • In Mission Viejo, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited for all groups regardless of race/ethnicity
• In Newport Beach, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited for all groups regardless of race/ethnicity
• In Orange, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Rancho Santa Margarita, there is relatively high access to environmentally health neighborhoods for all groups compared to the region and other jurisdictions in Orange County, and no racial/ethnic disparities.
• In San Clemente, there is relatively high access to environmentally health neighborhoods for all groups compared to the region and other jurisdictions in Orange County, and no racial/ethnic disparities.
• In Santa Ana, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Tustin, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.

Orange County 114 25-29 Regional AFH
• In Westminster, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.

Map 11 – Environmental Health, is a series of maps showing data from the California Office of Environmental Health Hazard Assessment (OEHHA) California Communities Environmental Health Screening Tool (CalEnviroScreen 4.0). These maps were created by California HCD to facilitate fair housing planning, using CalEnviroScreen data from OEHHA14F
15 .

The CalEnviroScreen tool is designed to identify communities most affected by pollution, and those where residents may be especially vulnerable to its effects. To do this, it uses a composite score based on 13 different indicators of pollution burden – such as exposure indicators (e.g., diesel particulate matter levels and lead risk from housing and environmental effect indicators (e.g., location of solid waste facilities) - as well as eight indicators of population characteristics including sensitive population indicators (e.g., asthma rates) and socioeconomic factor factors (e.g., poverty and linguistic isolation). More detailed information on the mapping methodology is available on the OEHHA website15F 16 .

On these maps, green areas represent regions with more positive environmental factors, while red areas indicate regions with more negative environmental factors.

These maps show the following relationship between an individual’s place of residence and their access to environmentally healthy neighborhoods:
• Countywide, the areas with more positive environmental factors are along the coast, in the south, and northeast.The areas with more negative environmental factors are in the central parts of the County north of I-405 and west of the Costa Mesa Freeway (SR-55).
• In the Orange County Urban County jurisdictions, most neighborhoods have primarily positive environmental factors. The areas with more negative environmental factors are located in the following places:
o Stanton.
o Southwest Placentia, next to Fullerton, which is an area of high POC segregation and is predominantly Hispanic.
o San Juan Capistrano, in the Census Tract that encompasses the interchange between I-5 and the Ortega Highway (SR-74), which is a high POC segregation area and is predominantly Hispanic.
• In Aliso Viejo, all neighborhoods in the city have positive environmental factors. 15 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 16 https://oehha.ca.gov/calenviroscreen
Orange County 115 25-29 Regional AFH
• In Anaheim, Anaheim Hills (a high White segregation area), has positive environmental factors. Much of the rest of the city is affected by negative environmental factors, with the severe environmental factors located in and around downtown, along I-5 cutting across the city, and along Riverside Freeway (SR-91) on the northern edge of the city.
• In Buena Park, there is one Census Tract with a score lower than 40 (indicating more positive environmental factors). This area is between La Palma Avenue and Crescent Avenue, on either side of Knott Avenue. Areas of the city with more negative environmental factors include the neighborhoods north of the Artesia Freeway (SR91) and adjacent to I-5, and the western part of the city, which includes numerous warehouses and distribution facilities.
• In Costa Mesa, areas with more positive environmental factors include neighborhoods east of Newport Boulevard (SR-55), which are high White segregation areas, as well as neighborhoods along the western edge of the city and north of I-405, which are also predominantly White. The areas with more negative environmental factors include neighborhoods downtown, which are predominantly Hispanic.
• In Fountain Valley, areas with more positive environmental factors include the neighborhoods in the southwest corner of city, which have a high concentration of White residents, and those surrounding Mile Square Regional Park, a high POC segregation area that is predominantly AAPI. The rest of the city experiences moderate environmental factors.
• In Fullerton, areas with more positive environmental factors include the neighborhoods near the Panorama Nature Preserve in the city’s northeast. Areas with more negative environmental factors include the neighborhoods in the southeast part of the city, which are predominantly Hispanic—this area includes the commercial/industrial area along the Riverside Freeway (SR-91); and neighborhoods in the southwest part of the city, around Fullerton Municipal Airport and to the south, which are also predominantly Hispanic.
• In Garden Grove, residential neighborhoods in West Garden Grove, west of Knott Street have more positive environmental factors and are areas of high White segregation. The rest of the city experiences less positive environmental factors, with the most negative factors located in West Garden Grove, east of Knott Street an industrial and commercial area, and along Garden Grove Freeway (SR-22), in the city’s southeast.
• In Huntington Beach, most of the city – particularly along the coast and in the southeastern region – has more positive environmental factors. However, an area with less positive environmental factors is in the industrial/commercial area between Beach Boulevard (SR-39) and Gothard Street, spanning from Talbert Orange County 116 25-29 Regional AFH
Avenue to Edinger Avenue.This area overlaps with the one predominantly Hispanic Census Tract.
• In Irvine, most of the neighborhoods in the city have positive environmental factors.

The few places with more negative environmental factors include the area west of San Diego Creek north of I-405 (which is primarily comprised of industrial and commercial land uses, including the Irvine Business Complex), the area between UC Irvine and I-405 (which is a high POC segregation area and is predominantly AAPI), and the eastern part of city along I-5 near Lake Forest, where Irvine Industrial Complex East and Irvine Technology Center are located.
• In La Habra, most of the city is affected by negative environmental factors, with the most negative factors concentrated in the central and southeast areas of the city/ This is likely due to the proximity to warehouses, distribution centers, and Imperial Highway (SR-90).These areas overlap with the high POC segregation areas, which are predominantly Hispanic.
• In Laguna Niguel, all neighborhoods in the city have positive environmental factors. • In Lake Forest, most neighborhoods in the city have positive environmental factors, except for those south of Serrano Creek, which experience more negative environmental factors.
• In Mission Viejo, all neighborhoods in the city have positive environmental factors. • In Newport Beach, all neighborhoods in the city have positive environmental factors. • In Orange, the neighborhoods east of Villa Park, which haver high White segregation, experience more positive environmental factors. Neighborhoods west of Glassel Street, which are predominantly Hispanic, are affected by more negative environmental factors.
• In Rancho Santa Margarita, all neighborhoods in the city have positive environmental factors.
• In San Clemente, most neighborhoods in the city have positive environmental factors, except for one area with moderate environmental factors. This area encompasses the neighborhoods north and east of Max Berg Plaza Park, and is classified as a low-medium concentration area with a predominantly White population.
• In Santa Ana, most of the city has negative environmental factors, with the most negative factors located in the east and southeast side of the city along the Costa Mesa Freeway (SR-55), where many of the commercial/industrial land uses are located. Other highly impacted areas include downtown and neighborhoods west of downtown. These are all areas of high POC segregation, and most are predominantly Hispanic, except for one of the Tracts to the far west of downtown, which is predominantly AAPI. There is one Census Tract with positive environmental factors located in the southern part of the city, within a racially integrated area between Orange County 117 25-29 Regional AFH
Segerstrom High School and the Bristol Place Shopping Mall, where White residents are the predominant group.
• In Tustin, neighborhoods north of I-5 have more positive environmental factors, and neighborhoods south of I-5 have more negative environmental factors. • In Westminster, most of the city has negative environmental factors, with the most negative factors located in the central neighborhoods, from I-405 north, between Beach Boulevard and Edwards Street.

Map 11 – Environmental Health – Region
Source: California HCD, AFFH Data Viewer
Orange County 118 25-29 Regional AFH
Map 11 – Environmental Health – North Orange County
Source: California HCD, AFFH Data Viewer
Orange County 119 25-29 Regional AFH
Map 11 – Environmental Health – Central Orange County
Source: California HCD, AFFH Data Viewer
Orange County 120 25-29 Regional AFH
Map 11 – Environmental Health – South Orange County
Source: California HCD, AFFH Data Viewer

6. Disability and Access
The following analysis describes the barriers that deny individuals with disabilities access to opportunity and community assets.

Table 7 – Disability by Type, presents the percentage of residents with various disabilities living in the region, Orange County, the Orange County Urban County jurisdictions, and in HUD Entitlement City. In the region and Orange County overall, the most prevalent form of disability is ambulatory difficulty, followed by independent living difficulty. Ambulatory difficulty is also the most prevalent form of disability in the Urban County jurisdictions and all HUD Entitlement Cities except for Aliso Viejo and Rancho Santa Margarita, where cognitive difficulty is most prevalent, and Irvine, where independent living difficulty is most prevalent.

Orange County 121 25-29 Regional AFH
Table 7 – Disability by Type
Orange County 122 25-29 Regional AFH
According to data from HUD, in Orange County, a total of 398 housing discrimination cases were opened between January 2019 and November 2024 (when this report was prepared).

As shown in Table 8, below, the majority (65.33%) of cases alleged discrimination based on disability. (Please note, the total number of cases in the table below equal more than 398, and the percentages equal more than 100% because one case can involve allegations of discrimination based on multiple protected classes). Table 9 shows the number of cases by jurisdiction, and the number and percentage of cases that included allegations of discrimination based on disability status. As the table shows, in nearly all jurisdictions, discrimination based (in whole or in part) on disability status comprises most cases.

Table 8 – Discrimination Complaints, Orange County, 2019-2024 Orange County 123 25-29 Regional AFH
Table 9 – Discrimination Complaints by Jurisdiction,
Orange County, 2019-2024
Orange County 124 25-29 Regional AFH
The fair housing challenges facing individuals with a disability were described during the stakeholder consultations and community meetings. Participants in these meetings reported the following barriers that deny individuals with disabilities access to opportunity and community assets:
• Individuals with disabilities often seek affordable housing in older buildings that may not meet accessibility standards, creating additional barriers. • Affordable housing options are concentrated in areas of Santa Ana and Anaheim, with fewer options in higher opportunity areas of the County. • Individuals with disabilities often face barriers in accessing necessary modifications in housing. Tenants must provide a doctor's letter to request modifications, yet landlords are often resistant to approving accommodation requests. In many cases, tenants are responsible for covering modification costs, unless the property is government-owned. Additionally, low-income individuals with disabilities struggle to afford the necessary modifications.

7. Patterns in Disparities in Access to Opportunity
The following analysis identifies and discusses any overarching patterns of access to opportunity and exposure to adverse community factors, including how these patterns compare to patterns of segregation, integration, and R/ECAPs. The analysis also identifies areas that experience: (a) high access; and (b) low access across multiple indicators.

In Orange County, there is a general pattern of disparities in access to opportunity between the cities in the central part of the County, and the cities and unincorporated areas along the coast and in the southern and northeastern parts of the County. Cities in central Orange County tend to have higher poverty areas, lower educational scores, lower economic scores, and worse environmental health factors. These cities are also comprised of many areas of high POC segregation, with predominantly Hispanic populations. Except for Garden Grove and Westminster, which have neighborhoods with predominantly AAPI populations. Conversely, the cities and unincorporated areas along the coast and in the south and northeast experience lower poverty rates, higher educational scores, higher economic scores, and better environmental health factors. These areas correspond to areas of high White segregation and predominantly White populations.

In the Orange County Urban County jurisdictions,
• The following racial/ethnic groups experience disparities in access across multiple indicators:
o Hispanic residents, and particularly those living below the Federal Poverty Level (FPL), have the least access to low poverty neighborhoods, neighborhoods in close proximity to high performing schools, and neighborhoods with high labor force participation and human capital.

Orange County 125 25-29 Regional AFH
• The following areas experience low access across multiple indicators:
o Southwest Placentia neighborhoods have low access to environmental health, high poverty, low economic scores, and are not located in a highquality transit area. This part of the city is a high POC segregation area that is predominantly Hispanic.
o Stanton residents experience low access to environmentally healthy neighborhoods and high exposure to poverty on the south side of Katella Avenue and on the east side of Beach Boulevard north of Katella Avenue. o In San Juan Capistrano, the neighborhoods surrounding the I-5 and the Ortega Highway (SR-74) interchange experience poor environmental health and have low economic scores. This is a high POC segregation area and is predominantly Hispanic.
• Apart from the areas above, the rest of the Urban County jurisdictions experience high environmental quality and have relatively low poverty. In addition, the following areas have access to educational and economic opportunities, as reflected in high education and economic scores on the maps analyzed above:
o Brea, Cypress, La Palma, Laguna Beach, Los Alamitos, North Tustin, Orange Park Acres, Villa Park, Yorba Linda, and the unincorporated areas east of Yorba Linda
In Aliso Viejo, residents have high access across multiple opportunities, including high education scores, high economic scores, high environmental quality, and low exposure to poverty. However, residents generally do not have good access to transit and neighborhoods with low transportation costs.

In Anaheim, Hispanic residents have the least access to low-poverty neighborhoods, neighborhoods close to high performing schools, and neighborhoods with high labor force participation and human capital. Geographically, neighborhoods near the downtown have low environmental health, low education scores, low economic scores; but good access to HQTAs. Conversely, Anaheim Hills, which is a predominantly White area, has the best access to environmentally healthy neighborhoods with low poverty rates, high education scores, and high economic scores.

In Buena Park, Hispanic and Black residents have less access than other groups to neighborhoods with low poverty rates and high performing schools. Geographically, the neighborhoods in the center of the city, between I-5 and the Artesia Freeway (SR-91), have poor environmental health, lower educational scores, and lower economic scores.

In Costa Mesa, Hispanic residents have the least access to low-poverty neighborhoods, neighborhoods close to high performing schools, and neighborhoods with high labor force participation and human capital. Geographically, neighborhoods downtown and west of downtown are less environmentally healthy and have lower education and economic Orange County 126 25-29 Regional AFH
scores. These are also predominantly Hispanic neighborhoods. Conversely, neighborhoods east of Newport Boulevard (SR-55), which are predominantly White, have higher education and economic scores, are more environmentally healthy, and have lower poverty rates.

In Fountain Valley, neighborhoods across the city have relatively high economic and educational scores, and relatively low poverty rates. White or AAPI residents comprise the predominant population in all neighborhoods.

In Fullerton, Hispanic residents have the least access to low-poverty neighborhoods, neighborhoods close to high performing schools, and neighborhoods with high labor force participation and human capital. Geographically, neighborhoods in southeast Fullerton (which are predominantly Hispanic), have relatively low economic and education scores, poor environmental quality, and relatively high poverty rates. Conversely, neighborhoods in the northern part of the city, which are predominantly White or AAPI, have higher education and economic scores, better environmental health, and lower poverty.

In Garden Grove, Hispanic and AAPI residents have the least access to low poverty neighborhoods and neighborhoods with high labor force participation and human capital.

Additionally, Hispanic residents also have the least access to neighborhoods with high performing schools. Geographically, the neighborhoods with access to the most opportunities are in West Garden Grove, where education and economic scores are high, environmental quality is high, and poverty is low. West Garden Grove is a predominantly White area.

In Huntington Beach, Hispanic residents have relatively low access to neighborhoods with good environmental health, low poverty, high education scores, and high economic scores.

Overall, access to opportunities in the city is high compared to the region.

In Irvine, residents across the city have relatively high access to opportunities.

Geographically, the neighborhoods surrounding UC Irvine have relatively low economic scores and relatively high poverty rates, but this is most likely due to the concentration of college students in this area.

In La Habra, neighborhoods in the city’s center and southeast of the center have poor environmental quality, low education scores, and low economic scores. These neighborhoods are also predominantly Hispanic.

In Laguna Niguel, residents have high access across multiple opportunities, including high education scores, high economic scores, high environmental quality, and low exposure to poverty. However, residents generally do not have good access to transit and neighborhoods with low transportation costs.

Orange County 127 25-29 Regional AFH
In Lake Forest, residents overall have relatively good access to opportunities, compared to the region. However, residents living below the FPL in the city generally have less access to opportunities than the rest of the population.

In Mission Viejo, residents across the city have relatively high access to opportunities (apart from transit and low-cost transportation). Most of the city’s neighborhoods are predominantly White, except in the south.

In Newport Beach, residents across the city have relatively high access to opportunities. All of the city’s neighborhoods are predominantly White.

In Orange, Hispanic, and Black residents (especially Black residents living below the FPL) have relatively low access to neighborhoods close to high performing schools, and to neighborhoods with high labor force participation and human capital. Geographically, neighborhoods west of Glassel Street (which are predominantly Hispanic), have lower education and economic scores, and worse environmental quality. Conversely, neighborhoods to the north and east of Villa Park (predominantly White), have high education and economic scores, and good environmental quality.

In Rancho Santa Margarita, residents across the city have relatively high access to opportunities. All of the city’s neighborhoods are predominantly White.

In San Clemente, residents have relatively high access to opportunities compared to the region. Geographically, compared to the rest of the city, neighborhoods north and east of Max Berg Plaza Park have lower environmental quality, lower economic scores, and slightly higher poverty rates.

In Santa Ana, Hispanic residents are more likely than other groups to be exposed to poverty in their neighborhoods and are less likely than other groups to live in close proximity to high performing schools, or in neighborhoods with high labor force participation and human capital. Geographically, neighborhoods downtown, west of downtown, and southeast of downtown have low economic scores, low education scores, high poverty rates, and poor environmental quality. Neighborhoods in the north and south of the city have better economic and education scores.

In Tustin, Hispanic residents (especially those below FPL) are less likely than other groups to live in close proximity to high performing schools, or in neighborhoods with high labor force participation and human capital; and are more likely to be exposed to poverty in their neighborhoods.

In Westminster, AAPI residents are more likely than other groups to be exposed to poverty in their neighborhoods and are less likely than other groups to live in close proximity to high performing schools or jobs. Native American residents living below the FPL are also less likely to live in close proximity to high performing schools or jobs.

Orange County 128 25-29 Regional AFH
This section describes the public or private policies or practices, demographic shifts, economic trends, or other factors that may have caused or contributed to the patterns described above.

Broadly speaking, disparities in access to opportunities between and within jurisdictions in Orange County are due, in part, to:
• Lack of affordable (market or publicly subsidized) housing in high opportunity areas, due to market factors, governmental constraints, and community opposition to high density zoning.
• Lack of public and private investment in low-opportunity neighborhoods. • Displacement of residents is due to rising housing costs.

Through the stakeholder consultations and community meetings, it was also reported that disparities in access to opportunities in the County are due to:
• In addition to landlord resistance to renting to HCV Program participants, the gap between HCV subsidy amounts and housing costs further inhibits HCV Program participants from accessing housing in higher cost (and higher opportunity areas). • Many seniors are on fixed incomes and cannot keep up with the rising cost of housing.
• The high cost of land, which makes it hard to build new affordable housing in high opportunity areas.
• The California Coastal Act, which limits development in high opportunity areas along the coast.
• Lack of accessible housing for individuals with disabilities.

Detailed lists of the public or private policies or practices, demographic shifts, economic trends, and other factors that have caused or contributed to disparities in access to opportunities in each of the jurisdictions are included in Section IV.

Orange County 129 25-29 Regional AFH
E. Disproportionate Housing Needs
The following analysis describes which groups experience higher rates of housing cost burden, severe housing cost burden, overcrowding, or substandard housing when compared to other groups.

Housing Problems
Table 10 – Disproportionate Housing Problems, shows 2017-2021 Comprehensive Housing Affordability Strategy (CHAS) data on the percentage of households experiencing at least one of the following four housing problems, organized by race/ethnicity:
• Lacks complete kitchen facilities: Household lacks a sink with piped water, a range or stove, or a refrigerator.
• Lacks complete plumbing facilities: Household lacks hot and cold piped water, a flush toilet, and a bathtub or shower.
• Overcrowding: A household is considered overcrowded if there are more than 1.01 individuals per room.
• Cost burden: A household is considered cost burdened if the household spends more than 30% of its total gross income for housing costs. For renters, housing costs include rent paid by the tenant, plus utilities. For owners, housing costs include mortgage payment, taxes, insurance, and utilities.

A disproportionately greater need exists when members of a racial or ethnic group in a certain income range experience housing problems at a rate that is least 10 percentage points higher than the rate experienced by all households within that income level. Table 10 reports the following:
• American Indian or Alaska Native households, and Pacific Islander households have disproportionate housing needs within the 80%-100% AMI range. • It is also worth noting that Hispanic households in the 30% AMI and below range experience housing needs at a much higher rate than the overall population in that income range, though the rate is slightly less than 10 percentage points.

Orange County 130 25-29 Regional AFH
Table 10 - Disproportionate Housing Problems, Orange County Percent of households experiencing at least one
housing burden, by income range
Race/Ethnicity Less than
30% AMI
30%-50%
AMI
50%-80%
AMI
80%-100%
AMI
Orange County as a whole 79.8% 78.9% 63.3% 42.6%
White 77.4% 72.4% 61.6% 43.8%
Black/African American 81.5% 85.9% 70.9% 37.5%
Asian 72.5% 78.5% 61.7% 44.1%
American Indian or Alaska Native 59.7% 60.7% 56.5% 54.2% Pacific Islander 78.1% 76.5% 71.7% 55.1%
Hispanic 89.5% 86.0% 65.4% 39.3%
Source: CHAS 2017-2021
Severe Housing Problems
Table 11 – Disproportionate Severe Housing Problems, shows 2017-2021 CHAS data on the percentage of households experiencing at least one of the following four severe housing problems, organized by race/ethnicity:
• Lacks complete kitchen facilities: Household does not have a stove/oven and refrigerator.
• Lacks complete plumbing facilities: Household does not have running water or modern toilets.
• Severe overcrowding: A household is considered severely overcrowded if there are more than 1.5 individuals per room.
• Severe cost burden: A household is considered severely cost burdened if the household spends more than 50% of its total income for housing costs. For renters, housing costs include rent paid by the tenant, plus utilities. For owners, housing costs include mortgage payment, taxes, insurance, and utilities.

According to Table 11, the following groups experience disproportionate need as defined above:
• Hispanic households have disproportionate severe housing needs within the 0%- 30% AMI range.
• American Indian or Alaska Native households, and Pacific Islander households have disproportionate severe housing needs within the 50%-80% AMI range. • American Indian or Alaska Native households have disproportionate severe housing needs within the 80%-100% AMI range.

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Table 11 - Disproportionate Severe Housing Problems, Orange County Percent of households experiencing at least one
severe housing burden, by income range
Race/Ethnicity Less than
30% AMI
30%-50%
AMI
50%-80%
AMI
80%-100%
AMI
Orange County as a whole 71.2% 55.5% 28.0% 14.8%
White 68.7% 52.5% 22.9% 10.5%
Black/African American 72.9% 55.5% 25.2% 4.3%
Asian 62.4% 52.5% 27.7% 15.5%
American Indian or Alaska Native 59.7% 17.0% 44.4% 30.6% Pacific Islander 58.1% 59.3% 40.7% 19.2%
Hispanic 82.2% 60.3% 34.6% 23.0%
Source: CHAS 2017-2021
The following analysis identifies which areas experience the greatest housing burdens and describes which of these areas align with segregated areas, integrated areas, or R/ECAPs, and the predominant race/ethnicity or national origin groups in such areas.

Map 12 – Housing Problems, is a series of maps illustrating concentrations of households experiencing housing burdens in Orange County. These maps were created by California HCD to facilitate fair housing planning, using data from the U.S. Census Bureau American Community Survey, 2018-2022 5-Year Estimates16F
17 . On these maps, areas with darker
shading have a higher percentage of households experiencing a particular housing problem (i.e., cost burden, overcrowding, incomplete plumbing, and incomplete kitchen facilities.

The maps show that the areas experiencing the greatest housing burdens are the following:
• Overcrowding is an issue that is generally only experienced by the residents of cities in the central and northern parts of the County. Overcrowding is not a significant concern in the coastal areas, the areas south and east of Irvine, or the northeastern region, including Yorba Linda and the unincorporated areas to the east Conversely, more than 20% of all units are overcrowded in the following areas:
o In Santa Ana, in most of the city, which are also areas of high POC segregation and are predominantly Hispanic.
o In Garden Grove, in the eastern and southeastern neighborhoods, which are areas of high POC segregation and are predominantly Hispanic in the east. 17 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing Orange County 132 25-29 Regional AFH
o In Anaheim, in the neighborhoods north and south of downtown, and around Disneyland. These are also areas of high POC segregation and are predominantly Hispanic.
o In Fullerton, in the neighborhoods south of downtown, which are predominantly Hispanic.
• Overpayment by renters is an issue everywhere in the County. In most neighborhoods in the County, over 40% of renter households are struggling with overpayment.
• Overpayment by owners is less of an issue than overpayment by renters but is also widespread throughout the County. In many neighborhoods, 20-40% of homeowner households struggle with overpayment. There are only a few areas where more than 60% or fewer than 20% of homeowner households struggle with overpayment. • Incomplete plumbing is not a significant concern in the County, as fewer than 2% of homes experience this issue. However, one exception is Fountain Valley, where 5- 10% of housing units are affected. This area includes the neighborhood surrounding Fountain Valley High School and north to Warner Avenue, which is an area of high POC segregation.
• Incomplete kitchen facilities are also not a significant concern in the County. In most of the County less than 10% of homes experience this issue. The areas where more than 10% of homes experience this issue are:
o In Anaheim, in the western neighborhoods, which are racially integrated and predominantly Hispanic, except for one Census Tract that is predominantly AAPI.
o In Orange, in the predominantly Hispanic area west of Glassel Street and north of Walnut Avenue.
o In La Habra, in one Census Tract in the north central part of the city. o In Irvine, near UC Irvine (which may reflect a concentration of student housing).

Orange County 133 25-29 Regional AFH
Map 12 – Housing Problems – Overcrowding
Source: California HCD, AFFH Data Viewer
Map 12 – Housing Problems – Overpayment by Renters
Source: California HCD, AFFH Data Viewer
Orange County 134 25-29 Regional AFH
Map 12 – Housing Problems – Overpayment by Owners
Source: California HCD, AFFH Data Viewer
Map 12 – Housing Problems – Lacking Complete Plumbing
Source: California HCD, AFFH Data Viewer
Orange County 135 25-29 Regional AFH
Map 12 – Housing Problems – Lacking Complete Kitchen
Source: California HCD, AFFH Data Viewer
The following analysis describes the differences in rates of renter and owner-occupied housing by race/ethnicity.

Table 12 – Housing Tenure by Race/Ethnicity, shows the percentages of households that are renters and homeowners by race/ethnicity, based on data from the 2018-2022 American Community Survey. The table shows that,
• Countywide, the homeownership rate is 56.5%, which is higher than the homeownership rate in the region.There are large disparities in homeownership by race/ethnicity. Black households have the lowest homeownership rate (32.4%). Less than 40% of Hispanic households own their home, and approximately 42% of Native households own their home. White and AAPI households have the highest homeownership rates.
• In the Orange County Urban County jurisdictions, homeownership rates are higher overall and for each group compared to the County. The same disparities in homeownership by race/ethnicity exist as in the County. • In Aliso Viejo, homeownership rates for AAPI, Black, and Hispanic households are higher than in the County overall, and homeownership rates for White households are lower.
• In Anaheim, homeownership rates are lower for all groups compared to the County, and similar racial/ethnic disparities exist.

Orange County 136 25-29 Regional AFH
• In Buena Park, homeownership rates and racial/ethnic disparities are similar to the County overall; however, the disparities are even larger due to a higher homeownership rate for White households compared to the County, and a lower rate for Black households compared to the County.
• In Costa Mesa, homeownership rates are lower for all groups compared to the County, and similar racial/ethnic disparities exist.
• In Fountain Valley, homeownership rates are higher compared to the County for all groups, except Black households. However, it is important to note that the small sample size for Black households may affect the accuracy of the data is not accurate. • In Fullerton, homeownership rates are lower for all groups than the County overall, except for AAPI households. Racial/ethnic disparities exist, with Native American households the least likely to own their home, and AAPI households most likely. • In Garden Grove, the Black and Hispanic homeownership rate is half the White homeownership rate. The AAPI homeownership rate in the city is lower than the AAPI homeownership countywide.
• In Huntington Beach, homeownership rates are lower for White, Black, and Hispanic households compared to the County overall, and higher for AAPI and Native American households. Similar racial/ethnic disparities exist in the city as in the County.
• In Irvine, homeownership rates are lower for all groups compared to the County overall, and racial/ethnic disparities are similar to the County, with Black and Hispanic households experiencing the lowest homeownership rates (15.7% and 18% respectively)
• In La Habra, homeownership rates are higher for all groups compared to the County, and similar racial/ethnic disparities exist as in the County. • In Laguna Niguel, homeownership rates are higher for all groups compared to the County, and racial/ethnic disparities exist—the Hispanic homeownership rate is the lowest, followed by the Black homeownership rate. The AAPI homeownership rate is the highest, followed by the White homeownership rate. • In Lake Forest, homeownership rates are higher for all groups compared to the County, except Native American households. Racial/Ethnic disparities exist, with AAPI and White homeownership higher than Black and Hispanic homeownership rates.
• In Mission Viejo, homeownership rates across all groups are much higher than in the County overall, though racial/ethnic disparities still exist. The Black homeownership rate is the lowest in the city, though it is above 60%. • In Newport Beach, homeownership rates are lower for all groups compared to the County overall, except for AAPI households, who have slightly higher homeownership rate in the city. The Black and Native American homeownership Orange County 137 25-29 Regional AFH
rates are very low in the city. However, due to the small sample sizes for these groups, the data may not be entirely accurate.
• In Orange, homeownership rates are comparable to the County overall, and similar disparities exist. However, the disparities are slightly larger in the city than in the County, as White, AAPI, and Hispanic homeownership rates are higher than in the County overall, while the Black homeownership rate is lower. • In Rancho Santa Margarita, homeownership rates are higher for all groups when compared to the County. However, there are still racial/ethnic disparities. Hispanic households have the lowest homeownership rate, and it is 20 percentage points lower than the AAPI homeownership rate, which is the highest rate in the city. • In San Clemente, homeownership rates are higher for White, AAPI, and Hispanic households compared to the County overall, while rates are lower for Black and Native American households. Due to the small sample size for Black and Native American households, the data may not be accurate. This causes the racial/ethnic disparities in homeownership rates to be larger than at the County level. • In Santa Ana, racial/ethnic disparities in homeownership rates are similar to the County overall, but less pronounced. This is because homeownership rates in the city are lower for White and AAPI households, and higher for Black, Hispanic, and Native American households compared to the County overall. • In Tustin, homeownership rates are very low for Black and Hispanic households, equaling less than half of the homeownership rate for AAPI and White households.

The AAPI homeownership rate is higher in the city than in the County overall, and the White homeownership rate is lower in the city than in the County overall. • In Westminster, there are large racial/ethnic disparities in homeownership. Black, Hispanic, and Native American households have the lowest rates (30%), and these rates are less than half the homeownership rate for White households, which is the highest in the city. The AAPI homeownership rate in the city is lower than in the County overall and is nearly 20 percentage points lower than the White homeownership rate in the city.

Orange County 138 25-29 Regional AFH
Table 12 - Homeownership and Rental Rates by Race/Ethnicity Orange County 139 25-29 Regional AFH
Table 12 - Homeownership and Rental Rates by Race/Ethnicity (continued) Orange County 140 25-29 Regional AFH
Table 12 - Homeownership and Rental Rates by Race/Ethnicity (continued) Orange County 141 25-29 Regional AFH
Charts 1 and 2, below, show denial rates for home purchase loans by race/ethnicity in Orange County and California between 2010-2021. In both Orange County and California, denial rates are highest for Black loan applicants, followed by Hispanic then Asian applicants. White applicants have the lowest denial rates. Denial rates are lower in Orange County for all groups compared to the state, except for Hispanic applicants who have the same denial rate in both geographies. Since the Great Recession, denial rates have fallen for all groups.

Chart 1: Home Purchase Loan Denial Rates by Race/Ethnicity, Orange County Source: Analysis of Home Mortgage Disclosure Act (HMDA) data by the Federal Reserve Banks of Philadelphia and Cleveland.

Orange County 142 25-29 Regional AFH
Chart 2: Home Purchase Loan Denial Rates by Race/Ethnicity, California Source: Analysis of Home Mortgage Disclosure Act (HMDA) data by the Federal Reserve Banks of Philadelphia and Cleveland.

This section describes the public or private policies or practices, demographic shifts, economic trends, or other factors that may have caused or contributed to the patterns described above.

Broadly speaking, disproportionate housing needs across and within jurisdictions in Orange County are influenced by several factors, including:
• The age of housing stock in some neighborhoods, and the high cost of home repairs/rehabilitation relative to incomes.
• Insufficient number of Housing Choice Vouchers or other types of publicly subsidized housing
• Land use and zoning laws that have led to the dominance of single-family housing, which is typically more expensive than multifamily housing.

Through stakeholder consultations and community meetings, it was also reported that disproportionate housing needs in the County are due to:
• Eviction notices have a particularly adverse impact on tenants, especially on families who are fleeing or those with a history of domestic violence. While the judicial system is making efforts to address these issues, barriers such as language and understanding legal terminology continue to pose challenges.

Orange County 143 25-29 Regional AFH
• Lack of adequate shelter for individuals experiencing homelessness, particularly for the most vulnerable groups such as trans women.
• Insufficient homebuyer education for minority homebuyers. • Lack of resources for organizations providing education and services to protected class groups.
• Language and digital literacy barriers that make it hard for LEP populations to locate and access housing resources.

Detailed lists of the public or private policies or practices, demographic shifts, economic trends, and other factors that have caused or contributed to disproportionate housing needs in each of the jurisdictions are included in Section IV.

F. Local and State Policies and Practices Impacting Fair Housing The following analysis describes how local laws, policies, ordinances, and other practices impede or promote fair housing (including how they impede or promote the siting or location of affordable housing in well-resourced neighborhoods, and equitable access to homeownership and other asset building and economic opportunities).

In general, land use and zoning laws across Orange County have led to the dominance of single-family housing, which is typically more expensive than multifamily housing and has contributed in various ways to reinforcing longstanding patterns of segregation, concentration of poverty, and disparities in access to opportunities. Through the Housing Element process mandated by the State of California, each jurisdiction has identified various public and/or private policies and practices that have contributed to the fair housing issues identified in this AFH, as well as efforts they are making to promote fair housing.

These items are detailed in Section IV.

This section describes any state or local fair housing laws and the characteristics protected under each law.

In the State of California, the Fair Employment and Housing Act (FEHA) and the Unruh Civil Rights Act prohibit discrimination in housing based on the following characteristics:
• Race
• Color
• National origin (including language use restrictions) • Religion
• Sex
• Familial status (including children under the age of 18 living with parents or legal custodians; pregnant women and people securing custody of children under 18) • Handicap (disability)
• Age
• Ancestry
Orange County 144 25-29 Regional AFH
• Citizenship
• Gender Identity and Gender Expression
• Genetic Information
• Immigration Status
• Marital Status
• Primary Language
• Sexual Orientation
• Source of Income
• Military or veteran status
This section describes efforts to increase fair housing compliance and enforcement capacity, and to ensure compliance with existing fair housing and civil rights laws and regulations.

Orange County jurisdictions rely on the state and local nonprofit fair housing providers to ensure fair housing compliance and enforcement, including the following organizations:

California Civil Rights Department
The California Civil Rights Department (CRD), formerly known as the Department of Fair Employment and Housing (DFEH), is responsible for enforcing state fair housing laws that make it illegal to discriminate against or harass someone because of a protected characteristic, that require reasonable accommodations for disabilities, and that prohibit retaliation against someone for exercising their rights. The CRD receives and investigates complaints and provides mediation and conflict resolution services throughout the state.

Fair Housing Council of Orange County
The Fair Housing Council of Orange County (FHCOC) is a nonprofit with a mission of ensuring access to housing and preserving human rights. FHCOC provides a variety of services in multiple languages, including community outreach and education, homebuyer education, mortgage default counseling, landlord-tenant mediation, and limited low-cost advocacy. In addition to these client services, FHCOC investigates claims of housing discrimination and assists with referrals to the state. FHCOC currently works in Anaheim, Santa Ana, Fountain Valley, Lake Forest, Laguna Niguel, Rancho Santa Margarita, the City of Orange, and Orange County.

Fair Housing Foundation
The Fair Housing Foundation (FHF) serves parts of Los Angeles County and several cities in Orange County, including Aliso Viejo, Buena Park, Costa Mesa, Fullerton, Garden Grove, Huntington Beach, Irvine, La Habra, Mission Viejo, Newport Beach, Orange, San Clemente, Tustin, and Westminster. FHF provides landlord-tenant counseling and mediation, rental housing counseling, and community outreach and education. In addition, the FHF screens Orange County 145 25-29 Regional AFH
fair housing complaints, investigates through testing, and either engages in conciliation or mediation efforts or refers the complaints to the appropriate administrative agencies.

This section describes the status of any unresolved findings, lawsuits, enforcement actions, settlements, or judgments in which the program participant has been a party related to fair housing or other civil rights laws in the jurisdiction.

There are no unresolved findings, lawsuits, enforcement actions, settlements, or judgments in which the program participants have been a party related to fair housing or other civil rights laws in the jurisdictions.

Orange County 146 25-29 Regional AFH
IV. Fair Housing Issues and Action Plan
For each participating jurisdiction, this section outlines (1) the issues identified in the preceding analysis; (2) the factors that create, contribute to, perpetuate, or increase the severity of each fair housing issue; and (3) the actions each jurisdiction has taken or will take to address those contributing factors in order to Affirmatively Further Fair Housing.

The actions listed below are included in the most recently approved and adopted Housing Element for each jurisdiction, and include actions taken to affirmatively further fair housing since the adoption of the Orange County Analysis of Impediments to Fair Housing Choice in 2020.

A. Orange County Urban County
Across the Urban County jurisdictions, the preceding analysis identified the following fair housing issues:
• Disparities in Access to Opportunities: Hispanic residents, and particularly those living below the FPL, have the least access to low poverty neighborhoods, neighborhoods in close proximity to high performing schools, and neighborhoods with high labor force participation and human capital.
• Disproportionate Housing Needs: Housing cost burden is an issue for renters across Orange County, including in the Urban County jurisdictions. Additionally, there are racial/ethnic disparities in homeownership. Specifically, Black, Latino, and Native American households have low homeownership rates compared to White and AAPI households. The Black homeownership rate, the lowest among all groups, is approximately half the White homeownership rate, which is the highest.

Within the jurisdictions that make up the Urban County, the following additional fair housing issues were identified:
• Unincorporated Orange County
o Segregation: There are areas of high White segregation in the unincorporated areas east of Rancho Santa Margarita, in North Tustin, in Orange Park Acres, and in Rossmoor.
• Brea
o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• Cypress
o Segregation: There are areas of high POC segregation (which are predominantly AAPI neighborhoods), and there is overlap between the location of publicly supported housing, including a high rate of voucher use, Orange County 147 25-29 Regional AFH
and areas of high POC segregation in the neighborhood near King Elementary School, in the north of the city.
o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• Dana Point
o Segregation: There are areas of high White segregation in the city. o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• La Palma
o Segregation: There are areas of high POC segregation in the city, which are predominantly AAPI neighborhoods.
• Laguna Beach
o Segregation: There are areas of high White segregation in the city. o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• Laguna Hills
o Segregation: There are areas of high White segregation in the city. o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• Laguna Woods
o Segregation: There are areas of high White segregation in the city. o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• Placentia
o Segregation and R/ECAPs:There are areas of high White segregation in the north of the city, and high POC segregation areas in the southwest corner of the city. The high POC segregation area also has several publicly supported housing units, including a high rate of voucher use. Additionally, in this part of the city, the neighborhoods south of Orangethorpe Avenue are a R/ECAP.

The R/ECAP Tract is predominantly Hispanic, as are the neighborhoods to the west and south in Fullerton and Anaheim.
o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing. Geographically, southwestern Placentia neighborhoods have low access to environmental health, high poverty, low Orange County 148 25-29 Regional AFH
economic scores, and are not located in a high-quality transit area. As noted above, this part of the city is a high POC segregation area that is predominantly Hispanic.
• San Juan Capistrano
o Segregation: There is a high POC segregation area that is predominantly Hispanic. There is overlap between the location of publicly supported housing, including a high rate of voucher use, and the areas of high POC segregation in the Census Tract that encompasses the interchange between I-5 and the Ortega Highway (SR-74).
o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing. Geographically, the neighborhoods around the I-5 and the Ortega Highway (SR-74) interchange experience poor environmental health and have low economic scores. This is a high POC segregation area and is predominantly Hispanic.
• Seal Beach
o Segregation: There are areas of high White segregation in the city. o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing.
• Stanton
o Segregation:There are areas of high POC segregation in the city, which are predominantly Hispanic or AAPI neighborhoods. There are overlaps between the location of publicly supported housing, including a high rate of voucher use, and areas of high POC segregation throughout the city. o Disparities in Access to Opportunity: Based on analysis of fair housing complaint data, individuals with disabilities disproportionately experience discrimination in housing. Additionally, all Stanton residents experience low access to environmentally healthy neighborhoods, and residents in the neighborhoods on the south side of Katella Avenue and on the eastside of Beach Boulevard north of Katella Avenue also experience high exposure to poverty.
• Villa Park
o Segregation: There are areas of high White segregation in the city. • Yorba Linda
o Segregation: There are areas of high POC segregation in the northern area of the city, which is predominantly AAPI, and areas of high White segregation elsewhere
The contributing factors to each of the fair housing issues listed above, along with each jurisdictions’ fair housing goals and actions, are outlined as follows:

Orange County 149 25-29 Regional AFH

1. Unincorporated Orange County
Issue: Segregation and R/ECAPs
Contributing Factors:

1. Lack of investment in certain neighborhoods, including lack of community revitalization strategies, lack of private investment, and lack of public investment, including in services and amenities.

2. Limited quantity of affordable housing due to community opposition, land use and zoning laws, and occupancy codes and restrictions.

3. Private discrimination, including source of income discrimination.

4. Limited knowledge of fair housing laws due to: limited resources to pay for outreach; increasingly fewer people rely on newspapers to receive information, and public notices or printed flyers are costly and ineffective means to reach the community at large; unknown language barriers and resource barriers to accessing information.

Actions: Timeframe:

Facilitate Affordable Housing Development through the following actions:

1. Create a Housing Opportunities Overlay Map and webpage providing information about the Housing Opportunities Overlay and identify areas where higher density projects would be permitted with expedited processing, and which may be eligible for density bonuses.

Within 18-months of
adoption/certification of
the Housing Element.

2. Develop informational materials on the County’s website regarding the County’s lot consolidation incentives and density bonus program.

Within 18-months of
adoption/certification of
the Housing Element.

3. Update the “Orange County Housing Opportunities Manual” and will also create and distribute promotional materials explaining the County’s expedited permit processing and incentives for affordable housing to be provided to developers in the region.

Within one year of
adoption and certification
of the Housing Element.

4. Publish and review the Affordable Housing Rental List. Annually

5. Review the County Housing Authority’s participation in the Housing Choice Voucher Section 8 Rental Assistance Program and pursue additional vouchers/funding when available.

Annually

6. Work with applicants who propose for-rent residential projects to encourage four-bedroom units for large families as part of the proposed developments.

As proposals are received
(ongoing)

7. Meet with Developers and DPRC to identify potential constraints to the development of affordable housing and housing for those with special needs in the County’s zoning regulations.

Within one year of
adoption. Address within
six months.

Coordination with Affordable Housing Stakeholders through the following actions:

8. Provide letters of support to affordable housing developers’ applications to local, State, and federal agencies for funding, Initiate by January 2025
Orange County 150 25-29 Regional AFH
provided the proposed projects are consistent with the goals and policies of the General Plan.

9. Work with cities and LAFCO to ensure that new planned communities in sphere of influence areas provide adequate sites at appropriate densities for affordable housing.

Annually

10. Conduct meetings with stakeholders, including the development community and property owners to facilitate housing
development.

Annually

11. Attend and promote development incentives at the monthly Housing Opportunities Committee meeting and the bi-monthly OC Housing Finance Trust meetings.

Twice annually

12. Meet with owners of the religious properties identified in the inventory of sites and provide information on regulatory changes, development standards and affordability requirements and incentives and/or assistance available through the County for development of housing on religious institution properties.

By January 2025

13. Meet with nonprofit developers and housing organizations to evaluate projects for acquisition and rehabilitation/new construction of new shelters, and long-term affordable housing, including senior housing.

Annually
Increase knowledge and enforcement of fair housing laws through the following actions:

14. Implement Restrictive Covenant Modification Plan (RCM) including Phase III, examination of remaining handwritten documents for unlawful languages and process.

By July 2027

15. Continue to work under contract with the FHCOC and/or other qualified fair housing service providers to provide fair housing services for all segments of the community. Evaluate and adjust the scope of services to ensure the County addresses any emerging trends in fair housing.

Annually

16. Provide federal/state/local information regarding discrimination to residents, including applicable Fair Housing Information and Discrimination Complaint Forms.

Annually

17. Maintain bilingual staff to assist non-English speaking families and ensure handicap accessible offices.

Annually

18. Work with the fair housing agencies to provide information regarding housing discrimination and intervention to resolve complaints.

Annually

19. Use non-traditional media (e.g., social media, County website) in outreach and education efforts in addition to print media and notices.

Annually
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20. Update the Affordable Housing Rental List (translated in multiple languages) on the County website.

Annually

21. Inform community members of the existence of the Orange County Fair Housing Council (FHCOC) and its oversight of fair housing practices by posting on the County’s website and at the Planning counter.

By December 2025

22. The County shall work with local resource agencies to implement an outreach program informing families within the County of housing and services available for individuals with
developmental disabilities.

Annually
Amend the zoning code and other local ordinances to facilitate new housing opportunities and increase housing mobility, including:

23. Allow emergency shelters without a Use Permit or other discretionary permit in the commercial and industrial portions of the Housing Opportunities Overlay Zone.

By October 2024

24. Remove the Site Development Permit requirement for
multifamily developments of one to four units and any
developments with 20% affordable units and allow by-right.

Amend the Site Development Permit requirements for objective findings for developments of units or more.

By October 2024

25. Adopt Objective Design Standards (ODS). By October 2024 Issue: Disparities in Access to Opportunities
Contributing Factors:

1. Unaffordable rents and sales prices in a range of sizes.

2. Displacement of residents due to economic pressures.

3. Lack of private and public investment in specific neighborhoods.

Actions: Timeframe:

Increase accessible and affordable housing opportunities for persons with disabilities through the following actions:

1. Review Definition of Single Housekeeping Unit. To promote flexibility to accommodate residents with different living conditions, the County will review and adopt revisions as appropriate to its zoning code to provide greater flexibility in consideration of accommodating a variety of household
situations for related and unrelated individuals living together.

By December 2026.

2. The County will review and revise its group home and zoning ordinances as needed to ensure ongoing compliance with state and federal fair housing laws. For example, the ordinance will be reviewed to ensure that a group home that operates as a single By December 31, 2025.

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housekeeping unit is permitted in any zoning district in the same manner as other residential uses in that zone (e.g., multifamily, single family). The definition of single housekeeping unit as to group homes will be revised to eliminate (1) the reference to residential activities that do not occur on a nonprofit basis and, (2) the requirement that the residents share lease agreements or ownership. In addition, the standards for group homes shall be objective and not unnecessarily constrain approval of group homes in that zoning district.

3. Seek State and Federal monies, as funding becomes available, for permanent supportive housing construction and
rehabilitation targeted for persons with disabilities, including persons with developmental disabilities.

Annually.

4. Develop a program /ordinance to provide regulatory incentives, such as expedited permit processing and fee waiver, to projects targeted for persons with disabilities, including persons with developmental disabilities.

Within 2 years of adoption
of the Housing Element.

5. On an ongoing basis, enforce building code provisions requiring accessible design.

Annually.

6. On an ongoing basis, implement reasonable accommodation ordinance.

Ongoing.

7. On an ongoing basis, ensure the permitting requirements for group homes and care facilities for seven or more persons are consistent with State law and fair housing requirements.

Ongoing.

Increase affordable housing opportunities in high opportunity areas through the following actions:

8. Sites Rezoning – Amend the HOO to accommodate a higher density of development, establish a minimum density for R2, R3, R4, RP, and MX zones, rezone C1, C2, CC, CH, CN, RP to MX, and expand the HOO.

Adopted by the Board of
Supervisors on June 25,
2024.

9. No Net Loss – Identify and make available additional adequate sites to accommodate the share of housing need by income level.

By end of 2024, if required.

10. Review incentives for density bonuses, expedited permit processing procedures, development standards, tax-exempt conduit financing, infrastructure financing assistance, and direct financial assistance.

Every two years.

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11. Review with DPRC members the existing and proposed codes, procedures, and fees to ensure that they do not unreasonably hinder housing production.