Analysis of Impediments to Fair Housing Choice 2025-2030 — Riverside City Council, May 20, 2025

City of Riverside

2025 Analysis of Impediments to Fair Housing Choice

Analysis of Impediments to Fair Housing Choice page iii City of Riverside March 2025
Contents

1. Introduction ................................................................................................................................... 1

1.1 Purpose of the Report ............................................................................................................ 1

1.2 Fair Housing Legal Framework ................................................................................................ 2

1.3 Lead Agency .......................................................................................................................... 6

2. Community Engagement in AI Process ............................................................................................. 7

2.1 Stakeholder Involvement ........................................................................................................ 7

2.2 Survey ................................................................................................................................... 7

3. Community Proﬁle .......................................................................................................................... 8

3.1 Regional Setting ..................................................................................................................... 8

3.2 Socioeconomic Setting .......................................................................................................... 8

4. Protected Class Proﬁles ................................................................................................................ 25

4.1 Race/Color .......................................................................................................................... 27

4.2 National Origin .................................................................................................................... 32

4.3 Gender ................................................................................................................................ 32

4.4 Familial Status ..................................................................................................................... 35

4.5 Persons with Disabilities ...................................................................................................... 39

4.6 Religion ............................................................................................................................... 42

4.7 Senior-Headed Households ................................................................................................. 43

4.8 Limited English Proﬁciency (LEP) .......................................................................................... 43

4.9 Source of Income ................................................................................................................ 45

4.10 Persons Experiencing Homelessness .................................................................................... 46

5. Public Sector Impediment Analysis................................................................................................ 49

5.1 Housing Development Policies and Programs ....................................................................... 49

5.2 AƯordable Housing Development Policies and Programs ....................................................... 67

5.3 Community Participation Process and Policies ...................................................................... 70

6. Private Sector Fair Housing Impediments Analysis ......................................................................... 73

6.1 Housing Discrimination ........................................................................................................ 73

6.2 Brokerage Services .............................................................................................................. 79

6.3 Steering ............................................................................................................................... 81

6.4 Appraisal Practices .............................................................................................................. 82

6.5 Unfair Lending Practices ...................................................................................................... 83

6.6 Homeowners Insurance ....................................................................................................... 90

6.7 Property Management .......................................................................................................... 92

6.8 Discriminatory Advertising ................................................................................................... 98

6.9 Hate Crimes ........................................................................................................................ 98

7. Private and Public Sector Fair Housing Impediments Analysis ........................................................ 101

7.1 Fair Housing Services.......................................................................................................... 101

7.2 Integration/Segregation ....................................................................................................... 107

7.3 Access to Opportunities ...................................................................................................... 121

7.4 Disproportionate Need........................................................................................................ 131

8. Fair Housing Progress Report........................................................................................................ 142

9. Fair Housing Action Plan .............................................................................................................. 150 Appendices
Appendix A: Public Outreach
Appendix B: Riverside Action Plan- AFFH Meaningful Actions Analysis of Impediments to Fair Housing Choice page iv
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Tables
Table 1: Population Growth (2010-2024) .................................................................................................. 9 Table 2: Age Characteristics – City of Riverside (2000-2022) .................................................................... 10 Table 3: Race and Ethnicity – City of Riverside (2000-2022) ..................................................................... 10 Table 4: English Language Ability – City of Riverside (2022) ..................................................................... 11 Table 5: Population and Household Characteristics – City of Riverside (2014, 2024) ................................. 11 Table 6: Household Characteristics and Trends – City of Riverside (2000-2022) ....................................... 12 Table 7: Income Categories for CDBG Program ...................................................................................... 13 Table 8: Median Household Income (2010-2022) .................................................................................... 13 Table 9: Household Income by Tenure – City of Riverside (2023) .............................................................. 14 Table 10: HUD FY 2024 Income Limits – County of Riverside ................................................................... 14 Table 11: Housing Assistance Needs by Income and Household Type (2020) ........................................... 15 Table 12: Poverty Characteristics – City of Riverside (2018-2022) ............................................................ 17 Table 13: Poverty Indicators – County of Riverside (2023) ........................................................................ 17 Table 14: Housing Stock by Type of Unit – City of Riverside (January 1, 2024) ............................................ 18 Table 15: Housing Stock Increase by Type of Unit – City of Riverside (January 1, 2014 to January 1, 2024) .. 18 Table 16: Comparison of Homeownership Rates by Year ........................................................................ 19 Table 17: Owner/Renter Occupancy of Single Family Homes – City of Riverside (2022) ............................. 19 Table 18: Labor Force and Employment Characteristics – City of Riverside (2018-2022) ........................... 21 Table 19: Employment by Industry – City of Riverside (2022) ................................................................... 21 Table 20: Employers with 1,000 or More Employees – City of Riverside (2024) .......................................... 22 Table 21: Resident Commute to Work Destinations (2020) ...................................................................... 22 Table 22: Commuting Characteristics – City of Riverside (2022) .............................................................. 23 Table 23: Educational Attainment for the Population 25 Years and Over – City of Riverside (2022) ............. 23 Table 24: Median Earnings by Educational Attainment – City of Riverside (2022) ...................................... 24 Table 25: School Enrollment by Race/Ethnicity and School District (2024) ............................................... 24 Table 26: Graduation Rate by District and Race/Ethnicity (2023) ............................................................. 24 Table 27: Race and Ethnicity (2017-2022) .............................................................................................. 27 Table 28: Poverty Status by Race and Ethnicity (2022) ............................................................................. 31 Table 29: Tenure by Race and Ethnicity (2022) ......................................................................................... 31 Table 30: Foreign Born Population by Region of Birth ............................................................................... 32 Table 31: Household Type by T enure ...................................................................................................... 33 Table 32: Poverty Status for Single-Family Households by Tenure (2022) .................................................. 33 Table 33: Poverty Status by Household Type and for Households with Children ........................................ 35 Table 34: Tenure by Presence of Children (2022) ..................................................................................... 38 Table 35: Characteristics of Population with a Disability (2022) ............................................................... 39 Table 36: Senior Headed Households by Tenure ..................................................................................... 43 Table 37: Limited English Speaking Households (2022) ........................................................................... 44 Table 38: Demographic Proﬁle of Housing Choice Voucher Recipients .................................................... 45 Table 39: Riverside Homeless Characteristics (2023) ............................................................................. 47 Table 40: Residential Land Use Designations Allowing Housing .............................................................. 51 Table 41: Residential Land Use Acreage Distribution .............................................................................. 52 Table 42: Parking Requirements ............................................................................................................ 54 Table 43: Allowable Residential Uses in Residential Zones ...................................................................... 55 Table 44: Allowable Residential Uses in Nonresidential Zones ................................................................ 56 Table 45: Typical Housing Development Fees ......................................................................................... 65 Table 46: Distribution of RHNA Sites ...................................................................................................... 69 Table 47: Housing Discrimination Complaints by Protected Class, FY 2019/2020 to FY 2023/2024 ........... 74 Table 48: Housing Discrimination Complaints by Race/Ethnicity, FY 2019/2020 to FY 2023/2024.............. 75 Table 49: Housing Discrimination Complaints by Protected Class, FY 2019/2020 to FY 2023/2024 ........... 75 Table 50: Basis for Discrimination Complaints Filed with CRD, FY 2020/2021 to FY 2023/2024 ................. 76 Analysis of Impediments to Fair Housing Choice page v
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Table 51: Acts of Discrimination for Complaints Filed with CRD, FY 2020/2021 to FY 2023/2024 ............... 76 Table 52: Close Reason for Complaints Filed with CRD, FY 2020/2021 to FY 2023/2024 ........................... 77 Table 53: Basis for Discrimination of Cases ﬁled with HUD (2019-2024) .................................................. 78 Table 54: Disposition of Home Loans ..................................................................................................... 84 Table 55: Demographics of Loan Applicants vs. T otal Population (2017) .................................................. 86 Table 56: Lending Patterns by Race/Ethnicity (2021) ............................................................................... 87 Table 57: Outcomes Based on Census Tract Income (2021) .................................................................... 88 Table 58: Outcomes Based on Minority Population of Census Tract (2017 and 2021) ................................ 88 Table 59: Housing Discrimination Complaints by Transaction Type in 2022 .............................................. 96 Table 60: Tenant/Landlord Complaints, FY 2019/2020 to FY 2023/2024 ................................................... 97 Table 61: Hate Crimes (2018-2022) ........................................................................................................ 99 Table 62: Dissimilarity Indices (1990 to 2022) ........................................................................................ 112 Table 63: Assisted Housing Units by Community ................................................................................... 117 Table 64: Licensed Community Residential Care Facilities by Type ........................................................ 120 Table 65: Domains and List of Indicators for Opportunity Maps .............................................................. 122 Table 66: Housing Problem by Tenure and Race..................................................................................... 132 Table 67: Housing Problems – Special Needs Populations ..................................................................... 132 Table 68: Cost Burdens by Race ........................................................................................................... 133 Table 69: Cost Burdens – Special Needs Populations ............................................................................ 133 Table 70: Overcrowding in Riverside ..................................................................................................... 135 Table 71: Progress in Implementing Actions to Remove/Mitigate Fair Housing Impediments .................... 143 Table 72: Progress in Implementing Actions to AƯirmatively Further Fair Housing ................................... 146 Table 73: Fair Housing Actions (2025-2030) .......................................................................................... 150

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Figures
Figure 1: Riverside Ward and Neighborhoods ......................................................................................... 26 Figure 2: Predominant Races – City of Riverside ..................................................................................... 28 Figure 3: Percentage Distribution of the Total Population by Race: White ................................................. 29 Figure 4: Percentage Distribution of the Total Population by Race: Hispanic ............................................. 29 Figure 5: Percentage Distribution of the Total Population by Race: Asian .................................................. 30 Figure 6: Percentage Distribution of the Total Population by Race: Black .................................................. 30 Figure 7: Percent of Children in Married Couple Households .................................................................. 36 Figure 8: Percent of Children in Single Female-Headed Households ........................................................ 37 Figure 9: Percent Population with a Disability ......................................................................................... 40 Figure 10: Households Speaking English Less than “Very Well” ............................................................... 44 Figure 11: Housing Choice Voucher Use Distribution .............................................................................. 46 Figure 12: Assisted Housing Inventory and City Facilities ........................................................................ 68 Figure 13: Distribution of Sixth Cycle Sites Inventory by Resource Category ............................................. 69 Figure 14: Riverside Zoning Designation Map ........................................................................................ 108 Figure 15: Renter Occupied Housing Units ............................................................................................ 109 Figure 16: Areas of Minority Concentration ........................................................................................... 110 Figure 17: Predominant Races.............................................................................................................. 111 Figure 18: Integration/Segregation ........................................................................................................ 112 Figure 19: Low to Moderate Income Population ..................................................................................... 113 Figure 20: Poverty Status ...................................................................................................................... 114 Figure 21: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) and High Segregation and Poverty Areas ...................................................................................................................... 115 Figure 22: Racially Concentrated Areas of AƯluence (RCAAs) ................................................................ 116 Figure 23: Riverside AƯordable Housing Inventory ................................................................................. 117 Figure 24: Housing Choice Voucher Concentration ............................................................................... 119 Figure 25: Median Gross Rents ............................................................................................................. 119 Figure 26: Licensed Care Facilities ....................................................................................................... 120 Figure 27: TCAC Resource Level Composite Scores............................................................................... 122 Figure 28: AƯordable and Assisted Housing by TCAC Resource Level ..................................................... 123 Figure 29: TCAC Education Opportunity Scores ..................................................................................... 124 Figure 30: Jobs Proximity Index ............................................................................................................. 126 Figure 31: TCAC Economic Domain Scores ........................................................................................... 127 Figure 32: TCAC Environmental Score ................................................................................................... 129 Figure 33: AllTransit Scores .................................................................................................................. 130 Figure 34: High Quality Transit Stops and Automobile Access ................................................................ 131 Figure 35: Cost Burden by Renters ........................................................................................................ 134 Figure 36: Cost Burden by Home Owners .............................................................................................. 134 Figure 37: Overcrowding ...................................................................................................................... 135 Figure 38: Units Over 30 Years Old ........................................................................................................ 136 Figure 39: Units Lacking Complete Plumbing ........................................................................................ 137 Figure 40: Units Lacking a Complete Kitchen ........................................................................................ 137 Figure 41: Displacement Risk ............................................................................................................... 139 Figure 42: SB 535 Disadvantaged Communities .................................................................................... 140

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1. Introduction

1.1 Purpose of the Report
The City of Riverside annually receives funds from the Federal Community Development Block Grant (CDBG) program and HOME Investments Partnerships Program (HOME). An AƯirmatively Furthering Fair Housing (AFFH) certiﬁcation is required of cities and counties that receive funds from these programs. The AFFH certiﬁcation states that the grantee receiving HUD funds: “…will aƯirmatively further fair housing … by conducting an analysis to identify impediments to fair housing choice within its jurisdiction, taking appropriate actions to overcome the eƯects of any impediments identiﬁed through the analysis, and maintaining records reﬂecting the analysis and actions in this regard. ” HUD interprets the broad objectives of the requirement to aƯirmatively further fair housing choice to mean that recipients must:
 Analyze and eliminate housing discrimination in the jurisdiction;  Promote fair housing choice for all persons;
 Provide opportunities for inclusive patterns of housing occupancy regardless of race, color, religion, sex, familial status, disability, and national origin;  Promote housing that is structurally accessible to, and usable by, persons with disabilities; and
 Foster compliance with the nondiscrimination provisions of the Federal Fair Housing Act.

Therefore, the fundamental purpose of the Analysis of Impediments to Fair Housing Choice (AI) is to maintain the City of Riverside’s compliance with the AFFH certiﬁcation. In so doing, the City will promote fair housing and remove or mitigate the public and private sector impediments that have been identiﬁed through the analysis.

The time period of the AI is FY 2025-2026 through FY 2029-2030. The AI time period is intended to remain aligned with the City’s 5-year Consolidated Plan.

1. Overview of HUD’s Analysis of Impediments and AB 686 Requirements Assembly Bill 686 (AB 686), signed in 2018, establishes an independent state mandate that expands the duty of all California’s public agencies to aƯirmatively further fair housing (AFFH).

AB 686 added to existing protections in California. With the passage of AB 686, state and local public agencies are required to aƯirmatively further fair housing through deliberate action to explicitly address, combat, and relieve disparities resulting from past and current patterns of segregation to foster more inclusive communities. Importantly, AB 686 also creates new housing element requirements applying to all housing elements due to be revised on or after January 1, 2021. These requirements include an assessment of fair housing practices, an analysis of the relationship between available sites and areas of high or low resources, and concrete actions in the form of programs to aƯirmatively further fair housing. Per AB 686, the City’s 2021-2029 Housing Element contains programs to remediate fair housing issues found Analysis of Impediments to Fair Housing Choice page 2
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in the analysis and further promote fair housing. The ﬁndings of the Housing Element’s Assessment of Fair Housing are also incorporated into this AI.

1.2 Fair Housing Legal Framework
Fair housing is a right protected by Federal and State of California laws. Among these laws, virtually every housing unit in California is subject to fair housing practices.

1. Federal Laws
The Fair Housing Act of 1968 and the Fair Housing Amendments Act of 1988 (42 U.S. Code §§3601-3619, §3631) are federal fair housing laws that prohibit discrimination in all aspects of housing, including the sale, rental, lease, or negotiation for real property. The Fair Housing Act prohibits discrimination based on the following protected classes:
 Race or color
 Religion
 Sex
 Familial status
 National origin
 Disability (mental or physical)
Speciﬁcally, it is unlawful to:
 Refuse to sell or rent after the making of a bona ﬁde oƯer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, disability, familial status, or national origin.  Discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, disability, familial status, or national origin.  Make, print, or publish, or cause to be made, printed, or published any notice, statement, or advertisement, with respect to the sale or rental of a dwelling that indicates any preference, limitation, or discrimination based on race, color, religion, sex, disability, familial status, or national origin, or an intention to make any such preference, limitation, or discrimination.
 Represent to any person because of race, color, religion, sex, disability, familial status, or national origin that any dwelling is not available for inspection, sale, or rental when such dwelling is in fact so available.
 For proﬁt, induce or attempt to induce any person to sell or rent any dwelling by representations regarding the entry or prospective entry into the neighborhood of a person or persons of a particular race, color, religion, sex, disability, familial status, or national origin.

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Reasonable Accommodations and Accessibility
The Fair Housing Amendments Act requires owners of housing facilities to make “reasonable accommodations” (exceptions) in their rules, policies, and operations to give people with disabilities equal housing opportunities. For example, a landlord with a “no pets” policy may be required to grant an exception to this rule and allow an individual who is blind to keep a guide dog in the residence. The Fair Housing Act also requires landlords to allow tenants with disabilities to make reasonable access-related modiﬁcations to their private living space, as well as to common use spaces, at the tenant’s own expense. Finally, the Act requires that new multi-family housing with four or more units be designed and built to allow access for persons with disabilities. This includes accessible common use areas, doors that are wide enough for wheelchairs, kitchens and bathrooms that allow a person using a wheelchair to maneuver, and other adaptable features within the units.

HUD Final Rule on Equal Access to Housing in HUD Programs On March 5, 2012, the U.S. Department of Housing and Urban Development (HUD) published the Final Rule on “Equal Access to Housing in HUD Programs Regardless of Sexual Orientation or Gender Identity. ” It applies to all McKinney-Vento-funded homeless programs, as well as to permanent housing assisted or insured by HUD. The rule creates a new regulatory provision that generally prohibits considering a person’s marital status, sexual orientation, or gender identity (a person’s internal sense of being male or female) in making homeless housing assistance available.

2. California Laws
The California Civil Rights Department (CRD), formerly known as the Department of Fair Employment and Housing (DFEH), enforces California laws that provide protection and monetary relief to victims of unlawful housing practices. The Fair Employment and Housing Act (FEHA) (Government Code §12955 et seq.) prohibits discrimination and harassment in housing practices, including:
 Advertising
 Application and selection process
 Unlawful evictions
 Terms and conditions of tenancy
 Privileges of occupancy
 Mortgage loans and insurance
 Public and private land use practices (zoning)
 Unlawful restrictive covenants
The following categories are protected by FEHA:
 Race or color
 Ancestry or national origin
 Sex
 Marital status
 Source of income
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 Sexual orientation
 Gender identity/expression
 Genetic information
 Familial status (households with children under 18 years of age)  Religion
 Mental/physical disability
 Medical condition
 Age
In addition, the FEHA contains similar reasonable accommodations and accessibility provisions as the federal Fair Housing Amendments Act.

The Unruh Civil Rights Act provides protection from discrimination by all business establishments in California, including housing and accommodations, because of age, ancestry, color, disability, national origin, race, religion, sex, and sexual orientation. While the Unruh Civil Rights Act speciﬁcally lists “sex, race, color, religion, ancestry, national origin, disability, and medical condition” as protected classes, the California Supreme Court has held that protections under the Unruh Act are not necessarily restricted to these characteristics.

Furthermore, the Ralph Civil Rights Act (California Civil Code §51.7) forbids acts of violence or threats of violence because of a person’s race, color, religion, ancestry, national origin, age, disability, sex, sexual orientation, political aƯiliation, or position in a labor dispute. Hate violence can be verbal or written threats; physical assault or attempted assault; and graƯiti, vandalism, or property damage.

The Bane Civil Rights Act (California Civil Code §52.1) provides another layer of protection for fair housing choice by protecting all people in California from interference by force or threat of force with an individual’s constitutional or statutory rights, including a right to equal access to housing. The Bane Act also includes criminal penalties for hate crimes; however, convictions under the Act are not allowed for speech alone unless that speech itself threatened violence.

And, ﬁnally, California Civil Code §1940.3 prohibits landlords from questioning potential residents about their immigration or citizenship status. Landlords in most states are free to inquire about a potential tenant’s immigration status and to reject applicants who are in the United States illegally. In addition, this law forbids local jurisdictions from passing laws that direct landlords to make inquiries about a person’s citizenship or immigration status.

In addition to these acts, Government Code §11135, §65008, and §§65580-65589.8 prohibit discrimination in programs funded by the State and in any land use decisions. Speciﬁcally, recent changes to §§65580-65589.8 require local jurisdictions to address the provision of housing options for special needs groups, including permanent supportive housing for the disabled and housing for the homeless.

In 2019, the State passed SB 329 and SB 222, expanding the source of income protection.

Under SB 329 and SB 222, all landlords in California will be required to accept Section 8 and VASH vouchers and other forms of rental assistance and to consider them as part of an Analysis of Impediments to Fair Housing Choice page 5
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applicant’s income. Both went into eƯect on January 1, 2020. In addition, AB 1482 was passed in 2019 to establish a cap on annual rent increase at 5 percent plus inﬂation and to enumerate the just causes to evict a tenant.

3. Fair Housing Deﬁned
In light of the various pieces of fair housing legislation passed at the Federal and State levels, fair housing throughout this report is deﬁned as follows:

A condition in which individuals of similar income levels in the same housing market have a like range of choice available to them regardless of their characteristics as protected under State and Federal laws.

Housing Issues, AƯordability, and Fair Housing
HUD’s OƯice of Fair Housing and Equal Opportunity (FHEO) draws a distinction between housing aƯordability and fair housing. Economic factors that aƯect a household’s housing choices are not fair housing issues per se. Only when the relationship between household income, household type, race/ethnicity, and other factors create misconceptions, biases, and diƯerential treatments would fair housing concerns arise.

Tenant/landlord disputes are also typically not related to fair housing. Most disputes between tenants and landlords result from a lack of understanding by either or both parties on their rights and responsibilities. Tenant/landlord disputes and housing discrimination cross paths when the disputes are based on factors protected by fair housing laws and result in diƯerential treatment.

4. Fair Housing Impediments
Within the legal framework of Federal and State laws, and based on the guidance provided by HUD’s Fair Housing Planning Guide, impediments to fair housing choice can be deﬁned as:
 Any actions, omissions, or decisions taken because of the characteristics protected under State and Federal laws, which restrict housing choices or the availability of housing choices; or
 Any actions, omissions or decisions which have the eƯect of restricting housing choices or the availability of housing choices on the basis of characteristics protected under State and Federal laws.

To aƯirmatively promote equal housing opportunity, a community must work to remove impediments to fair housing choice. Furthermore, eligibility for certain federal funds requires compliance with federal fair housing laws. Speciﬁcally, to receive HUD Community Planning and Development (CPD) formula grants, a jurisdiction must:
 Certify its commitment to actively further fair housing choice;  Maintain fair housing records; and
 Conduct an analysis of impediments to fair housing.

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1.3 Lead Agency
The lead agency for preparation of the AI and Fair Housing Action Plan is the Community and Economic Development Department/CDBG & Grants Division.

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2. Community Engagement in AI Process
The City conducted a number of outreach activities to solicit input on fair housing issues from the community. Appendix A provides documentation of these outreach activities.

2.1 Stakeholder Involvement
The City conducted two virtual stakeholder meetings to receive input on fair housing issues:
 Monday, October 7, 2024
 Wednesday, October 9, 2024
About 30 agencies that serve the housing and supportive needs of Riverside residents were invited to attend the meetings. The following agencies attended the meetings:
 Family Promise
 Housing Authority of the City of Riverside
 Housing Authority of the County of Riverside
 Fair Housing Council of Riverside County
The key challenges in Riverside are available and aƯordable housing options for lower income households. Black and Hispanic persons are disproportionately impacted by homelessness.

Regarding housing discrimination, the trends of discriminating based on race/color and disability continue. Reaching owners of small rental properties continues to be an issue.

These owners are less likely to be aware of fair housing laws.

2.2 Survey
In conjunction with the Consolidated Plan development, the City conducted a fair housing survey, which was available online. However, only 15 responses were received. About half of the respondents were minority (Hispanic and Black). Of the 15 responses, two reported having experienced housing discrimination, claiming the following bases of discrimination:
disability/medical conditions; family status; and source of income. In addition, a few respondents, while not speciﬁcally indicating they had experienced housing discrimination, did comment on having been denied reasonable accommodation. For those respondents who indicated fair housing issues, most did not report the incidents due to fear of retaliation or they did not believe it would make any diƯerence.

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3. Community Proﬁle

3.1 Regional Setting
HUD’s 1996 Fair Housing Planning Guide advises grantees to include in the AI “jurisdictional background data”: demographics, income, employment, housing proﬁle and other relevant data.

Not only does Riverside possess a rich variety of neighborhoods and a large and diverse housing stock, but the City also is a regional hub for higher education, technology, commerce, law, ﬁnance, and culture. Riverside beneﬁts from excellent freeway and rail access, high- speed ﬁber-optic telecommunications, reasonable land and building costs, City-owned electrical and water systems, and a large general aviation airport.

Riverside is home to the Fair Housing Council of Riverside County, Inc. and the Civil Rights Institute of Inland Southern California, as well as aƯordable housing developers such as Habitat for Humanity and the Riverside Housing Development Corporation, and community resource providers such as the Community Access Center.

Founded in the early 1870s, Riverside is now the most populous city in the Inland Empire and the 12th most populous city in California. It is located approximately 60 miles from the City of Los Angeles. Although the community’s residents take pride in their City as a whole, 28 distinct neighborhoods are the fundamental building blocks of the community. With only a few exceptions, all of Riverside's neighborhoods include areas for living, working, education, and cultural activities, and personal attachments to neighborhoods are very evident.

3.2 Socioeconomic Setting

1. Demographic Proﬁle
Population Growth
Riverside is the largest city and the cultural, civic and economic heart of the Inland Southern California region, located approximately 60 miles east of Los Angeles. With a population of 316,690, Riverside is the 59th largest city in the United States, the 12th largest in California, and the 6th largest in Southern California.

Between 2010 and 2020, the County of Riverside saw a signiﬁcant population increase of 10 percent. The City of Riverside and most neighboring cities saw more gradual population growth ranging from 2 percent to 5 percent. Between 2020 and 2024, the County saw a slower growth rate of only 1 percent. The cities of Riverside, Jurupa Valley, and Moreno Valley experienced slight decreases in population (0.3 percent, 0.1 percent, and 0.4 percent, respectively), while Norco had a signiﬁcant decrease in population of 5.9 percent. This

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declining trend was seen statewide as California’s population dropped for the ﬁrst time in 2023 since gaining statehood in 1850.1
Table 1: Population Growth (2010-2024)
Jurisdiction 2010 2020 2024
Growth Rate
2010-2020 2020-2024
Riverside 303,871 317,624 316,690 4.5% -0.3%
Corona 152,374 156,670 156,615 2.8% 0.0%
Jurupa Valley – 104,801 104,721 – -0.1%
Moreno Valley 193,365 208,069 207,146 7.6% -0.4%
Norco 27,063 26,628 25,068 -1.6% -5.9%
Perris 68,386 78,550 79,311 14.9% 1.0%
Riverside County 2,189,641 2,418,185 2,442,378 10.4% 1.0% Note: Jurupa Valley was incorporated in 2011.

Sources: Bureau of the Census, 2010-Census; State Department of Finance Population and Housing Estimates, 2020, 2024.

Age Characteristics
Housing demand is aƯected by the age characteristics of a community, among other factors.

Traditionally, young adults prefer apartments, condominiums, and smaller single-family homes that are aƯordable. Middle-aged adults typically prefer larger homes as they begin to raise families. However, as children leave home, seniors often prefer smaller, moderate-cost condominiums and single-family homes with less extensive maintenance needs. In recent years, the escalating housing prices in Southern California have meant that many young families ﬁnd it increasingly diƯicult to ﬁnd adequately sized homes at aƯordable prices.

Age and fair housing intersect when managers or property owners make housing decisions based on the age of residents. For example, managers and property owners may prefer to rent to mature residents, limit the number of children in their complex, or discourage older residents due to their disabilities. While a housing provider may establish reasonable occupancy limits and set reasonable rules about the behavior of tenants, those rules cannot single out children for restrictions that do not apply also to adults.

Table 2 shows age characteristics for the City of Riverside from 2000 to 2022. The American Community Survey (ACS) data indicates that the City’s population is aging, consistent with trends throughout the State and the nation. The 2022 ACS estimates show that 21 percent of the City population is 55 or older and 38 percent is 24 or younger. In comparison, 15 percent of the population was 55 or older and 43 percent was 24 or younger reported by the 2000 U.S.

Census.

1 Johnson, H., McGhee, E., Subramaniam, C., and Hsieh, V. (October 2023). What’s Behind California’s Recent Population Decline—and Why It Matters. Public Policy Institute of California. Accessed April 4, 2024. https://www.ppic.org/publication/whats-behind-californias-recent-population-decline-and-why-it-matters/.

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Table 2: Age Characteristics – City of Riverside (2000-2022) Age Group
(Years)
2000 2010 2022
Number
Percent of
Total Number
Percent of
Total Number
Percent of
Total
<5 19,709 7.7% 23,702 7.9% 18,454 5.8%
5-14 44,856 17.6% 44,800 14.9% 42,693 13.5%
15-24 44,339 17.4% 58,332 19.4% 58,632 18.5%
25-34 37,071 14.5% 44,476 14.8% 49,516 15.7%
35-44 40,410 15.8% 41,366 13.8% 42,814 13.5%
45-54 29,793 11.7% 39,340 13.1% 36,855 11.7%
55-64 16,355 6.4% 23,531 7.8% 31,508 10.0%
65+ 22,560 8.8% 25,006 8.3% 35,604 11.3%
Total 255,093 100.0% 300,553 100.0% 316,076 100.0%
Sources: Bureau of the Census, 2000 Census; 2006-2010 and 2018-2022 American Community Survey (ACS).

Race and Ethnic Characteristics
Since 2000, the Hispanic/Latino population in Riverside has seen continuous growth, representing 55 percent of the City population in 2022 from only 38 percent in 2000 (see Table 3). During this period, the White population saw an inverse trend, representing 46 percent of the population in 2000 and 27 percent in 2022. Currently, the Asian population represents the third largest racial/ethnic group in the City (8 percent), followed by the Black/African American population (5 percent).

Patterns of racial/ethnic segregation, including trends related to access to opportunities and disproportionate housing needs, are further discussed in Chapter 7, Private and Public Sector Fair Housing Impediments Analysis, of this Analysis of Impediments to Fair Housing Choice.

Table 3: Race and Ethnicity – City of Riverside (2000-2022) Race/Ethnicity
2000 2010 2022
Number
Percent of
Total Number
Percent of
Total Number
Percent of
Total
Hispanic/Latino 97,315 38.1% 148,953 49.0% 174,987 55.4% White 116,254 45.6% 103,398 34.0% 86,337 27.3%
Black/African American 18,051 7.1% 19,917 6.6% 17,060 5.4% American Indian/Alaska
Native
1,415 0.6% 1,297 0.4% 767 0.2%
Asian 14,233 5.6% 21,934 7.2% 25,932 8.2%
Native Hawaiian/Other
Paciﬁc Islander
848 0.3% 1,019 0.3% 973 0.3%
Other 492 0.2% 617 0.2% 552 0.2%
Two or more races 6,558 2.6% 6,736 2.2% 9,468 3.0%
Total 255,166 100.0% 303,871 100.0% 316,076 100.0%
Sources: Bureau of the Census, 2000-2010 Census; 2018-2022 American Community Survey (ACS).

Reﬂective of the demographics in the City, 46 percent of Riverside residents speak languages other than English at home, according to 2018-2022 ACS estimates. Spanish is the most prevalent non-English language, with around 37 percent of the population over 5 years old speaking Spanish at home. As presented in Table 4, 33 percent of Spanish speakers speak English less than “very well. ” Asian and Paciﬁc Islander language speakers have the largest

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City of Riverside March 2025
proportion of persons who speak English less than “very well” of 42 percent. According to the 2018-2022 ACS estimates, the top ﬁve languages spoken by people that are linguistically isolated (speak English less than “very well”) are Spanish (36,222 persons), other Indo- European languages (2,074 persons), Chinese (2,004 persons), Vietnamese (1,929 persons), and Tagalog (1,113 persons).

Table 4: English Language Ability – City of Riverside (2022) Language Ability
Asian and
Paciﬁc Islander Spanish
Other
Indo-European Other
#
% of
Total #
% of
Total #
% of
Total #
% of
Total
Speak English "very well" 9,284 58.1% 74,720 67.4% 5,176 68.0% 2,261 65.1% Speak English less than
"very well" 6,705 41.9% 36,222 32.6% 2,433 32.0% 1,214 34.9% Total 15,989 100.0% 110,942 100.0% 7,609 100.0% 3,475 100.0% Source: American Community Survey 2018-2022.

2. Household Proﬁle
Information on household characteristics aids in understanding changing housing needs. The U.S. Census deﬁnes a household as all persons who occupy a housing unit, which may include single persons living alone, families related through marriage or blood, and unrelated individuals living together.

Household Characteristics
Table 5 provides data on population and household characteristics in 2014 and 2024. During the 10-year time span, the population grew by 4,954 persons and the number of households (occupied housing units) increased by 4,376, according to California Department of Finance (DOF) estimates.

Between 2014 and 2024, the average household size decreased by 0.14 person from 3.20 to

3.06 persons per household. The group quarters population increased by 4,138 persons between 2014 and 2024.

Table 5: Population and Household Characteristics – City of Riverside (2014, 2024) Population January 1, 2014 January 1, 2024 Increase
Group Quarters Population 12,967 17,105 4,138
Household Population 298,769 299,585 816
Total Population 311,736 316,690 4,954
Total Housing Units 98,790 101,922 3,132
Occupied Housing Units 93,495 97,871 4,376
Vacant Housing Units 5,295 4,051 -1,244
Vacancy Rate 5.4% 4.0% -1.40%
Persons per Household 3.20 3.06 -0.14
Source: January 1, 2014 Department of Finance, E-8 Population and Housing Estimates for Cities, Counties, and the State; January 1, 2024 Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State 2020-2024.

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City of Riverside March 2025
Household Composition and Size
DiƯerent household types generally have diƯerent housing needs. Seniors or young adults typically comprise a majority of single-person households and tend to reside in apartment units, condominiums, or smaller single-family homes. Families, meanwhile, often prefer single-family homes. Household size can be an indicator of changes in population or use of housing. An increase in household size can indicate a greater number of large families or a trend toward overcrowded housing units. A decrease in household size, on the other hand, may reﬂect a greater number of elderly or single-person households or a decrease in family size. Household composition and size are often two interrelated factors. Communities that have a large proportion of families with children tend to have a larger average household size.

Such communities have a greater need for larger units with adequate open space and recreational opportunities for children.

Since 2000, Riverside has been a family-oriented community, where more than 70 percent of households identiﬁed themselves as families. The share of families in the City has increased from 71 percent in 2000 to 74 percent in 2022. However, the share of families with children fell during the same period, from 41 percent to 33 percent.

Over the past 20 years, the average household size increased slightly, from 3.01 to 3.32, as did the average family size, from 3.54 to 3.80. Consistent with the increase in household and family size, the population of single-person households has decreased from 21 percent in 2000 to 19 percent in 2022. Average household and family size in the City are slightly larger than for Riverside County as a whole, which had an average household size of 3.19 and an average family size of 3.70 in 2022.

Table 6: Household Characteristics and Trends – City of Riverside (2000-2022) Household Type
2000 2010 2022
Number Percent Number Percent Number Percent
Total Households 82,128 100.0% 90,865 100.0% 90,540 100.0% Families 58,634 71.4% 65,551 72.1% 66,776 73.8%
With Children 33,792 41.1% 34,070 37.5% 29,982 33.1%
Non-Families 23,494 28.6% 25,314 27.9% 23,764 26.2%
Living Alone 17,550 21.4% 18,297 20.1% 16,849 18.6%
Other 5,944 7.2% 7,017 7.7% 6,915 7.6%
Average Household Size 3.01 3.23 3.32
Average Family Size 3.54 3.76 3.80
Sources: Bureau of the Census, 2000; 2006-2010 and 2018-2022 American Community Survey (ACS).

3. Income Proﬁle
Household income is the most important factor determining a household’s ability to balance housing costs with other basic life necessities. A stable income is the means by which most individuals and families ﬁnance current consumption and make provision for the future through saving and investment. The level of cash income can be used as an indicator of the standard of living for most of the population.

Households with lower incomes are limited in their ability to balance housing costs with other needs and often the ability to ﬁnd housing of adequate size. While economic factors that aƯect a household’s housing choice are not a fair housing issue per se, the relationships

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City of Riverside March 2025
among household income, household type, race/ethnicity, and other factors often create misconceptions and biases that raise fair housing concerns.

For purposes of most housing and community development activities, HUD has established the four income categories based on the Area Median Income (AMI) for the Metropolitan Statistical Area (MSA). HUD income deﬁnitions diƯer from the State of California income deﬁnitions. Table 7 compares the HUD and State income categories. This AI report is a HUD- mandated study and therefore HUD income deﬁnitions are used. For other housing documents of the City (such as the Housing Element of the General Plan), the State income deﬁnitions may be used, depending on the housing programs and funding sources in question.

Table 7: Income Categories for CDBG Program
HUD Deﬁnition State of California Deﬁnition
Extremely Low Income Less than 30% of AMI Extremely Low Income Less than 30% of AMI Low Income 31-50% of AMI Very Low Income 31-50% of AMI
Moderate Income 51-80% of AMI Low Income 51-80% of AMI
Middle/Upper Income Greater than 80% of AMI Moderate Income 81-120% of AMI Above Moderate Income Greater than 120% of AMI
Source: U.S. Department of Housing and Urban Development (HUD) and California Department of Housing and Community Development (HCD), 2024.

Note: Other HUD programs may deﬁne low income as 80% AMI Median Household Income
According to the 2018-2022 ACS, Riverside households have a median household income of $83,448. Table 8 displays median household income in the City and Riverside County, as recorded by the 2006-2010 and 2018-2022 ACS. Median household income in the City is slightly lower than the in the County overall. The median household income saw about the same rate of growth in the City and the County between 2010 and 2022.

Table 8: Median Household Income (2010-2022)
Jurisdiction
Median Household Income
Percent Change 2010 2022
Riverside $56,991 $83,448 46.4%
Riverside County $57,768 $84,505 46.3%
Source: American Community Survey, 2006-2010, 2018-2022.

Income Distribution
Fair housing choice, according to HUD, means the ability of persons of similar income levels regardless of race, color, religion, sex, national origin, familial status and disability to have available to them the same housing choices. This means, for instance, those households of diƯerent races but with similar income levels should have available to them the same housing choices. Another example is that female householders, male householders and married couples with similar income levels should have available to them the same housing choices.

A housing market that treats female and male householders with the same incomes diƯerently would not be providing fair housing choice.

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City of Riverside March 2025
Household income has a positive impact on enabling people to ﬁnd the housing of their choice. As incomes become higher, a fuller range of housing choice with respect to type, cost, and neighborhood location become available to them.

Table 9 shows the number and percentages of households in ﬁve income groups by tenure.

Approximately 42 percent of Riverside’s 90,665 households have lower incomes, which makes them eligible to participate in the City’s CDBG- and HOME-funded programs. Lower income renters comprise 26 percent of all the City’s households (23,535 lower income renters of 90,665 total households). The largest income group (30,320 households) is above moderate income owners.

Income distribution, including a geographical analysis, is expanded upon in Chapter 7, Private and Public Sector Fair Housing Impediments Analysis.

Table 9: Household Income by Tenure – City of Riverside (2023) Household Income
Owner Renter Total
Households Percent Households Percent Households Percent Extremely Low 3,185 6.4% 8,525 20.9% 11,710 12.9%
Very Low 3,915 7.9% 6,490 15.9% 10,405 11.5%
Low 7,005 14.1% 8,520 20.8% 15,525 17.1%
Moderate 5,355 10.8% 4,735 11.6% 10,090 11.1%
Above Moderate 30,320 60.9% 12,610 30.8% 42,930 47.4%
Total 49,780 100.0% 40,880 100.0% 90,665 100.0%
Source: Comprehensive Housing AƯordability Strategy (“CHAS”) Data, based on the 2016-2020 American Community Survey.

Extremely Low: Less than or = 30% HAMFI Very Low: >30% to less than or = 50% HAMFI Low: >50% to less than or = 80% HAMFI Moderate:
>80% to less than or = 100% HAMFI Above Moderate: >100% HAMFI.

HAMFI refers to HUD Area Median Family Income.

Table 10 shows HUD’s 2024 annual income limits, adjusted by household size, for extremely low-, very low-, and low-income households. Table 9 above indicates that 8,525 extremely low income renters live in Riverside. A 4-person extremely low income family would have an annual income of $31,200 or less.

Table 10: HUD FY 2024 Income Limits – County of Riverside Number of Persons Extremely Low Very Low Low
1 $21,550 $35,900 $57,400
2 $24,600 $41,000 $65,600
3 $27,700 $46,100 $73,800
4 $31,200 $51,250 $82,000
5 $36,580 $55,350 $88,600
6 $41,960 $59,450 $95,150
7 $47,340 $63,550 $101,650
8 $52,720 $67,650 $108,250
Source: U.S. Department of Housing and Urban Development, FY 2024 Income Limits.

Note: Riverside County is part of the Riverside-San Bernardino-Ontario, CA MSA, so all information presented here applies to all of the Riverside-San Bernardino-Ontario, CA MSA. The Riverside-San Bernardino-Ontario, CA MSA contains the following areas: Riverside County, CA; and San Bernardino County, CA.

The FY 2014 Consolidated Appropriations Act changed the deﬁnition of extremely low- income to be the greater of 30/50ths (60 percent) of the Section 8 very low-income limit or the poverty guideline as established by the Department of Health and Human Services (HHS), provided that this amount is not greater than the Section 8 50% very low-income limit. Consequently, the extremely low (30%) income limits may equal the very low (50%) income limits.

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City of Riverside March 2025

Table 11: Housing Assistance Needs by Income and Household Type (2020) Household Income and
Housing Problem
Renter-Occupied Owner-Occupied Total
Household
s
Elderly
Household
Small
Household
Large
Household Total
Elderly
Household
Small
Household
Large
Household Total
Extremely Low Income
(<30%MFI) 2,245 2,905 800 8,525 1,265 1,105 300 3,185 11,710 With any housing problem 81.1% 87.8% 100.0% 83.8% 79.1% 90.5% 83.3% 82.4% 83.4% Cost burden >30% 73.7% 85.9% 96.3% 82.1% 79.1% 88.7% 65.0% 79.7% 81.4% Cost burden >50% 58.1% 83.3% 76.9% 74.0% 64.4% 77.4% 50.0% 67.7% 72.3% Very Low Income
(30-50% MFI) 1,040 2,640 1,455 6,490 1,910 1,200 500 3,915 10,405 With any housing problem 84.6% 93.6% 97.3% 93.1% 55.5% 86.3% 79.0% 69.7% 84.3% Cost burden >30% 84.1% 91.5% 83.5% 88.7% 58.6% 86.3% 73.0% 69.1% 81.3% Cost burden >50% 39.9% 54.9% 28.2% 48.4% 21.2% 52.5% 28.0% 37.8% 44.4% Low Income (50-80% MFI) 850 4285 1290 8520 2250 2475 1660 7005 15525 With any housing problem 75.3% 74.4% 84.9% 75.0% 40.9% 64.4% 72.6% 56.9% 66.8% Cost burden >30% 74.1% 64.5% 52.7% 64.4% 40.2% 63.0% 52.4% 51.5% 58.6% Cost burden >50% 11.8% 11.0% 6.2% 12.1% 19.1% 15.2% 6.9% 14.7% 13.3% Moderate and Above
Moderate Income (>80% MFI) 1,710 8,760 2,545 17,345 8,070 18,005 6,570 35,675 53,020 With any housing problem 23.7% 21.5% 44.2% 25.2% 12.8% 14.5% 30.4% 17.3% 19.9% Cost burden >30% 18.9% 14.2% 5.1% 14.8% 12.1% 13.7% 8.1% 12.5% 13.2% Cost burden >50% 0.8% 0.2% 0.0% 0.5% 2.5% 1.5% 1.1% 1.8% 1.4% All Households 5,845 18,590 6,090 40,880 13,495 22,785 9,030 49,780 90,665 With any housing problem 64.1% 54.3% 72.8% 58.6% 29.8% 27.4% 42.6% 31.1% 43.5% Cost burden >30% 59.6% 48.0% 45.9% 50.9% 29.7% 26.5% 21.8% 26.7% 37.6% Cost burden >50% 31.4% 23.4% 18.1% 25.8% 13.7% 9.3% 5.3% 10.7% 17.5% Note: Data presented in this table is based on special tabulations from sample Census data. The number of households in each category usually deviates slightly from the 100% count due to the need to extrapolate sample data out to total households. Interpretations of this data should focus on the proportion of households in need of assistance rather than on precise numbers.

Source: 2023 HUD Comprehensive Housing AƯordability Strategy (CHAS) Data (based on American Community Survey, 2016-2020 Estimates).

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City of Riverside March 2025
Household Income by Household Type
Household income often varies by household type. As shown, in Table 11 above, approxi- mately 44 percent of the City’s households experienced at least one housing problem (physical defects, overcrowding, cost burden, and/or severe cost burden). The incidence of housing problems was higher among renter households (59 percent) than households who owned their homes (31 percent). Large households faced housing problems at a higher proportion than the elderly and small families, regardless of income or tenure (73 percent of large renter households and 43 percent of large owner households).

Housing problems, including cost burden, overcrowding, and substandard housing conditions, are discussed further in Chapter 7, Private and Public Sector Fair Housing Impediments Analysis.

Poverty
People in poverty may be unable to secure housing in neighborhoods that oƯer opportunities such as superior schools and proximity to good parks and other amenities. Poverty is a measure of income or, more accurately, the lack of income. In accordance with the Consolidated Plan Final Rule, the City’s FY 2024/2025 to FY 2028/2029 Consolidated Plan will set forth an anti-poverty strategy.

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

Examples of oƯicial United States 2023 poverty thresholds are:2  1 person less than 65 years of age $15,852
 2 people, householder less than 65 years of age $20,404  3 people, 1 child less than 18 years of age $24,526
 4 people, 2 children less than 18 years of age $30,900 Table 12 demonstrates that approximately 13 percent of all Riverside residents live in households with annual incomes below the poverty level. The highest poverty rates are experienced by female-householder families (16 percent to 19 percent) and elderly persons aged 65 or older (12 percent to 16 percent).

2 United States Census Bureau, 2023 Poverty Thresholds by Size of Family and Number of Children. Accessed August 2024. https://www.census.gov/data/tables/time-series/demo/income-poverty/historical-poverty- thresholds.html.

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City of Riverside March 2025
Table 12: Poverty Characteristics – City of Riverside (2018-2022) Population 2018-2022 ACS 2022 ACS
Total Population 12.8% 12.8%
18 to 64 years 11.8% 11.7%
65 years and over 12.3% 15.7%
All Families 9.0% 8.6%
Married Couple Families 5.0% 5.6%
Female Householder Families 19.4% 16.2%
Source: 2018-2022 American Community Survey 5-Year Estimates, T able CP03, Comparative Economic Characteristics and 2022 American Community Survey 1-Year Estimates, Table CP03, Comparative Economic Characteristics

Table 13 reports on additional poverty statistics based on the California Poverty Measure (CPM) for the County of Riverside. The CPM accounts for how the social safety net, speciﬁcally, CalFresh, CalWORKS, the Earned Income Tax Credit (EITC), and other means- tested programs, moderates poverty. The CPM poverty rate of 12 percent for the County is comparable to the poverty rate of 11 percent based on 2022 ACS poverty rate estimates for Riverside County. Poverty rates are reduced due to social safety net programs, most signiﬁcantly the CalFresh program.

Patterns of poverty in the City of Riverside are expanded upon in Chapter 7, Private and Public Sector Fair Housing Impediments Analysis.

Table 13: Poverty Indicators – County of Riverside (2023) Poverty Indicator County
CPM Poverty Rate 11.8%
Rate margin of error (% pt) 1.4
Number 291,500
Number margin of error 42,800
CPM Child Poverty Rate 10.6%
Rate margin of error (% pt) 2.2
CPM Poverty Threshold, renter family of 4 ($) $37,621
Increase in poverty without safety net Increase (% pt) 8.3 Margin of error (% pt) 1.2
Increase in poverty without CalFresh Increase (% pt) 3.1 Margin of error (% pt) 0.9
Increase in poverty without CalWORKs and General
Assistance (GA)
Increase (% pt) 0.7
Margin of error (% pt) 0.5
Increase in poverty without federal EITCs Increase (% pt) 1.0 Margin of error (% pt) 0.5
Source: Public Policy Institute of California and Stanford Center on Poverty and Inequality, Poverty Across California, 2023.

4. Housing Proﬁle
A discussion of fair housing choice must be preceded by an assessment of the housing market. A diverse housing stock that includes a mix of conventional and specialized housing helps ensure that all households, regardless of their income level, age group, and familial status, have the opportunity to ﬁnd suitable housing. This chapter provides an overview of the characteristics of the local and regional housing markets.

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City of Riverside March 2025
The Census Bureau deﬁnes a housing unit as a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied (or, if vacant, is intended for occupancy) as separate living quarters. Separate living quarters are those in which the occupants live separately from any other individuals in the building and that have direct access from outside the building or through a common hall.

Housing Stock
Table 14 shows that almost 102,000 housing units comprise the housing stock. Single-family detached and attached homes account for just over two-thirds (67 percent) of the housing stock. Multi-family housing in structures containing 10 or more dwellings comprises almost one-sixth (16 percent) of the housing stock.

Over the past 10 years, muti-family housing with ﬁve or more units saw the largest growth of 8 percent since 2014 (see Table 15). The number of single-family attached units increased by 4 percent, single-family detached units increased by 2 percent, and multi-family housing with two to four units increased by 0.1 percent during this period. The City saw a decrease in mobile homes, RVs, and vans as housing arrangements by 4 percent. Overall, the housing stock increased 3 percent between 2014 and 2024.

Table 14: Housing Stock by Type of Unit – City of Riverside (January 1, 2024) Type of Unit # of Units Percent
1 unit, detached 64,589 63.4%
1 unit, attached 4,106 4.0%
2 to 4 units 6,257 6.1%
5-9 units 5,579 5.5%
10-19 units 5,881 5.8%
20 or more units 10,509 10.3%
Mobile homes, RV , Van, etc. 2,099 2.1%
Total 101,922 100.0%
Source: State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State January 1, 2024.

The 2018-2022 American Community Survey (Table DP04) data on units in structure were used to calculate the number of units in structures containing 5 or more units

Table 15: Housing Stock Increase by Type of Unit – City of Riverside (January 1, 2014 to January 1, 2024)
Type of Unit # of Units Percent
1 unit, detached 1,116 1.7%
1 unit, attached 158 3.8%
2 to 4 units 5 0.1%
5+ units 1,941 7.8%
Mobile homes, RV , Van, etc. -80 -3.8%
Total 3,132 3.1%
Source: January 1, 2014 Census and State of California, Department of Finance, E-5 Population and Housing Estimates for Cities, Counties, and the State January 1, 2024.

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City of Riverside March 2025
Homeownership
Homeownership is a key indicator of community and personal well-being, because owning a home is often a household’s major asset and home equity often contributes to a large share of wealth. Table 16 shows the 2000, 2010, and 2022 homeownership rates for the City of Riverside, Riverside County, California, and the Nation. In all three periods, Riverside had a somewhat lower homeownership rate than the County and the Nation and almost the same as the State.

Table 16: Comparison of Homeownership Rates by Year
Area 2000 2010 2022
City of Riverside 56.6% 55.7% 55.5%
Riverside County 68.9% 67.4% 68.5%
California 56.9% 55.9% 55.6%
Nation 66.2% 65.1% 64.8%
Source: 2000 Census Summary File 1, Table QT-H2: Tenure, Household Size and Age of Householder; 2010 Census DP-1 Proﬁle of Population and Housing Characteristics: 2010, Housing Tenure; 2018-2022 American Community Survey (ACS) 5-Year Estimates, T able DP04: Selected Housing Characteristics.

During the 2000-2022 period, the percentage of owner-occupied housing decreased slightly from 57 percent to 56 percent. Two possible reasons for the decline are that 1) foreclosed upon homes became renter-occupied and 2) more multifamily than single-family housing units were added to the housing stock.

The homeownership rate in the City is signiﬁcantly smaller than the share of single-family homes in Riverside, representing 67.4 percent of the housing stock. But, as Table 17 reveals, almost one of every four single-family detached homes are renter-occupied. Additionally, more than half of single-family attached homes are renter-occupied. Overall, 26 percent of Riverside’s single-family homes are renter-occupied. The large population of college students residing in the City may contribute to the signiﬁcant proportion of renters residing in single- family homes. According to the 2018-2022 ACS, 38,259 students are enrolled in college (undergraduate) or graduate school in Riverside, representing approximately 12 percent of the total population. In comparison, 178,085 students are enrolled in college or graduate school countywide, representing only 7 percent of the total population.

Table 17: Owner/Renter Occupancy of Single Family Homes – City of Riverside (2022) Housing Type Owner Percent Renter Percent Total
Single Family Detached 46,784 76.3% 14,497 23.7% 61,281 Single Family Attached 2,385 45.2% 2,887 54.8% 5,272
Total 49,169 73.9% 17,384 26.1% 66,553
Source: 2018-2022 American Community Survey 5-Year Estimates, T able B25024, Units in Structure and Table B25032, Tenure by Units in Structure.

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City of Riverside March 2025

5. Employment and Transportation Proﬁle
Labor Force and Employment Characteristics
Having a job and earning income is a prerequisite to enabling families to ﬁnd housing of their choice, that is within their means, and that is located in neighborhoods they and their children like. Housing choice for all racial and ethnic groups is diminished when unemployment rates are high because they depress household income and increase the number of poverty income families.

Key labor force and employment terms are deﬁned below:

Labor Force – All people classiﬁed in the civilian labor force plus members of the U.S.

Armed Forces (people on active duty with the United States Army, Air Force, Navy, Marine Corps, or Coast Guard).

Labor Force Participation Rate – The labor force participation rate represents the proportion of the population that is in the labor force. For example, if there are 100 people in the population 16 years and over, and 64 of them are in the labor force, then the labor force participation rate for the population 16 years and over is 64 percent.

Not in Labor Force – All people 16 years old and over who are not classiﬁed as members of the labor force. This category consists mainly of students, homemakers, retired workers, seasonal workers interviewed in an oƯ season who were not looking for work, institutionalized people, and people doing only incidental unpaid family work (less than 15 hours during the reference week).

Unemployment Rate – The unemployment rate represents the number of unemployed people as a percentage of the civilian labor force. For example, if the civilian labor force equals 100 people and seven people are unemployed, then the unemployment rate is seven percent.

Table 18 shows that Riverside’s civilian labor force ranges between approximately 160,000 and 170,000 persons 16 years of age or older, resulting in a labor force participation rate of about 64 percent, according to the 2018-2022 ACS. Based on 2018-2022 estimates, there are 10,262 unemployed persons in the City resulting in an unemployment rate of 3 percent. The City’s unemployment rate has been gradually decreasing in recent years. The 2013-2017 ACS estimated the unemployment rate in Riverside was 10 percent. This exceptionally high unemployment rate was due to the depressed housing market and slowed economy that took place between 2012 and 2016.

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City of Riverside March 2025
Table 18: Labor Force and Employment Characteristics – City of Riverside (2018-2022) 2018-2022 ACS 2022 ACS
Population 16 years and over 250,285 258,174
In Civilian Labor Force* 159,932 169,708
% in Civilian Labor Force 63.9% 65.7%
Not in Civilian Labor Force 90,103 88,296
% Not in Civilian Labor Force 36.0% 34.2%
In Civilian Labor Force, Unemployed 10,262 8,262
Civilian Unemployment Rate 3.1% 4.9%
Source: 2018-2022 American Community Survey 5-Year Estimates, T able CP03, Comparative Economic Characteristics and 2022 American Community Survey 1-Year Estimates, Table CP03, Comparative Economic Characteristics. *Does not include persons in the Armed Forces

Table 19 provides data on the composition of the City’s 150,122 employed population. The industry sectors with the largest populations of employed persons are educational services, health care and social assistance (23 percent), retail trade (12 percent), manufacturing (10 percent), and arts, entertainment, recreation, accommodation, and food services (10 percent). The industry sectors with the largest gains in jobs over the past decade include transportation, warehousing, and utilities (+65 percent), arts, entertainment, recreation, accommodation, and food services (+45 percent), and public administration (+43 percent).

Table 19: Employment by Industry – City of Riverside (2022) Industry Sector # Employed
Sector
Share
Change
Since 2010
Median
Earnings
(2022)
Civilian employed population 16 years and over
with earnings
150,122 100.0% 14.7% $40,113
Agriculture, forestry, ﬁshing and hunting, and mining 738 0.5% 15.0% $38,333 Construction 13,424 8.9% 16.4% $47,101
Manufacturing 14,605 9.7% -6.7% $44,582
Wholesale trade 4,013 2.7% -19.2% $44,953
Retail trade 17,520 11.7% 11.4% $30,992
Transportation warehousing, and utilities: 12,502 8.3% 64.8% $37,146 Information 2,080 1.4% -16.8% $60,521
Finance and insurance, real estate, and rental and
leasing
6332 4.2% -15.2% $50,565
Professional, scientiﬁc, management, and
administrative and waste management services
13,915 9.3% 13.7% $41,509
Educational services, health care, and social
assistance
34,774 23.2% 15.0% $47,178
Arts, entertainment, recreation, accommodation,
and food services
14,626 9.7% 44.7% $16,330
Other services, except public administration 7,923 5.3% 14.9% $33,102 Public administration 7,670 5.1% 43.1% $70,013
Source: 2006-2010 and 2018-2022 American Community Survey 5-Year Estimates, Table DP03 and Table S2413.

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City of Riverside March 2025
Major Employers
Table 20 list the major employers located in Riverside. Eleven of the 13 employers with 1,000 or more employees provide government, educational, and healthcare services. The major employers mirror the industry sectors with the largest number of jobs – health care and social assistance; educational services; and government.

Table 20: Employers with 1,000 or More Employees – City of Riverside (2024) Employer Employees Industry
County of Riverside 24,290 Government OƯices
March Air Forces Reserve 9,600 Military
University of California, Riverside 8,593 Education
Riverside University Health Systems 8,000 Medicare
Kaiser Permanente 5,846 Healthcare
Riverside Uniﬁed School District 5,003 Education
City of Riverside 2,336 Government OƯices
Riverside Community Hospital 2,200 Healthcare
Riverside Community College District 2,100 Education
Alvord Uniﬁed School District 1,898 Education
Riverside County OƯice of Education 1,700 Education
Cal Baptist University 1,442 Education
Collins Aerospace Systems 1,000 Aircraft Components Manufacturing Source: City of Riverside, T op Employers, August 2024.

Commuting Patterns
Over 80 percent of Riverside County commuters commute to jobs located within the Inland Empire counties of Riverside and San Bernardino. Among other adjacent counties, Riverside County has the most workers commuting to Orange County (7 percent), followed by Los Angeles County (5 percent), and San Diego County (5 percent).

Table 22 shows commuting characteristics for workers in the City of Riverside. Most workers (86 percent) drive to work by car, truck, or van. Another 8 percent work from home, 2 percent walk, and 2 percent use public transportation. The largest proportion of workers (16 percent) commute 60 or more minutes to work. Another 16 percent commute 30 to 34 minutes, 15 percent commute 20 to 24 minutes, and 13 percent commute 15 to 19 minutes. Long commutes can cause unusually high transportation costs and reduce the amount of income that can be allocated to housing costs.

Table 21: Resident Commute to Work Destinations (2020)
Place # of Commuters Percent
San Bernardino County 113,716 11.2%
Riverside County 725,518 71.2%
Orange County 75,863 7.4%
Los Angeles County 53,172 5.2%
Rest of California 4,317 0.4%
San Diego County 47,073 4.6%
Total 1,019,659 100.0%
Sources: 2016-2020 5-Year ACS Commuting Flows

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City of Riverside March 2025
Table 22: Commuting Characteristics – City of Riverside (2022) Workers 16 years and over 146,251
Means of Transportation to Work
Car, truck, or van 85.9%
Public transportation (excluding taxicab) 1.9%
Walked 2.4%
Bicycle 0.6%
Taxicab, motorcycle, or other means 1.1%
Worked from home 8.1%
Travel Time to Work
Less than 10 minutes 8.7%
10 to 14 minutes 11.4%
15 to 19 minutes 13.3%
20 to 24 minutes 14.9%
25 to 29 minutes 5.4%
30 to 34 minutes 15.7%
35 to 44 minutes 6.7%
45 to 59 minutes 8.2%
60 or more minutes 15.80%
Source: 2018-2022 American Community Survey 5-Year Estimates, T able S0801.

6. Education and Schools Proﬁle
Educational Attainment
Higher incomes enable households to more eƯectively acquire housing of their choice and within their means. And householders with higher levels of educational achievement, on average, have higher earnings. As noted in the labor force and employment discussion, one means to improve economic indicators is through educational attainment: better educated and skilled residents earn higher wages. The primary way in which a city can attract higher skilled workers is through improving local amenities and services, such as improving schools.

Table 23 indicates the educational attainment of the population 25 years of age and older.

More than 26 percent of the population has a Bachelor’s, Graduate, or Professional Degree.

Table 24 demonstrates that median earnings increase as a higher level of educational attainment is achieved. The median earnings of a person with a bachelor’s degree are nearly twice those of a person who did not graduate from high school.

Table 23: Educational Attainment for the Population 25 Years and Over – City of Riverside (2022)
Educational Attainment Number Percent
Less than 9th Grade 17,088 8.2%
9th to 12 Grade, No Diploma 15,311 7.4%
High School Graduate 57,696 27.8%
Some College, No Degree 46,533 22.4%
Associate’s Degree 15,446 7.4%
Bachelor’s Degree 32,898 15.9%
Graduate or Professional Degree 22,368 10.8%
Total 207,340 100.0%
Source: 2022 American Community Survey 1-Year Estimates, T able C15002, Sex by Educational Attainment for the Population 25 Years and Over.

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City of Riverside March 2025
Table 24: Median Earnings by Educational Attainment –
City of Riverside (2022)
Educational Attainment 2018-2022 ACS 2022 ACS
Less than High School Graduate $33,169 $34,502
High School Graduate $39,636 $40,593
Some College or Associate’s Degree $45,148 $42,167
Bachelor’s Degree $58,006 $59,860
Graduate or Professional Degree $84,165 $75,000
Source: 2018-2022 American Community Survey 5-Year Estimates and 2022 American Community Survey 1-Year Estimates, Table B20004, Median Earnings in the Past 12 Months (in 2022 Inﬂation- Adjusted Dollars) by Sex by Educational Attainment for the Population 25 Years and Over.

K-12 Schools
Table 25 reports on the school enrollment by race and ethnicity for Riverside Uniﬁed and Alvord Uniﬁed School Districts. Table 26 shows graduation rates for these districts by race/ethnicity for the 2023-2024 school year. Graduation rates for all racial/ethnic groups are above 90 percent. In comparison, the graduation rates Statewide and Countywide were 89 percent and 92 percent, respectively, during this period. Access to educational opportunities in the City of Riverside are further discussed in Chapter 7, Private and Public Sector Fair Housing Impediments Analysis, of this Analysis of Impediments to Fair Housing Choice.

Table 25: School Enrollment by Race/Ethnicity and School District (2024) Race/Ethnicity
Riverside
Uniﬁed Percent
Alvord
Uniﬁed Percent Total Percent
American Indian/Alaska Native 105 0.3% 30 0.2% 135 0.2% Asian 1,521 3.9% 605 3.6% 2126 3.8%
Black/African American 2,344 5.9% 647 3.9% 2991 5.3%
Filipino 436 1.1% 236 1.4% 672 1.2%
Hispanic 27,144 68.7% 13,565 81.4% 40709 72.5%
Native Hawaiian/Paciﬁc Islander 123 0.3% 83 0.5% 206 0.4% Two or More Races 816 2.1% 284 1.7% 1100 2.0%
White 6,351 16.1% 1,212 7.3% 7563 13.5%
Total 39,505 100.0% 16,663 100.0% 56168 100.0%
Source: DataQuest Annual Enrollment Data, California Department of Education, 2023-2024.

Note: Excludes Not Reported race/ethnicity

Table 26: Graduation Rate by District and Race/Ethnicity (2023) Race/Ethnicity
Riverside Uniﬁed Alvord Uniﬁed
Cohort Students Graduation Rate Cohort Students Graduation Rate American Indian/Alaska Native 17 94.1% – –
Asian 126 94.4% 49 100.0%
Black/African American 187 93.6% 50 98.0%
Filipino 62 98.4% 25 100.0%
Hispanic 1,954 90.9% 1,209 94.2%
Paciﬁc Islander 16 100.0% – –
Two or more races 52 98.1% 15 100.0%
White 641 95.8% 129 96.1%
Source: DataQuest Annual Enrollment Data, California Department of Education, 2023-2024.

Note: Excludes Not Reported race/ethnicity

Analysis of Impediments to Fair Housing Choice page 25
City of Riverside March 2025

4. Protected Class Proﬁles
A “protected class” is a group of people with a common characteristic who are legally protected from housing discrimination on the basis of that characteristic. Protected classes are created by both Federal and State law. The protected classes under federal law include:
 Race
 Color
 National Origin
 Sex (including gender identity and sexual orientation)  Familial Status
 Disability (mental and/or physical)
 Religion
The Fair Housing Act prohibits both intentional housing discrimination and housing policies and practices that discriminate against the seven protected classes/groups. In addition to the seven classes protected under federal law, California law enumerates seven additional groups: age, marital status, ancestry, source of income, genetic information, and other arbitrary factors. Because the AI is a federal document, the analysis focuses primarily on the protected classes listed in the federal Fair Housing Act. However, the analysis also includes protected groups and special needs populations that are considered during the Consolidated Planning Process including:
 Seniors
 Limited English Proﬁciency
 Source of Income
 Persons Experiencing Homelessness
AB 686 mandated that cities include an Assessment of Fair Housing (AFH) in their Sixth Cycle Housing Element update. To aid in this analysis, the Housing and Community Development (HCD) department developed the AFFH Mapping Tool, which oƯers geographic mapping capabilities to visualize and analyze demographic data related to fair housing. This Chapter integrates the most recent data from the AFFH Mapping Tool for the protected classes covered by the tool.

The City of Riverside is divided into seven wards for administrative and planning purposes.

However, maps accompanying this analysis will display geographic areas by neighborhood names for better visualization and understanding and to complement the analysis done in the Sixth Cycle Housing Element. While neighborhoods do not perfectly align with ward boundaries, both a map and a table are provided to illustrate their relationship.

Analysis of Impediments to Fair Housing Choice page 26 City of Riverside March 2025 Figure 1: Riverside Ward and Neighborhoods Ward Neighborhoods Ward Neighborhoods 1 Northside Downtown Eastside Wood Streets Grand (partial) 5 Arlington Ramona La Sierra South (partial) Arlington South Presidential Park Casa Blanca 2 Hunter Industrial Park University Canyon Crest (partial) Sycamore Canyon Park Sycamore Canyon/Canyon Springs Mission Grove (partial) 6 Arlanza Arlington (partial) La Sierra (partial) La Sierra South (partial) 3 Airport Grand Magnolia Center Victoria Ramona (partial) 7 Airport (partial) Arlanza (partial) La Sierra Acres La Sierra Hills La Sierra (partial) 4 Arlington Heights Hawarden Hills Alessando Heights Canyon Crest (partial) Mission Grove (partial) Orangecrest

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City of Riverside March 2025

4.1 Race/Color3

1. Population Characteristics by Race and Ethnicity
The Fair Housing Act does not deﬁne race. The racial categories included on the 2010 Census form generally reﬂect a social deﬁnition of race recognized in this country, and are not an attempt to deﬁne race biologically, anthropologically, or genetically. In addition, the U.S.

Census Bureau recognizes that the race categories include both racial and national origin or socio-cultural groups. Census 2020 and the American Community Survey provide for six race categories:
 White Alone
 Black, African American Alone
 American Indian or Alaska Native Alone
 Asian Alone
 Native Hawaiian or Other Paciﬁc Islander Alone
 Some Other Race Alone
Individuals who chose more than one of the six race categories are referred to as the two or more races population. All respondents who indicated more than one race can be collapsed into the two or more races category, which combined with the six alone categories, yields seven mutually exclusive categories. Thus, the six race alone categories and the two or more races category sum to the total population. Ethnicity means being of Hispanic or Latino Origin or not being of such origin.

In the past 5 years for which data is available, between 2017 and 2022, the racial and ethnic makeup of the City has stayed relatively the same. The City continues to be predominantly Hispanic (55 percent) and White (27 percent), but the percentage of White population has decreased while the percentage of Hispanic population has increased. The percentage of other minority populations has also increased (Asian and Two or more races).

Table 27: Race and Ethnicity (2017-2022)
2017 2022
Race/Ethnicity # % # %
White alone 99,868 31.1% 86,337 27.3%
Black or African American alone 18,271 5.7% 17,060 5.4% American Indian and Alaska Native alone 818 0.3% 767 0.2% Asian alone 22,727 7.1% 25,932 8.2%
Native Hawaiian and Other Paciﬁc Islander alone 822 0.3% 973 0.3% Some other race alone 1,077 0.3% 552 0.2%
Two or more races 8,252 2.6% 9,468 3.0%
Hispanic or Latino 169,735 52.8% 174,987 55.4%
Total 321,570 100.0% 316,076 100.0%
Sources: 2012-2017 and 2018-2022 American Community Survey 5-Year Estimates, Table B03002: Hispanic or Latino Origin by Race.

3 Color analysis is often combined with race in studies because detailed data on color alone is not widely available. Racial and ethnic data is more commonly collected and used.

Analysis of Impediments to Fair Housing Choice page 28 City of Riverside March 2025 Figure 2 displays the predominant races by tract, with darker colors representing higher levels of predominance. Throughout the City, the predominant races are White non-Hispanic and Hispanic-Latino. Hispanic or Latino population is most prominent in the western part of the City, including the Arlanza and La Sierra Acres neighborhoods; in the central area around the 91 Freeway, such as Casa Blanca and Arlington Heights; and in the Eastside neighborhood just east of Downtown. White non-Hispanic population is predominant in eastern parts of the City, especially in Victoria and Canyon Crest. Although the map shows that two or more races are predominant in Sycamore Canyon Park (red tract), the 2017-2021 ACS estimates on which the map is based reported the population in this tract was only 12 people, all of whom identiﬁed as two or more races. The most recent 2018-2022 ACS estimates show that the population for this tract has dropped to zero. The City considers Sycamore Canyon Park to be unpopulated. Figure 2: Predominant Races – City of Riverside Figure 3 through Figure 6 below show the concentration of the population by race for White (non-Hispanic), Hispanic, Asian, and Black/African American groups. These four groups make up 95 percent of the population (27 percent White, 55 percent Hispanic, 8 percent Asian, and 5 percent Black). It is important to note that the dark colors on each map represent diƯerent population concentrations due to the varying sizes of these groups. For example, for White population, the darker colors (maximum values) represent tracts where White population make up to 69 percent of the tract’s population, while for Black population, the maximum values represent up to 20 percent of the tract.

Analysis of Impediments to Fair Housing Choice page 29 City of Riverside March 2025 Figure 3: Percentage Distribution of the Total Population by Race: White Figure 4: Percentage Distribution of the Total Population by Race: Hispanic

Analysis of Impediments to Fair Housing Choice page 30 City of Riverside March 2025 Figure 5: Percentage Distribution of the Total Population by Race: Asian Figure 6: Percentage Distribution of the Total Population by Race: Black

Analysis of Impediments to Fair Housing Choice page 31
City of Riverside March 2025

2. Poverty and Tenure by Race and Ethnicity
Approximately 13 percent of the total population has incomes below the poverty level.

Table 28 shows that poverty rates diƯer by race and ethnicity. All groups except the White Alone (10.2 percent) experience poverty rates greater than the citywide average of 12.8%. The Asian poverty rate is the highest among the minority races at 18.5 percent.

Although poverty rates diƯer, any household with such low incomes – regardless of race or ethnicity – would be unable to aƯord market rate housing. Poverty incomes severely restrict their ability to attain the housing of their choice.

Table 28: Poverty Status by Race and Ethnicity (2022)
Total # Below Poverty % Below Poverty
Population for whom poverty status is determined 301,385 38,432 12.8% White alone 82,712 8,423 10.2%
Black or African American alone 17,217 2,279 13.2%
American Indian and Alaska Native alone 2,361 331 14.0% Asian alone 22,942 4,239 18.5%
Native Hawaiian and Other Paciﬁc Islander alone 1,269 154 12.1% Some other race alone 81,750 12,107 14.8%
Two or more races 38,483 40,08 10.4%
Hispanic or Latino origin (of any race) 169,241 22,579 13.3% Sources: 2018-2021 American Community Survey 5-Year Estimates, T able S1701 Poverty Status in the Past 12 Months.

Prospective homeowners may experience housing discrimination during the process of buying a home. For instance, discriminatory behavior could be made by real estate agents, appraisers, lenders, and home insurance agents. Renters, on the other hand, could be denied access to housing while in-place tenants could be discriminated against by landlords.

Approximately 56 percent of Riverside’s households are owner-occupied (Table 29). Some groups have a homeownership rate of 56 percent or more: White Alone, Not Hispanic householders (65 percent), Asian householders (57 percent), and Native Hawaiian/Paciﬁc Islanders householders (62 percent). Black/African American, American Indian/Alaska Native, and Hispanic householders experience lower home ownership rates.

Table 29: Tenure by Race and Ethnicity (2022)

Owner Household Renter Household
Total # % # %
White Alone, Not Hispanic 21,996 65.4% 11,626 34.6% 33,622 Black or African American 2,489 39.3% 3,841 60.7% 6,330 American Indian/Alaska Native 375 46.3% 435 53.7% 810
Asian 4,138 57.3% 3,082 42.7% 7,220
Native Hawaiian or Other
Paciﬁc Islander
254 62.3% 154 37.7% 408
Some Other Race 8,817 45.9% 10,382 54.1% 19,199
Two or More Races 5,030 53.2% 4,422 46.8% 9,452
Hispanic or Latino of any race 20,258 49.9% 20,303 50.1% 40,561 T otal 50,227 55.5% 40,313 44.5% 90,540
Sources: 2018-2022 American Community Survey 5-Year Estimates, T able B25003A-I Tenure by Race/Ethnicity.

Analysis of Impediments to Fair Housing Choice page 32
City of Riverside March 2025
There is a high correlation between the number and percentage of renter households and the need for fair housing services. The overwhelming majority of the alleged housing discriminatory acts reported to HUD and the Fair Housing Council of Riverside County are ﬁled by renter householders (see Chapter 7: Private and Public Sector Fair Housing Impediments Analysis). In addition, between 2019 and 2024, FHCRC received 18,234 tenant/landlord complaints, the majority of which were related to notices, lease/rental agreements, repairs, and rental assistance.

4.2 National Origin
The Fair Housing Act and the California Fair Employment and Housing Act prohibit discrimina- tion based upon national origin. According to the United States Department of Justice, such discrimination can be based either upon the country of an individual’s birth or where his or her ancestors originated. Between 2019 and 2024, approximately 7 percent of housing discrimination complaints ﬁled with the FHCRC by Riverside residents cited national origin as the basis. HUD reported that 3 out of the 48 housing discrimination complaints ﬁled during this period (6 percent) were also based on national origin.4 Foreign-born population includes anyone who is not a U.S. citizen or a U.S. national at birth, including respondents who indicated they were a U.S. citizen by naturalization or not a U.S. citizen. Table 30 indicates that Riverside’s foreign born population consists of approximately 70,262 persons. Of this total number, the majority are from Latin America (69 percent) and Asia (24 percent).

Table 30: Foreign Born Population by Region of Birth
Region # %
Europe 2,462 3.5%
Asia 16,547 23.6%
Africa 1,915 2.7%
Oceania 263 0.4%
Latin America 48,627 69.2%
Northern America 448 0.6%
Total 70,262 –
Source: 2018-2022 American Community Survey 5-year Estimates, Table B05002 Place of Birth by Nativity and Citizenship Status.

4.3 Gender
Federal and State fair housing laws prohibit discrimination based on a person’s gender. The Department of Justice (DOJ) emphasizes that the Fair Housing Act prohibits housing discrimination based on gender. The DOJ has prioritized addressing sexual harassment in housing, noting that poor women with limited housing choices often feel forced to endure harassment to avoid eviction.5

4 See Chapter 6: Private Sector Fair Housing Impediments Analysis 5 Source: United States Department of Justice, Civil Rights Division, Housing and Civil Enforcement Section, The Fair Housing Act, July 25, 2008, pages 2 and 3.

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City of Riverside March 2025
There are approximately 158,000 males and females each in the City of Riverside. Six percent of the City’s female population report living alone while 5 percent of the City's male population reports living alone. Tenure by sex data is only available for single-male and single- female family households. ACS 2018-2022 estimates that single-male and single-female family households are more likely to be renters than owners (Table 31). Married couple families are the largest household type and the only group that is predominantly homeowners (69 percent). The second largest household type is persons living alone, which has a homeownership rate of almost 44 percent.

Table 31: Household Type by Tenure Owner Renter Total # % # % # %
Family households 40,725 61.0% 26,051 39.0% 66,776 73.8% Married-couple family 31,490 69.2% 14,048 30.8% 45,538 50.3% Other family 9,235 43.5% 12,003 56.5% 21,238 23.5%
Male householder, no spouse
present
3,211 49.0% 3,337 51.0% 6,548 7.2%
Female householder, no
spouse present
6,024 41.0% 8,666 59.0% 14,690 16.2%
Nonfamily households 9,502 40.0% 14,262 60.0% 23,764 26.2% Householder living alone 7,435 44.1% 9,411 55.9% 16,846 18.6% Householder not living alone 2,067 29.9% 4,851 70.1% 6,918 7.6% Total 50,227 55.5% 40,313 44.5% 90,540 100.0%
Source: 2018-2022 American Community Survey 5-Year Estimates, T able B25011: Tenure by Household Type (Including Living Alone) and Age of Householder.

Note: The last column is the percentage of household type of all households – married couple families (45,538) as a percentage of all households (90,540).

Single-female households, especially renters, have high rates of poverty. Approximately 20 percent of single-female headed households earn incomes below the poverty level, compared to only 12 percent of all households (Table 32). This percentage is even higher for single-female renter householders (25 percent) and single-female householders with children. By contrast, only 13 percent of single-male householders earn incomes below the federal poverty line.

Table 32: Poverty Status for Single-Family Households by Tenure (2022) Household Type Total
Below
Poverty Level
% Below
Poverty Level
Single female householder 14,690 2,850 19.4%
Owner 6,024 720 12.0%
Renter 8,666 2,130 24.6%
Single female householder, with children 8,924 2,321 26.0% Single male householder 6,548 858 13.1%
Owner 3,211 246 7.7%
Renter 3,337 612 18.3%
Single male householder, with children 3,468 583 16.8%
All Households 90,540 11,178 12.3%
Sources: 2018-2022 American Community Survey 5-Year Estimates, Table B25011, B17019, B17017, B17012, B11005.

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City of Riverside March 2025
According to the FHCRC, sex/gender was the basis (6.9 percent) of housing discrimination complaints ﬁled by Riverside residents between 2019 and 2024. According to HUD, between 2019 and 2024, three of the 48 persons who ﬁled a housing discrimination complaint did so on the basis of sex.

FHCRC also reported that sexual harassment rose in Riverside County during the COVID-19 Pandemic. During this time, FHCRC ﬁled two sexual harassment complaints with HUD and one sexual orientation complaint with the California Civil Rights Department (CRD), formerly known as the Department of Fair Employment and Housing (DFEH). According to the FHCRC, these three cases highlight a growing trend in the county where landlords, unable to evict tenants for non-payment, resort to other tactics and diƯerential treatment, hoping tenants will vacate voluntarily. This behavior resembles constructive eviction, a legal term in property law describing situations where a landlord fails to fulﬁll their duties, rendering the property uninhabitable. In cases of sexual harassment or discrimination based on sexual orientation, these actions could be seen as constructive eviction, particularly when eviction moratoriums prevent legal evictions.

1. Victims of Domestic Violence
Victims of domestic violence are protected under both Federal and California fair housing laws. At the Federal level, the Fair Housing Act (FHA) prohibits discrimination based on sex, which includes protections for victims of domestic violence, requiring housing providers to make reasonable accommodations such as early lease termination or lock changes.

Additionally, the Violence Against Women Act (VAWA) speciﬁcally safeguards victims of domestic violence, dating violence, sexual assault, and stalking residing in federally subsidized housing by prohibiting denial of housing assistance or eviction based on their victim status and allowing for emergency transfers to ensure safety.

In California, the Fair Employment and Housing Act (FEHA) extends protections against housing discrimination to victims of domestic violence, sexual assault, and stalking, also mandating reasonable accommodations. California Civil Code §1946.7 further allows victims to terminate their leases early without penalty upon providing proper notice and documentation, such as a restraining order or a police report. Both Federal and State laws require that housing providers maintain the conﬁdentiality of information related to the victim's status and any accommodations requested or provided. These protections aim to provide stability and safety for victims of domestic violence, ensuring they have legal means to maintain their housing and seek safer living conditions.

Between 2017 and 2022, the California Department of Justice reported receiving 34,464 domestic-violence-related calls to law enforcement in Riverside County, averaging around 6,892 annually. Black/African American residents are disproportionately impacted by domestic violence, with higher rates two to three times higher than Hispanic and non- Hispanic White residents.6

6 Ruedas, G. Escobar, S. (2024). Domestic Violence in Riverside County. Riverside University Health System- Public Health, Epidemiology and Program Evaluation.

Analysis of Impediments to Fair Housing Choice page 35
City of Riverside March 2025

4.4 Familial Status
Familial status refers to the presence of children under the age of 18, whether the child is biologically related to the head of household, and the martial status of the head of the household. The Fair Housing Amendments Act of 1988 prohibits discriminatory housing practices based on familial status. In most instances, according to the United States Department of Justice, the Act prohibits a housing provider from refusing to rent or sell to families with children. The Act protects families with children less than 18 years of age, pregnant women, or families in the process of securing custody of a child under 18 years of age, and single-parent households.

About 40 percent of the City’s 90,540 households have children under 18 years of age (Table 33). The majority of households with children (65 percent) are married-couple family households. About 25 percent of households with children are in single-female headed households.

Table 33: Poverty Status by Household Type and for Households with Children

Total With Children Below Poverty
Below Poverty
(with Children)
# % # % # % # %
Family households 66,776 73.8% 35,795 53.6% 5,986 9.0% 5,986 16.7% Married-couple family 45,538 50.3% 23,403 51.4% 2,278 5.0% 2,278 9.7% Other family 21,238 23.5% 12,392 58.3% 3,708 17.5% 2,904 23.4% Single male householder 6,548 7.2% 3,468 53.0% 858 13.1% 583 16.8% Single female householder 14,690 16.2% 8,924 60.7% 2,850 19.4% 2,321 26.0% Nonfamily households 23,764 26.2% - - 5,192 21.8% - -
Householder living alone 16,846 18.6% - - 2,157 12.8% - - Householder not living alone 6,918 7.6% - - 3,035 43.9% - - Total 90,540 100.0% 36,041 39.8% 11,178 12.3% - -
Sources: 2018-2022 American Community Survey 5-Year Estimates, Table B25011, B17019, B17017, B17012, B11005.

Notes: A nonfamily household is a householder living alone or with nonrelatives only. Unmarried couples households, whether opposite- sex or same-sex, with no relatives of the householder present are tabulated in nonfamily households.

Figure 7 shows a high percentages of children in married couple households throughout the City with some areas, especially in Alessandro Heights, Mission Grove, Canyon Crest, Victoria, Grand, and University neighborhoods, where more than 80 percent of children live in married couple households. The Victoria, Canyon Crest, Alessandro Heights, Mission Grove, and Orangecrest neighborhoods were developed after 1980 and consist almost exclusively of suburban tract housing.

By contrast, Figure 8 shows that children in female headed households are concentrated in the Arlington, Arlington Heights, Downtown, and Hunter Industrial Park neighborhoods.

Female headed households with children require special consideration and assistance because of their greater need for aƯordable housing and accessible day care, health care, and other supportive services.

Analysis of Impediments to Fair Housing Choice page 36 City of Riverside March 2025 According to the FHCRC, familial status was the basis of approximately 6 percent of housing discrimination complaints ﬁled by Riverside residents between 2019 and 2024. According to HUD, between 2019 and 2024, four of the 48 persons (8.3 percent) who ﬁled a housing discrimination complaint did so on the basis of familial status.7 Figure 7: Percent of Children in Married Couple Households 7 See Chapter 6: Private Sector Fair Housing Impediments Analysis.

Analysis of Impediments to Fair Housing Choice page 37 City of Riverside March 2025 Figure 8: Percent of Children in Single Female-Headed Households 1. Single-Parent Households Single-parent households often require special consideration and assistance as a result of their greater need for aƯordable housing, as well as accessible day care, health care, and other supportive services. Due to their relatively lower per-capita income and higher living expenses such as day-care, single-parent households have limited opportunities for ﬁnding aƯordable, decent, and safe housing. In 2022, approximately 21,238 single-parent households resided within Riverside, representing 24 percent of the City’s households (Table 33). Single-parent households, especially single mothers, may also be discriminated against in the rental housing market. Of particular concern are single-parent households with lower incomes. Data from the 2018-2022 American Community Survey (ACS) indicates that approximately 26 percent and 17 percent of the City’s female-headed households with children and male-headed households had incomes below the poverty level, respectively (Table 33). According to 2018-2022 ACS estimates, 77 percent of single female-headed households that have recently received food stamps are households with children under 18 years old (2,717 households).

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City of Riverside March 2025

2. Tenure by Familial Status
The need for fair housing services is directly correlated to size of the fair housing protected groups against whom housing discrimination is practiced. Table 34 shows that about 40 percent of households, regardless of tenure, have children under the age of 18.

Renters are the group that makes most housing discrimination complaints. There are about 16,100 renter-household with children in the City. As noted earlier, familial status is the basis for approximately 6 percent of all housing discrimination complaints ﬁled by Riverside residents to FHCRC and 8 percent of complaints to HUD.

Table 34: Tenure by Presence of Children (2022)
Presence of Children Owner Percent Renter Percent Total Percent With Related Children Under 18 Years 19,381 38.6% 16,082 39.9% 35,463 39.2% No Related Children Under 18 Years 30,846 61.4% 24,231 60.1% 55,077 60.8% T otal 50,227 100.00% 40,313 100.00% 90,540 100.0%
Source: 2018-2022 American Community Survey 5-Year Estimates, Table B25012 Tenure by Families and Presence of Own Children.

3. Large Households
Large households are deﬁned as those having ﬁve or more members. These households are usually families with two or more children or families with extended family members such as in-laws or grandparents. It can also include multiple families living in one housing unit to save on housing costs. Large households are a special needs group because the availability of adequately sized, aƯordable housing units is often limited. To save for necessities such as food, clothing, and medical care, lower- and moderate-income large households may reside in smaller units, resulting in overcrowding. Furthermore, families with children, especially those who are renters, may face discrimination or diƯerential treatment in the housing market. For example, some landlords may charge large households a higher rent or security deposit, limit the number of children in a complex, conﬁne them to a speciﬁc location, limit the time children can play outdoors, or choose not to rent to families with children altogether, which would violate fair housing laws.

The 2018-2022 American Community Survey (ACS) found 17,917 large households in Riverside, representing approximately 20 percent of all households. Among the City’s large households, 59 percent owned their own homes, while 41 percent were renter-households.

According to the 2016-2020 CHAS data, of the City large family-households, 40 percent had lower- and moderate-incomes (less than 80 percent Area Median Income (AMI)).

Approximately 58 percent of large renter-households earned lower and moderate incomes compared to 27 percent of large owner-households in the same income categories.

The housing needs of larger households are typically met through larger units. While the ACS shows that 29 percent of occupied housing units (26,106 units) in the City had four or more bedrooms, only a small portion of these units (17 percent) were occupied by renters. Since 20 percent of Riverside’s households are large households, lower-income large renter households may have greater diƯiculty securing adequately sized units than other large renter households.

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4.5 Persons with Disabilities
The Fair Housing Amendments Act of 1988 prohibits discriminatory housing practices based on handicap/disability status in all types of housing transactions. Among other prohibitions, the Act is intended to prohibit the application of special restrictive covenants and conditional or special use permits that have the eƯect of limiting the ability of such individuals to live in the residence of their choice. In addition, the law prohibits applying one standard to one class of individuals while applying a diƯerent standard to another class of individuals. For example, it would be illegal to ask an individual with a disability applying for an apartment to provide a credit report if applicants without a disability do not have to provide one.

Other discriminatory practices in the private sector that limit fair housing options for individuals with disabilities often stem from property management policies. For instance, “denied reasonable modiﬁcation/ accommodation” is often cited as an alleged act in housing discrimination complaints. Additionally, apartment rental ads often state “no pets allowed, ” even though disabled persons may have service or companion animals. In the public sector, housing opportunities can be impeded because a community has not adopted a reasonable accommodation procedure, or if adopted has not made the procedure widely known in the community. According to the FHCRC, disability was the basis for almost 50 percent of all housing discrimination complaints ﬁled by Riverside residents between 2019 and 2024.

According to HUD, 18 of the 48 housing discrimination complaints ﬁled did so on the basis of disability. Chapter 6 evaluates property management practices in detail.

Of the civilian noninstitutionalized an estimated 33,824 (11 percent) have a disability (Table 35). White, non-Hispanic residents, and Hispanic/Latino residents make up the majority of the City’s population with a disability. Also, seniors (over 65 years old) make up 41 percent of the City’s population with a disability. One in four households (23,711 households) has a member with a disability. Table 35 also shows that the most common disabilities among the population with a disability are ambulatory diƯiculties, cognitive diƯiculties, and independent living diƯiculties.

Table 35: Characteristics of Population with a Disability (2022) With a Disability
% of Population
with a Disability
Total civilian noninstitutionalized population 33,824 100.0% Race/Ethnicity
White alone 18,121 53.6%
Black or African American alone 2,500 7.4%
American Indian and Alaska Native alone 455 1.3%
Asian alone 2,537 7.5%
Native Hawaiian/Other Paciﬁc Islander alone 209 0.6%
Some other race alone 6,555 19.4%
Two or more races 3,447 10.2%
White alone, not Hispanic or Latino 12,905 38.2%
Hispanic or Latino (of any race) 14,708 43.5%

Analysis of Impediments to Fair Housing Choice page 40 City of Riverside March 2025 Table 35: Characteristics of Population with a Disability (2022) With a Disability % of Population with a Disability Age Under 5 years 196 0.6% 5 to 17 years 2,595 7.7% 18 to 34 years 5,620 16.6% 35 to 64 years 11,599 34.3% over 65 years old 13,814 40.8% Disability Type1 With a hearing diƯiculty 8,585 25.4% With a vision diƯiculty 5,999 17.7% With a cognitive diƯiculty 13,532 40.0% With an ambulatory diƯiculty 16,930 50.1% With a self-care diƯiculty 7,816 23.1% With an independent living diƯiculty 13,168 38.9% Source: 2018-2022 American Community Survey 5-Year Estimates, Table S1810 Disability Characteristics Notes: 1. Persons with a disability can have more than one type of disability and be classiﬁed within more than one of the categories listed. Percentage taken from the total population with a disability. Census tracts with higher percentages of persons with disabilities are scattered throughout the City and not concentrated in one area, though they are highest (relative to other tracts in the city) in southern Arlanza/Northern Arlington, Arlington Heights, and Magnolia Center. Figure 9: Percent Population with a Disability

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City of Riverside March 2025
Riverside is home to a vibrant and active deaf community, with the presence of the California School for the Deaf, Riverside (CSDR). The CSDR provides comprehensive education and support services for deaf and hard-of-hearing students from preschool through high school, fostering a strong sense of community and pride. Additionally, Riverside hosts various social, cultural, and advocacy events aimed at promoting deaf culture and raising awareness about issues aƯecting the deaf community. The City’s commitment to inclusivity is further demonstrated by the creation of the Commission of the Deaf in 2023. Duties of the new Commission of the Deaf include serving in an advisory capacity to help create an integrated community that promotes full participation in society, education and employment, eƯective communication, and cultural awareness; reviewing community policies, programs, and actions which aƯect persons within the deaf community and make appropriate recommenda- tions to City Council; render advice and assistance as requested to other City boards, commissions, and City departments on matters aƯecting members of the deaf community; and performing other functions, community outreach, and duties as may be directed by the City.

Four factors – aƯordability, design, location, and discrimination – signiﬁcantly limit the supply of housing available to persons with disabilities. The most pressing need for persons with disabilities is housing that accommodates the nature of their disability. Most single-family homes are inaccessible to people with mobility and sensory limitations. Conventional housing often does not feature widened doorways and hallways, access ramps, larger bathrooms, lowered countertops, and other features necessary for accessibility. The cost of retroﬁtting a housing unit often prohibits disabled individuals from buying a home, even among those who could otherwise aƯord one.

The location of housing is also a factor for individuals with mobility-related disabilities, as they often rely upon public transportation. Transportation services for persons with disabilities are typically provided by public and private agencies. The City’s Special Transportation Division manages the Riverside Connect Program. Riverside Connect is an origin-to-destination advanced reservation transportation service for seniors and persons with disabilities.

Understanding the employment status of people with disabilities may also be an important component in evaluating specialized housing needs. In Riverside, only 26 percent of the population with a disability is employed, which is far lower than the 61 percent employment rate among those without disabilities. This data indicates housing units that are universally accessible will also need to be aƯordable given disabled individuals’ limited employment status and incomes.

1. Persons with Developmental Disabilities
SB 812, which took eƯect January 2011, amended State Housing Element Law to require the analysis of the persons with disabilities to include an evaluation of the special housing needs of persons with developmental disabilities. A "developmental disability" is deﬁned as a disability that originates before an individual becomes 18 years old, continues or can be expected to continue indeﬁnitely, and constitutes a substantial disability for that individual.

This includes intellectual disability, cerebral palsy, epilepsy, and autism.

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Many persons with developmental disabilities can live and work independently within a conventional housing unit. More severely disabled individuals often require a group living environment, however, where supervision is provided. The most severely aƯected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the ﬁrst issue in supportive housing for the developmentally disabled is the transition from the person’s living situation as a child to an appropriate level of independence as an adult.

The U.S. Census does not have speciﬁc information regarding persons with developmental disabilities. However, each nonproﬁt regional center contracted with the California Department of Developmental Services maintains an accounting of the number of persons served. The Inland Regional Center serves persons in the City of Riverside, as well as other cities in the Inland Empire. As of December 2021, the Inland Regional Center served 3,802 individuals with developmental disabilities residing in Riverside County. About 47 percent of clients are under the age of 18, and the majority of clients live at home with a parent, family, or guardian.

4.6 Religion
The Fair Housing Act speciﬁcally protects individuals from religious discrimination in housing.

For example, if a Jewish tenant requests to place a mezuzah on their doorpost, or a Muslim tenant needs a designated prayer area, the landlord must accommodate these requests unless they pose a signiﬁcant burden. Similarly, tenants are allowed to display religious symbols, like crosses or shrines, in their homes or on their doors. The Act also requires landlords to address any harassment tenants face due to their religious practices, ensuring they can observe their faith without fear of discrimination.

The U.S. Census Bureau and American Community Survey do not collect data on religion.

Religious data in the United States is typically gathered by private organizations and research institutions and is limited at the City level. The most recent data available for the Riverside County area was gathered by the Association of Religion Data Archives (ARDA). According to ARDA, in 2020 approximately 44.2 percent of the County’s population (1.1 million) were adherents8 of a religious body. Of these adherents, the majority were Catholic (61 percent), followed by Evangelical Protestant (21 percent), Latter-day Saints (5 percent), Jehovah’s Witnesses (4 percent), and Black Protestant (3 percent).

8 Adherents include full members, non-member children, and other regular participants who are not considered members. Surveyors (Association of Statisticians of American Religious Bodies, ASARB) ask participating religious bodies to provide or estimate the number of these adherents.

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4.7 Senior-Headed Households
Senior-headed households are considered special needs groups due to their relatively low incomes, disabilities or limitations, and dependency needs. The senior age range includes individuals over 65 years of age.9 This group has four main concerns: limited and often ﬁxed income; poor health and associated high healthcare costs; mobility limitation and transit dependency; and high costs of housing.

According to ACS data collected between 2018 and 2022, households headed by seniors (age 65+) represented approximately 21 percent of all Riverside households (Table 36). Of these, the majority (73 percent) owned their homes, while the remaining 27 percent rented.

Additionally, about 14 percent of the City’s households consist of seniors living alone, with about 40 percent of these senior-headed households renting. Many seniors have a disability; roughly 40 percent of Riverside’s noninstitutionalized senior population had one or more disabilities according to ACS data collected during the same period.

The need for housing for senior individuals will likely increase as the City’s number of senior- headed households continues to grow. It will therefore be particularly important for the City to promote housing types that accommodate senior lifestyles and incomes.

Table 36: Senior Headed Households by Tenure

Owner Renter Total
# % # % # %
Householder 65 years or over 14,000 73.2% 5,116 26.8% 19,116 21.1% Householder over 65 year living alone 4,085 59.7% 2,759 40.3% 6,844 13.6% Source: 2018-2022 American Community Survey, Table B25007 Tenure by Age of Householder and Table B25011 Tenure by Household Type (Including Living Alone) and Age of Householder.

Notes: Total column percentages calculate the percent from all households – 90,540. (i.e., the percent of all households (90,540) that are headed by householder over 65 years or older (19,116).

4.8 Limited English Proﬁciency (LEP)
According to HUD’s OƯice of General Counsel (OGC), people with limited English proﬁciency are not a protected class under the Fair Housing Act. However, the OGC explains that there is a close link between Limited English Proﬁciency (LEP) and certain racial and national origin groups. Therefore, HUD advises that an analysis of people with LEP be included in the AI.

LEP refers to a person’s limited ability to read, write, speak, or understand English. Individuals who are LEP are not a protected class under the Act. Nonetheless, the Act prohibits housing providers from using LEP selectively based on a protected class or as a pretext for discrimination because of a protected class. The Act also prohibits housing providers from using LEP in a way that causes an unjustiﬁed discriminatory eƯect.

The American Community Survey deﬁnes a “limited English speaking household” as one in which no member 14 years old and over 1) speaks only English at home or 2) speaks a language other than English at home and speaks English “Very well. ” This question identiﬁes

9 HUD definition of seniors is 62 years or older. However, Census data usually is available for persons 65 years or older.

Analysis of Impediments to Fair Housing Choice page 44 City of Riverside March 2025 households that may need English-language assistance. Approximately 6,077 limited English speaking households reside in Riverside. Almost 68 percent are Spanish speaking, and 20 percent speak Asian and Paciﬁc Island languages. Limited English speaking households comprise about 7 percent of all households living in the City. These limited English speaking households are concentrated in northern Riverside (Eastside, University, and Hunter Industrial Park) as well as in west Riverside (La Sierra Acres and Arlanza). Table 37: Limited English Speaking Households (2022) Limited English-Speaking Households Percent of all Limited English-Speaking Households Households Speaking: Spanish 4,106 67.6% Other Indo-European Languages 503 8.3% Asian and Paciﬁc Island Languages 1,239 20.4% Other Languages 229 3.8% T otal 6,077 100.0% Source: 2018-2022 American Community Survey, Table S1602, Limited English Speaking Households Figure 10: Households Speaking English Less than “Very Well”

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City of Riverside March 2025

4.9 Source of Income
In 2019, the State passed SB 329 and SB 222, expanding the source of income protection.

The City’s Housing Authority currently administers the Housing Choice Voucher (HCV) program, which assists 2,068 residents as of September 2024. Of these, 1,754 are supported through the Tenant Based Program, while 314 are supported through the Project Based Voucher Program. HCV recipients represent a diverse population, with a signiﬁcant number of elderly and individuals with disabilities (Table 38). Approximately 56 percent of recipients are elderly, and 53 percent have a disability. Black residents are overrepresented among HCV recipients, making up 33 percent of the pool despite only representing 5 percent of the City's overall population.

To ensure fair housing compliance, the Housing Authority refers voucher holders to the Fair Housing Council of Riverside County for guidance. Additionally, the Housing Authority oƯers the Family Self-SuƯiciency Program to help participants achieve self-suƯiciency. The current waitlist for HCV assistance is substantial, with 144,350 individuals registered, and wait times are inﬂuenced by funding availability and applicant preferences.

Table 38: Demographic Proﬁle of Housing Choice Voucher Recipients

Number of
Recipients
Percent of
Recipients
Special Needs
Elderly (62 years or older) 1,149 56.4%
With a disability 1,069 52.5%
Race
American Indian/Alaska Native 41 2.0%
Asian 76 3.7%
Black/African American 665 32.6%
Native Hawaiian/Other Paciﬁc Islander 24 1.2%
White 1,232 60.5%
Other 30 1.5%
Ethnicity
Hispanic 712 34.9%
Non-Hispanic 1,356 66.5%
Total 2,068 101.5%
Source: Riverside Housing Authority, September 2024.

Geographically, HCV recipients are concentrated in neighborhoods in northern Riverside (Downtown, Eastside, Hunter Industrial Park, University, Magnolia Center and Grand) and are most concentrated in west Ramona. Most notably, HCV recipient is less prevalent in southern Riverside, in areas that have been identiﬁed as racially concentrated areas of aƯluence and higher resources (see the Public/Private Sector Analysis of Impediments).

Analysis of Impediments to Fair Housing Choice page 46 City of Riverside March 2025 Figure 11: Housing Choice Voucher Use Distribution Between 2019 and 2023, FHCRC received 14 discrimination complaints speciﬁcally citing source of income protection. Notably, the number of such complaints increased signiﬁcantly in recent years, with four and six complaints ﬁled in FY 2022 and FY 2023, respectively. This is a sharp rise from the previous years, which typically saw only one or two complaints. 4.10 Persons Experiencing Homelessness According to United States Department of Housing and Community Development (HUD), the homeless population includes:  Individuals and families who lack a ﬁxed, regular, and adequate nighttime residence, including individuals who are exiting an institution where they resided for 90 days or less and who resided in an emergency shelter or a place not meant for human habitation immediately before entering that institution;  Individuals and families who will imminently lose their primary nighttime residence;  Unaccompanied youth and families with children and youth who are deﬁned as homeless under other federal statutes who do not otherwise qualify as homeless under this deﬁnition; or

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 Individuals and families who are ﬂeeing, or are attempting to ﬂee, domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions that relate to violence against the individual or a family member According to the City’s 2023 Point in Time Homeless Count, the total homeless count was 977 individuals, with the majority (62 percent) unsheltered. Additional information about Riverside’s homeless characteristics is presented in the table below.

Table 39: Riverside Homeless Characteristics (2023)
Category # % City Count
Age
Children (≤17) 6 1.0%
Youth (18-24) 36 6.0%
Adults (25-34) 517 85.5%
Adults (65+) 46 7.6%
Living Situation
Abandoned Building 18 6.5%
Bus Station 4 1.5%
Encampment 31 11.3%
Park 21 7.6%
Street 116 42.2%
Tent/Shed 38 13.8%
Tiny Home (without basic amenities) 2 0.7%
Under Bridge 6 2.2%
Vehicle 39 14.2%
Other 0 0.0%
Primary Reason for Homelessness (interview only)
Family Disruption 70 25.5%
Domestic Violence 7 2.5%
Jail Release 17 6.2%
Lack of Income 44 16.0%
Medical Discharge 1 0.4%
Mental Illness 14 5.1%
Runaway 6 2.2%
Substance Abuse 20 7.3%
Unemployment 26 9.5%
Other 47 17.1%
Challenges / Barriers (interview only, not mutually exclusive) Chronic Health Issue 54 19.6%
Domestic Violence 21 7.6%
HIV AIDS 1 0.4%
Mental Health Issue 63 22.9%
Physical Disability 57 20.7%
PTSD 77 28.0%
Substance Abuse 85 30.9%
Traumatic Brain Injury 45 16.4%
Developmental Disability 37 13.5%

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Table 39: Riverside Homeless Characteristics (2023)
Category # % City Count
Special Interest Questions
Households w/ Children 1 0.4%
Chronically Homeless (generated based on qualifying responses) 127 46.2% First Time Homeless (self-report) 82 29.8%
Pet Owner 49 17.8%
Foster Care Experience 5 1.8%
Formerly Incarcerated 47 17.1%
Health Insurance Coverage 173 62.9%
Veterans (extrapolated) 60 21.8%
Source: Riverside County 2023 Homeless Point-in-Time Count and Survey.

Notes: Age calculations based on total homeless count (977 persons). All other categories based on interviews (265 unsheltered persons).

In October 2022, the City of Riverside adopted the Riverside Homeless Action Plan. The plan sets forth speciﬁc goals aimed at preventing homelessness, increasing housing production with a focus on aƯordability, enhancing the availability of services for physical and mental health and substance use disorder treatment, improving the availability and eƯectiveness of emergency shelters, creating a coordinated regional infrastructure of services, and expanding public awareness.

Each goal includes speciﬁc progress targets. For instance, the housing production goal aims to increase the inventory of aƯordable housing units by ﬁve percent and maintain 90 percent of expiring aƯordable housing covenants. In terms of service enhancement, the target is to reduce chronic homelessness by 5 percent and homelessness among individuals struggling with substance abuse by 5 percent. For emergency shelters, the goal is to increase the number of emergency shelter beds by 25 percent in 2023 and reduce the number of unsheltered individuals by 10 percent.

The plan was reviewed and commented upon during several community meetings to gather input from low-income residents at risk of becoming homeless, service providers working with currently homeless individuals, and those who have experienced homelessness in the past.

This feedback process will continue throughout the implementation of the plan to ensure its relevance to changing conditions.

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5. Public Sector Impediment Analysis
Public policies established at the regional and local levels can aƯect housing development and therefore may have an impact on the range and location of housing choices available to residents. Fair housing laws are designed to encourage an inclusive living environment and active community participation. This section presents an overview of government regulations, policies, and practices enacted by the City that may impact fair housing choice.

5.1 Housing Development Policies and Programs
The General Plan of a jurisdiction establishes a vision for the community and provides long- range goals and policies to guide the development in achieving that vision. Two of the eight State-mandated General Plan elements – Housing and Land Use Elements – have direct impact on the local housing market in terms of the amount and range of housing choice. The Zoning Ordinance, which implements the Land Use Element, is another important document that inﬂuences the amount and type of housing available in a community – the availability of housing choice.

1. Housing Element Law and Compliance
As one of the State-mandated elements of the local General Plan, the Housing Element is the only element with speciﬁc statutory requirements and is subject to review by the State Department of Housing and Community Development (HCD) for compliance with State law.

Housing Element law requires that local governments adequately plan to meet the existing and projected housing needs of all economic segments of the community. The law acknowledges that, for the private market to adequately address housing needs and demand, local governments must adopt land use plans and regulatory systems that provide opportunities for, and do not unduly constrain, housing development. Speciﬁcally, the Housing Element must:
 Identify adequate sites which will be made available through appropriate zoning and development standards and with services and facilities needed to facilitate and encourage the development of a variety of types of housing for all income levels in order to meet the community’s housing goals;
 Assist in the development of adequate housing to meet the needs of extremely low-, lower- and moderate-income households;
 Address, and where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing;
 Conserve and improve the condition of the existing aƯordable housing stock; and  Promote and aƯirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and

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City of Riverside March 2025
other characteristics protected by the California Fair Employment and Housing Act, or any other state and federal fair housing laws.

Speciﬁcally in 2017, the State passed AB 686, requiring the Sixth Cycle Housing Element update (covering the 2021-2029 planning period) to include an analysis of barriers that restrict access to opportunity and a commitment to speciﬁc meaningful actions to aƯirmatively further fair housing.

Compliance Status
A Housing Element found by HCD to be in compliance with State law is presumed to have adequately addressed its policy constraints. According to HCD, as of September 26, 2022, the City’s Adopted Sixth Cycle Housing Element meets statutory requirements of State Housing Element Law (Government Code, § 65580 et seq).

2. Land Use Element
The Land Use Element of a General Plan designates the general distribution, location, and extent of uses for land planned for housing, business, industry, open space, and public or community facilities. As it applies to housing, the Land Use Element establishes a range of residential land use categories, speciﬁes densities (typically expressed as dwelling units per acre [du/ac]), and suggests the types of housing appropriate in a community. Residential development is implemented through the zoning districts and development standards speciﬁed in the jurisdiction’s Zoning Ordinance.

Residential Densities
Multiple factors, governmental and non-governmental, aƯect the supply and cost of housing in a local housing market. The governmental factor that most directly inﬂuences these market conditions is the allowable density range of residentially designated land. In general, higher densities allow developers to take advantage of economies of scale, reduce the per-unit cost of land and improvements, and reduce developments costs associated with new housing construction. Reasonable density standards ensure the opportunity for higher-density residential uses to be developed within a community, increasing the feasibility of producing aƯordable housing. Minimum required densities in multi-family zones ensure that land zoned for multi-family use, the supply of which is often limited, will be developed as eƯiciently as possible for multi-family uses.

Riverside’s General Plan Land Use designations that allow residential uses are summarized in Table 40. In addition to the residential land use categories, the City has adopted multiple Speciﬁc Plans that contain additional residential land use categories or districts. State law requires a local government to make a ﬁnding that a density reduction, rezoning, or downzoning is consistent with its Housing Element prior to requiring or permitting a reduction of density of a parcel below the density used in determining Housing Element compliance.

The legislation also allowed courts to award attorneys’ fees and costs if the court determines that the density reduction or downzoning was made illegally.

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Table 40: Residential Land Use Designations Allowing Housing General Plan
Land Use Category
Corresponding
Zone Districts
Max Density
(du/ac)
Type of Residential Development
Allowed
Agricultural/Rural Residential RA-5 0.20 Residential agriculture Hillside Residential RC 0.63 Residential conservation
Semi-Rural Residential RR
RE
R-1-1/2acre

3.3 Rural residential, residential estate,
single-family
Very Low Density Residential RE
R-1-1/2 acre

3.2 Residential estate, single family
Low Density Residential RR
RE
R-1-1/2 acre
R-1-13000
R-1-10500

6.0 Rural residential, residential estate,
single-family
Medium Density Residential RE
R-1-1/2 acre
R-1-13000
R-1-10500
R-1-8500
R-1-7000
MH

8.0 Residential estate, single-family. Mobile
home park
Medium High Density
Residential
R-1-7000
R-3-4000
R-3-3000

14.5 Single-family and multi-family
High Density Residential R-3-4000
R-3-3000
R-3-2500
R-3-2000
R-3-1500
29 Multi-family
Very High Density Residential R-4 40 Multi-family
Downtown Speciﬁc Plan DSP Various Mixed-use
Orangecrest Speciﬁc Plan OSP Various Mixed-use
Mixed-Use- Neighborhood MU-N
R-1-13000
R-1-10500
R-1-8500
R-1-7000
10 du/ac, and

1.0 FAR/acre
Mixed-use, single-family
Mixed-Use – Village MU-V
R-3-4000
R-3-3000
R-3-2500
R-3-2000
R-3-1500
R-4
30/401 du/ac,
and 2.5
FAR/acre
Mixed-use, multi-family
Mixed Use- Urban MU-U
R-3-4000
R-3-3000
R-3-2500
R-3-2000
R-4
40/601 du/ac,
and 4.0
FAR/acre
Mixed-use, multi-family
Agriculture RA-5 0.20 Residential agriculture
Source: City of Riverside, 2021-2029 Housing Element.

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The relative amounts of single- and multi-family zoned land is a fair housing concern because communities that are predominantly or exclusively single-family limit the range of available housing choices, and, as a consequence, may adversely impact fair housing protected groups such as racial minorities and disabled people. Table 41 shows that 6.1 percent of the residential acreage is designated for multi-family housing in the MHDR, HDR and VHDR Zones. With the rezoning that occurred along the Housing Element adoption in August 2022, increased capacity (approximately 400 acres) was made available to accommodate additional housing opportunities.

Table 41: Residential Land Use Acreage Distribution
Residential Land Use Category
Net Acreage
in the City
Percent of
Residential Acres
A/RR Agricultural/Rural Residential 5,116 19.1
HR Hillside Residential 4,061 15.2
SRR Simi-Rural Residential 1,227 4.6
VLDR Very Low Density Residential 1,327 5.0
LDR Low Density Residential 2,563 9.6
MDR Medium Density Residential 10,877 40.6
MHDR Medium High Density Residential 665 2.5
HDR High Density Residential 856 3.2
VHDR Very High Density Residential 108 0.4
Total 26,800 100.0
Source: Riverside General Plan 2025, Amended August 2019, Table LU-4, page LU-145

3. Zoning Ordinance
The Zoning Ordinance implements the General Plan by establishing zoning districts that correspond with General Plan land use designations. Development standards and permitted uses in each zoning district are speciﬁed to govern the density, type, and design of diƯerent land uses for the protection of public health, safety, and welfare (Government Code, §§65800- 65863). Several aspects of the Zoning Ordinance that may aƯect a person’s access to housing or limit the range of housing choices available are described below.

As part of the Housing Element update, jurisdictions are required to evaluate their land use policies, zoning provisions, and development regulations, and make proactive eƯorts to mitigate any constraints identiﬁed. The following review is based on the current Zoning Ordinance as of the writing of this AI.

Deﬁnition of Family
A community can potentially restrict access to housing for households failing to qualify as a “family” by the deﬁnition speciﬁed in the Zoning Ordinance. For instance, a landlord may refuse to rent to a “nontraditional” family based on the zoning deﬁnition of a family. A landlord may also use the deﬁnition of a family as an excuse for refusing to rent to a household based on other hidden reasons, such as household size. Even if the code provides a broad deﬁnition, deciding what constitutes a “family” should be avoided by jurisdictions to prevent confusion or give the impression of restrictiveness.

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California court cases10 have ruled that a deﬁnition of “family” that: 1) limits the number of persons in a family; 2) speciﬁes how members of the family are related (i.e., by blood, marriage or adoption), or 3) a group of not more than a certain number of unrelated persons as a single housekeeping unit, is invalid. Court rulings stated that deﬁning a family does not serve any legitimate or useful objective or purpose recognized under the zoning and land planning powers of the jurisdiction, and therefore violates rights of privacy under the California Constitution. A Zoning Ordinance also cannot regulate residency by discrimination between biologically related and unrelated persons. Furthermore, a zoning provision cannot regulate or enforce the number of persons constituting a family.

The deﬁnition of family within the Zoning Code is, “any individual or group of individuals living together, in a dwelling unit as a single housekeeping unit. Family does not include larger institutional group living situations, such as in a boarding house or hotel/motel/long-term stay. ” The City’s deﬁnition does not include limitations related to blood relation or number of unrelated persons and, therefore, does not limit the development of group housing for persons with disabilities.

Density Bonus
The City initially adopted density bonus provisions for aƯordable housing in accordance with Government Code §65915-65918 in 2007 and most recently updated the Density Bonus Ordinance in 2024. The City’s density bonus regulations are contained in Chapter 19.545 of the Zoning Code. These provisions facilitate the development of aƯordable housing by allowing for a density bonus and other regulatory concessions in exchange for the development of aƯordable housing units. Based on the number of units provided and the percentage designated for low-income, very-low income, or senior households, an applicant may request a density bonus and/or other concessions such as reductions in development standards or reductions in fees.

The 2021-2029 Housing Element Action Plan included an action to bring the City’s Density Bonus Ordinance into compliance with more recent changes to state law, including AB 1763 and AB 2345. The City completed amendments in 2022 and 2024 to comply with updated state law and will continue to monitor state density bonus law to ensure ongoing compliance with state requirements.

Parking Requirements
Communities that require an especially high number of parking spaces per dwelling unit can negatively impact the feasibility of producing aƯordable housing or housing for special needs groups by reducing the achievable number of dwelling units per acre, increasing development costs, and thus restricting the range of housing types constructed in a community. Typically, the concern for high parking requirements is limited to multiple-family, aƯordable, or senior housing. The basic parking standards for the City of Riverside are presented in Table 42.

When compared to other cities in the region, Riverside’s parking requirements are comparable and, in some cases, more lenient. For example, Riverside requires two spaces

10 City of Santa Barbara v. Adamson (1980), City of Chula Vista v. Pagard (1981), among others.

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per unit for multi-family units with two or more bedrooms, where some cities may require 2.5 or more spaces per unit with three or more bedrooms. Additionally, Riverside does not require any guest parking for multi-family developments, further removing a constraint on achieving the maximum density for a multi-family project. Finally, the City has removed parking requirements altogether for ADUs, which is above and beyond what is required by State law.

Table 42: Parking Requirements
Dwelling Type Required Parking1
Single-family residential Two parking spaces/unit, within a private garage Accessory dwelling unit None required
Multi-family residential Studio: 1 space/unit
1 Bedroom: 1.5 spaces/unit
2 or more Bedrooms: 2 spaces/unit
Rooms that can be used as bedrooms count as bedrooms. At least 75% of the total spaces must be within an enclosed garage or carport.

Tandem parking may be provided when assigned to units with two or more bedrooms.

Group Housing 6 or fewer residents: Parking shall be provided consistent with the requirements for single-family or multi-family dwellings, dependent on the type of residential development in which the group housing is located.

More than 6 residents: Determined by the designated Approving or Appeal Authority in conjunction with required land use or development permits, based on the impacts of the proposal and similar uses.

Assisted Living (7 or more clients) 0.5 parking spaces per bed Transitional Housing / Supportive
Housing
Parking shall be provided consistent with the requirements for single- family or multi-family dwellings, dependent on the type of residential development in which the transitional or supportive housing is located.

Emergency Shelters SuƯicient parking to accommodate all staƯ working in the emergency shelter, provided that the standards do not require more parking than that for other residential or commercial uses within same zone.

Mobile Home Park 1 parking space per mobile home site plus 1 oƯ-street guest parking space for every 5 mobile home sites
Single Room Occupancy 1 parking space/unit
Senior Housing 1 parking spaces/unit, of which 50% must be covered either in a carport or a garage
Student Housing 1.1 parking spaces per bed; or 0.5 space/bed if housing is located within ¼ mile of a major transit stop or campus.

Source: City of Riverside Zoning Code, 2024.

The City has updated its parking requirements for emergency shelters to comply with the requirements of AB 139 that limit required parking to spaces needed to accommodate staƯ working at the shelter. Although the City’s parking requirements for transitional housing and supportive housing are generally consistent with state requirements, AB 2162 contains special provisions for supportive housing located within one-half mile of transit. In this case, no parking is required. An additional zoning amendment is needed to comply with this requirement.

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Variety of Housing Opportunity
To ensure fair housing choice in a community, the City’s Zoning Code should provide for a range of housing types, including single-family, multi-family, accessory dwelling units, mobile and manufactured homes, residential care facilities, emergency shelters, supportive housing, transitional housing, and single room occupancy (SRO) units. Table 43 and Table 44 provide a summary of Riverside’s Zoning Ordinance as it relates to ensuring a variety of housing opportunities.

Table 43: Allowable Residential Uses in Residential Zones Residential Uses
Residential Zones
RC RA-5 RR RE R-1 R-3 R-4
Traditional Housing
Single-Family Dwelling Detached P P P P P P1 P1
Single-Family Dwelling Attached X X P P P P1 P1
Manufactured Dwelling P P P P P P P
Mobile Home Park - - With Overlay Zone X X
Accessory Dwelling Unit/
Junior Accessory Dwelling Unit

P P P P P P P
Multiple-Family (2 or more units) X X X X X 2 P P
Live-Work X X X X X X X
Planned Residential Development PRD - PRD PRD PRD X X
Special Needs Housing
Assisted Living (Residential Care Facility) X X X X C C X Boarding House X X X X X C X
Caretaker Living Quarters
Agricultural - C MC - MC - -
Industrial Use & Commercial Storage - - - - - - -
Temporary during Construction TUP TUP TUP TUP TUP TUP TUP Group Homes (6 or fewer persons) P P P P P P P
Group Homes (7 or more persons) X X C C C X X
Parolee/Probationer (6 or fewer persons) X X MC MC MC X X Parolee/Probationer (7 or more persons) X X C C C X X
Senior Housing4 X X X X MC P P
Emergency Shelters (6 or fewer persons)3 X X MC MC MC X X Emergency Shelters (7 or more persons)3 X X C C C X X
Sober Living Homes P P P P P P P
Student Housing X X X X X C C
Supportive Housing (6 or fewer persons) P P P P P P P
Supportive Housing (7 or more persons) P P P P P P P
Transitional Housing (6 or fewer persons) P P P P P P P Transitional Housing (7 or more persons) P P P P P P P
Tiny Home Community (Foundation) X X X X X P P
P Permitted by Right
C Conditional Use Permit
PRD Planned Residential Development Permit
SP Site Plan Review Permit
MC Minor Conditional Use Permit
X Prohibited Use
TUP Temporary Use Permit

1. Permitted as part of a PRD.

2. Legal existing duplexes built prior to the adoption of the Zoning Code are permitted in the R-1-7000 zone.

3. Emergency shelters are permitted by right in the Industrial Zone.

4. Age Restricted to 55+.

5. Group homes with 7+ persons cannot be permitted in the RA-5 and RC Zones as modiﬁcations to these zones require voter approval pursuant to Proposition R and Measure C.

Source: City of Riverside Zoning Code

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Table 44: Allowable Residential Uses in Nonresidential Zones Residential Uses
Commercial Mixed Use1

O CR CG CRC MU-N MU-V MU-U
Traditional Housing
Single-Family Dwelling Detached x x x x P x x
Single-Family Dwelling Attached x x x x P x x
Manufactured Dwelling x x x x P x x
Mobile Home Park x x x x x x x
Accessory Dwelling Unit/Junior Accessory Dwelling Unit x x x x P P P Multiple-Family (2 or more units) x x x x x P P
Live Work x x x x P/MC P/MC P/MC
Planned Residential x x x x x x x
Special Needs Housing
Assisted Living C C C x x x x
Boarding House x x x x x x x
Caretaker Living Quarters
Agricultural x x x x x x x
Industrial Use/Commercial Storage x x x x x x x
T emporary during Construction TUP TUP TUP TUP TUP TUP TUP Group Homes (6 or fewer) x x x x P P P
Group Homes (7 or more) C C C C x x x
Senior Housing3 x x x x MC P P
Emergency Shelters (6 or fewer persons)2 MC MC MC x x x x Emergency Shelters (7 or more)2 C C C x x x x
Single Room Occupancy (SRO) x x x x x x C
Sober Living Homes x x x x P P P
Student Housing x C C x x C C
Supportive Housing (6 or fewer clients) MC MC MC X P P P Supportive Housing (7 or more clients) C C C X P P P
Transitional Housing (6 or fewer clients) MC MC MC X P P P Transitional Housing (7 or more clients) C C C X P P P
Tiny Home Community4 C C C C C C C
Source: City of Zoning code, 2020
P = Permitted by right.

C = Conditional Use Permit
PRD = Planned Residential
SP = Site Plan Review Required
MC = Minor Conditional Use
X = Prohibited Use
TUP = Temporary Use Permit

1. Mixed-use is also allowed in the Downtown Speciﬁc Plan.

2. Shelters are permitted by right in the Industrial Zone.

3. Age Restricted to 55+.

4. Only permitted with a CUP when incidental to an Assemblies of People – Non-Entertainment use

Single- and Multi-Family Uses
Single- and multi-family housing types include detached and attached single-family homes, duplexes, town homes, condominiums, and rental apartments. The City’s Zoning Code identiﬁes a variety of zones where these uses are allowed. However, the Zoning Code implements “pyramid or cumulative zoning” because lower-density single-family uses are allowed in zones intended for higher density multi-family uses. Allowing or requiring a lower density use in a zone that can accommodate higher density uses is regulated by State law.

Recent changes to the Housing Element law such as AB 1397 and SB 2292 (Adequate Sites), SB 166 and SB 330 (No Net Loss), and AB 678 (Housing Accountability Act) provide certainty regarding development density. For Housing Element sites to accommodate the lower income RHNA, a minimum density of 20 units per acre was established.

Commented [TM1]: Need another footnote – only
permitted with a CUP when incidental to an Assemblies
of People – Non-Entertainment use
Commented [RK2R1]: Footnote added

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Mobile Homes and Manufactured Housing
State law requires local governments to permit manufactured or mobile homes meeting federal safety and construction standards on a permanent foundation in all single-family residential zoning districts (Section 65852.3 of the California Government Code). Because these units can be a source of housing for lower-income individuals, including seniors and the disabled, overly restrictive regulation of these uses can indirectly impede housing choice.

The City allows the installation of manufactured homes certiﬁed under the National Manufactured Housing Construction and Safety Standards Act of 1974 on a foundation system, pursuant to §18551 of the Health and Safety Code, on lots zoned for conventional single-family residential dwellings. Such uses are not subject to any administrative, planning, or development process or requirement. The Riverside Zoning Code meets all legal requirements for mobile and manufactured housing types.

Tiny Home Communities and Mobile Home Parks
Tiny home communities and mobile home parks allow for multiple single-family dwellings to be placed on one site. With smaller unit sizes, they provide another source of aƯordable housing, particularly for smaller lower income households. Per the Zoning Code, a tiny home is deﬁned as: “a structure constructed on a chassis, intended for separate, independent living quarters that meets all of the following conditions:
 The unit cannot (and is designed not to) move under its own power;  When sited on a parcel the wheels and undercarriage shall be skirted;  No larger than allowed by California State Law for movement on public highways;  Has at least 100 square feet of ﬁrst ﬂoor interior living space;  Is self-contained unit including basic functional areas supporting daily needs (cooking, sleeping, toiletry);
 Is designed and built to look like a conventional building structure;  Shall be licensed and registered with the California Department of Motor Vehicles and meet the American National Standards Institute 119.5 or National Fire Protection Association 1192 requirements;
 Is served by underground utilities; and
 Is not a recreational vehicle as deﬁned in the Zoning Code.

Tiny home communities with structures on a chassis are allowed with the approval of a conditional use permit in the RR, RE, R-1, and R-3 residential zones and all commercial and mixed-use zones, but only when conﬁgured as incidental uses to a primary Assemblies of People – Non-Entertainment use. Tiny home communities where the structures are placed on a permanent foundation are permitted within the R-3 and R-4 zones.

According to the Department of Finance, there were an estimated 2,227 mobile home units within the City of Riverside, several of which provide aƯordable housing for seniors. Mobile home parks are permitted in the RR, RE, and R-1 zones with a Mobile Home Park Overlay Zone and approval of a conditional use permit. The Zoning code requires that mobile home parks be at least 10 acres, have a maximum density of 10 units per acre, and comply with standards in accordance with Title 25 of the California Code of Regulations. The Zoning code establishes

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setback standards for mobile home parks that are like the R-3 zone. The City has also worked with partners to rehabilitate and preserve the condition of viable mobile home parks.

Accessory Dwelling Units
California law requires local jurisdictions to adopt ordinances that establish the conditions under which Accessory Dwelling Units (ADUs) are permitted. In response to changing State regulations, the City has updated its ADU provisions several times over the past few years, most recently in 2022. However, with multiple new ADU-related bills passed by the State legislature each year, the City’s provisions need to be reviewed and updated once again for compliance with new provisions, most recently AB 2533 and SB 1211. Additionally, State regulations will continue to be monitored and future amendments to the City’s Zoning Code made as necessary to remain in compliance.

Caretaker’s Living Quarters
Caretaker’s living quarters can provide a signiﬁcant source of aƯordable housing. The Zoning Code deﬁnes a caretaker’s living quarters as a single-family dwelling unit as an accessory to an agricultural, professional, commercial, or industrial use for occupancy by the owner/caretaker. Caretaker’s living quarters for industrial uses are permitted in three industrial zones (I, AI, and AIR) and the CS Overlay zone pursuant to a Minor Conditional Use Permit, where 24-hour onsite management is required. Within the industrial and commercial zones, the unit is limited to 650-square feet and 2 bedrooms and is covenant restricted to be occupied by the owner or employee of the business where the unit is located. Caretaker’s living quarters associated with agricultural uses are permitted with a conditional use permit in the RA-5 zone and with a minor conditional use permit in the RR and R-1 zones with a minimum lot size of ﬁve acres.

Senior Housing
The Riverside Zoning Code allows development of multi-family senior housing in zones that allow multi-family development. Senior housing developments are also subject to additional density bonuses and additional use allowances based on the zoning district. In addition, senior housing could be permitted in single-family residential zones as a group home or residential care facility of six or fewer or with a minor conditional use permit in R-1 zones.

Farmworker Housing
The Residential Agricultural Zone (RA-5) is established to provide areas where general agricultural uses can occur independently or in conjunction with a single-family residence that preserves the agricultural character of the area. Currently, only Caretaker’s Living Quarters (see discussions above) are identiﬁed as an accessory use conditionally permitted in the zone.

The Employee Housing Act requires the following: (1) Employee housing for six or fewer employees is considered and permitted similarly as a single-family residential use, (2) Farmworker housing for 36 beds or 12 units should be considered an agricultural use and permitted similarly as other agricultural uses in the same zone (such as the City’s RA-5 zone).

The 2021-2029 Housing Element included a program to amend the Zoning Code to implement

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State requirements (Program 5-5). In November 2023, the City made amendments to the Zoning Code deﬁnition of “agricultural use” to include farmworker housing consistent with the Employee Housing Act; however, an amendment to clarify that employee housing for six or fewer employees is permitted as a single-family residence is still necessary. This provision of employee housing for six or fewer employees extends beyond the scope of farmworker housing but covers all employer-provided housing.

Single Room Occupancy Housing (SRO)
AB 2634 amending the State Housing Element law also mandates that local jurisdictions address the provision of housing options for extremely low-income (ELI) households. Single- Room Occupancy (SRO) units provide a source of aƯordable housing for lower income individuals, including seniors, single workers, and persons that have recently experienced homelessness. The Zoning Code deﬁnes an SRO development as “a multi-unit housing development for very low income persons that typically consists of a single room and shared bath, also may include a shared common kitchen and common activity area. ” SRO units typically do not require a move-in deposit and are leased monthly, further removing barriers for very low-income individuals.

Pursuant to SB 2 (2007), jurisdictions must include provisions for SRO development and are limited on the types of performance and development standards that they may impose on SROs. In 2018, as part of the implementation of the 2014-2021 Fifth Cycle Housing Element, the City adopted Ordinance No. 7408 which included provisions for SRO development. SRO projects are conditionally permitted in the MU-U zone. Chapter 19.401 of the Zoning Code contains site location, operation, and development standards for SROs which are consistent with State law.

Student Housing
The City of Riverside has an extensive system of universities, colleges, and educational institutions and one of the largest populations of students in southern California. To accommodate the need for student housing, the Zoning Code allows student housing, fraternities and sororities, and dormitories with a conditional use permit in two residential zones (R-3 and R-4), two oƯice and commercial zones (CR and CG), and two mixed-use zones (MU-V and MU-U). Thousands of student units are available in Riverside and developers are proposing additional units.

Policies for Housing for Persons with Disabilities
Residential Care Facilities
The Lanterman Developmental Disabilities Services Act (§5115 and §5116 of the California Welfare and Institutions Code) declares that mentally and physically disabled persons are entitled to live in normal residential surroundings and that the use of property for the care of six or fewer disabled persons is a residential use for zoning purposes. A state-authorized, certiﬁed, or licensed family care home, foster home, or group home serving six or fewer persons with disabilities or dependent and neglected children on a 24-hour-a-day basis is considered a residential use that is permitted in all residential zones. No local agency can impose stricter zoning or building and safety standards on these homes (commonly referred

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to as “group” homes) of six or fewer persons with disabilities than are required of the other permitted residential uses in the zone. The Lanterman Act covers only licensed residential care facilities.

To that end, the Health and Safety Code (§§1500 et seq.) requires that State-licensed residential care facilities serving six or fewer persons be (1) treated the same as a residential use, (2) allowed by right in all residential zones, and (3) treated the same with respect to regulations, fees, taxes, and permit processes as other residential uses of the same type in the same zone. Residential care facilities include but are not limited to residential facilities for the elderly, persons with developmental disabilities, and other state-licensed facilities.

The Zoning Code permits the above uses primarily under the term “group homes, ” which is deﬁned as, “any living situation including motels and hotel buildings that are not for temporary use, that accommodates unrelated individuals, and may include but not be limited to the following types of facilities: (1) licensed alcohol and drug treatment facilities; (2) licensed board and care homes for the elderly including convalescent or rest homes and nursing homes; (3) licensed homes for minor children; (4) licensed homes for mental patients; (5) licensed homes for the developmentally disabled; and (6) single- room occupancy (SRO) projects. Group housing would typically involve a living arrangement where either support services are provided to the occupants, where cooking, living or support sanitary facilities are shared in common between the occupants or where there is a formal program establishing rules of conduct and purpose of the facility. ”
As required by State law, group homes serving six or fewer persons are permitted in all residential zones and all mixed-use zones as a by-right use. Larger facilities serving seven or more individuals are conditionally permitted in the RR, RE, and R-1 residential zones and the O, CR, CG, and CRC commercial zones. Besides general regulations, group homes serving seven or more persons are subject to a 300-foot separation from another group home (including an assisted living facility or shelter) and 1,000 feet from a parolee/probationer home. A group home shall have no more than 40 beds nor shall serve more than 40 clients at the same time (RMC Section 19.315.040).

The City, through its Zoning Code, deﬁnes group homes to include motels and hotels that are used for an extended stay, student dormitory, and other group housing situations. While not consistent with the State deﬁnition of group homes under the Lanterman Disabilities Services Act, the City’s approach is broader and permissible and helps the City achieve its housing goals. The City will review the zoning provisions for large group homes (i.e., seven or more occupants) and implement mitigating strategies to remove potential constraints to placing large group homes in Zoning districts that are constrained by voter-approved restrictions (i.e., RA-5 and RC).In order to provide clarity on which types of uses are permitted as residential care facilities, adding a deﬁnition for residential care facility and/or updating the deﬁnition for group homes and the other similar uses listed above has been added as a Program in the 2021-2029 Housing Element (Program 5-3).

Emergency Shelters
An emergency shelter provides housing with minimal supportive services for homeless persons and is limited to occupancy of 6 months or less by a homeless person. No individual

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or household may be denied emergency shelter because of an inability to pay (Health and Safety Code §50801[e]). Enacted in 2007, SB 2 requires local governments to identify one or more zones where emergency shelters can be permitted without approval of a discretionary permit. Further, the identiﬁed zone must have suƯicient capacity to accommodate local shelter need and provide capacity for at least one year-round shelter, at a minimum. The City may require a ministerial permit where limited conditions may be applied; however, the local standards for emergency shelters must be objective and facilitate the development of this use.

In response to State regulations, the City created the Emergency Shelter (ES) Overlay Zone in 2010 where emergency shelters are permitted by-right. The ES Overlay Zone may be applied to the City’s commercial zones and all residential zones, except for the RC and RA-5 zones. The City also has development standards which address lighting, parking, security, management, and number of beds; these standards remain ﬂexible to allow proposals to be evaluated on a case-by-case basis. However, the ES Overlay requires the applicant to process a Zone Change to utilize the overlay provisions. In April 2021, the City amended the Zoning Code to eliminate the ES Overlay. Instead, emergency shelters are now a permitted use by-right in the City’s Industrial Zone. The City’s Industrial zones are located along major corridors and therefore oƯer access to public transportation and services.

Development standards applicable to emergency shelters include varying minimum separation requirements from other emergency shelter facilities, group housing, senior housing, schools, parks, businesses licensed for the sale of alcohol for consumption oƯ- premises, which could constrain the development of this type of facility by reducing the number of locations where it is a use permitted by-right. To address this constraint, the 2021- 2029 Housing Element contains a program to modify these minimum separation standards to further facilitate the provision of emergency shelters, in addition to updating parking standards to be consistent with maximum parking requirements per AB 139 (Program 5-8).

These amendments were completed in 2024. Other standards contained in the Zoning Code relate to the operation of such facilities and are consistent with the requirements of State law, and therefore are not a constraint on this type of facility.

Low Barrier Navigation Centers
Adopted in 2019, AB 101 requires jurisdictions to permit Low Barrier Navigation Centers in mixed-use zones and other nonresidential zones permitting multi-family housing, provided they meet certain requirements. AB 101 deﬁnes a Low Barrier Navigation Center as “a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public beneﬁts, health services, shelter, and housing. ” Low Barrier shelters may include options such as allowing pets, permitting partners to share living space, and providing storage for residents’ possessions. The 2021-2029 Housing Element included Program 5-7 to adopt amendments for consistency with AB 101 and these amendments were completed in 2022.

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Transitional Housing
Transitional housing provides additional housing options for people with disabilities, a protected class of the population. Transitional housing facilities are intended to provide a stay of six months and up to two years during which residents are provided case management and other supportive services that prepare them to obtain and maintain housing and become self- suƯicient. Transitional housing may be provided in a variety of forms, including in group homes, single-family residences, and multi-family residences. Pursuant to State law, transitional housing must be treated as a residential use and may only be subject to the restrictions that apply to other residential dwellings of the same type in the same zone.

The Zoning Code permits transitional housing by-right, regardless of size, in all residential and mixed-use zones. In the O, CR, and CG commercial zones, facilities serving six or fewer individuals require a minor conditional use permit and facilities serving more than six individuals require a conditional use permit.

Supportive Housing
Supportive housing is defined as housing with no limit on length of stay that is occupied by a target population and that is linked to onsite or oƯsite services that assist the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community (California Health and Safety Code §50675.14 [b]). Target population means persons, including persons with disabilities, and families who are "homeless, " as that term is deﬁned by §11302 of Title 42 of the United States Code, or who are "homeless youth, " as that term is deﬁned by paragraph (2) of subdivision (e) of §11139.3 of the Government Code.

Like transitional housing, supportive housing may be provided in a group home setting, or within a single- or multi-family residential setting. The Zoning Code allows supportive housing by-right in all residential and mixed-use zones, and supportive housing facilities are only subject to the restrictions that apply to residential dwellings of the same type in the same zone. Small supportive housing facilities (six or fewer clients) are also permitted with a minor conditional use permit in the O, CR, and CG commercial zones. Large facilities (more than six clients) require a conditional use permit in these commercial zones.

The State Legislature adopted AB 2162 in 2018, which requires jurisdictions to permit supportive housing developments with 50 or fewer units by-right in zones where multi-family and mixed-use development is permitted, provided the development meets certain requirements. Further, cities may not impose parking requirements for supportive housing based on the number of units if they are located within one-half mile of a public transit stop.

While the City’s current Code is compliant with the requirement that larger facilities be permitted by-right in certain zones as described above, a zoning code amendment is necessary to clarify that parking is not required for supportive housing developments meeting the speciﬁc requirements of AB 21622 and within one-half mile of a public transit stop.

Reasonable Accommodation
Both Federal and State fair housing laws require local governments to make reasonable accommodations in local zoning and land use regulations when such accommodations are

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necessary to aƯord disabled persons an equal opportunity to use and enjoy a dwelling.

Reasonable accommodations most commonly grant modiﬁcations or exceptions to development standards; for example, a setback modiﬁcation to allow a wheelchair access ramp within the required front yard setback of a dwelling.

The City ﬁrst adopted Chapter 19.850, “Fair Housing and Reasonable Accommodation, ” in 2003 and most recently updated its Request for Reasonable Accommodation procedures in 2022. Prior to the most recent amendments, Requests for Reasonable Accommodation followed the same timeline as a Variance and were subject to the required approval ﬁndings for variances, in addition to the reasonable accommodation ﬁndings. The 2022 amendments revised the reasonable accommodations procedures and removed the requirement to make the variance approval ﬁndings.

Requests for Reasonable Accommodations are typically reviewed and approved by the Development Review Committee; however, the Committee may refer complex or controversial requests to the Planning Commission. To approve a Request for Reasonable Accommodation, the following ﬁndings must be made by the Development Review Committee:
 The persons who will use the subject property are protected under Fair Housing Laws;  The requested exception to zoning law is necessary to make speciﬁc housing available to a dwelling occupant;
 The requested exception will not impose an undue ﬁnancial or administrative burden on the City; and
 The requested exception will be in compliance with all applicable Building and Fire Codes and will not require a fundamental alteration of the zoning laws and procedures.

Decisions of the Development Review Committee or Planning Commission on Request for Reasonable Accommodation applications may be appealed to the City Council.

4. Building, Occupancy, Health and Safety Codes
Building Codes
Building codes, such as the California Building Standards Code,11 are necessary to protect public health, safety, and welfare. However, local codes that require substantial improve- ments to a building might not be warranted and deter housing construction and/or neighborhood improvement.

The California Building Standards Code is published every three years by order of the California legislature. The Code applies to all jurisdictions in the State of California unless otherwise annotated. Adoption of the triennial compilation of Codes is not only a legal mandate, it also ensures the highest available level of safety for citizens and that all construction and maintenance of structures meets the highest standards of quality.

11 California Building Code, adopted by the Building Standards Commission, is actually a set of uniform building, electrical, mechanical, and other codes adopted by professional associations such as the International Conference of Building Officials, and amended to include California-specific requirements.

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The latest version of California Code of Regulations (2022 CBC), Title 24, the California Building Standards Code was adopted by the City of Riverside and became eƯective on January 1, 2023. As part of the adoption of the CBC, a city may adopt additional codes if it makes an express ﬁnding that such modiﬁcation is reasonably necessary because of local climatic, geological, or topographical conditions (Health and Safety Code §17958.7). The City Council has adopted local amendments to address these speciﬁc local conditions, primarily related to ﬁre suppression and protection; repair and reconstruction of damaged structures; seismic safety concerns; and noise insulation standards.

In addition, City adheres to federal laws that require at least 5 percent of publicly funded new units be accessible to persons with mobility impairments and an additional 2 percent of the units be accessible to persons with hearing or visual impairments. New multiple-family housing must also be built so that: 1) the public and common use portions of such units are readily accessible and usable by persons with disabilities; 2) doors allowing passage into and within such units can accommodate wheelchairs; and 3) all units contain adaptive design features.

The City has established a procedure for resolving the application of building codes and its impact on housing opportunities for people with disabilities. The City is charged with the responsibility to convene an Accessibility Appeals Board comprised of four members of the Planning Commission, plus three additionally designated persons with disabilities, at least two of whom shall be mobility impaired. This Board may conduct hearings on written appeals of decisions of the Building OƯicial regarding accessibility issues and approve or disapprove interpretations and enforcement actions taken by the Building OƯicial relating to access.

Occupancy Standards
In general, no State or federal regulations govern occupancy standards. The California Civil Rights Department (CRD) (formerly known as the Department of Fair Employment and Housing (DFEH)) uses the “two-plus-one” occupancy standard in considering the number of persons per housing unit – two persons per bedroom plus an additional person per unit. While CRD also uses other factors, such as the age of the occupants and size of rooms, to consider the appropriate standard, the two-plus-one rule is generally followed. Other guidelines are also used as occupancy standards – the California Fire Code and the California Housing Code. The Fire Code allows one person per 200 square feet of building ﬂoor area. The Uniform Housing Code outlined a standard of one person for every 50 square feet of bedroom space.

These standards are typically more liberal than the “two-plus-one” rule.

The Zoning Code does not contain an occupancy standard or deﬁnitions of “dwelling unit” or “family” that could be interpreted as an occupancy standard that could be more restrictive than that established in the California Fire Code or CRD guidelines.

5. Development Fees
The City of Riverside collects fees to process plans submitted for residential projects and to ﬁnance the provision of important services that are needed to accommodate housing and population growth. Some fees are collected to fund City services and infrastructure, while others are collected on behalf of and passed through to other agencies for similar purposes.

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Fees and exactions are used to ﬁnance public facilities, roadways, water and sewer infrastructure, schools, and other community services.

As shown in Table 45, the total fees per unit for a typical 25-unit apartment project are $26,862. For a similar project, but with aƯordable units and on a site that was previously developed, the per-unit fees are $19,312. The total per unit fees for the 10-unit condominium project were $36,296, indicating that the cost per unit generally goes down with the development of additional units. The cost for single-family units falls around $49,897 per unit in subdivisions and is lower at $44,792 for an inﬁll unit.

While permit and development fees do represent a signiﬁcant cost, they are necessary to expand and maintain infrastructure to support expanding residential development and to cover the City’s costs of reviewing and processing permits. Riverside’s development fees do not represent a greater constraint to housing development in comparison to other jurisdictions in the region. The Western Riverside Council of Governments conducted an Analysis of Development Impact Fees in Western Riverside County in 2016. The fee study showed that the average residential development impact fees in the region were $28,314 per multifamily unit. Therefore, the per-unit fees indicated in Table H-1: Typical Housing Fees, ranging from $19,312 to $36,296, are generally comparable to the region. Riverside’s permit fees are lower than average, when it is considered that the totals presented include actual construction cost for water and electricity service. Figure H-2: Development Fees shows the City’s fees for permitting processes in 2020 that are often needed for residential construction including site plan review, conditional use permits, and variances. The Western Riverside County Council of Government’s (WRCOG) Transportation Uniform Mitigation Fee (TUMF) program includes an exemption for aƯordable projects. The TUMF is typically the largest development fee for a project; therefore, the exemption is a signiﬁcant incentive. Finally, developers proposing apartments or Planned Residential Developments (PRD) that contain units aƯordable to lower income residents can receive higher densities (and thereby project revenues) plus concessions for qualiﬁed projects through the AƯordable Housing Density Bonus provisions. Density bonuses improve the ﬁnancial feasibility of projects and create a third layer of ﬁnancial beneﬁts for developers.

Table 45: Typical Housing Development Fees

25-Unit
Multi-Family
Apartment
Project1
25-Unit Multi-
Family Apartment
Project
(AƯordable)2
10-Unit
Condominium
Project3
30-Unit
Single-Family
Subdivision4
Single Family
Unit, Inﬁll5
Entitlement Fees
Design Review $3,560 $3,560 $3,560 $3,560 -
Tentative Map - - $10,516 $10,516 -
Preliminary WQMP Review $1,669 $1,669 $1,669 $1,669 -
Landscape Design Review $919 $919 $919 $1,407 $488
Permitting, Utilities Design and Construction9
Building Plan Check
(valuation based)
$8,000 $8,000 $5,000 $30,000 $1,400
Grading Permit $4,100 $4,100 $4,100 $15,200 $2,700
Final Map Check - - $5,000 $5,000 -
Final WQMP Plan Check $1,500 $1,500 $1,500 $1,500 -

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Table 45: Typical Housing Development Fees

25-Unit
Multi-Family
Apartment
Project1
25-Unit Multi-
Family Apartment
Project
(AƯordable)2
10-Unit
Condominium
Project3
30-Unit
Single-Family
Subdivision4
Single Family
Unit, Inﬁll5
Sewer Permit $7,700 $7,700 $6,000 $20,000 $1,700
Storm Drain Fee $1,000 $1,000 $1,000 $16,000 $500
Sewer Connection Fee $91,000 $91,000 $36,000 $129,000 $4,300 Acreage Fee (Storm Drain
Supplement)
$900 $900 $500 $4,500 $150
Utility Plan Review Deposit $2,000 $2,000 $2,000 $2,000 - Water10 $43,700 $43,700 $37,700 $175,00 $1,500
Electrical11 $100,000 $100,000 $85,000 $200,000 $2,500
Development Impact and Permit Fees
Local Park Fee $76,000 $76,000 $26,000 $139,380 $4,646
Regional Park Fee $5,500 $5,500 $3,000 $27,445 $850
Aquatic Park Fee $7,400 $7,400 $2,400 $13,050 $435
TraƯic Impact Fee (City) $10,500 $10,500 $4,200 $15,750 $525 TraƯic Signal Fee $3,100 $3,100 $1,300 $5,700 $190
Building Fee (valuation
based)
$8,000 $8,000 $5,000 $30,000 $1,400
TUMF (County)6 $159,725 $63,890 $266,190 $8,873
MSHCP (County)7 $29,025 $11,610 $109,050 $3,635
School Fees $100,250 $100,250 $40,100 $255,000 $8,500
Miscellaneous8 $6,000 $6,000 $5,000 $20,000 $500
Total $671,548 $482,798 $362,964 $1,496,917 $44,792
Total per Unit $26,862 $19,312 $36,296 $49,897 $44,792
Source: City of Riverside, Planning Division, 2021

1. 25-unit multi-family apartment project on 1-acre site with 1,000 sf/unit

2. 25-unit aƯordable multi-family apartment project on 1-acre site with 1,000 sf/unit, developed on a site that was previously developed

3. 10-unit condominium project on 0.5-acre site with 1,000 sf/unit

4. Low-income housing projects may be exempt from this fee.

5. Projects on sites that were previously developed are exempt from this fee.

6. Miscellaneous permits/fees include ﬁre permits, street tree fees, inspections, temporary power, issuance, imaging fees, etc.

7. The Utilities cost estimates assume standard rates and installation and do not account for additional costs that frequently occur based on the speciﬁc of a given site or project. Construction costs may double or triple those shown.

8. Includes ﬁre service (6”), domestic service (2”), landscape service (2”), and other construction/installation costs.

9. Includes cost of typical design and construction.

Conclusions and Recommendations
The City has identiﬁed impediments within its planning and zoning policies that must be addressed to advance fair housing initiatives eƯectively. Amendments to the Zoning Code are necessary to align with State law, focusing on areas such as:
 Group Homes/Residential Care Facilities: Review and develop mitigating strategies to eliminate barriers for large group homes in restrictive Zoning districts (RA-5 and RC).  Permanent Supportive Housing: A zoning code amendment is necessary to clarify that parking is not required for supportive housing developments within one-half mile of a public transit stop.

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 Employee and Farmworker Housing: The Zoning Code currently does not address the requirements of the Employee Housing Act. Changes to the Zoning Code will allow the City to implement the State requirements.

5.2 AƯordable Housing Development Policies and Programs In general, many minority and special needs households are disproportionately aƯected by a lack of adequate and aƯordable housing in a region. While aƯordability issues are not directly fair housing issues, expanding access to housing choices for these groups cannot ignore the aƯordability factor. Insofar as rent-restricted or non-restricted low-cost housing is concentrated in certain geographic locations, access to housing by lower-income and minority groups in other areas is limited and can therefore be an indirect impediment to fair housing choice. Furthermore, various permit processing and development impact fees charged by local government results in increased housing costs and can be a barrier to the development of aƯordable housing. These issues are examined in the subsections below.

1. Siting of AƯordable Housing
Riverside has 63 aƯordable housing developments, ranging in size from one to 268 housing units. These developments include senior housing, supportive housing, and project-based rental housing. As shown in Figure 12 assisted housing is located throughout west and north Riverside. Most of these aƯordable housing developments are concentrated in northern and western Riverside where transit services and facilities (government facilities, community centers, and shopping centers) are concentrated.

Analysis of Impediments to Fair Housing Choice page 68 City of Riverside March 2025 Figure 12: Assisted Housing Inventory and City Facilities 2. Sixth Cycle Sites Inventory AB 686 requires that jurisdictions identify sites throughout the community in a manner that is consistent with its duty to aƯirmatively further fair housing. The site identiﬁcation requirement involves not only an analysis of site capacity to accommodate the Regional Housing Needs Allocation (RHNA), but also whether the identiﬁed sites serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. Sites were placed based on available vacant and underutilized properties throughout the city placing a high priority to the available sites in high resource areas. The built-out nature of the city along with the number of residential units needed to meet RHNA requirements limited the city’s ability to be selective in the placement of sites which resulted in a concentration of sites in low resource areas. However, the city’s RHNA sites strategy attempts to disperse the sites to oƯer opportunities in high resource areas. About 13 of the RHNA units are in the highest and high resources census tracts. Furthermore, the city’s RHNA sites strategy provides a signiﬁcant number of moderate-income units in the low resource areas. This would help to facilitate mixed-income neighborhoods. In addition, the city included policies and programs including those that serve to support fair housing through fair housing enforcement and programs to assist special needs groups in its 2021-2029 Housing Plan.

Analysis of Impediments to Fair Housing Choice page 69 City of Riverside March 2025 Figure 13: Distribution of Sixth Cycle Sites Inventory by Resource Category Table 46: Distribution of RHNA Sites TCAC Resource Category Lower Income Moderate Income Above Moderate Income All RHNA Units # % # % # % # % Highest 0 0.0 % 970 7.7% 0 0.0 % 970 4.6% High 259 3.1% 1,541 12.3% 0 0.0 % 1,800 8.6% Moderate (Rapidly Changing) 143 1.7% 510 4.1% 0 0.0 % 653 3.1% Moderate 3,113 37.0% 3,550 28.3% 31 55.4% 6,694 31.9% Low 2,130 25.3% 4,237 33.8% 25 44.6% 6,392 30.4% High Segregation and Poverty 2,763 32.9% 1,727 13.8% 0 0.0 4,490 21.4% Total 8,408 100.0% 12,535 100.0% 56 1 20,999 100.0% Conclusions The concentration of aƯordable housing in low resource areas, both in the current aƯordable housing inventory and in the Sixth Cycle sites inventory, presents an opportunity for positive transformation in these neighborhoods. Redeveloping the sites in these areas would have a positive impact on these neighborhoods through the introduction of new economic

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opportunities; the introduction of new aƯordable housing options; providing new or refurbished infrastructure and public realm improvements; and providing new funding for services and amenities like schools through payment of development impact fees. The City's inclusion of place-based, community health, and environmental equity strategies in its Housing and Action Plans underscores a commitment to improving these areas while safeguarding residents from displacement. Moving forward, sustained implementation of these strategies will be crucial in fostering inclusive growth and enhancing quality of life across these communities.

5.3 Community Participation Process and Policies
Adequate community involvement and representation are important to overcoming and identifying impediments to fair housing or other factors that may restrict access to housing.

Decisions regarding housing development in a community are typically made by the City Council and Planning Commission. The Council members are elected oƯicials and answer to the constituents. Planning Commissioners serve an advisory role to the elected oƯicials. The City’s Planning Commission consists of nine members. In addition to the City Council and Planning Commission, most jurisdictions have appointed commissions, committees, and boards to address speciﬁc issues. For example, the City of Riverside has a Commission of the Deaf, Budget Engagement Commission, Commission on Disabilities, Commission on Aging, and the Humans Relations Commission.

Commission of the Deaf. Members act in an advisory capacity on facilitating the removal of barriers toward integration and participation of persons of the deaf community into all economic, political and community living areas.

Budget Engagement Commission. Advise on spending and policy priorities based on information received through quarterly ﬁnancial and performance reports including revenues from transaction and use tax, work with City staƯ to maximize public engagement on municipal budgetary issues, and provide input on performance measures and reporting programs.

Commission on Disabilities. Advise the City Council on all matters aƯecting persons with disabilities in the community; review community policies, programs, and actions that aƯect persons with disabilities; and help create a public awareness of the needs in areas such as housing, employment, and transportation.

Commission on Aging. Study the local senior issues to learn about current programs, deﬁne future needs, and reference Best Practices to make recommendations to the Mayor and City Council on how to maintain and improve its status as a Senior-Friendly Community.

Human Relations Commission. Advise on issues of discrimination and advocate for equal opportunity, justice, and access to services and opportunities. The Commission engages in activities designed to aid in the elimination of prejudice, intolerance, and discrimination against individuals or groups because of race, color, religion, national origin, language, citizenship status, sex, sexual orientation, gender identity, gender expression, or cultural background. The Commission empowers communities and institutions by promoting an informed and inclusive multicultural society.

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Community participation can be limited or enhanced by actions or inaction by a public agency. A broader range of residents may feel more comfortable approaching an agency with concerns or suggestions if that agency oƯers sensitivity or diversity training to its staƯ members that typically interface with the public. In addition, if there is a mismatch between the linguistic capabilities of staƯ members and the native languages of local residents, non- English speaking residents may be unintentionally excluded from the decision-making process. Another factor that may aƯect community participation is the inadequacy of an agency or public facility to accommodate residents with various disabilities.

Finally, the City’s public facilities are accessible; however, not all facilities are fully compliant with every requirement under the Americans with Disabilities Act (ADA). The City makes every eƯort to reasonably accommodate persons with disabilities at public meetings and to ensure equal access to any public facility, program, service, or function.

On December 2023, the City Council adopted a Citywide Community Engagement Policy.12 that provides a comprehensive policy for engagement and formalizes expectations for community outreach eƯorts for projects of all types. The City will continue to prioritize implementation of the Citywide Community Engagement Policy for all land use proposals, both City-initiated and applicant-driven. Opportunities to reﬁne and expand engagement eƯorts for housing development projects will be examined as opportunities to revisit the Policy arise.

The City's outreach eƯorts demonstrate a multi-faceted approach to engaging the community, focusing on inclusivity, accessibility, and responsiveness to diverse needs. Key aspects of the City’s outreach are as follows:

Multi-Channel Communication and Accessibility
The City advertises meetings and events using a combination of the City website, social media, mailers, local newspapers, and the Riverside Chamber of Commerce calendar. This variety of communication channels, supplemented by city-wide mailer distribution, maximizes accessibility across demographic groups, including those without digital access.

Meetings are oƯered in English, Spanish, and American Sign Language (ASL), and other language accommodations are provided upon request. This proactive approach accommodates Riverside's linguistic diversity, ensuring that residents with limited English proﬁciency can participate meaningfully.

Meetings and events are held in ADA-compliant locations, and ASL interpreters and other language accommodations are available upon request. Additionally, accessibility accommodations are actively promoted in outreach materials, ensuring residents are fully informed and encouraged to participate.

12 Citywide Community Engagement Toolkit,
https://riversideca.legistar.com/View.ashx?M=F&ID=12350609&GUID=B23EC379-48C4-4A6B-929A- 8BF4A5E8324A

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All information about housing opportunities and resources is available in English and Spanish, with additional languages available upon request.

Targeted Outreach and Inclusivity
The City uses city-wide mailer distribution and targeted social media outreach using ﬁlters to reach various demographics to reach marginalized communities.

Meetings held in each city ward further ensure accessibility for residents in hard-to-reach neighborhoods, supporting equitable engagement across the City.

Feedback Mechanisms and Ongoing Evaluation
Feedback from community meetings is recorded and followed up with, ensuring community voices are valued and incorporated into decision-making. Contact information on mailers and social media allows the City to gather input from residents unable to attend, expanding the reach of community input.

Regular evaluations through the Annual Action Plan and a ﬁve-year city-wide survey provide data on outreach eƯectiveness, allowing the City to adjust strategies in alignment with fair housing goals, thus fostering continuous improvement.

Conclusions and Recommendations
The presence of elected oƯicials, advisory commissions, and inclusive policies demonstrates a commitment to diversity and representation in decision-making processes. Continued monitoring of outreach eƯectiveness through feedback and periodic evaluations will help the City make ongoing improvements, aligning eƯorts with fair housing goals.

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6. Private Sector Fair Housing Impediments Analysis
Private sector impediments to fair housing, prohibited by the 1968 Federal Fair Housing Act (FFHA) and its amendments, as well as the California Fair Employment and Housing Act (FEHA), include various forms of discriminatory practices and barriers that limit equal access to housing opportunities based on protected characteristics. This AI presents an analysis of nine potential private sector impediments to fair housing choice.

6.1 Housing Discrimination
Sections 804 (a), (b), and (d) of the 1968 Fair Housing Act, as amended, describe several prohibited housing discriminatory practices such as the following:
(a) To refuse to sell or rent after the making of a bona ﬁde oƯer, or to refuse to negotiate for the sale or rental of, or otherwise make unavailable or deny, a dwelling to any person because of race, color, religion, sex, familial status, or national origin. (b) To discriminate against any person in the terms, conditions, or privileges of sale or rental of a dwelling, or in the provision of services or facilities in connection therewith, because of race, color, religion, sex, familial status, or national origin. (d) To represent to any person because of race, color, religion, sex, handicap, familial status, or national origin that any dwelling is not available for inspection, sale, or rental when such dwelling is in fact so available.

The California Fair Employment and Housing Act (FEHA) prohibits unlawful practices similar to those that are described in the 1968 Federal Fair Housing Act, as amended. The State law expands the description of prohibited practices to “harassment, ” and to “harass, evict, or otherwise discriminate” for the purpose of “retaliation” against a protected class. Moreover, the State law expands the protected classes to include, among others, sexual orientation, marital status, ancestry, age, and source of income.

Housing discrimination complaints can be ﬁled directly with the U.S. Department of Housing and Urban Development (HUD). In California the housing discrimination complaints are processed by HUD’s OƯice of Fair Housing and Equal Opportunity (FHEO). Riverside residents may also ﬁle complaints with the State Civil Rights Department (formerly Department of Fair Employment and Housing, DFEH), and the Fair Housing Council of Riverside County, Inc. (FHCRC).

1. Fair Housing Council of Riverside County (FHCRC)
FHCRC is a non-proﬁt organization that has the capacity to provide fair housing information, outreach, and enforcement to 24 cities and communities located in Riverside County, including the City of Riverside. The organization is approved by HUD and works with government oƯices to ensure Fair Housing laws are upheld. The mission of the Fair Housing Council is to provide comprehensive services that aƯirmatively address and promote fair housing (anti-discrimination) rights and further other housing opportunities for all per-sons without regard to race, color, national origin, religion, sex, familial status, presence of children, disability, ancestry, marital status, or other arbitrary factors.

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Housing discrimination complaint data was compiled by the FHCRC for the period from FY 2019-2020 through FY 2023-2024. During this 5-year period, 292 housing discrimination complaints were made with the FHCRC by Riverside residents. Table 47 shows that disability was the most frequently cited basis for complaints (46 percent overall, with 34 percent for physical disability and 12 percent for mental disability). One reason for this is that discrimination against individuals with disabilities is often more visible, usually appearing as an explicit rejection of requests for reasonable accommodations or modiﬁcations to housing units. Race, source of income, national origin, and religion also ranked among the top ﬁve bases for discrimination complaints.

Table 47: Housing Discrimination Complaints by Protected Class, FY 2019/2020 to FY 2023/2024
Protected Class Number of Complaints Percentage Distribution Physical Disability 97 34.0%
Race 38 13.3%
Mental Disability 34 11.9%
Source of Income 23 8.1%
National Origin 19 6.7%
Religion 18 6.3%
Familial Status 16 5.6%
Sex 15 5.3%
Age 11 3.9%
Sexual Orientation 7 2.5%
Arbitrary 4 1.4%
Gender 2 0.7%
Ancestry 1 0.4%
Total 285 100.0%
Source: Housing discrimination complaint records of the Fair Housing Council of Riverside County, Inc.

Note: This table reﬂects the total instances a protected class was cited as the basis for a complaint, not the total number of complaints.

FHCRC provided demographic information for residents ﬁling discrimination complaints.

Among the 292 complainants for whom race/ethnicity data was available, approximately 40 percent were White, 36 percent were Black/African American, and 14 percent were Hispanic.

Black residents are disproportionately aƯected by discrimination, comprising 5 percent of the city's population but representing over one-third of the discrimination complainants. White residents are also overrepresented, though to a lesser extent.

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Table 48: Housing Discrimination Complaints by Race/Ethnicity, FY 2019/2020 to FY 2023/2024
Race/Ethnicity
Number
of Complaints
Percentage
Distribution % Population
White 119 39.5% 27.3%
Black/African American 106 35.2% 5.4%
Hispanic 41 13.6% 55.4%
More than one race 16 5.3% 3.0%
Asian 7 2.3% 8.2%
Unknown/Other (Other Multi-Race/Non-Hispanic) 2 0.7% N/A Chose not to respond 1 0.3% N/A
Total 292 100.00% N/A
Source: Housing discrimination complaint records of the Fair Housing Council of Riverside County, Inc.

Note: In FY 2022, FHCRC's quarterly reports changed their approach to reporting race and ethnicity. Before FY 2022, they oƯered 21 combined race/ethnicity options (e.g., Black/African American & Hispanic, Hispanic Black & White, Black non-Hispanic). After FY 2022, they began reporting race and ethnicity separately. The race categories now include American Indian/Alaska Native, Asian, Black or African American, Native Hawaiian or Other Paciﬁc Islander, and White. Ethnicity is reported separately as Hispanic and non-Hispanic. For calculations, the detailed race categories from prior to FY 2022 were grouped as follows: “White” includes White Non-Hispanic and White, “Black/African American” includes “Black/African American and Black Non-Hispanic, and “Hispanic” includes Hispanic, Hispanic Black, Hispanic Black & White, Black/AA & Hispanic.

FHCRC also reports on the number of complaints made by special needs populations (seniors, female-headed households, and persons with disabilities. About 61 percent of complainants belonged to a special needs population. Of these 179 complainants, 127 were persons with disabilities, 29 were female head of households, and 23 were seniors. This aligns with the fact that disability was the most common basis for discrimination complaints.

Actions/resolutions for 142 of the complaints were reported between FY 2019 and FY 2023.

About 72 percent of complaints were counseled, while 25 percent were resolved through education. Only 3 percent (four complaints) were sent to the State Civil Rights Department or to HUD.

Table 49: Housing Discrimination Complaints by Protected Class, FY 2019/2020 to FY 2023/2024
Action Number of Complaints Percentage Distribution
Education 36 25.4%
Counseled 102 71.8%
Civil Rights Department/HUD 4 2.8%
Attorney 0 0.0%
Mediated 0 0.0%
Closed 0 0.0%
Total 142 100.0%
Source: Housing discrimination complaint records of the Fair Housing Council of Riverside County, Inc.

2. Civil Rights Department (CRD)
The mission of the California Civil Rights Department (CRD) is to protect Californians from employment, housing and public accommodation discrimination, and hate violence. To achieve this mission, CRD keeps track of and investigates complaints of housing

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discrimination, as well as complaints in the areas of employment, housing, public accommodations, and hate violence.

Between FY 2020 and FY 2024, 33 cases in Riverside were ﬁled with CRD through the California Civil Rights System (CCRS) (https://ccrs.calcivilrights.ca.gov/s/). The most frequent basis of complaints were disability and race (Table 50). Most complaints involved denial of equal terms and denial of rental/sale/lease (Table 51).

Table 50: Basis for Discrimination Complaints Filed with CRD, FY 2020/2021 to FY 2023/2024
Action Number of Complaints Percentage Distribution
Disability 14 42.4%
Race 11 33.3%
Source 8 24.2%
Color 7 21.2%
Ancestry 5 15.2%
Nat Origin 5 15.2%
Other 5 15.2%
Marital Status 4 12.1%
Sex/Gender 4 12.1%
Fam Status 2 6.1%
Sex Harass 2 6.1%
Religion 1 3.0%
Genetic Info 1 3.0%
Sex Orientation 1 3.0%
Military Status 1 3.0%
Total 71 –
Source: California Civil Rights Department (CRD), August 2024.

Note: This table reﬂects the total instances a protected class was cited as the basis for a complaint, not the total number of complaints.

Some complaints cited multiple basis for discrimination.

Table 51: Acts of Discrimination for Complaints Filed with CRD, FY 2020/2021 to FY 2023/2024
Action Number of Complaints Percentage Distribution
Denied equal terms 20 60.6%
Denied rental/sale/lease 17 51.5%
Denied reasonable accommodation for a disability 11 33.3% Subject to discriminatory statements/advertising 11 33.3% Evicted 5 15.2%
Other 5 15.2%
Subject to restrictive rule/covenant 5 15.2%
Denied reasonable accommodation for religious creed 1 3.0% Subject to discriminatory zoning/land use 1 3.0%
Total 76 –
Source: California Civil Rights Department (CRD), August 2024.

Note: This table reﬂects the acts of discrimination cited in complaints, not the total number of complaints. Some complaints cited multiple acts.

Investigations at CRD begin with the intake of a complaint. Complainants are ﬁrst interviewed to collect facts about possible discrimination. Interviews are normally conducted by

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telephone. If the complaint is accepted for investigation, the CRD drafts a formal complaint that is signed by the complainant and served. If jurisdictional under federal law, the complaint is also ﬁled with the United States Department of Housing and Urban Development (HUD). As a substantially equivalent agency, CRD's ﬁndings are usually accepted by HUD. The recipient of the complaint (usually a landlord, seller, property manager, seller, or agent) is required to answer and has the opportunity to negotiate resolution with the complainant. If the case is not resolved voluntarily, the CRD conducts a formal investigation.

If the investigative ﬁndings do not show a violation of the law, CRD will close the case. If investigative ﬁndings show a violation of law, the CRD schedules a formal conciliation conference. During the conciliation conference, the CRD presents information supporting its belief that there has been a violation and explores options to resolve the complaint. If formal conciliation fails, the CRD Housing Administrator may recommend litigation. If litigation is required, the case may be heard before the Fair Employment and Housing Commission (FEHC) or in civil court. Potential remedies for cases settled by the FEHC include out-of- pocket losses, injunctive relief, access to the housing previously denied, additional damages for emotional distress, and civil penalties up to $10,000 for the ﬁrst violation. Court remedies are identical to FEHC remedies with one exception; instead of civil penalties, a court may award unlimited punitive damages.

Of the 33 complaints ﬁled with the CRD, 70 percent were closed due to no cause determination, 18 percent were settled through voluntary mediation, and 6 percent were successfully conciliated or settled (Table 52).

Table 52: Close Reason for Complaints Filed with CRD,
FY 2020/2021 to FY 2023/2024
Action Number of Complaints Percentage Distribution
No Cause Determination 23 69.7%
Settled by CRD: Voluntary Mediation 6 18.2%
Conciliation/Settlement Successful 2 6.1%
Dismissed for Lack of Jurisdiction 1 3.0%
Complaint Withdrawn 1 3.0%
Total 33 100.0%
Source: California Civil Rights Department (CRD), August 2024.

3. U.S. Department of Housing and Urban Development (HUD) The U.S. Department of Housing and Urban Development (HUD) maintains a record of all housing discrimination complaints for jurisdictions, including the City of Riverside. According to the HUD website, any person who believes their housing rights have been violated may submit a complaint to HUD via phone, mail or the Internet. These grievances can be ﬁled on the basis of race, color, national origin, sex, disability, religion, familial status and retaliation.

HUD refers complaints to the California Civil Rights Department (CRD), which has 30 days to address the complaint. As a substantially equivalent agency, CRD’s ﬁndings are usually accepted by HUD. Thereafter, HUD tracks the complaint and its issues and outcomes as a “dually ﬁled” complaint.

Between January 2019 and June 2024, 39 fair housing cases were recorded by HUD in Riverside. Each case may allege multiple bases of discrimination. Cases involving

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discrimination based on disability and race were the most common although incidences concerning retaliation, color, national origin, and sex were also reported. Most (33) of the 39 cases have been closed, according to HUD. Among these 33 closed cases, 21 cases were determined that no violations occurred; one case was withdrawn by the complainant after resolution; 10 cases were successfully settled/conciliated; and one case was closed because the complainant failed to cooperate.

Table 53: Basis for Discrimination of Cases ﬁled with HUD (2019-2024) 2019 2020 2021 2022 2023 2024 Total*
% of
Basis
Total Cases 3 3 7 10 12 4 39
Basis for Discrimination
Color 1 1 1 4 8.3%
Disability 2 2 3 7 3 18 37.5%
Familial Status 1 1 4 8.3%
National Origin 1 1 1 3 6.3%
Race 1 2 1 2 2 11 22.9%
Religion 1 1 2.1%
Retaliation 1 2 1 4 8.3%
Sex 1 2 3 6.3%
Total 4 5 8 12 15 4 48 100.0%
Source: Department of Housing and Urban Development (HUD), June 2024. *A total of 39 cases were ﬁled, but because some cases alleged discrimination on multiple grounds, the total in this row indicates how often the protected class was cited as a basis for discrimination.

Conclusions and Recommendations
To address housing discrimination eƯectively, the city can take a variety of proactive steps.

This includes fostering ongoing partnerships with a fair housing provider (FHCRC) to conduct community-wide outreach and educational initiatives aimed at increasing awareness of fair housing laws and rights among residents. Maintaining these partnerships will ensure the availability of fair housing services, such as processing discrimination complaints and oƯering counseling to landlords and tenants. Additionally, the city can implement and enforce policies that promote inclusivity in housing design and accommodations for individuals with disabilities, ensuring all properties meet accessibility standards. Moreover, providing comprehensive training programs for landlords, property managers, and real estate professionals on fair housing laws, reasonable accommodations, and cultural sensitivity will further support the city's commitment to fostering fair and equitable housing opportunities for all residents. These actions collectively aim to create a more inclusive and accessible housing environment within the community.

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6.2 Brokerage Services

1. National Association of REALTORS® (NAR)
The National Association of REALTORS® (NAR) has developed a Fair Housing Program to provide resources and guidance to REALTORS® in ensuring equal professional services for all people. The term REALTOR® identiﬁes a licensed professional in real estate who is a member of the NAR; however, not all licensed real estate brokers and salespersons are members of the NAR.

In January 2020, NAR leadership passed the Fair Housing Action Plan, abbreviated ACT!, emphasizing Accountability, Culture Change, and Training to advance fair housing in the industry. NAR provides resources to its members, brokerages, and associations to implement ACT! locally.

Code of Ethics
Article 10 of the NAR Code of Ethics provides that “REALTORS® shall not deny equal professional services to any person for reasons of race, color, religion, sex, handicap, familial status, or national origin. REALTORS® shall not be a party to any plan or agreement to discriminate against any person or persons on the basis of race, color, religion, sex, handicap, familial status, national origin, sexual orientation, or gender identity. ” Additionally, Standard of Practice Article 10-1 states that, “When involved in the sale or lease of a residence, REALTORS® shall not volunteer information regarding the racial, religious or ethnic composition of any neighborhood nor shall they engage in any activity which may result in panic selling, however, REALTORS® may provide other demographic information. ” Standard of Practice 10-3 adds that “REALTORS® shall not print, display or circulate any statement or advertisement with respect to selling or renting of a property that indicates any preference, limitations or discrimination based on race, color, religion, sex, handicap, familial status, national origin, sexual orientation, or gender identity. ” NAR requires all REALTORS® to take an Ethics course developed by NAR as an online course in addition to attending orientation, and every 3 years after joining. All newly instated REALTORS® have 60 days to attend orientation from their activation and 30 days from their activation to complete the Code of Ethics requirement (which is due every 3 years).

Diversity Certiﬁcation
NAR has created a diversity certiﬁcation, “At Home with Diversity: One America” to be granted to licensed real estate professionals who meet eligibility requirements and complete the NAR “At Home with Diversity” course. The certiﬁcation will signal to customers that the real estate professional has been trained on working with diversity in today’s real estate markets. The coursework provides valuable business planning tools to assist real estate professionals in reaching out and marketing to a diverse housing market. The NAR course focuses on diversity awareness, building cross-cultural skills, and developing a business diversity plan.

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2. California Department of Real Estate (DRE)
The California Department of Real Estate (DRE) is the licensing authority for real estate brokers and salespersons. As noted earlier, not all licensed brokers and salespersons are members of the National or California Association of REALTORS® .

The DRE has adopted education requirements that include courses in ethics and in fair housing. To renew a real estate license, each licensee is required to complete 45 hours of continuing education, including three hours in each of the four mandated areas: Agency, Ethics, Trust Fund, and Fair Housing. The fair housing course contains information that will enable an agent to identify and avoid discriminatory practices when providing real estate services to clients.

The law requires, as part of the 45 hours of continuing education, completion of ﬁve mandatory three-hour courses in Agency, Ethics, Trust Fund Handling and Fair Housing and Risk Management. These licensees will also be required to complete a minimum of 18 additional hours of courses related to consumer protection. The remaining hours required to fulﬁll the 45 hours of continuing education may be related to either consumer service or consumer protection, at the option of the licensee.

3. California Association of REALTORS® (CAR)
The California Association of REALTORS (CAR) is a trade association of realtors statewide. As members of organized real estate, realtors also subscribe to a strict code of ethics as noted above. CAR has Diversity and Inclusion Programs and multiple committees and forums (Diversity Committee, Fair Housing and Diversity Forum, Fair Housing Policy Committee, Global Real Estate Forum, and Young Professionals Network Forum) to foster diversity and inclusion within their organizations.

4. Inland Valleys Association of REALTORS®
Real estate professionals whose business is located in the City of Riverside most likely belong to the Inland Valleys Association of REALTORS (IVAR). IVAR has more than 6,000 members, and its headquarters are located on Elizabeth Street in the City of Riverside. According to the Association’s LinkedIn page, “The Association's governing documents have been approved by the National Association of REALTORS® , and the Association is fully compliant with both national and state requirements. The Bylaws have recently been updated to include the most recent thinking of leadership at the national, state and local level. ” In addition, IVAR’s Fair Housing Committee oƯers a platform for members to learn about housing discrimination and advocate for equal housing rights in the community. Like all associations, IVAR has a Multiple Listing Service (MLS). The California Regional Multiple Listing Service, Inc. has established rules and regulations. When entering a new listing on the MLS, according to these rules and regulations, the “property description” ﬁeld may only contain a description of the property, its features, its location or community, speciﬁc terms to or exclusions from a sale (or lease), or legally required statements. Among the items not allowed to appear in the property description is any language that violates Fair Housing/HUD Guidelines. Further, Section VI Public Remarks Sub Part C9 “What is Not Allowed” , of the CRMLS Rules and Regulations

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Reference Guide states the following: “Language that violates applicable fair housing laws and guidelines. ”
Conclusions and Recommendations
Given the eƯorts outlined by organizations like the NAR, the DRE, and local associations such as IVAR, real estate professionals have robust tools to combat housing discrimination. To further advance fair housing goals with limited resources, focusing on ongoing education, community partnerships, and eƯective complaint monitoring remains crucial. These measures can strengthen fair housing practices without requiring substantial ﬁnancial investments, promoting equity and inclusivity in housing markets.

6.3 Steering
Steering is a practice in real estate where agents guide prospective home buyers towards or away from certain neighborhoods based on race, ethnicity, religion, or other discriminatory factors. This is illegal under the Fair Housing Act, as it perpetuates segregation and limits housing opportunities for certain groups. Steering can aƯect the diversity and inclusivity of communities, leading to unequal access to resources and services.

Examples of prohibited steering practices include:
 A realtor deliberately guiding potential purchasers toward or away from certain neighborhoods because of membership in a protected class.  A lender who deliberately guides loan applicants toward or away from certain types of loans because of membership in a protected class.
 Limiting a renter's housing choices by guiding or encouraging the person to look elsewhere, based on a fair housing protected characteristic. This type of steering mostly aƯects apartment seekers as opposed to in-place tenants.

The steering of home buyers probably happens less frequently than in the past because the internet enables home buyers to be more active in the search process and less reliant on realtors. According to the NAR 2023 Proﬁle of Home Buyers and Sellers,13 all homebuyers used the internet to search for a home, with 41 percent starting by looking at properties online and only 20 percent initially contacting a real estate agent.

Conclusions and Recommendations
Steering may adversely impact homebuyers in their search process and when they apply for a loan. Steering also may adversely impact in-place renters and rental apartment seekers.

Corrective actions may be taken by the Federal and State governments regarding loan steering so that abuse does happen in the future as frequently as it occurred in the early to mid-2000s.

However, the steering of apartment seekers is likely to continue, although it is not possible to

13 https://cdn.nar.realtor/sites/default/files/documents/2023-profile-of-home-buyers-and-sellers-highlights-11- 13-2023.pdf?_gl=1*1gic4u7*_gcl_au*MjI0NDAyOTg3LjE3MTg2NTc2NDI.

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measure its frequency. Although steering cannot be precisely quantiﬁed, there is evidence that it exists and, therefore, it does create an impediment to fair housing choice.

6.4 Appraisal Practices
The 1968 Federal Fair Housing Act, as amended, makes it unlawful to discriminate against a protected class in appraising property. An appraisal is a written assessment of market value and is used by mortgage underwriters to determine whether there is suƯicient collateral to lend money to a homebuyer. Unlawful discriminatory appraisal practices, for example, may include:
 Taking into account the race and ethnic make-up of a neighborhood  Taking into the account the race and ethnicity of the seller and/or buyer Homebuyers requiring a loan to buy a home are given the opportunity to review an appraisal report. The Uniform Residential Appraisal Report is a six-page form used by appraisers to determine the value of a home. In bold letters, the form states:
“Note: Race and the racial composition of the neighborhood are not appraisal factors. ” At the end of the report, there are “appraiser’s certiﬁcations, ” which include certiﬁcation #17:
“I did not base, either partially or completely, my analysis and/or opinion of market value in this appraisal report on the race, color, religion, sex, age, marital status, handicap, familial status, or national origin of either the prospective owners or occupants of the subject property or of the present owners or occupants of the properties in the vicinity of the subject property or on any other basis prohibited by law. ”
Under both federal law (the Equal Credit Opportunity Act of 1976 and its implementing regulations) and California law (Business & Professions Code §11423), a lender is generally obligated to inform a credit applicant of the right to receive a copy of the appraisal used in connection with an application, and to honor the applicant's written request for a copy of the appraisal report.

The California Association of REALTORS (CAR) explains that one of the reasons a buyer should obtain an appraisal is “to make sure the lender has not engaged in any discriminatory practices. ”
Consequently, a homebuyer/borrower is entitled to a copy of the appraisal. But a homebuyer and borrower during the purchase process has a bewildering array of documents to review and sign. Additionally, given an appraisal to review, they may not have the knowledge to review an appraisal report to determine if, for example, race or ethnicity were considered in making the appraisal.

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Conclusions and Recommendations
Complaints regarding discriminatory appraisal practices are not routinely collected by local, State or Federal agencies. Data are unavailable to demonstrate if discriminatory appraisal practices adversely impact some of Riverside real estate transactions.

6.5 Unfair Lending Practices
Equal access to credit so that borrowers can purchase a home is a fundamental goal of fair housing. Section 805 of the 1968 Federal Fair Housing Act, as amended, and the Equal Credit Opportunity Act of 1976 prohibit the denial of access to credit because of a loan applicant’s race, color, religion, sex, handicap, familial status, or national origin. This section reviews the lending practices of ﬁnancial institutions and the access to ﬁnancing for all households, particularly minority households and those with lower incomes. Lending patterns in lower and moderate-income neighborhoods and areas of minority concentration are also examined.

However, publicly available data on lending does not contain detailed information to make conclusive statements of discrimination, but can only point out potential areas of concerns.

Furthermore, except for outreach and education eƯorts, a local jurisdiction’s ability to inﬂuence lending practices is limited. Such practices are largely governed by national policies and regulations. Key pieces of legislation are summarized below, although additional protections have been provided during the “great depression” and implosions of the housing market.

1. Legislative Protection
The Community Reinvestment Act (CRA) in 1977 and the subsequent Home Mortgage Disclosure Act (HMDA) were designed to improve access to credit for all members of the community and hold the lender industry responsible for community lending.

Community Reinvestment Act and Home Mortgage Disclosure Act The CRA is intended to encourage regulated ﬁnancial institutions to help meet the credit needs of their entire communities, including lower- and moderate-income neighborhoods.

Depending on the type of institution and total assets, a lender may be examined by diƯerent supervising agencies for its CRA performance. However, the CRA rating is an overall rating for an institution and does not provide insights regarding the lending performance at speciﬁc locations by the institution.

Home Mortgage Disclosure Act
In tandem with the CRA, the HMDA requires lending institutions to make annual public disclosures of their home mortgage lending activity. Under HMDA, lenders are required to disclose information on the disposition of home loan applications and on the race or national origin, gender, and annual income of loan applicants. HMDA data provide some insight into the lending patterns that exist in a community. However, HMDA data are only an indicator of potential problems; the data cannot be used to conclude deﬁnite redlining or discrimination practices due to the lack of detailed information on loan terms or speciﬁc reasons for denial.

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Conventional versus Government-Backed Financing
Conventional ﬁnancing involves market-rate loans provided by private lending institutions such as banks, mortgage companies, savings and loans, and thrift institutions. To assist lower- and moderate-income households that may have diƯiculty in obtaining home mortgage ﬁnancing in the private market, due to income and equity issues, several government agencies oƯer loan products that have below market rate interests and are insured (“backed”) by the agencies. Sources of government-backed ﬁnancing include loans insured by the Federal Housing Administration (FHA), the Department of Veterans AƯairs (VA), and the Rural Housing Services/Farm Service Agency (RHA/FSA). Often, government-backed loans are oƯered to the consumers through private lending institutions. Local programs such as ﬁrst- time homebuyer and rehabilitation programs are not subject to HMDA reporting requirements.

2. Lending Patterns
The availability of ﬁnancing aƯects a person’s ability to purchase or improve a home. Under the Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications by the income, gender, and race of the applicants. This applies to all loan applications for home purchases, improvements and reﬁnancing. HMDA data are submitted by lending institutions to the FFIEC. Certain data is available to the public via the FFIEC site either in raw data format or as pre-set printed reports.

The 2021 HMDA data reported a total of 27,988 loan applications to purchase homes located in the City of Riverside (Table 54), of which 75 percent were reﬁnance loans.

Table 54: Disposition of Home Loans
Loan Type
Total Applications Approved Denied All Others
# % # % # % # %
Conventional Purchase 4,959 18% 3517 71% 511 10% 931 10% Gov’t-Backed Purchase 1,186 4% 882 74% 92 8% 212 8%
Home Improvement 957 3% 443 46% 341 36% 173 36%
Reﬁnance 20,886 75% 13,762 66% 2,287 11% 4,837 11%
All 27,988 100% 18,604 66% 3,231 12% 6,153 12%
Source: FFIEC Home Mortgage Disclosure Act One Year National Loan Level Dataset, 2021.

Home Purchase Loans
In 2021, a total of 4,959 households applied for conventional loans to purchase homes in the City. The approval rate in 2021 for conventional home purchase loans was approximately 71 percent, while 10 percent of applications were denied.

Potential homeowners can also choose to apply for government-backed home purchase loans when buying their homes. In a conventional loan, the lender takes on the risk of losing money in the event a borrower defaults on a mortgage. For government-backed loans, the loan is insured, either completely or partially, by the government. The government does not provide the loan itself, but instead promises to repay some or all of the money in the event borrower defaults. This reduces the risk for the lender when making a loan.

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Government-backed loans generally have more lenient credit score requirements, lower down payment requirements, and are available to those with recent bankruptcies. However, these loans may carry higher interest rates and most require homebuyers to purchase mortgage insurance. Furthermore, government-backed loans have strict limits on the amount a homebuyer can borrow for the purchase of a home. Table 54 shows that 1,186 households applied for government-backed loans in 2021 (4 percent of loan applications that year).

Approval rates for these loans were higher and denial rates were lower than for conventional home purchase loans in 2021. Of the government-backed loan applications, approximately 74 percent were approved, and eight percent were denied in 2021.

Home Improvement Loans
Reinvestment in the form of home improvement is critical to maintaining the supply of safe and adequate housing. Historically, home improvement loan applications have a higher rate of denial when compared to home purchase loans. Part of the reason is that an applicant’s debt-to-income ratio may exceed underwriting guidelines when the ﬁrst mortgage is considered with consumer credit balances. Another reason is that many lenders use the home improvement category to report both second mortgages and equity-based lines of credit, even if the applicant’s intent is to do something other than improve the home (e.g., pay for a wedding or college). Loans that will not be used to improve the home are viewed less favorably, since the owner is divesting in the property by withdrawing accumulated wealth.

From a lender’s point of view, the reduction in owner equity represents a higher risk. In 2021, 957 applications for home improvement loans were submitted by Riverside households. Of these applications, 46 percent were approved and 36 percent were denied.

Reﬁnancing
Homebuyers reﬁnance existing home loans for a number of reasons. Reﬁnancing can allow homebuyers to take advantage of better interest rates, consolidate multiple debts into one loan, reduce monthly payments, alter risk (i.e. by switching from variable rate to ﬁxed rate loans), or free up cash and capital.

Approximately 75 percent of loan applications submitted by Riverside households in 2021 were for home reﬁnancing (20,886 out of 27,988 applications). About 66 percent of these applications were approved and 11 percent were denied. However, due to the high interest rates in recent years, the overall reﬁnancing activities are expected to have been lowered.

Lending Patterns by Race/Ethnicity and Income Level
The federal Fair Housing Act prohibits discrimination in mortgage lending based on race, color, national origin, religion, sex, familial status, or handicap (disability). It is, therefore, important to look not just at overall approval and denial rates for a jurisdiction, but also whether these rates vary by other factors, such as race/ethnicity. Unfortunately, other characteristics (such as disability) are not monitored and therefore no data is available for analysis.

In an ideal situation, the applicant pool for mortgage lending should reﬂect the demographics of a community. When one racial/ethnic group is overrepresented or underrepresented in the total applicant pool, it could be an indicator of access to opportunities. Such a ﬁnding may be

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a sign that access to mortgage lending is not equal for all individuals. As shown in Table 55, White applicants were noticeably overrepresented in the loan applicant pool during 2021, while Hispanics were signiﬁcantly underrepresented.

Table 55: Demographics of Loan Applicants vs. Total Population (2017) Percent of Applicant Pool Percent of Total Population Variation White 56% 31% +25%
Black 4% 6% -1%
Hispanic 7% 53% -46%
Asian 9% 7% +2%
Note: Percent of total population estimates are based on 2021 applicant data and compared to total population estimates from the 2017- 2021 American Community Survey.

Source: American Community Survey, 2017-2021; FFIEC Home Mortgage Disclosure Act One Year National Loan Level Dataset, 2021.

In addition to looking at whether access to lending is equal, it is important to analyze lending outcomes for any signs of potential discrimination by race/ethnicity. Approval rates for loans tend to increase as household income increases; however, lending outcomes should not vary signiﬁcantly by race/ethnicity among applicants of the same income level. Table 56 summarizes lending outcomes by race/ethnicity and income.

Loan approval rates in Riverside demonstrate a clear correlation between income levels and access to ﬁnancing across various racial and ethnic groups. The data indicates that White applicants exhibit the highest approval rates at each income tier, particularly in the upper- income bracket, where 72 percent of applications are approved. In contrast, Black and Hispanic applicants consistently show lower approval rates, especially at lower income levels. For instance, only 48 percent of Black applicants in the low-income category and 39 percent of Hispanic applicants received approval compared to 53 percent of low income White applicants.

The lower number of applications from Black and Hispanic individuals at low income levels may suggest potential barriers, such as limited credit access and insuƯicient ﬁnancial education, which could impede their ability to apply for loans. Additionally, the data reveals that even at higher income levels, Black and Hispanic applicants face challenges, with only 61 percent of Black applicants and 60 percent of Hispanic applicants in the upper-income category receiving loan approvals, compared to 72 percent of White applicants and 68 percent of Asian applicants.

Overall, these ﬁndings highlight systemic issues within the lending process, where biases may disproportionately aƯect the ability of Black and Hispanic applicants to secure ﬁnancing compared to their White and Asian counterparts.

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Table 56: Lending Patterns by Race/Ethnicity (2021)

Applications Approved Denied
Withdrawn/
Incomplete
# % # 2021 # 2021 # 2021
White
Low (0-49% AMI) 925 6% 490 53% 250 27% 185 20%
Moderate (50-79% AMI) 1913 13% 1,217 64% 292 15% 404 21% Middle (80-119% AMI) 3869 26% 2,774 72% 351 9% 744 19%
Upper (≥120% AMI) 8,066 55% 5,801 72% 720 9% 1,545 19%
Total 1,4773 100% 10,282 70% 1,613 11% 2,878 19%
Black
Low (0-49% AMI) 83 7% 40 48% 24 29% 19 23%
Moderate (50-79% AMI) 106 9% 57 54% 24 23% 25 24%
Middle (80-119% AMI) 253 22% 140 55% 39 15% 74 29%
Upper (≥120% AMI) 686 61% 416 61% 97 14% 173 25%
Total 1,128 100% 653 58% 184 16% 291 26%
Hispanic
Low (0-49% AMI) 123 6% 48 39% 53 43% 22 18%
Moderate (50-79% AMI) 271 14% 144 53% 52 19% 75 28%
Middle (80-119% AMI) 591 31% 335 57% 100 17% 156 26%
Upper (≥120% AMI) 922 48% 550 60% 126 14% 246 27%
Total 1,907 100% 1077 56% 331 17% 499 26%
Asian
Low (0-49% AMI) 129 5% 60 47% 39 30% 30 23%
Moderate (50-79% AMI) 179 8% 105 59% 31 17% 43 24%
Middle (80-119% AMI) 423 18% 271 64% 51 12% 101 24%
Upper (≥120% AMI) 1,641 69% 1119 68% 203 12% 319 19%
Total 2,372 100% 1555 66% 324 14% 493 21%
All
Low (0-49% AMI) 1,580 6% 754 48% 471 30% 355 22%
Moderate (50-79% AMI) 3,113 12% 1,868 60% 512 16% 733 24% Middle (80-119% AMI) 6,620 25% 4,446 67% 718 11% 1,456 22% Upper (≥120% AMI) 15,229 57% 10,479 69% 1,560 10% 3,190 21% Total 26,542 100% 17,547 66% 3,261 12% 5,734 22%
Source: FFIEC Home Mortgage Disclosure Act One Year National Loan Level Dataset, 2021.

Lending Patterns by Census Tract Characteristics
Income Level
To identify potential geographic diƯerences in mortgage lending activities, an analysis of the HMDA data was conducted by census tract. Based on the Census, HMDA deﬁnes the following income levels.14
 Low-Income Tract – Tract Median Income less than or equal to 49 percent AMI  Moderate-Income Tract – Tract Median Income between 50 and 79 percent AMI  Middle-Income Tract – Tract Median Income between 80 and 119 percent AMI  Upper-Income Tract – Tract Median Income equal to or greater than 120 percent AMI

14 These income definitions are different from those used by HUD to determine Low and Moderate Income Areas.

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Table 57 summarizes the loan approval and denial rates of census tracts by income level in 2021. In 2021, there were 25 applicants from census tracts categorized as low-income by HMDA. Close to half of loan applications were submitted by residents from the City’s upper income tracts. In general, home loan approval rates were the same as the income level of the census tract increased, while denial rates were similar across all income levels except at low census tract income level, where denial rates were highest. Higher income households are more likely to qualify for and be approved for loans, so this trend is to be expected.

Table 57: Outcomes Based on Census Tract Income (2021)
Tract Income Level
Total Applicants Approved Denied Other
# % # % # % # %
Low 25 0.1% 16 64% 5 20% 4 16%
Moderate 4056 14% 2,648 65% 487 12% 921 23%
Middle 10,458 37% 6,884 66% 1,259 12% 2,315 22%
Upper 13,449 48% 9,056 67% 1,480 11% 2,913 22%
Total 27,988 100% 18,604 66% 3,231 12% 6,153 22%
Source: FFIEC Home Mortgage Disclosure Act One Year National Loan Level Dataset, 2021.

Minority Concentration
HMDA also provides the minority population percentage within each census tract. Table 58 summarizes the home loan approval and denial rates of census tracts in the City by the proportion of minority residents in 2021. A census tract with more than 50 percent minority population is considered “substantially minority. ” In 2022, approximately 84 percent of loan applications originated from census tracts designated as substantially minority. Approval and denial rates were comparable, regardless of whether the tract was classiﬁed as substantially minority or not.

Table 58: Outcomes Based on Minority Population of Census Tract (2017 and 2021) Tract Income Level
Total Applicants Approved Denied Other
# % # % # % # %
2021
Substantially Minority 23,610 84% 15,573 66% 2802 12% 5235 22% Not Substantially Minority 4,378 16% 3,031 69% 429 10% 918 21% Total 27,988 100% 18,604 66% 3231 12% 6153 22%
Source: FFIEC Home Mortgage Disclosure Act One Y ear National Loan Level Dataset, 2021.

Conclusions and Recommendations
The analysis of loan approval rates by race in Riverside reveals distinct disparities, even when controlling for income levels, indicating that factors beyond income may be inﬂuencing lending outcomes for certain racial groups. While higher approval rates at higher income levels are anticipated, signiﬁcant discrepancies appear across racial groups at similar income levels, particularly aƯecting Black and Hispanic applicants.

For instance, at low-income levels, Black and Hispanic applicants experienced markedly lower approval rates than their White counterparts. This gap persists at middle and upper

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income levels, where White and Asian applicants consistently achieve higher approval rates than Black and Hispanic applicants with comparable incomes. Speciﬁcally, at upper-income levels, Black applicants received approvals for only 61 percent of their applications, and Hispanic applicants for 60 percent, compared to 72 percent for White applicants and 68 percent for Asian applicants, suggesting that race may be impacting loan approvals beyond income factors alone.

Geographically, there are additional disparities based on the income level of census tracts and their racial composition. Loan approval rates improve as the income level of a census tract increases, which is expected due to income qualiﬁcations. However, approval rates within "substantially minority" tracts are comparable to other tracts, suggesting that while race may impact individual approval rates, the location-based factor has a more complex relationship. Despite similar approval and denial rates in high-minority areas, applicants from these neighborhoods may face barriers linked to both racial and socioeconomic factors, such as lower ﬁnancial education, limited credit access, or fewer community resources supporting home ownership.

The combination of these race and geographic ﬁndings indicates that while lending patterns align with income to some degree, there are broader systemic issues. Minority applicants, especially Black and Hispanic individuals, face both individual-level barriers in securing loans, even at higher income levels, and community-level barriers based on their tract locations. These patterns underscore the need for fair housing enforcement, ﬁnancial education programs, and inclusive credit-building initiatives to address the intersection of race, income, and geography in access to home ﬁnancing.

The City's First Time Homebuyer Program, administered by the Fair Housing Council of Riverside County (FHCRC), is actively addressing many of the issues identiﬁed in lending and geographic disparities in access to homeownership. This program empowers prospective homebuyers through comprehensive educational workshops and outreach initiatives, supporting especially those from low to moderate-income backgrounds and minority groups.

First Time Homebuyer Program
The First Time Home Buyer Program hosted by the FHCRC is designed to empower prospective homebuyers through comprehensive educational workshops and outreach initiatives. Throughout the past ﬁve years, the program has demonstrated a robust commitment to community engagement and educational support.

The program hosts workshops in diverse locations within Riverside County, spanning cities like Hemet, Corona, and various neighborhoods in Riverside such as Northside and Arlanza.

These workshops are strategically chosen to ensure accessibility and inclusivity, aiming to reach individuals from all backgrounds and income levels. During the COVID-19 pandemic, the FHCRC adapted its workshops to online webinars to ensure continued access to crucial education and support for aspiring homeowners amid unprecedented challenges. Workshops are also held in Spanish. Over the past ﬁve years, at least 420 residents in FHCRC service area have attended First-Time Homebuyer Workshops. Of these, about 70 percent of program participants were low to moderate income, 38 percent were non-White minorities, and 63

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percent were women. In 2022, FHCRC returned to the 8 hours HUD Certiﬁed workshop format at their location at Mission Heritage Plaza in the City of Riverside.

Key components of the workshops include educating participants on the home buying process, budgeting, mortgage loan processes, identifying predatory lending practices, understanding credit impacts, and navigating down payment assistance programs. By providing this knowledge, the FHCRC equips attendees with essential tools to make informed decisions and overcome barriers to homeownership. Moreover, the program actively addresses common concerns among ﬁrst-time homebuyers, including scams targeting vulnerable individuals during the home purchasing process. By educating participants on recognizing and avoiding fraudulent practices, the FHCRC empowers them to protect their ﬁnancial interests eƯectively.

Partnerships with entities like Bank of America, which in 2019 dedicated over 1 billion annually for the next ﬁve years towards First Time Homebuyer down payment assistant programs, further enhance the program's impact. This ﬁnancial support makes homeownership more attainable for low to moderate-income individuals, contributing to economic stability and community development.

Down payment assistance programs are essential to ﬁrst time homebuyers; unfortunately, not only ﬁrst time buyers, but also lenders unaware down payment assistance. The California Housing Finance Agency (CalHFA) has access to a comprehensive selection of home buyer assistance programs, mostly geared toward ﬁrst-time homebuyers with low or moderate incomes. However, most of these programs require attending a HUD certiﬁed homebuying counseling course. Many agencies charge a fee for this certiﬁcation course. However, FHCRC’s First Time Home Homebuying workshop is a no cost service.

6.6 Homeowners Insurance
An example of a housing policy or practice that may have a disparate impact on a protected class is the provision and pricing of homeowner’s insurance. The ﬁnal rule states that “HUD has long interpreted the Fair Housing Act to prohibit discriminatory practices in connection with homeowners insurance. ”
Without insurance, banks and other ﬁnancial institutions lend less. For example, if a company excludes older homes from coverage, lower-income and minority households who can only aƯord to buy in older neighborhoods may be disproportionately aƯected. Another example includes private mortgage insurance (PMI). PMI obtained by applicants from Community Reinvestment Act (CRA) protected neighborhoods is known to reduce lender risk. Redlining of lower-income and minority neighborhoods can occur if otherwise qualiﬁed applicants are denied or encouraged to obtain PMI.

Homeowners insurance can be made unavailable due to the claims history of a property or of the buyer seeking coverage. CLUE (Comprehensive Loss Underwriting Exchange) report is a claims-information report generated by LexisNexis® , a consumer-reporting agency. The report generally contains up to seven years of personal-auto and personal-property claims history.

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An insurer may request a CLUE report when an application is made for coverage or request is made for a quote. The company uses the applicant’s claims history or the history of claims at a speciﬁc property to decide if it will oƯer coverage and the premium amount. Insurance company studies show a relationship between past and future claims.

When a home is sold in California, the seller is not obligated to provide the buyer with a CLUE report. According to the California Association of REALTORS (CAR), the standard residential purchase agreement:
“ … simply requires the seller to disclose known material facts and defects including "known insurance claims within the past ﬁve years. " In other words, if the seller had a ﬁre in the kitchen 2 years ago and made an insurance claim, then the seller must disclose this fact to the buyer. The C.A.R. purchase contract does not require purchase of a third-party report, such as C.L.U.E. Sellers may make the disclosures of known insurance claims by using the C.A.R. Standard Form "Supplemental Statutory and Contractual Disclosures" (Form SSD), which allows a seller to disclose his or her awareness of insurance claims via a simple yes/no checkbox format. ” [Emphasis added]
A seller must disclose only known insurance claims; C.A.R. purchase agreements do not require sellers to discover unknown claims, or to purchase reports or other third- party information to make this disclosure. Although sellers may choose to provide and pay for a third-party report to provide this optional third-party information to buyers, neither the law nor C.A.R. 's purchase agreement require that they do so. ” [Emphasis added]
CAR points out, however:
“Given the increased diƯiculty of obtaining aƯordable homeowners' insurance in recent years, buyers should obtain quotes as early as possible in the home buying process. In the process of obtaining insurance, the insurance agent or underwriter will most likely be checking the insurance database, as a matter of course, without charge.

Buyers should seek insurance quotes during the inspection period so that there will be clear understanding of the cost of the insurance early in the transaction, and so that buyers will have an opportunity to evaluate this fact during the inspection period. ” In recent years, major insurance companies have pulled out of the California housing market, particularly due to the high ﬁre hazards. Homeowners in Very High Fire Hazard Severity Zones are faced with signiﬁcantly higher insurance rates. Those homes, however, tend to locate near hillside areas and are at lower density neighborhoods.

Conclusions and Recommendations
Data are unavailable that demonstrates if the availability and cost of homeowners insurance are impediments to fair housing choice. To aƯirmatively further fair housing the FHCRC will describe “CLUE Reports” as part of its discussion on homeowners insurance at the First-time Homebuyers workshops.

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6.7 Property Management
The FHA covers most – but not all – housing. Some exemptions to coverage under the FHA include: (a) owner-occupied buildings with no more than four units (which is commonly known as the Mrs. Murphy exemption); (b) single family housing sold or rented without the use of a broker if the private individual owner does not own more than three such single family homes at one time; or (c) housing operated by organizations and private clubs that limit occupancy to members.

Under California law, the owners of apartment buildings with 16 or more housing units must provide for on-site property management. More speciﬁcally, California Law Civil Code Title 25, Section 42 requires a manager, janitor, housekeeper, or other responsible person to live on the premises and have charge of every apartment complex that has 16 or more apartments units on the property if the property owner does not live on the premises. Apartment properties between 4 and 15 units must have a notice placed in a conspicuous place stating the property owner’s name and address or the name and address of the agent in charge of the apartment house if the owner does not reside upon the premises. The Civil Code does not require apartment managers to reside on properties that have 4 or less units.

1. Rental Housing Stock and Renter Householders
Property management policies and practices are of keen importance to Riverside residents. At least 24 percent of the rental housing stock is located in structures having 16 or more housing units.15 However, it is possible that structures with fewer units – 4-plexes for example – are located on the same premises and, therefore, could have 16 or more apartments in the complex. It is noteworthy that 38 percent of the rental housing stock is comprised of single- family homes and would not have on-site property management.

The owners and managers of apartment buildings must comply with a variety of fair housing laws such as:
 Residential Occupancy Standards (ROS)
 Reasonable accommodations
 Reasonable physical modiﬁcations
 Service and companion animals
 Other property management discriminatory practices
Residential Occupancy Standards (ROS)
A residential occupancy standard is a rule limiting the number of persons who may legally occupy a given space. California has adopted the Uniform Housing Code as its governmental occupancy code for health and safety purposes. (Health & Safety Code §17922(a); Title 25, California Code of Regulations §32). Private owners also enforce occupancy standards usually in the form of the number of persons per bedroom or per apartment unit.

15 American Community Survey (ACS) provides units-in-structure breakdowns within specific intervals. The interval for 16 or more units is not available. Therefore, 24 percent represents 20 or more units.

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Housing providers’ concerns related to residential occupancy standards include concerns about harm to property, such as wear and tear, nuisance, overwhelmed building systems, increased management costs, and potential liability. Other tenants and neighbors may share some of those concerns, as well. The residential occupancy standard issue was complicated by the 1988 Fair Housing Act amendments that added familial status as a protected characteristic. These amendments allowed tenants to argue that a private residential occupancy standard that is more restrictive than the relevant government residential occupancy standard discriminates on the basis of familial status. Enforcement of a residential occupancy standard may harm tenants by forcing them to reconﬁgure their desired household conﬁguration, to purchase more housing, to change location, or to accept lower- quality housing. These possibilities also entail additional search time and costs. Tenants may also suƯer discrimination. The most often harmed group is families with children, particularly larger families, nontraditional families, and blended families, which are statistically more likely to consist of people of color.

The CRD’s current intake standard for acceptance of familial status complaints related to residential occupancy standards was articulated in a January 31, 1989 notice. It uses the well- known “two-people- per-bedroom-plus one” standard. If a complaint is accepted, a non- exhaustive list of factors is consulted to determine if there has been a violation. The factors overlap with those in the Keating Memorandum, but are somewhat distinct.

Familial status was cited as the basis for discrimination in 13 complaints ﬁled with the FHCRC in the past 5 years. During the roughly same 5-year period, four familial status complaints were ﬁled with HUD, though it is unknown if family size was the issue.

FHCRC also provides tenant/landlord counseling services to Riverside residents. Between FY 2019 and FY 2023, FHCRC received over 18,000 tenant/landlords complaints. About 213 (1.2 percent) of these were related to occupancy standards.

Reasonable Accommodations
HUD and the DOJ describe a reasonable accommodation for purposes of the Act as follows:

A “reasonable accommodation” is a change, exception, or adjustment to a rule, policy, practice, or service that may be necessary for a person with a disability to have an equal opportunity to use and enjoy a dwelling, including public and common use spaces. Since rules, policies, practices, and services may have a diƯerent eƯect on persons with disabilities than on other persons, treating persons with disabilities exactly the same as others will sometimes deny them an equal opportunity to use and enjoy a dwelling. The Act makes it unlawful to refuse to make reasonable accommodations to rules, policies, practices, or services when such accommodations may be necessary to aƯord persons with disabilities an equal opportunity to use and enjoy a dwelling.

Data on the failure to permit a reasonable accommodation are maintained neither by the State CRD nor the FHCRC. However, residents ﬁling discrimination complaints on the basis of disability often identify “failure to make reasonable accommodation” as the alleged

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discriminatory act. Fourteen of the 39 complaints ﬁled by Riverside residents described the “failure to make a reasonable accommodation” as one of the alleged acts.

The majority of housing discrimination complaints ﬁled with the FHCRC had disability as their basis. It is likely that many of these complaints were made because of failure to allow a reasonable accommodation.

In addition, during testing for reasonable accommodations, FHCRC have observed instances where housing providers do not permit the following:
 Allowing a live-in caregiver or assistance animal (note that assistance animals are not considered pets)
 Emotional support animals
 Limiting the assistance animal based on generalized assumptions about certain species or breeds.

The outcomes of these practices by housing providers have resulted in positive test ﬁndings (reasonable accommodations denied), particularly in apartment communities that enforce breed restrictions.

Reasonable Physical Modiﬁcations
According to HUD: “A reasonable modiﬁcation is a structural change made to existing premises, occupied or to be occupied by a person with a disability, in order to aƯord such person full enjoyment of the premises. Reasonable modiﬁcations can include structural changes to interiors and exteriors of dwellings and to common and public use areas. A request for a reasonable modiﬁcation may be made at any time during the tenancy. The Act makes it unlawful for a housing provider or homeowners’ association to refuse to allow a reasonable modiﬁcation to the premises when such a modiﬁcation may be necessary to aƯord persons with disabilities full enjoyment of the premises. ” 16 Data are unavailable from the FHCRC, CRD and HUD concerning the incidence of housing discrimination complaints made because of the failure to allow a reasonable physical modiﬁcation. HUD does publish data on this issue or alleged act. These data show that during the past ﬁve years, 14 complaints were made because of a “failure to permit a reasonable accommodation. ”
Service and Companion Animals
Under Federal and State fair housing laws, individuals with disabilities may ask their housing provider to make reasonable accommodations in the "no pets" policy to allow for their use of a service and/or companion animal. Under the law, such animals are not considered pets. The housing provider may ask the disabled applicant/tenant to provide veriﬁcation of the need for the animal from a qualiﬁed professional. Once that need is veriﬁed, the housing provider must generally allow the accommodation.

16 Source: U.S. Department of Justice, Civil Rights Division and U.S. Department of Housing and Urban Development, Office of Fair Housing and Equal Opportunity, Joint Statement on Reasonable Modifications Under the Fair Housing Act, March 5, 2008, page 3

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Data are unavailable from the FHCRC, CRD and HUD concerning denials of service or companion animals. As stated earlier, these incidents may be reported as failure to make reasonable accommodations or discrimination on the basis of disabilities when making discrimination complaints. Mental disability was cited in 17 of the discrimination complaints ﬁled with FHCRC between FY 2019 and FY 2023. In addition, failure to make reasonable accommodation was listed in 14 of the discrimination complaints ﬁled with HUD during the same time period.

Section 8 Voucher Holders
In 2019, the State passed SB 329 and SB 222, expanding the source of income protection.

Under SB 329 and SB 222, all landlords in California will be required to accept Section 8 and Veterans AƯairs Supportive Housing (VASH) vouchers and other forms of rental assistance and to consider them as part of an applicant’s income. Both went into eƯect on January 1, 2020. In addition, AB 1482 was passed in 2019 to establish a cap on annual rent increase at 5 percent plus inﬂation and to enumerate the just causes to evict a tenant. This bill also prohibits ads stating “No Section 8. ”
Between 2019 and 2023, FHCRC received 14 discrimination complaints citing source of income protection as the basis for discrimination. However, in FY 2022 and FY 2023 source of income discrimination complaints increased the most to four and six, respectively (while in previous years only one to two complaints were ﬁled).

Other Property Management Discriminatory Practices
For purposes of preparing its annual report, the National Fair Housing Alliance (NFHA) collects data from private fair housing organizations based on the most common types of housing transactions: rental, real estate sales, mortgage lending, homeowners insurance, harassment, advertising, and HOA/Condo based on protected class. Housing discrimination occurs most often in the rental market, and the complaints reported in 2022 were overwhelmingly rental-related complaints (83 percent, 27,226 complaints of 33,007 complaints recorded). The prevalence of discrimination in the rental market over other types of transactions is because it is the most common and frequent type of housing transaction and because it is easier to detect discrimination due to the simplicity of the transaction itself.

Testing for rental discrimination is far more straightforward than testing for a real estate sales or mortgage lending case.

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Table 59: Housing Discrimination Complaints by Transaction Type in 2022 Type Number of Complaints Percentage Distribution
Rental 27,336 82.8%
Sales 917 2.8%
Lending 365 1.1%
Insurance 31 0.1%
Harassment 915 2.8%
Advertising 206 0.6%
HOA/Condo 227 0.7%
Other 3,010 9.1%
Total 100.0%
Source: National Fair Housing Alliance (NFHA), 2023 Fair Housing Trends Report. https://nationalfairhousing.org/wp- content/uploads/2023/08/2023-Trends-Report-Final.pdf

As previously reported, 39 Riverside residents ﬁled housing discrimination complaints between January 2019 and June 2024. Among the discriminatory practices alleged in the complaints are the following:
 Discriminatory refusal to rent
 Discriminatory refusal to negotiate for rental
 Discriminatory terms, conditions, privileges, or services and facilities  False denial or representation of availability
 Discriminatory advertising, statements and notices
 Discriminatory acts under Section 818 (e.g., coercion) The FHCRC does not collect data on the alleged acts when housing discrimination complaints are ﬁled with the organization. However, FHCRC does reports on the number of tenant/landlord complaints made. From FY 2019 to FY 2023, there were 18,234 rental complaints, with the most common issues being related to notices, lease agreements, repairs, and rental assistance.

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Table 60: Tenant/Landlord Complaints,
FY 2019/2020 to FY 2023/2024
Case Categories # of Complaints % of Complaints
Notices 3,227 17.7%
Lease/Rental Terms 2,499 13.7%
Repairs 2,491 13.7%
Rental Assistance 2,294 12.6%
Other 1,487 8.2%
Eviction 1,289 7.1%
Rent Increases 940 5.2%
AƯordable Housing 765 4.2%
Deposits 622 3.4%
Section 8 Issues/Information 529 2.9%
Entering/Harassment 503 2.8%
Habitability 324 1.8%
Mold 320 1.8%
Lead 318 1.7%
Occupancy Standards 213 1.2%
Homeless Assistance Referrals 205 1.1%
Mobile Homes 86 0.5%
Foreclosure Issues 68 0.4%
Late Fees 54 0.3%
Total 18,234 100.0%
Source: Fair Housing Council of Riverside County Quarterly Reports FY 2019 to FY 2023.

Conclusions and Recommendations
Riverside’s rental market faces fair housing challenges, particularly concerning occupancy standards, accessibility for individuals with disabilities, and income-based discrimination.

The enforcement of Residential Occupancy Standards (ROS) can impose restrictions that disproportionately aƯect families, especially those with children, leading to potential discrimination against larger and nontraditional family structures. Also, discriminatory practices related to familial status, denial of reasonable accommodations, and refusals to rent to Section 8 voucher holders are common. Addressing these issues requires expanding educational outreach, particularly to smaller rental property managers, and increasing compliance monitoring and enforcement to protect vulnerable populations.

The following actions will be implemented to remove or mitigate this impediment to fair housing choice:
 Continue to oƯer workshops and seminars to property managers and renters.  FHCRC will conduct a survey of 10-15 on-site property managers or property management companies to determine their familiarity with fair housing laws and requirements
 FHCRC will update model written property management policies that it will transmit to property management ﬁrms.

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6.8 Discriminatory Advertising
Rental advertisements cannot include discriminatory references. Of a total of 97 rental listings posted on Zillow.com between April and June 2024. From a 20 percent sample from the listings (20 listings), none contained overt discriminatory language. However, 11 listings contained potentially discriminatory language, all related to their pet policy. These listings have breed restrictions, size limitations, or outright prohibitions on pets that could impact individuals who require assistance animals as reasonable accommodations under fair housing laws. In one instance, the listing read that “All applications will require a pet screening prior to ﬁnal approval whether you have pets or not, including service animals. ” Persons with disabilities are one of the protected classes under fair housing law, and apartments must allow “service animals” and “companion animals, ” under certain conditions. Service animals are animals that are individually trained to perform tasks for people with disabilities such as guiding people who are blind, alerting people who are deaf, pulling wheelchairs, alerting and protecting a person who is having a seizure, or performing other special tasks. Service animals are working animals, not pets. Companion animals, also referred to as assistive or therapeutic animals, can assist individuals with disabilities in their daily living and as with service animals, help disabled persons overcome the limitations of their disabilities and the barriers in their environment.

Persons with disabilities have the right to ask their housing provider to make a reasonable accommodation in a “no pets” policy to allow for the use of a companion or service animal.

However, in the case of rental ads that speciﬁcally state “no pets, ” some persons with disabilities may not be aware of their right to ask for an exception to this rule. Because of this, a person with a disability may see themselves as limited in their housing options and a “no pets” policy could, therefore, be interpreted as potentially discriminatory. It's essential for these properties to clarify their policies regarding assistance animals to ensure compliance with fair housing regulations.

Conclusions and Recommendations
The rental listings reviewed did not contain discriminatory terms or phrases. Therefore, no impediment to fair housing choice was found to exist because of discriminatory advertising.

6.9 Hate Crimes
Hate crimes are crimes committed because of a bias against race, religion, disability, ethnicity, or sexual orientation. In an attempt to determine the scope and nature of hate crimes, the Federal Bureau of Investigation’s (FBI) Uniform Crime Reporting Program collects statistics on these incidents.

To a certain degree, hate crimes are an indicator of the environmental context of discrimina- tion. These crimes should be reported to the Police or SheriƯ’s department. On the other hand, a hate incident is an action or behavior that is motivated by hate but is protected by the First Amendment right to freedom of expression. Examples of hate incidents can include name calling, epithets, distribution of hate material in public places, and the display of

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oƯensive hate-motivated material on one’s property. The freedom guaranteed by the U.S.

Constitution, such as the freedom of speech, allows hateful rhetoric as long as it does not interfere with the civil rights of others. Only when these incidents escalate can they be considered an actual crime.

Hate crime statistics compiled by the Federal Bureau of Investigation (FBI) show that a total of 70 hate crimes were committed in Riverside over the most recently reported ﬁve-year period.

Most of the hate crimes committed in the City were based on race or ethnicity (74 percent, Table 61). Hate crime victims were predominantly Black or African American (29 victims), Hispanic or Latino (ﬁve victims), or White (ﬁve victims). The incidents occurred most often in residence homes (14 crimes), on highways, alleys, streets, or sidewalks (14 crimes), and in schools (13 crimes). According to the FBI, the most common oƯenses reported were aggravated assault (24 crimes), vandalism (20 crimes), and intimidation (19 crimes).

Table 61: Hate Crimes (2018-2022)
2018 2019 2020 2021 2022 Total %
Race/ Ethnicity/ Ancestry 9 10 10 12 11 52 74.3%
Religion 1 1 2 0 3 7 10.0%
Sexual Orientation 0 4 3 2 2 11 15.7%
Disability 0 0 0 0 0 0 0.0%
Gender 0 0 0 0 0 0 0.0%
Gender Identity 0 0 0 0 0 0 0.0%
Multiple Bias 0 0 0 0 0 0 0.0%
Total 10 15 15 14 16 70 100.0%
Source: U.S. Department of Justice Federal Bureau of Investigation, Crime Data Explorer. Hate crime data reported by Riverside Police Department, Riverside Community College, and University of California: Riverside, 2017-2022.

Housing-related hate activity most often includes harassment/intimidation or retaliation.

According to HUD regulation 4 C.F .R. § 100.400, it is unlawful to: (1) Threaten, intimidate, or interfere with persons in their enjoyment of a dwelling because of their protected class or the protected class of visitors/associates, (2) Intimidate or threaten any person because that person is engaging in activities designed to make other persons aware of, or encouraging such other persons to exercise, fair housing rights, (3) Retaliate against any person because that person has made a complaint, testiﬁed, assisted, or participated in any manner in a proceeding under the Fair Housing Act. As shown in Table 60, 503 entering/harassment complaints were made with FHCRC by Riverside residents between FY 2019 and FY 2023, though it is unknown if these complaints were discriminatory acts.

Conclusions and Recommendations
Hate crimes, primarily motivated by race and ethnicity according to FBI statistics, highlight signiﬁcant disparities and vulnerabilities faced by minority groups. The prevalence of these crimes in residential settings, schools, and public spaces underscores the pervasive nature of discrimination that aƯects individuals' daily lives.

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Addressing hate crimes and housing-related discrimination requires a multifaceted approach.

The following actions are recommended to remove or mitigate this impediment to fair housing choice:
 FHCRC will collaborate with local universities and schools to ensure vulnerable communities are informed about their rights and have access to resources to supported their housing needs.
 FHCRC will educate residents to recognize and report hate incidents promptly as part of their fair housing workshops.

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7. Private and Public Sector Fair Housing Impediments
Analysis
Many fair housing issues are not exclusively within the domain of either the private or public sectors. This AI presents an analysis of three potential public/private sector impediments to fair housing choice.

7.1 Fair Housing Services
The analysis of fair housing services, including enforcement and outreach activities, is crucial to understanding their impact on fair housing choice. Signiﬁcant challenges such as limited resources and awareness of fair housing rights often hinder eƯective enforcement eƯorts.

This can lead to underreporting of discrimination incidents, missed opportunities for legal recourse, and the persistence of discriminatory practices within housing markets. To address these issues, eƯorts are needed to enhance awareness through training programs for housing industry professionals, public education campaigns, advocacy endeavors, and enforcement measures.

1. Fair Housing Council of Riverside County (FHCRC)
Education and Outreach
Fair Housing Council of Riverside County (FHCRC) takes part in a variety of activities to ﬁght housing discrimination, such as free educational workshops, outreach to the community, and the investigation of housing discrimination complaints. The capacity of the FHCRC enables it to provide fair housing information, outreach and enforcement to 24 cities and communities located in Riverside County plus the unincorporated area of the County.

The FHCRC provides a full range of services including:
 Anti-discrimination
 Landlord/tenant counseling
 First time homebuyer seminars
 Foreclosure prevention
 Loan modiﬁcation
 Back-to-Work FHA
 Training
The funding that supports the eƯorts of the FHCRC includes Community Development Block Grant (CDBG) funds received from participating jurisdictions within its service area and grant funds such as Fair Housing Initiatives Program (FHIP) and Fair Housing Assistance Program (FHAP) provided by HUD’s OƯice of Fair Housing and Equal Opportunity (FHEO).

FHIP provides funds to eligible organizations through competitive grants under three initiatives that are designed to prevent or eliminate discriminatory housing practices and inform individuals of their rights and responsibilities under the Fair Housing Act: Private Enforcement Initiative, Education and Outreach Initiative, and Fair Housing Organizations

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Initiative. The FHCRC was awarded a FHIP grant of $300,000 in 202X to undertake various enforcement, education and outreach activities that AƯirmatively Further Fair Housing. The activities are designed to minimize and eliminate impediments to fair housing choice.

Speciﬁcally, FHCRC conducts systemic investigations, provides technical assistance to municipalities regarding compliance with fair housing laws, and provide fair housing education to the population of Riverside County.

Fair Housing Initiatives Program
The Fair Housing Initiative Program (FHIP) administered by FHCRC has had a profound impact on promoting fair housing practices and combating discrimination across Riverside County in the past ﬁve years. Through robust outreach and education initiatives, FHCRC reached thousands of residents annually, empowering them with crucial knowledge of their fair housing rights and responsibilities. Workshops and educational sessions covered a wide array of topics, including tenant rights, landlord responsibilities, and protections against discrimination based on race, disability, familial status, and more. These eƯorts not only informed residents but also equipped them with tools to identify and report housing discrimination, ensuring fair treatment in housing transactions.

FHCRC’s collaborations with local universities, such as UC Riverside, demonstrated a commitment to addressing speciﬁc housing challenges faced by international students and other marginalized groups. By tailoring educational outreach to these populations, FHCRC ensured that vulnerable communities were informed about their rights and had access to resources that supported their housing needs.

Furthermore, FHCRC’s participated in community events, town hall meetings, and formed partnerships with local organizations and government agencies to foster broader community awareness and support for fair housing principles. In the past ﬁve years, FHCRC hosted or participated in events that reached over 14,000 persons. These activities included:
 Hosting Fair Housing, First-Time Homebuyer, and Tenant’s Rights Workshops; Workshops on Disability
 Providing Fair Housing Trainings to management organizations and realtors  Attending community events such as Long Night of Arts and Innovation, The Group Annual Breakfast, Casa Blanca Customer Resource Center Open House, Town Hall Meetings, Jazz Festival at White Park, Park Avenue Missionary Baptist Church event outreach, Northside Improvement Association meeting
 Meeting with City Council StaƯ and participating in Planning class between HCAs and Freedom Mortgage.

During the COVID-19 pandemic, FHCRC adapted by leveraging virtual platforms to continue delivering educational content and outreach eƯorts. This approach enabled the organization to maintain its educational mission amidst challenging circumstances, including navigating eviction moratoriums and other housing-related crises exacerbated by the pandemic.

FHCRC partnered with Wakeland Housing and Development Corporation to build Mission Heritage Plaza, a new complex that includes a Civil Rights Institute and Walk of Fame, new

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aƯordable homes, and oƯices for the Fair Housing Council in downtown Riverside. Mission Heritage Plaza opened in October 2022 and provides resources to Riverside residents.

Enforcement
The enforcement of fair housing laws is accomplished by HUD, the California Civil Rights Department (CRD, formerly the Department of Fair Employment and Housing, DFEH), and the Fair Housing Council of Riverside County, Inc. (FHCRC). The CRD is responsible for enforcing State fair housing laws that make it illegal to discriminate. The CRD may ﬁle signed complaints with HUD if the matter falls within the jurisdiction of that agency. As a substantially equivalent agency, CRD’s ﬁndings are usually accepted by HUD.

Private Enforcement Initiative (FHIP-PEI)
The Fair Housing Initiatives Program Private Enforcement Initiative (FHIP-PEI) assists people who believe that they have been victims of housing discrimination. FHCRC reviews allegations to determine if there are any violations. If there are any Fair Housing violations, the enforcement agencies are notiﬁed. There are two types of enforcement agencies: The Federal Department of Housing and Urban Development (HUD) and the California Civil Rights Department (CRD). Fair housing discrimination complaints are explored in more detail in Chapter 6: Private Sector Fair Housing Impediments Analysis.

Under the Private Enforcement Initiative (FEI) funded by the Fair Housing Initiatives Program, FHCRC conducts extensive site testing across Riverside County to identify violations of fair housing laws. Through paired tests at various properties, FHCRC has uncovered instances where individuals from diƯerent demographic backgrounds receive unequal treatment, highlighting systemic issues in housing practices.

For example, one of the trends uncovered through testing and complaint investigation was a rise in sexual harassment during COVID-19. In 2020, FHCRC ﬁled two sexual harassment complaints with HUD and one sexual orientation complaint with CRD. These three cases highlighted a growing trend within the County, as landlords that cannot evict due to non- payment resort to other tactics and diƯerential treatment in the hopes the tenants may vacate on their own. This is also known as a “constructive eviction, ” which is a term used in the law of real property to describe a circumstance in which a landlord either does something or fails to do something they have a legal duty to provide, rendering the property uninhabitable. In sexual harassment and sexual orientation based discrimination, this could be viewed as constructive eviction when eviction moratoriums prevent legal evictions.

In response to the COVID-19 pandemic, FHCRC played a crucial role in enforcing eviction moratoriums and adapting to virtual platforms like Zoom and GoToWebinar for fair housing education. Collaborating with cities and nonproﬁt organizations, FHCRC ensured that both housing providers and the public were educated about their rights, particularly under the COVID-19 Tenant Protection Act of 2020 (AB 3088). The initiative included mailing Fair Housing literature and surveys to targeted apartment complexes (selected based on complaints received), focusing on issues such as sexual harassment, which saw an increase during the pandemic. From April to June 2021 alone, FHCRC tested 23 properties and noted an uptick in disability-related discrimination cases compared to other protected classes.

Analysis of Impediments to Fair Housing Choice page 104 City of Riverside March 2025
Furthermore, in 2020 FHCRC organized virtual town hall meetings across Riverside County, engaging with stakeholders to discuss tenant protections, fair housing rights, and resources available to residents. These meetings brought together legal experts, housing professionals, and city oƯicials to address emerging challenges exacerbated by the pandemic. Despite challenges posed by COVID-19, FHCRC remained committed to combating discrimination by continuing property testing, surveys, and collaborating closely with enforcement agencies like HUD and CRD. Discriminatory practices, particularly evident in rental processes based on familial status, disability, and race, remain a focal point for ongoing investigations and advocacy eƯorts.

The 2021-2029 Housing Element concluded that based on City staƯ experience in conducting community outreach for various planning and community development matters, expanded eƯorts are needed as it relates to Fair Housing enforcement. The contributing factors to this impediment were:
 Lack of a variety of inputs media (e.g., meetings, surveys, interviews)  Lack of accessibility to draft documents
 Lack of digital access
 Lack of resources for fair housing agencies and organizations  Racially and ethnically concentrated areas of poverty Evaluation of FHCRC Services
The Fair Housing Council of Riverside County (FHCRC) oƯers a full array of housing counseling services that aƯirmatively promote housing rights and obligations. FHCRC is contracted by the City with CDBG funds to oƯer education, training and technical assistance, enforcement activities, and annual audits with paired testing. However, challenges remain due to limited resources and lack of awareness among residents and landlords on rights and responsibilities under the law.

During stakeholder outreach meetings, FHCRC identiﬁed several challenges and emerging trends that need to be addressed to enhance fair housing outcomes in Riverside. A key concern raised was the necessity for expanded outreach eƯorts, currently constrained by limited funding. Furthermore, the FHCRC noted that while their primary focus has historically been on renter issues, they anticipate emerging challenges related to homeownership that will also require increased attention. For example, rising insurance costs may lead to higher mortgage rates, resulting in a surge in foreclosures. This issue is particularly alarming as it disproportionately impacts low- to moderate-income families, many of whom are already facing ﬁnancial hardships.

A particularly emerging concern stems from recent changes in the real estate commission process, which came into eƯect in August 2024. According to the 2022 National Association of Realtors’ President Leslie Rouda Smith, these changes, which require homebuyers to pay brokers directly, are expected to signiﬁcantly increase closing costs.17 According to a recent study, this shift could disproportionately aƯect Black and Hispanic/Latino families, making it harder for them to qualify for mortgages. This is alarming because these groups already face

17 https://www.housingwire.com/articles/opinion-changing-real-estate-compensation-harms-fair-housing/

Analysis of Impediments to Fair Housing Choice page 105 City of Riverside March 2025
considerable barriers to homeownership, and higher closing costs would exacerbate existing racial disparities in housing. This change could undermine fair housing eƯorts by reducing access to aƯordable housing, particularly for low-income and minority buyers.

To eƯectively address the emerging fair housing challenges in Riverside, including issues in the homebuyer market such as rising insurance costs and changes to real estate commission structures, FHCRC will likely require increased funding and an expanded scope of services.

These resources are essential for enhancing outreach, housing counseling, and legal support to ensure equitable access for low-income and minority communities amid these evolving challenges.

2. California Civil Rights Department (CRD)
The California Civil Rights Department (CRD) provides a variety of fair housing services to ensure equal housing opportunities and to prevent discrimination. One of their primary services is the investigation of complaints. Enforcement is another critical service provided by the CRD. The department takes legal action against individuals or entities that violate state fair housing laws. In addition to enforcement, the CRD conducts education and outreach programs. These programs are designed to inform the public, housing providers, and tenants about their rights and responsibilities under fair housing laws, promoting awareness and understanding of these important regulations.

The CRD also oƯers mediation and conciliation services to help resolve disputes related to fair housing. These services provide an alternative to litigation, allowing landlords and tenants or buyers and sellers to settle their diƯerences amicably. Furthermore, the department provides technical assistance to housing providers and the general public, helping them understand and comply with fair housing laws. This technical assistance can include guidance on best practices and legal requirements to prevent discrimination.

Finally, the CRD is involved in policy development and advocacy. The department works on developing policies and advocating for legislation that promotes fair housing and addresses systemic discrimination in housing. By engaging in policy work and advocacy, the CRD aims to create a more equitable housing environment for all residents of California.

3. HUD’s OƯice of Fair Housing and Equal Opportunity (FHEO) Similar to the California Civil Rights Department (CRD), HUD's OƯice of Fair Housing and Equal Opportunity (FHEO) provides a range of services to ensure fair housing and prevent discrimination including investigation of complaints, enforcement, education and outreach, policy development, and technical assistance.

A critical component of FHEO's eƯorts is the Fair Housing Initiatives Program (FHIP), which provides funding to support organizations dedicated to eliminating housing discrimination.

The FHIP supports a variety of activities, including educational campaigns, enforcement eƯorts, and testing to uncover discriminatory practices. It also funds research and data collection to better understand and address housing discrimination trends. As stated earlier, FHCRC has received grant funding from FHIP to provide fair housing services in the City of Riverside and Riverside County.

Analysis of Impediments to Fair Housing Choice page 106 City of Riverside March 2025

4. Inland Valleys Association of Realtors (IVAR)
The Inland Valleys Association of REALTORS (IVAR) oƯers several fair housing services and resources aimed at promoting professional standards and ethical practices within the real estate community. Some of their key services include:

1. Professional Standards and Ethics: IVAR has a dedicated Professional Standards Committee that oversees disciplinary proceedings related to ethical violations and professional misconduct among REALTORS. This includes issues such as misleading advertising, failure to disclose necessary information, and improper handling of client relationships. The committee can impose sanctions ranging from warnings to suspension or expulsion from the association.

2. Education and Training: IVAR provides training and educational resources to ensure that its members are knowledgeable about fair housing laws and best practices. This helps realtors maintain compliance with legal standards and ethical guidelines.

3. Advocacy and Support: The association actively engages in legislative advocacy to support fair housing policies and practices. This includes working with local, state, and national organizations to inﬂuence policies that promote fair housing and protect consumers' rights. Speciﬁcally, IVAR’s Fair Housing and Diversity Committee advocates for fair housing practices and equal opportunities in housing while promoting diversity within the real estate industry. The committee works to engage members from diverse backgrounds, develop and implement educational programs and special events, and maintains a dedicated “Fair Housing & Diversity” webpage. It also collaborates with key stakeholders like the Fair Housing Council and REALTIST, aiming to positively impact fair housing and diversity issues in the Inland Empire through education, visibility, and strategic initiatives.

5. California Apartment Association
The California Apartment Association (CAA) serves a diverse membership base that includes property owners, managers, and real estate professionals involved in the rental housing industry. CAA provides educational programs, such as workshops and online courses, that cover topics like tenant screening, reasonable accommodation requests, and anti- discrimination practices. These training sessions help members stay informed about current fair housing laws and best practices.

The association also oƯers expert legal support, including access to legal counsel and resources for handling discrimination claims and navigating complex regulatory issues. For example, CAA’s legal team can assist members in drafting compliant rental agreements and responding to complaints of discriminatory practices.

In addition, CAA engages in active advocacy to inﬂuence fair housing policies at local, state, and national levels. This includes participating in legislative lobbying, submitting comments on proposed regulations, and working with policymakers to promote balanced and eƯective housing laws.

Analysis of Impediments to Fair Housing Choice page 107 City of Riverside March 2025
Conclusions and Recommendations
No impediment to fair housing exists because of the lack of an organization to enforce or educate on fair housing laws. The analysis reveals that fair housing services, such as those provided by the Fair Housing Council of Riverside County (FHCRC), play a critical role in promoting fair housing choice and combating discrimination. However, challenges remain due to limited resources, underreporting of discrimination incidents, and lack of awareness among residents, landlords and housing professionals on rights and responsibilities under the law. FHCRC’s eƯorts in education, outreach, and enforcement have made signiﬁcant strides, but more comprehensive strategies are necessary to ensure that fair housing laws are eƯectively enforced and that vulnerable communities are protected.

7.2 Integration/Segregation
A major objective of the federal Housing and Community Development Act of 1974 was “the reduction of the isolation of income groups within communities and geographical areas and the promotion of an increase in the diversity and vitality of neighborhoods through the spatial deconcentration of housing opportunities for persons of lower income and the revitalization of deteriorating or deteriorated neighborhoods. ” Consequently, examining integration and segregation is crucial in fair housing analysis to provide insights into how housing opportunities are distributed across communities and the extent to which disparities exist.

California AB 686 required cites to include an Assessment of Fair Housing as part of the Sixth Cycle Housing Element update. To assist in the analysis, HCD created an AFFH Mapping Tool that provides geographic mapping capabilities to visualize and analyze housing patterns, demographic data, socioeconomic characteristics, and other relevant factors related to fair housing. The City of Riverside used this mapping tool for its AFFH in the 2021-2029 Housing Element. This AI incorporates the latest available data from the AFFH Mapping tool, expanding its analysis and including additional maps and characteristics to enhance understanding and planning eƯorts.

1. Tenure
Tenure, whether individuals own or rent their homes, directly inﬂuences neighborhood demographics and community dynamics. Homeownership often signiﬁes stability and investment in a community, potentially fostering integration if diverse groups of homeowners reside together. Conversely, patterns in rental tenure can reveal segregation if certain racial or socioeconomic groups are disproportionately concentrated in speciﬁc neighborhoods.

Renter households are concentrated in west and northern neighborhoods of the city, speciﬁcally in Arlanza, University, Hunter Industrial Park, and Downtown. These patterns may be attributed to the development history and zoning of these neighborhoods (Figure 14).  Arlanza: Previously the grounds for Camp Anza, this is one of the most geographically diverse neighborhoods of the City as it contains a mix of nearly every type of land use found in Riverside. Arlanza's residential areas range from semi-rural home sites to high density apartments, with much of the residential area made up of medium density

Analysis of Impediments to Fair Housing Choice page 108 City of Riverside March 2025 single-family tract development. The neighborhood also includes intensive urban commercial and industrial development.  University: The University neighborhood draws its name from Riverside's University of California campus and oƯers a unique mix of land uses, ranging from high-density student-oriented apartments to a thriving center of commerce and entertainment, to low density hillside housing and ﬁnally to large sections of farmland. Renter concentration is high likely due to the large student population residing in this area. However, a large residential neighborhood that occupies a quarter of this region is almost hidden behind the UC Riverside.  Hunter Industrial Park: This neighborhood consists almost entirely of industrial and commercial oƯice development, with a small single-family residential area situated near the interchange of the 60 Freeway and I-215.  Downtown: Downtown Riverside serves as both the cultural epicenter and historic heart of the City. It is home to numerous governmental, educational, and cultural landmarks, oƯering a vibrant mix of businesses, public facilities, parks, and community amenities. Figure 14: Riverside Zoning Designation Map

Analysis of Impediments to Fair Housing Choice page 109 City of Riverside March 2025 Figure 15 shows Sycamore Canyon Park (dark purple area south of Canyon Crest) as an area with a concentration of renters, however, this area is mostly covered by a park and is estimated to only have 12 housing units. Similarly, Sycamore Canyon/Canyon Springs neighborhood is also shown as having a high concentration of renters, but these areas include no residential properties; rather they are intended to provide for the City’s future when large-scale development occurs. Figure 15: Renter Occupied Housing Units 2. Race/Ethnicity HUD’s 1996 Fair Housing Planning Guide states that “the jurisdiction should describe the degree of segregation by race and ethnicity. ” The metrics for measuring level of racial integration/segregation, include:  Areas of minority population concentration  Index of Dissimilarity  Racially/ethnically concentrated areas of poverty (R/ECAPs) Areas of Minority Population An area of minority concentration is deﬁned as a Census tract whose proportion of minority population is greater than the overall Riverside County average of 67.6 percent. As shown in Figure 16, minority concentration tracts are located in west Riverside in La Sierra Acres, La Sierra, La Sierra South, Arlanza, Arlington, Arlington Heights, and Casa Blanca as well as in Eastside, Northside, Hunter industrial Park, and University in northern Riverside. Sycamore Canyon/Canyon Springs is also considered an area of minority concentration.

Analysis of Impediments to Fair Housing Choice page 110 City of Riverside March 2025 Figure 16: Areas of Minority Concentration Figure 17 shows the predominant races by tract and Riverside’s Hispanic or Latino-identiﬁed population are primarily predominant in the western part of the City, also including the Arlanza, La Sierra Acres neighborhoods; in the central portion of the City around the 91 Freeway (Casa Blanca and Arlington Heights); and in the Eastside neighborhood immediately to the east of Downtown. According to the AFFH assessment in the 2021-2029 Housing Element, these areas are recognized as having long histories of Hispanic and Latino settlement strongly associated with the early growth of the City’s citrus and railroad industries at the turn of the 20th Century (in the cases of the Eastside and Casa Blanca) and, in the case of Arlanza and La Sierra Acres, military operations and related industrial activities during and after World War II. Minority communities developed and later ﬂourished in Eastside and Casa Blanca due in part to the de facto and de jure segregation that prohibited many workers from ﬁnding residences in areas of “Riverside proper” to the north and west in the City’s original Mile Square district (now Downtown Riverside) and its ﬁrst streetcar suburbs that grew up around the former Paciﬁc Electric streetcar routes that once traversed Magnolia Avenue. In the western portion of the city, the largely agrarian unincorporated area that would become Arlanza and La Sierra Acres was transformed ﬁrst by the establishment of Camp Anza, a base of military operations that saw the arrival and embarkation of over 600,000 servicepersons during World War II. Following the war, a series of annexations that doubled the City’s size and

Analysis of Impediments to Fair Housing Choice page 111 City of Riverside March 2025 tripled its population were concurrent with a postwar boom in the construction of suburban housing tracts on the decommissioned Camp Anza. To this day, former military barracks and operations buildings persist in this area, having been converted to homes, apartments and businesses. Figure 17: Predominant Races Index of Dissimilarity Dissimilarity indices are measures of segregation, with higher indices meaning a higher degree of segregation (<40 is low, 40-55 is moderate, >55 is high).18 The dissimilarity index can be interpreted as the share of one group that would have to move to a diƯerent tract to create perfect integration for these two groups. In Riverside, minority (non-white) residents overall are not considered segregated from White residents, with a segregation index of 39.21 in 2022. Each racial group's segregation index also falls below 40, indicating relatively low segregation levels. However, segregation between each racial group and Whites has increased over the past 30 years, except for between Black and White residents. The most signiﬁcant increase was seen between Asian and White residents, with dissimilarity indices increasing by 12 points over the past 30 years. 18 Lessons from the Ground: Best Practices in Fair Housing Planning, HUD. [this URL does not work]

Analysis of Impediments to Fair Housing Choice page 112 City of Riverside March 2025 Table 62: Dissimilarity Indices (1990 to 2022) 1990 Trend 2000 Trend 2010 Trend 2020 Trend 2022 Trend Non-White/White 26.85 29.33 30.14 33.15 29.21 Black/White 31.29 25.94 24.81 30.46 30.21 Hispanic/White 31.53 33.85 33.83 37.00 32.37 Asian or P .I./White 20.77 27.52 31.81 36.2 32.71 Sources: AƯirmatively Furthering Fair Housing Data and Mapping Tool, Table AFFH-6, 2020. Dissimilarity calculator, 2023. https://www.hudexchange.info/resource/6870/lessons-from-the-ground-best-practices-in-fair-housing-planning-dissimilarity-index/ Figure 18 shows racial segregation/integration measures from 2020 by tract based on methodology from the Othering & Belonging Institute. Their measures show that high minority segregation is located across neighborhoods in the City: Arlanza and Casa Blanca in the west, parts of Eastside and Hunter Industrial Park neighborhoods in the North, and Sycamore Canyon in the south. On the other hand, White residents are segregated from other races Victoria and Canyon Crest, areas which are also identiﬁed as having a predominance of White population in Figure 17 above. Figure 18: Integration/Segregation

Analysis of Impediments to Fair Housing Choice page 113 City of Riverside March 2025

3. Low and Moderate Income Population
HUD deﬁnes a Low and Moderate Income (LMI) area as block group where over 51 percent of the population is low- and moderate-income. Figure 19 identiﬁes that LMI areas in the City by tract are concentrated in west and north Riverside in the neighborhoods of Arlanza, Airport, and Casa Blanca in west Riverside and Eastside, Hunter Industrial Park, and University in north Riverside. These neighborhoods correspond to the some of the areas with a concentration of minorities and high People of Color (POC) segregation.

Figure 19: Low to Moderate Income Population

Poverty Status
While low and moderate income areas have a cutoƯ threshold of 51 percent low moderate income persons within a tract, poverty status measures the percentage of the population whose income falls below the Federal poverty line. In Riverside, areas with the highest concentration of poverty correlate to those low and moderate income areas in Arlanza and north Riverside (Figure 20). However, Figure 20 also shows that other neighborhoods in west and north Riverside, especially along Magnolia Avenue, have relatively higher concentrations of poverty.

Analysis of Impediments to Fair Housing Choice page 114 City of Riverside March 2025 Figure 20: Poverty Status 4. Racially/Ethnically Concentrated Areas of Poverty (R/ECAPs) To assist communities in identifying racially or ethnically concentrated areas of poverty (R/ECAPs), HUD developed a census tract-based deﬁnition of R/ECAPs. The deﬁnition involves a racial/ethnic concentration threshold and a poverty test:  A nonwhite population of 50% or more  A poverty rate that exceeds 40% or is three or more times the average tract poverty rate for the metropolitan area, whichever threshold is lower RECAPs are located in the northern parts of the City in the Hunter Industrial Park and University neighborhoods (Figure 21, red hashed areas). HUD’s data sources for R/ECAPs have not been updated since 2013. Because of this, the City also includes an analysis of areas of High Segregation and Poverty as identiﬁed in the 2021-2029 Housing Element using TCAC/HCD’s mapping tool. TCAC/HCD’s areas of High Segregation and Poverty uses a location quotient for segregation and a poverty threshold of 30 percent of the population living below the poverty line. This approach helps to measure concentration of race in a small area for a more precise result.

Analysis of Impediments to Fair Housing Choice page 115 City of Riverside March 2025 A cluster of four of these areas is in the northern part of the City surrounding Downtown and includes tracts in the Eastside and Hunter Industrial neighborhoods (Figure 21, yellow areas). The other tract with High Segregation and Poverty is in Aranza, which as pointed earlier has a high concentration of Hispanic population and higher concentrations of industrial land uses. Figure 21: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) and High Segregation and Poverty Areas 5. Racially Concentrated Areas of AƯluence (RCAAs) While racially concentrated areas of poverty and segregation (R/ECAPs) have long been the focus of fair housing policies, racially concentrated areas of aƯluence (RCAAs) must also be analyzed to ensure housing is integrated, a key to fair housing choice. According to HUD’s policy paper, “Whites are the most racially segregated group in the United States and in the same way neighborhood disadvantage is associated with concentrated poverty and high concentrations of people of color, conversely, distinct advantages are associated with residence in aƯluent, White communities. ” HCD has created a version of the RCAA metric to better reﬂect California’s relative diversity and regional conditions, and to aid local jurisdictions in their analysis of racially concentrated areas of poverty and aƯluence pursuant to AB 686 and AB 1304. According to HCD’s RCAAs data, RCAAs are located in neighborhoods of Canyon Crest, Alessandro Heights, and Orangecrest in southeast Riverside (Figure 22).

Analysis of Impediments to Fair Housing Choice page 116 City of Riverside March 2025 Figure 22: Racially Concentrated Areas of Affluence (RCAAs) 6. Assisted Housing To further fair housing in Riverside, the City provides a range of housing options for all persons. Housing opportunities include conventional single-family and multi-family housing. For those with special needs, however, the City also provides a large inventory of subsidized housing, community care facilities, emergency shelters and transitional housing, as well as other treatment and recovery centers. This section inventories the range of housing opportunities for persons with special needs and displays their general location. Assisted Housing Developments Riverside has 63 aƯordable housing developments, ranging in size from 1 to 268 housing units totaling 4,011 aƯordable units. According to the 2021-2029 Housing Element, these developments include senior housing, supportive housing, and project-based rental housing. As shown in Figure 23, assisted housing is located throughout west and north Riverside. It is notable that assisted housing is not located in areas identiﬁed as racially concentrated areas of aƯluence (Figure 22 above).

Analysis of Impediments to Fair Housing Choice page 117 City of Riverside March 2025 Figure 23: Riverside Affordable Housing Inventory Source: California Housing Partnership (May 2023), 2021-2029 Riverside Housing Element. Table 63: Assisted Housing Units by Community Community Number of AƯordable Units Ramona 780 Eastside 543 La Sierra 516 Downtown 428 Arlanza 368 Arlington 341 Magnolia Center 285 University 278 Northside 156 Casa Blanca 148 Airport 87 Presidential Park 53 La Sierra South 28 Total 4,011 Sources: California Housing Partnership (May 2023) from HCD’s AFFH mapping tool, 2021-2029 Riverside Housing Element.

Analysis of Impediments to Fair Housing Choice page 118 City of Riverside March 2025
Housing Choice Vouchers Rental Assistance
The Housing Choice Voucher Program (HCV) provides rental assistance to very low-income households who obtain housing in the private rental market. The HCV program’s success depends upon the ability of participants to search for and ﬁnd suitable housing in the private rental market. The program encourages participants to avoid high-poverty neighborhoods and encourages the recruitment of landlords with rental properties in lower-poverty neighborhoods. An analysis of the trends in HCV concentration can be useful in examining the success of the program in improving the living conditions and quality of life of its holders.

HCV programs are managed by Public Housing Agencies (PHAs), and the programs assess- ment structure (SEMAPS) includes an “expanding housing opportunities” indicator that shows whether the PHA has adopted and implemented a written policy to encourage participation by owners of units located outside areas of poverty or minority concentration. A study prepared by HUD’s Development OƯice of Policy Development and Research found a positive association between the HCV share of occupied-housing and neighborhood poverty concentration and a negative association between rent and neighborhood poverty. This means that HCV use was concentrated in areas of high poverty where rents tend to be lower.

In areas where these patterns occur, the program has not succeeded in moving holders out of areas of poverty.

Within Riverside, about 2,068 HCVs are distributed across the City. Census tracts with the highest concentration of HCV renter households are concentrated in west and north neighborhoods of the City though La Sierra, Arlington, Arlanza, Ramona, Magnolia Center, Eastside, Downtown, University, and Industrial Park (Figure 24). These areas also have the lowest median gross rents in the City (less than $1,500, Figure 25).19 This means HCV participants are ﬁnding housing in the most aƯordable areas of the City. In addition, HCV households are also correlated with areas with a concentration of low and moderate income population and areas of minority concentration. As with assisted aƯordable housing, there are no HCV holds in the areas identiﬁed as RCAAs. The Fair Housing Plan should include actions to promote housing mobility through HCV use in higher resource areas.

19 In the AFFH Data Viewer Tool, the value shown under the Housing Affordability Index is the median gross rent per census tract. The map showing the Housing Affordability Index (LAI) provides standardized household housing and transportation cost estimates for all 50 states and the District of Columbia. Using ACS 2012-2016 data.

Analysis of Impediments to Fair Housing Choice page 119 City of Riverside March 2025 Figure 24: Housing Choice Voucher Concentration Figure 25: Median Gross Rents

Analysis of Impediments to Fair Housing Choice page 120 City of Riverside March 2025 Licensed Community Care Facilities Persons with special needs, such as the elderly and those with disabilities, must also have access to housing. Community care facilities provide a supportive housing environment to persons with special needs in a group environment. Restrictions that prevent this type of housing represent a fair housing concern. According to the Community Care Licensing Division of the California Department of Social Services, as of July 2024, there were 199 State-licensed community care facilities with a total capacity of 3,225 beds/persons in Riverside (Table 64). Figure 26 shows that licensed care facilities are distributed throughout the City, with many close to the corridors with bus routes and near high quality transit stop areas. Table 64: Licensed Community Residential Care Facilities by Type Type Number of Facilities Total Capacity Adult Day Care 11 680 Adult Residential Facility* 109 644 Residential Care for the Elderly 79 1,901 Total 199 3,225 Source: State of California Department of Social Services, Community Care Licensing Division, July 2024. Notes: *Includes one (1) Social Rehabilitation Facility with a capacity for 16 persons. Figure 26: Licensed Care Facilities Source: State of California Department of Social Services, Community Care Licensing Division, July 2024.

Analysis of Impediments to Fair Housing Choice page 121 City of Riverside March 2025
Conclusions and Recommendations
In summary, the neighborhoods of North and West Riverside reveal a striking concentration of minorities, poverty, and segregation. Speciﬁcally, areas like Arlanza, Casa Blanca, and Eastside exhibit high levels of minority segregation, coupled with low moderate-income populations and elevated poverty rates. Moreover, these neighborhoods are characterized by a signiﬁcant presence of Housing Choice Voucher (HCV) households and assisted housing units. Similarly, neighboring areas such as University and Hunter Industrial Park also reﬂect these patterns of high poverty and segregation. In contrast, South Riverside stands out as a racially concentrated area of aƯluence, with lower minority concentration and no assisted or HCV households.

These ﬁndings highlight the disparities in housing conditions and demographic composition across diƯerent regions of Riverside, emphasizing the critical need for targeted policies and interventions to address inequalities and promote inclusive community development.

7.3 Access to Opportunities
Signiﬁcant disparities in access to opportunity are deﬁned by the AFFH Final Rule as “substantial and measurable diƯerences in access to educational, transportation, economic, and other opportunities in a community based on protected class related to housing. ”

1. TCAC Opportunity Maps
To assist in the assessment of fair housing, the Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (CTCAC) convened in the California Fair Housing Task force to “provide research, evidence-based policy recommendations, and other strategic recommendations to HCD and other related state agencies/departments to further the fair housing goals (as deﬁned by HCD). ” The Task Force has created Opportunity Maps to identify resources levels across the state “to accompany new policies aimed at increasing access to high opportunity areas for families with children in housing ﬁnanced with 9% Low Income Housing Tax Credits (LIHTCs). ” These opportunity maps are made from composite scores of three diƯerent domains made up of a set of indicators. Table 65 shows the full list of indicators. The opportunity maps include a measure or “ﬁlter” to identify areas with poverty and racial segregation. To identify these areas, census tracts were ﬁrst ﬁltered by poverty and then by a measure of racial segregation.

The criteria for these ﬁlters were:
 Poverty: Tracts with at least 30 percent of population under federal poverty line.  Racial Segregation: Tracts with a racial location quotient higher than 1.25 for Blacks, Hispanics, Asians, or all people of color in comparison to the County.

Analysis of Impediments to Fair Housing Choice page 122 City of Riverside March 2025 Table 65: Domains and List of Indicators for Opportunity Maps Domain Indicator Economic Poverty Adult education Employment Job proximity Median home value Environmental CalEnviroScreen 4.0 pollution Indicators and values Education Math proﬁciency Reading proﬁciency High School graduation rates Student poverty rates Source: California Fair Housing Task Force, Methodology for the 2023 TCAC/HCD Opportunity Maps, January 2023. The 2023 TCAC/HCD opportunity map for Riverside identiﬁed High Resource areas in the southern parts of the city (in Canyon Crest, Alessandro Heights, and Mission Grove) and Low Resource areas in west and north Riverside. As noted in the integration/segregation analysis in the earlier section, these neighborhoods with lower resources are also correlated with areas of minority concentration, low and moderate income population concentration, and segregated neighborhoods. There is also a correlation between High Resource neighborhoods and neighborhoods with a low concentration of minorities and high White segregation. All RCAA tracts except for one are also High Resource. Another important note is absence of assisted housing or HCV households in High Resource tracts. The higher median rents in these areas tend to preclude the use of HCVs due to the limits of HUD payment standards. Figure 27: TCAC Resource Level Composite Scores

Analysis of Impediments to Fair Housing Choice page 123 City of Riverside March 2025 Figure 28: Affordable and Assisted Housing by TCAC Resource Level HUD has developed a series of indices for the purpose of fair housing assessment to help inform communities about disparities in access to opportunity. HUD-provided index scores are based on nationally available data sources and assess residents’ access to key opportunity assets in Riverside. The data has not been updated since 2020 when the 2020 AI was last published. Nevertheless, the index scores will be evaluated alongside TCAC metrics in Education, Economic, and Environmental domains as part of this analysis to provide a current evaluation of access to these resources mirroring the approach taken in the 2021-2029 Housing Element AFFH analysis. 2. Education Domain The “school proﬁciency index” developed by HUD uses school-level data on the performance of 4th grade students on state exams to describe which neighborhoods have high-performing elementary schools nearby and which are near lower performing elementary schools. The index values are percentile ranked at the state level and range from 0 to 100. The higher the score, the higher the school system quality is in a neighborhood. According to the 2020 indices, the school proﬁciency index scores were:  White, Non-Hispanic: 37.51  Black, Non-Hispanic: 33.23  Asian or Paciﬁc Islander, Non-Hispanic: 32.84  Native American, Non-Hispanic: 32.71  Hispanic: 30.27

Analysis of Impediments to Fair Housing Choice page 124 City of Riverside March 2025 These index scores indicate that non-White students had lower access to schools with high proﬁciency scores compared to White, non-Hispanic students. According to the 2020 AI, with the exception of Hispanics, all other students are enrolled in schools that score above average in their proﬁciency at a higher proportion than the demographic proportion of the entire population enrolled. The TCAC/HCD Opportunity Maps can help to identify areas within the community that provide access to opportunity for residents or, conversely, provide poor access to opportunity. Education scores are presented ranging from zero to one, with zero representing lower education outcomes and one representing positive education outcomes. In Riverside, there are clusters of areas that provide diƯerent ranges of access to better educational outcomes as Figure 29 shows. In the western portion of the City there a number of Census tracts that have some of the least positive educational outcomes, especially within Arlanza, La Sierra, and Arlington. In other parts of the City, such as the southeast, there are tracts with higher educational outcomes which coincide with the RCAAs (Figure 22) and high white segregation areas (Figure 18). By contrast, the lower-scoring census tracts are also predominantly Hispanic (Figure 17) and have higher concentrations of poverty (Figure 20). It should be noted that the low score tract Sycamore Canyon is the Sycamore Canyon Wilderness Park that has no housing or population. Figure 29: TCAC Education Opportunity Scores

Analysis of Impediments to Fair Housing Choice page 125 City of Riverside March 2025
Kidsdata.org reported that in 2021, 68.1 percent of students in Riverside County were considered to be high-need (i.e., those who are eligible for free or reduced-price school meals, are English Learners, or are foster youth – as reported in the Unduplicated Pupil Count). In the Riverside Uniﬁed School District (RUSD), 71.9 percent of students are considered high-need, while in Alvord Uniﬁed School District, which serves the western half of the City, 78 percent of the students are considered to be high-need. Alvord Uniﬁed serves the areas of the city with some of the lowest scoring tracts.

3. Economic Domain
The “labor market engagement index” provides a summary description of the relative intensity of labor market engagement and human capital in a neighborhood. This is based upon the level of employment, labor force participation, and educational attainment in a census tract.

The higher the score, the higher the labor force participation and human capital in a neighborhood.

According to the 2020 indices, labor market engagement index scores were:
 White, Non-Hispanic: 41.37
 Black, Non-Hispanic: 33.67
 Asian or Paciﬁc Islander, Non-Hispanic: 34.40
 Native American, Non-Hispanic: 31.02
 Hispanic: 27.00
These index scores indicate a large gap in labor market engagement and human capital between White and non-White residents. Moreover, Hispanic residents had the lowest labor market engagement index, more than 15 points below White, non-Hispanic residents.

In addition, HUD calculates a jobs proximity index, which quantiﬁes the accessibility of a given residential neighborhood as a function of its distance to all job locations within a region/CBSA, with larger employment centers weighted more heavily. The higher the index value, the better the access to employment opportunities for residents in a neighborhood. In 2020, the jobs proximity indices were as follows:
 White, Non-Hispanic: 70.56
 Black, Non-Hispanic: 74.69
 Asian or Paciﬁc Islander, Non-Hispanic: 73.97
 Native American, Non-Hispanic: 71.47
 Hispanic: 70.16
In the case of jobs proximity, Black and Asian/Paciﬁc Islander, non-Hispanic residents had slightly better access to employment opportunities. As shown in Figure 30, jobs proximity index scores are highest along Magnolia Avenue and State Route 91 and decrease as distance from these corridors increases.

Analysis of Impediments to Fair Housing Choice page 126 City of Riverside March 2025 Figure 30: Jobs Proximity Index As described in Table 65, the TCAC/HCD opportunity scoring system take into account poverty, adult education, employment, job proximity, and median home value to calculate an economic domain score between 0 and 1, where one is more positive economic outcomes. Figure 31 shows a more comprehensive picture of the distribution of economic opportunity. Economic opportunity is lowest along the same corridors that have the highest jobs proximity index and vice versa. Western, southwestern, and northern neighborhoods have the lowest economic scores, while southern neighborhoods (Alessandro Heights, Canyon Crest, Mission Grove, and Sycamore Canyon/Canyon Springs) have the highest access to economic opportunity.

Analysis of Impediments to Fair Housing Choice page 127 City of Riverside March 2025 Figure 31: TCAC Economic Domain Scores There are two primary ways that economic indicators can improve in any location. The ﬁrst is through educational attainment: better educated and skilled residents earn higher wages. The primary way in which a city can attract higher skilled workers is through improving local amenities and services, such as improving schools. The second is by nurturing the city’s better-paying industries and attracting more of such industries, consistent with the city’s job base. Better-paying industries can provide employment opportunities for local workers and enhance their ability to earn higher incomes. If the City of Riverside seeks to improve economic indicators in the community, it should focus its attention in these areas. The San Bernardino County Workforce Development Board operates programs that are funded by the Department of Labor’s Workforce Innovation and Opportunity Act. One of the programs is the America’s Job Centers of California (AJCCs) that has three locations that serve portions of the Inland Empire. One of these AJCCs is located in Hunter Industrial Park. In addition, the Rubidoux Youth Opportunity Center located near northern riverside is an aƯiliate American Job Center that provides a career resource room, internet access, personal computers and rooms where employers can interview job seekers. The Riverside County Economic Development Agency (EDA) also works to help provide business expansion or help business relocate to Riverside County easier. The EDA has programs that help develop hiring criteria, advertise employee recruitment, screen and test applicants, and provide training programs for businesses in the community.

Analysis of Impediments to Fair Housing Choice page 128 City of Riverside March 2025

4. Environmental Domain
HUD’s “environmental health index” summarizes potential exposure to harmful toxins at a neighborhood level. The higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the value, the better the environmental quality of a neighborhood. The 2020 environmental health index values were:
 White, Non-Hispanic: 24.25
 Black, Non-Hispanic: 23.18
 Asian or Paciﬁc Islander, Non-Hispanic:24.62
 Native American, Non-Hispanic: 22.23
 Hispanic: 22.04
These index values indicate poor environmental quality overall for all races, though White and Asian/Paciﬁc Islander, non-Hispanic residents had slightly higher scores. TCAC/HCD’s environmental domain scores use the CalEnviroScreen 4.0 pollution Indicators and values, the CalEnviroScreen tool was developed by the California OƯice of Environmental Health Hazard Assessment (OEHHA) to help identify California communities disproportionately burdened by multiple sources of pollution called the California Communities Environmental Health Screening Tool (CalEnviroScreen). Lower scoring census tracts tend to be more burdened by pollution from multiple sources and are most vulnerable to its eƯects, considering their socioeconomic characteristics and underlying health status.

In Riverside, most of the City is impacted by pollution and has low scoring census tracts as Figure 32 shows. The highest scoring census tracts are in the eastern portion of the City, in Alessandro Heights, Canyon Crest, Mission Grove, Orange Crest, and parts of Victoria. The areas with lower scores do aƯect minority populations and areas of high percentage of non- white residents.

According to the American Lung Association (ALA) 2023 State of the Air Report, both San Bernardino and Riverside counties score an F in the Ozone Grade.20 An F grade means that the county had nine more days than average of high air pollution levels. Overall, the Inland Empire has an Ozone Grade of F because of the number of unhealthy air quality days and the risk populations take from the pollutants present. Because this is a regional tool, it can be assumed the issues aƯecting residents in the Inland Empire as a whole also aƯect Riverside residents.

In the Inland Empire, communities are most being aƯected by the burden of online shopping with the increase of diesel trucks and freight lines continue. San Bernardino County has the Country’s worst ozone pollution and aƯects special needs groups in this area and the surrounding region the most. Also, communities with high percentages of minority populations are the most aƯected as the majority of the County’s new warehouses neighbor minority concentrated areas according to a California Air Resource Board study done in 2019.

20 American Lung Association, 2023 State of the Air Report.

Analysis of Impediments to Fair Housing Choice page 129 City of Riverside March 2025 Figure 32: TCAC Environmental Score 5. Transit Access AllTransit, an online resource for transit connectivity, access and frequency data, explores metrics that reveal the social and economic impact of transit, speciﬁcally looking at connectivity, access to jobs, and frequency of service. According to AllTransit, the City of Riverside has a score of 5.2 out of 10, with a score of 10 being high connectivity, access to jobs and frequency of service. This is comparable to other Cities in the region who average a score of 4.8. This shows that the City’s residents have diƯiculties accessing consistent and reliable transportation that is also aƯordable to them. The further away from the 91 freeway, the lower the overall transit score. In the northernmost portion of the City, where there is a high number of minority populations, the majority of the transit scores average at 2.

Analysis of Impediments to Fair Housing Choice page 130 City of Riverside March 2025 Figure 33: AllTransit Scores Figure 34 shows the high quality transit stops and areas (one-half mile buƯer around estimated high quality transit stops) provided by HCD’s AFFH mapping tool. The map also shows the percentage households with automobile access as provided by California's Healthy Places Index (HPI) tool.21 High quality transit areas are located in western and northern Riverside, with a gap along Ramona, Casa Blanca, Presidential Park, and Arlington Heights, where automobile access is relatively lower and there are higher concentrations of poverty and minorities. However, these HQTA are connected as shown by the high transit scores (6-9) in Figure 33. 21 The Healthy Place Index (HPI) was developed to assess and prioritize community health needs across the state. It was created by the nonprofit Public Health Alliance of Southern California in collaboration with the Advancement Project California and community partners. The automobile access indicator evaluates the availability of private vehicles as a means of transportation.

Analysis of Impediments to Fair Housing Choice page 131 City of Riverside March 2025 Figure 34: High Quality Transit Stops and Automobile Access Conclusions and Recommendations There are signiﬁcant disparities in resource access across Riverside, with western and northern neighborhoods experiencing lower resources, higher concentrations of minorities and poverty, while there is higher resource availability in southeastern Riverside, particularly in areas designated as RCAAs. This divide is mirrored in education outcomes, which show higher achievement levels exclusively in southeastern neighborhoods. Despite the presence of numerous jobs along Magnolia Ave and State Route 91, economic outcomes in these areas are notably low. Transit access is generally adequate, with transit services concentrated along these corridors. Similarly, environmental outcomes are less favorable in western and northern neighborhoods compared to their southeastern counterparts, where environmental scores are consistently higher. To address the disparities in Riverside the City will need to implement placed-based strategies to improve these neighborhoods. 7.4 Disproportionate Need The AFFH Rule Guidebook deﬁnes “disproportionate housing needs” as “a condition in which there are signiﬁcant disparities in the proportion of members of a protected class experiencing a category of housing needs when compared to the proportion of a member of any other relevant groups or the total population experiencing the category of housing need in the applicable geographic area” (24 C.F .R. §5.152). The analysis is completed by assessing cost burden, severe cost burden, overcrowding, and substandard housing. Other disproportionate needs include gentriﬁcation, displacement, and disadvantaged communities.

Analysis of Impediments to Fair Housing Choice page 132 City of Riverside March 2025
The Comprehensive Housing AƯordability Strategy (CHAS) developed by the Census for HUD provides detailed information on housing needs by income level for diƯerent types of households in Riverside. Housing problems considered by CHAS include:
 Housing cost burden, including utilities, exceeding 30% of gross income;  Severe housing cost burden, including utilities, exceeding 50% of gross income;  Overcrowded conditions (housing units with more than one person per room); and,  Units with physical defects (lacking complete kitchen or bathroom) As shown Table 66, a higher percent of Black (47.0 percent), Asian (47.4 percent), and Hispanic (51.4 percent) households experience housing problems compared to American Indian (30.5 percent), White (33.8 percent), and all City households (43.5 percent). Renter- households, independent of race, experience housing problems at higher rates than owner- occupied households (58.6 percent and 31.1 percent, respectively).

Table 66: Housing Problem by Tenure and Race
With Housing
Problem White Black Asian
American
Indian
Paciﬁc
Islander Hispanic All
Owner-Occupied 23.8% 32.1% 38.4% 29.2% 0.0% 38.5% 31.1% Renter-Occupied 52.0% 55.1% 100.0% 31.6% 100.0% 63.6% 58.6% All Households 33.8% 47.0% 47.4% 30.5% 7.7% 51.4% 43.5% Source: HUD CHAS, 2016-2020.

Elderly and large households may also be subject to disproportionate housing problems, whether it is aƯordability or adequate physical needs (number of rooms, complete facilities).

Table 67 shows that renter elderly and large households experience housing problems at greater rates than all households in the City. In general, renters experience housing problems at a greater rate than owners.

Table 67: Housing Problems – Special Needs Populations
With
Housing
Problem
Renter Households Owner Households
All HH Elderly
Large HH
(5+ persons) All Renter Elderly Large HH All Owners
Riverside 64.1% 72.8% 58.6% 29.8% 42.6% 31.1% 43.5%
Source: HUD CHAS, 2016-2020.

1. Cost Burden
A household is considered cost burdened if it spends more than 30 percent of its income in housing costs, including utilities. About 38 percent of households in the City experience housing cost burdens. Similar to any housing problem trends shown in Table 66, Black, Asian, and Hispanic households experience cost burdens at higher rates than White households and all households combined (Table 68). Also, renters, regardless of race, experience cost burdens at higher rates than owners. Riverside renter elderly and large households experience cost burdens at much higher rates than renters (Table 69). About 60 percent of elderly renters and 46 percent of renter large households in the City experience cost burdens.

Analysis of Impediments to Fair Housing Choice page 133 City of Riverside March 2025
Table 68: Cost Burdens by Race
Cost Burden White Black Asian
American
Indian
Paciﬁc
Islander Hispanic All HH
Owner-Occupied 22.7% 31.4% 35.3% 26.9% 0.0% 28.9% 26.7% Renter-Occupied 47.8% 52.9% 53.8% 31.6% 100.0% 51.9% 50.9% All Households 31.7% 45.4% 43.1% 29.5% 7.7% 40.7% 37.6% Source: HUD CHAS, 2016-2020.

Table 69: Cost Burdens – Special Needs Populations
Cost Burden
Renter Households Owner Households
All HH Elderly
Large HH
(5+ persons) All Renter Elderly Large HH All Owners
Riverside 59.6% 45.9% 50.9% 29.7% 21.8% 26.7% 37.6%
Source: HUD CHAS, 2016-2020.

AƯordability could be a barrier to housing for persons with disabilities or special needs populations who rely on Supplemental Security Income (SSI) as their primary source of income. These households may experience cost burden when SSI incomes are not adequate to pay for rent and do not increase at rates comparable to rent increases.

The highest concentration of renter-households experiencing cost burdens are located in the western and northern census tracts within the City. Over 40 percent of renter households in most tracts in these areas experience housing cost burdens. These census tracts also have high minority concentrations (especially Hispanic, Figure 17) and households living in poverty (Figure 20).

In contrast, owner households burdened by costs are distributed more widely across the City, with the highest concentration found in tracts located in northern neighborhoods such as Hunter Industrial Park and University, where over 60 percent of households experience cost burdens.

Analysis of Impediments to Fair Housing Choice page 134 City of Riverside March 2025 Figure 35: Cost Burden by Renters Figure 36: Cost Burden by Home Owners

Analysis of Impediments to Fair Housing Choice page 135 City of Riverside March 2025

2. Overcrowding Overcrowding is deﬁned as housing units with more than one person per room (including dining and living rooms but excluding bathrooms and kitchen). According to the 2022 ﬁve-year ACS estimates, about 10 percent of households in the City experience overcrowding conditions. Census tracts with overcrowded households are concentrated in the north and north west of the City (Arlanza, La Sierra neighborhoods, and Eastside, Hunter Industrial Park, and University) that are also areas of higher concentrations of racial/ethnic minorities, families with children, female-headed households with children, and LMI households, and neighborhoods in the north identiﬁed as RECAPs (Figure 37). Of the 9,225 households experiencing overcrowded conditions, 35 percent were in owner-occupied households, and 65 percent were renters. This suggests that renters are disproportionately aƯected by overcrowding – as of 2022, only 45 percent of the households in Riverside were renter-occupied, but they represent 65 percent of all overcrowded households. In addition, more than 62 percent of occupied housing units in the City had three or more bedrooms (the minimum size considered large enough to avoid most overcrowding issues for households with ﬁve or more persons), but only 23 percent of these units were occupied by renters. This pattern suggests an inadequate supply of larger rental units. Table 70: Overcrowding in Riverside Tenure Overcrowded Households1 Severely Overcrowded Households2 % Overcrowded Households % of All Households3 Owner 3,220 675 34.9% 6.4% Renter 6,005 2,065 65.1% 14.9% Total 9,225 2,740 100.0% 10.2% Notes: 1) Overcrowding 1.01 or more persons per bedroom. 2) Severe overcrowding 1.51 or more persons per bedroom. 3) % of households for that category. Source: American Community Survey 2018-2022 (5-Year Estimates) Figure 37: Overcrowding

Analysis of Impediments to Fair Housing Choice page 136 City of Riverside March 2025

3. Substandard Conditions Examining the age of the current housing stock is one way to understand how historical development patterns have contributed to the City's built form. The time during which the largest share of Riverside's housing units was built is 1970-1979, and approximately 76 percent of the City’s housing stock was constructed prior to 1990. This is consistent with trends seen in the SCAG region, where more units were built during 1970-1979 than any other period. Housing that is 30 years old or older, like most of the housing in Riverside, is assumed to require some rehabilitation. Features such as electrical capacity, kitchen features, and roofs usually need updating if no prior replacement work has occurred. As seen in Figure 38, over 75 percent of housing units in most tracts in the City are more than 30 years old. Tracts with the lower concentration of housing over 30 years old are located in eastern parts of the City (Sycamore/Canyon Springs, Mission Grove, and Orange Crest). However, the need for rehabilitation does not necessarily make a housing unit substandard. The ACS estimates that about one percent of homes in Riverside are in substandard condition currently – including one percent (1,011 units) lacking complete kitchen facilities and about 0.3 percent (327 units) lacking plumbing. Figure 39 and Figure 40 show that substandard housing units are concentrated in Ramona, Arlington, Hunter Industrial Park, and University neighborhoods. Figure 38: Units Over 30 Years Old

Analysis of Impediments to Fair Housing Choice page 137 City of Riverside March 2025 Figure 39: Units Lacking Complete Plumbing Figure 40: Units Lacking a Complete Kitchen

Analysis of Impediments to Fair Housing Choice page 138 City of Riverside March 2025

4. Displacement
For the AFFH in the Housing Element, HCD deﬁnes sensitive communities as “communities [that] currently have populations vulnerable to displacement in the event of increased development or drastic shifts in housing cost. ” The following characteristics deﬁne a vulnerable community:
 The share of very low-income residents is above 20%; and  The tract meets two of the following criteria:
 Share of renters is above 40%;
 Share of people of color is above 50%;
 Share of very low-income households (50% AMI or below) that are severely rent burdened households is above the county median;
 The community or areas in close proximity have been experiencing displacement pressures (percent change in rent above County median for rent increases); or  DiƯerence between Census tract median rent and median rent for sur-rounding Census tracts above median for all tracts in the County (rent gap).

In Riverside, a number of census tracts are identiﬁed as vulnerable communities. These communities are generally concentrated in Arlanza and Arlington in western Riverside and in northern Riverside in Downtown, Eastside, Hunter Industrial Park, and University neighbor- hoods (Figure 41). This is generally consistent with the historical development patterns of the city, which begin with its establishment in the Mile Square (now Downtown) area and outlying villages, including Casa Blanca and Arlington. These were originally isolated communities developed around citrus packinghouses and railroad depots established concurrently with the growth of the City’s citriculture industry at the turn of the 20th Century.

Over the following decades, as postwar suburban development – facilitated in part by the construction of what is now known as the 91 freeway – subsumed much of the City’s citrus industry, the City simultaneously grew its borders and its population. Communities closest to the major rail and roadway transportation corridors (i.e., Magnolia and Arlington Avenues) grew rapidly. Federal policies that prioritized and subsidized racially homogeneous suburban development, at the direct expense of more diverse, established urban neighborhoods, were a contributing factor to this pattern.

Analysis of Impediments to Fair Housing Choice page 139 City of Riverside March 2025 Figure 41: Displacement Risk As described in Section 7.2-6 Assisted Housing Developments, existing housing that receives governmental assistance is often a signiﬁcant source of aƯordable housing in many communities. Riverside has 63 aƯordable housing developments, ranging in size from 1 to 268 housing units. Many of these are located in tracts vulnerable to displacement (Figure 41). To help combat displacement of residents and preserve aƯordability the City may be able to acquire and rehabilitate these units. Apartment projects often need rehabilitation, and the property owner may have insuƯicient funds to complete periodic repairs and renovations. In these situations, the City may ﬁnd it advantageous to work with the property owner and oƯer a ﬂexible number of ﬁnancial incentives (e.g., low-interest loans, renegotiating current loan packages, cash incentives) in return for extending the length of the aƯordability covenants on the aƯordable units. Rehabilitation and preservation costs depend on numerous factors, most notably the condition of the property, the amount of deferred maintenance, the ﬁnancial viability of the project, and the length of the aƯordability term. The City of Riverside, working in conjunction with nonproﬁt and for-proﬁt partners, has completed several major acquisition and rehabilitation projects that provide a basis for making a magnitude-of-order estimate of the future cost of such activities. In the latter parts of the 20th century, regional population growth pressure and the predominant convention of suburban expansion facilitated the development of outlying tract housing developments in the western and southeastern edges of the City. These areas absorbed a substantial amount of white, middle-class homeowners from coastal cities who found themselves priced out of single-family homeownership in suburban Los Angeles and Orange Counties. This helped to establish the latter-20th and early-21st century

Analysis of Impediments to Fair Housing Choice page 140 City of Riverside March 2025 characterization of Riverside and surrounding Inland Empire cities as “bedroom” communities for a labor force largely tied to the coast, despite their long histories as independent economic centers of the Inland region. These historical patterns are generally consistent with the distribution of displacement risk in the City, particularly as rapidly escalating housing costs across Southern California send higher-earning households in search of more aƯordable oƯerings further Inland, thereby increasing displacement risk to the established lower-income communities in Riverside. 5. Disadvantaged Communities California Senate Bill 535 (SB 535) was enacted in 2012. This bill amended the California Global Warming Solutions Act of 2006 and introduced changes related to the allocation of funds from the Greenhouse Gas Reduction Fund. Speciﬁcally, SB 535 mandated that a minimum of 25 percent of the funds generated from the Greenhouse Gas Reduction Fund be allocated to projects that beneﬁt disadvantaged communities, and that at least 10 percent of those funds be spent directly within those communities. The bill aimed to ensure that these communities, which are often disproportionately aƯected by environmental issues, receive direct beneﬁts and support from California's eƯorts to reduce greenhouse gas emissions. These communities are identiﬁed and prioritized using the Disadvantaged Communities Map (Figure 42). In Riverside, disadvantaged communities are located in western and northern neighborhoods of the City. Figure 42: SB 535 Disadvantaged Communities

Analysis of Impediments to Fair Housing Choice page 141 City of Riverside March 2025
Conclusions and Recommendations
Renters face higher rates of housing problems compared to homeowners (59 percent and 39 percent, respectively), with elderly renters disproportionately aƯected (64 percent). These challenges – cost burden, overcrowded households, substandard housing, and the risk of displacement – are concentrated in western and northern Riverside. These areas also exhibit high concentrations of minorities, poverty, and R/ECAPs in northern Riverside, along with a prevalence of single female-headed households. Communities such as Arlanza, Arlington, Ramona in the west, and Downtown, Eastside, University, and Hunter Industrial Park in the east, stand out as areas with signiﬁcant needs as they are designated as low resource or areas of High Poverty and Segregation.

To uplift these neighborhoods in Riverside, the City should focus on place-based strategies to encourage community revitalization, including preservation of existing aƯordable housing and rehabilitation of existing structures. Financial assistance programs can also alleviate cost burdens. The City should also provide more aƯordable housing opportunities within these neighborhoods as well as in areas of higher resources and enhancing mobility strategies to promote inclusion.

Analysis of Impediments to Fair Housing Choice page 142 City of Riverside March 2025

8. Fair Housing Progress Report
The 2020 Riverside AI Fair Housing Action Plan identiﬁed several fair housing impediments in Riverside and outlined actions the City would take remove or mitigate the identiﬁed impediments. This section reviews the City's progress in implementing these actions. The evaluation also assesses the appropriateness of the impediments, categorizing them as follows:
a) Conditions and impediment are no longer relevant;
b) Impediment has been fully mitigated;
c) Impediment remains inadequately addressed;
d) Impediment has become more concerning; and
e) Impediment previously misidentiﬁed as fair housing issues.

The Action Plan also outlined actions to aƯirmatively further fair housing (AFFH). These actions were not related to a speciﬁc impediment but are which contribute to eliminating housing discrimination and segregation; foster inclusive neighborhoods; provide housing for disabled persons, a protected class; and otherwise create positive impacts and change by promoting fair housing. Progress in implementing these actions and their continued appropriateness is also evaluated.

Analysis of Impediments to Fair Housing Choice page 143 City of Riverside March 2025

Table 71: Progress in Implementing Actions to Remove/Mitigate Fair Housing Impediments Impediment Actions Accomplishments Appropriateness
Private Sector Impediments
Housing Discrimination
Housing discrimination, particularly on
the basis of disability, race, and familial
status, is an impediment to fair housing
choice. Based on past trends, at least 40
housing discrimination complaints may
be ﬁled by Riverside residents with HUD
during the ﬁve year period between FY
2020-2021 and FY 2024-2025. During the
same period, it is estimated that at least
500 housing discrimination complaints
may be ﬁled with the FHCRC.
 During the ﬁve-year period from FY 2020-2021
through FY 2024-2025, the City will have the
FHCRC provide fair housing services which will
include the processing of housing
discrimination complaints and landlord/tenant
counseling services. Often a landlord/tenant
issue has as its basis a housing discrimination
concern.
 In FY 2020-2021, the FHCRC will develop in
cooperation with the Community Access
Center and Inland Regional Center actions to
address the fair housing concerns of disabled
persons.

Accomplished. Between FY 2019 to FY 2024,
292 housing discrimination complaints were
made with the FHCRC by Riverside residents.

Almost 20,000 landlord/tenant complaints
were received by the FHCRC.

FHCRC worked in cooperation with the
Community Access Center and the Blindness
Support Center and obtained a MOU to
collaborate in addressing disability related fair
housing issues. The FHCRC does not partner
with the Inland Regional Center but does have
an MOU with the Arc of Riverside County to
support developmentally disabled persons.

This included conducting presentations and
distributing literature.

C) Impediment
remains inadequately
addressed.

Steering
Although steering cannot be precisely
quantiﬁed, there is evidence that it exists
and, therefore, it does create an
impediment to fair housing choice.
 During the ﬁve-year period from FY 2020-2021
through FY 2024-2025, the FHCRC will provide
at the ﬁrst time homebuyer workshops 1)
examples of how to detect “steering” when
using the internet to conduct a home search
process and 2) examples of how to detect loan
steering.
 During the ﬁve-year period from FY 2020-2021
through FY 2024-2025, the FHCRC will provide
information on how to detect steering behavior
by resident property managers to renters
attending workshops and Town Hall meetings.
 In FY 2020-2021, the FHCRC will add a
“steering” category to the categories of alleged
housing discriminatory acts.

Accomplished. Steering is identiﬁed by the
FHCRC as a practice that leads to
discriminatory outcomes by limiting housing
options based on protected characteristics.

Both First Time Homebuyer (FTHB) workshops
and fair housing training sessions for resident
property managers address and highlight the
deﬁnition of steering and how to detect
steering behavior.

C) Impediment
remains inadequately
addressed.

Analysis of Impediments to Fair Housing Choice page 144 City of Riverside March 2025
Table 71: Progress in Implementing Actions to Remove/Mitigate Fair Housing Impediments Impediment Actions Accomplishments Appropriateness
Lending Practices
The City’s goal is to improve the loan
approval rates of all racial and ethnic
populations that want to buy a home
located in Riverside. Excessive debt to
income ratios impede fair housing choice
because borrowers cannot qualify to buy
a home in a neighborhood they like. Many
of these borrowers should not apply for a
loan until after they have their debts
under control.

Evidence of a potential fair housing
impediment is the fact that in 2018 a low
percentage of Black borrowers applied
for a loan to buy a home in Riverside.

Additionally, black borrowers
experienced above average loan denial
rates.
 During the ﬁve-year period from FY 2020-2021
through FY 2024-2025, the FHCRC will provide
at ﬁrst-time home buyer workshops informa-
tion on debt-to-income ratios that are accept-
able to lenders. Implementation of this
recommended action should result in better
prepared borrowers and cause an increase in
loan approval rates of all loan applicants,
regardless of race or ethnicity.
 The FHCRC will annually monitor the disparity
in loan denial rates between White, Non-
Hispanic and Black borrowers. If the disparity
continues, the FHCRC will contact lenders to
determine the causes of the loan denial
disparities. The FHCRC also will conduct
outreach to the Inland Valleys Association of
REALTORS (IVAR) and Black REALTORS to craft
initiatives to improve Black homeownership
and reduce loan denial rates.

Partially accomplished. The FHCRC covers
debt-to-income ratios in FTHB workshops and
by using the interactive budget when
completing one-on-one pre-purchase
counseling.

The HMDA software used to produce reports
to track and monitor lenders was not covered
under any grant program the FHCRC has;
therefore, disparities in loan denial rates were
not tracked.

The FHCRC collaborates annually with IVAR.

IVAR members also have access to the Annual
Housing Conference.

C) Impediment
remains inadequately
addressed.

Property Management Practices
The housing discrimination complaints
ﬁled with HUD’s San Francisco OƯice demonstrate that discriminatory property management practices exist in Riverside
and, therefore, constitute an impediment
to fair housing choice.
 In FY 2020-2021, the FHCRC will explore the
potential to create Riverside City Apartment
Association.
 In FY 2020-2021, the FHCRC will conduct a
survey of 10-15 on-site property managers or
property management companies to determine
their familiarity with fair housing laws and
requirements.
 In FY 2021-2022, the FHCRC will prepare model
written property management policies that it
will transmit to property management ﬁrms.

Partially accomplished. The FHCRC works
with the Orange County Apartment
Association and the Southern California
Rental Association which operate in Riverside
County. The establishment of a new
Apartment Association was not achieved and
would require additional funding.

Property managers were consulted on fair
housing laws and requirement under the
preparation of the 2020 AI. The FHCRC
conducts surveys related to housing
discrimination allegations and produces a Fair
Housing Audit Report for the City of Riverside
annually.

C) Impediment
remains inadequately
addressed.

Analysis of Impediments to Fair Housing Choice page 145 City of Riverside March 2025
Table 71: Progress in Implementing Actions to Remove/Mitigate Fair Housing Impediments Impediment Actions Accomplishments Appropriateness
The FHCRC provides materials on best
practices related to fair housing and
distributes materials on various topics such
as Fair Housing Pitfalls, Dos and Don’ts of Fair
Housing, and HUD/DOJ joint statements.

Land Use and Zoning
The City's current land use and zoning
policies do not adequately deﬁne or
support transitional, supportive, and
aƯordable senior housing and are an
impediment to fair housing.

The following actions will be carried forward to the
FY 2020/21-FY 2024/2025 AI time period:
 Deﬁne transitional and supportive housing by
referencing the deﬁnitions in Government Code
Sections 65582(f) and (g).
 Prepare a brochure and additional information
promoting the Reasonable Accommodation
Procedure.
 Conduct a survey of multifamily housing
developments owned by the City’s Housing
Authority or ﬁnancially assisted by the City to
ensure management policies and practices
aƯirmatively further fair housing.
 Amend the Zoning Code to deﬁne aƯordable
senior housing as being restricted to residents
62 years of age or older.

The Zoning Code also needs to be amended to
address the requirements of laws enacted in 2018.

AB 2162 requires supportive housing to be a use by
right in zones where multifamily and mixed uses
are permitted, including nonresidential zones
permitting multifamily uses, if the proposed
housing development meets speciﬁed criteria, and
requires a local government to approve, within
speciﬁed periods, a supportive housing
development that complies with these
requirements.

Partially accomplished. Riverside’s Zoning
Code deﬁnes transitional and supportive
housing in accordance with State law. The
City’s current Code is complaint AB 2162 that
supportive housing to be a use by right in
zones where multifamily and mixed uses are
permitted, including nonresidential zones
permitting multifamily uses, the Zoning Code
needs to be amended to ensure that parking
requirements for supportive housing are
complaint with AB 2162 (no minimum parking
requirements if development is within ½ mile
of a public transit stop).

Reasonable Accommodation Procedure
packets are available to tenants. As of
September 2024, brochures are under
development to be included in each tenant
application.

Riverside Housing Development Corporation
property management staƯ obtains annual
certiﬁcation by FHCRC to ensure
management of policies and practices at
Housing Authority owned housing
developments aƯirmatively further fair
housing.

Zoning code does not deﬁne aƯordable senior
housing.

C) Impediment
remains inadequately
addressed.

Analysis of Impediments to Fair Housing Choice page 146 City of Riverside March 2025

Table 72: Progress in Implementing Actions to AƯirmatively Further Fair Housing Action Action Accomplishment Appropriateness
Private Sector
Population Diversity
Although the City as whole has a low
segregation level, there are
neighborhoods with concentrations of
minority populations. Some of these
neighborhoods also experience poverty
rates considerably higher than the
citywide average. The issues of
population diversity, residential
integration/segregation, and access to
opportunity will be explored in greater
detail during the preparation of the
Assessment to Fair Housing (AFH)
section of the 2021-2029 Housing
Element.

In FY 2020-2021, the City will evaluate the
contribution that the following actions
could make toward reducing minority
population concentrations and poverty:
 Place-based strategies in the
neighborhoods with minority
population concentrations and high
poverty rates.
 Development of aƯordable family
apartment housing in high opportunity
neighborhoods
 Development of market rate housing
in neighborhoods with minority
population concentrations.

Accomplished. The City completed an AFH as part of
the 2021-2029 Housing Element Update and
developed AFFH meaningful actions to address
issues. The meaningful actions address fair housing
services and outreach and enforcement; housing
mobility, place-based strategy to encourage
community revitalization; new housing choices in
areas of high opportunity; Housing for Persons with
Disabilities; protection existing residents from
displacement; community health strategies; and
environmental equity strategies.

Meaningful actions will
continue to be
implemented per the
City’s 2021-2029
Housing Element Action
Plan.

Brokerage Services
Based on the available information it was
determined that membership of minority
populations in real estate organizations is
not impeded by laws, rules, or policies.

Although no impediment was found to
exist, to aƯirmatively further fair housing:

In FY 2020-2021 to FY 2024-2025, the
FHCRC will –
 Participate in the meetings of IVAR’s
Housing Committee.
 OƯer to teach the 3-hour Fair Housing
course that REALTORS and
salespersons must complete when
they renew their license every four
years.

Accomplished. FHCRC is participating in IVAR’s
Housing Committee trainings. The most recent IVAR
training was held in July 2024. A FHCRC
representative also attends IVAR’s monthly breakfast
meetings to speak about fair housing.

FHCRC oƯered a 3-hour Fair Housing Certiﬁcation
Training labeled Fair Housing 101 as well as
Advanced Fair Housing Training 102.

C) Impediment remains
inadequately addressed
Appraisal Practices
Complaints regarding discriminatory
appraisal practices are not routinely
collected by local, State or Federal
agencies. Data are unavailable to
demonstrate if discriminatory appraisal
Although no impediment was found to
exist, to aƯirmatively further fair housing –
 In FY 2020-2021 to FY 2024 2025, the
FHCRC will describe the appraisal
process and the contents of an
Accomplished. The FTHB workshop discussion,
conducted by the FHCRC, includes the appraisal
process and the contents of an appraisal report.

A) Conditions and
impediment are no
longer relevant.

Although no
impediment was

Analysis of Impediments to Fair Housing Choice page 147 City of Riverside March 2025
Table 72: Progress in Implementing Actions to AƯirmatively Further Fair Housing Action Action Accomplishment Appropriateness
practices adversely impact some of
Riverside real estate transactions.
appraisal report at the First Time
Homebuyer workshops.
identiﬁed, the FHCRC
will continue to educate
the public regarding the
appraisal process at the
FTHB workshops.

Lending Practices
In 2018, Hispanic purchased homes in
resource- rich neighborhoods to a far less degree than Non- Hispanic White buyers.

The factors impeding Hispanics to buy
homes in resource-rich neighborhoods
are probably manifold.

To aƯirmatively further fair housing –
 In FY 2020-2021 to FY 2024-2025, the
FHCRC will describe how to use the
internet in the neighborhood-home
search process and how to identify
the neighborhood types at the First
Time Homebuyer workshops.
 Annually, the City will support the
eƯorts of the FHCRC to secure
funding for outreach to minority
communities through HUD’s Fair
Housing Initiatives Program (FHIP).

Partially accomplished. The FTHB participants are
given information on the home search process.

In coordination with the FHCRC, City staƯ presented
the Down-Payment Assistance Program for low-
income, ﬁrst-time homebuyers at the FTHB
workshops. The program was also presented at
various locations in the City.

C) Impediment remains
inadequately
addressed.

Homeowners Insurance
Data are unavailable that demonstrates if
the availability and cost of homeowners
insurance are impediments to fair
housing choice.

To aƯirmatively further fair housing –
 In FY 2020-2021 to FY 2024-2025, the
FHCRC will describe “CLUE Reports”
as part of its discussion on
homeowners insurance at the FTHB
workshops.

Accomplished. The FTHB workshops provide an
overview of homeowner insurance and this includes
the CLUE Report.

B) Impediment has been
fully mitigated.

Hate Crimes
The number of hate crimes occurring at
residences has declined dramatically to
two a year. Therefore, an impediment to
fair housing choice does not exist at this
time.

In FY 2020-2021 to FY 2024-2025, the City
staƯ will review the California Depart-
ment of Justice annual hate crime reports
to ascertain if an action must be taken
because of an increase in hate crime
events. If an action is needed, it will be
included in the Consolidated Plan Annual
Action Plan.

Accomplished. Between 2018 and 2022, 70 hate
crimes have been reported in the City. Most hate
crimes committed were based on race or ethnicity.

The number of hate crimes committed annually has
slightly increased during this period.

D) Impediment has
become more
concerning.

Public Sector

Analysis of Impediments to Fair Housing Choice page 148 City of Riverside March 2025
Table 72: Progress in Implementing Actions to AƯirmatively Further Fair Housing Action Action Accomplishment Appropriateness
Residential Land Use
Because the City provides for a variety of
housing opportunities for disabled
persons, no impediments were found to
exist regarding the City’s planning and
zoning policies, practices, and
regulations.

The competition for low income housing
tax credits is keen. Family projects
proposed on sites located in census
tracts designated as Highest Resource
and High Resource are awarded site
amenity and bonus points.

To aƯirmatively further fair housing, the
City will continue to implement the
following policies which are included in
the adopted 2014-2021 Housing Element:

Housing for People with Disabilities.

Increase the supply of permanent,
aƯordable, and accessible housing suited
to the needs of persons with disabilities;
provide assistance to persons with
disabilities to maintain and improve their
homes.

Supportive Services. Continue to fund
the provision of supportive services for
persons with special needs to further the
greatest level of independence and equal
housing opportunities.

To aƯirmatively further fair housing, the
City will conduct a robust sites inventory
to identify sites in the Highest and High
Resource Neighborhoods that are already
zoned or suitable to be rezoned to a
multifamily zoning designation.

Accomplished. The City has supported the needs for
a variety of housing opportunities for persons with
disabilities and special needs populations through
its Consolidated Plan activities.
 Between FY 2020 and FY 2023, the City placed or
continued to assist 270 formerly homeless
individuals who obtained housing through the
Tenant-Based Rental Assistance Program and
funded the development of 202 aƯordable
housing units using HOME funds. In addition,
2,527 persons received overnight shelter during
the year and 46 individuals received rental
assistance and case management through the
Rapid-Rehousing Program using ESG funds.
 During the same time period, 1,047 eligible
households received Housing Subsidy
Assistance, 1,273 eligible households received
Supportive Services, and 402 households
received Housing Information Services using
HOPWA funds.

The City conducted a sites inventory analysis as part
of the Sixth Cycle Housing Element update and
identiﬁed suitable sites for its RHNA units.

C) Impediment remains
inadequately
addressed.

While the actions
identiﬁed in the 2020 AI
have been
accomplished,
additional impediments
related to planning and
zoning policies have
been identiﬁed as part
of the City’s Housing
Element update and
speciﬁc actions have
been identiﬁed to
mitigate the
impediments.

Assessment of Fair Housing
The Housing Element Update which will
cover the 2021-2029 period will need to
include an Assessment of Fair Housing
(AFH). State guidelines describing what
must be contained in AFH have not been
released. However, an analysis may be
required of a broad range of potential
public sector impediments.

Pursuant to State law and to aƯirmatively
further fair housing, the City will prepare
an Assessment of Fair Housing by
October 2021.

The City will continue to
comply with State AFH
requirements to identify
potential impediments.

Analysis of Impediments to Fair Housing Choice page 149 City of Riverside March 2025
Table 72: Progress in Implementing Actions to AƯirmatively Further Fair Housing Action Action Accomplishment Appropriateness
displacement; community health strategies; and
environmental equity strategies.

Demographics of Publicly Supported Housing
The demographics of individual
developments have evolved since the
projects were built and may change in the
future when turnover occurs. Vacant
units probably occur infrequently,
however. For example, Victoria Heights is
the only LIHTC development that
advertises rent units in the Press
Enterprise.

With respect to the occupancy of all
LIHTC developments, the Black
population occupies this aƯordable
housing in a proportion greater than they
represent of the City’s population.

One of the objectives of the HOME
Program and other federal housing
programs is to promote fair housing by
ensuring outreach to all potential eligible
households, especially those least likely
to apply for housing assistance.

AƯirmative marketing consists of actions
to provide information and otherwise
attract eligible persons to available
housing without regard to race, color,
national origin, sex, religion, familial
status or disability.

To aƯirmatively further fair housing –
 In FY 2020-2021, the FHCRC work
with the on- site property managers of
LIHTC rental housing developments to
develop and adopt aƯirmative
marketing procedures.

Accomplished. When requested, the FHCRC
periodically developed and adopted aƯirmative
marketing procedures with housing providers.

FHCRC was active in the development of the
aƯirmative marketing procedures of the Mission
Heritage Plaza property.
b) Impediment has been
fully mitigated

Analysis of Impediments to Fair Housing Choice page 150 City of Riverside March 2025

9. Fair Housing Action Plan
The 2021-2029 City of Riverside Housing Element contains a series of meaningful actions to aƯirmatively further fair housing (AFFH). The Housing Element AFFH meaningful actions are incorporated into this AI report as Appendix B. Also, based on the assessment conducted in previous sections, the City will pursue additional actions to address fair housing issues identiﬁed.

Table 73: Fair Housing Actions (2025-2030)
Private Sector
Housing Discrimination Actions to Remove/Mitigate Impediments Housing discrimination, particularly
on the basis of disability, race, and
familial status, is an impediment to
fair housing choice.
 Continue to utilize FHCRC to provide fair housing services which will include the processing of housing discrimination complaints and landlord/tenant counseling services. Often a landlord/tenant issue has as its basis a housing discrimination concern.  Continue outreach and education activities, and community partnerships to promote fair housing practices.
 Continue to oƯer workshops and seminars to property managers and renters.
 FHCRC will conduct a survey of 10-15 on-site property managers or property management companies to determine their familiarity with fair housing laws and requirements
 FHCRC will update model written property management policies that it will transmit to property management ﬁrms.

Lending Practices Actions to Remove/Mitigate Impediments The City’s goal is to improve the loan
approval rates of all racial and ethnic
populations that want to buy a home
located in Riverside.
 FHCRC will annually monitor the disparity in loan denial rates between White, Non-Hispanic and Black borrowers. If the disparity continues, the FHCRC will contact lenders to determine the causes of the loan denial disparities.

Land Use and Zoning Actions to Remove/Mitigate Impediments The following Zoning Code
amendments are recommended:
 Group Homes/Residential Care Facilities: Review and develop mitigating strategies to eliminate barriers for large group homes in restrictive Zoning districts (RA-5 and RC).
 Permanent Supportive Housing: A zoning code amendment is necessary to clarify that parking is not required for supportive housing developments within one-half mile of a public transit stop.  Employee and Farmworker Housing: The Zoning Code currently does not address the requirements of the Employee Housing Act.

Changes to the Zoning Code will allow the City to implement the State requirements.

Hate Crimes Actions to AFFH
The number of hate crimes occurring
at residences has been fairly
consistent over the last ﬁve years,
with race/ethnicity/ancestry, religion,
and sexual orientation being the
primary bases of hate.
 FHCRC will collaborate with local universities and schools to ensure vulnerable communities are informed about their rights and have access to resources to support their housing needs.  FHCRC will educate residents to recognize and report hate incidents promptly as part of their fair housing workshops.

Analysis of Impediments to Fair Housing Choice Appendix A – page 1 City of Riverside March 2025
Appendix A: Public Outreach
This appendix provides documentation of outreach activities conducted.

Stakeholder Meetings

Analysis of Impediments to Fair Housing Choice Appendix A – page 2 City of Riverside March 2025

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Fair Housing Survey

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Analysis of Impediments to Fair Housing Choice Appendix B – page 1 City of Riverside March 2025
Appendix B: Riverside Action Plan- AFFH Meaningful Actions Fair Housing
Issues Contributing Factors
Meaningful
Actions Action Description Lead
Fair Housing
Services
Outreach and
Enforcement
Lack of a variety of inputs media
(e.g., meetings, surveys, interviews)
Lack of accessibility to draft
documents
Lack of digital access
Lack of resources for fair housing
agencies and organizations
HE-3.2 3.2 Adopt a City-wide policy that supports continued collaboration and participation with fair housing service provider(s) that increases fair housing opportunities across the City. Ensure eƯorts are tailored to maximize eƯicacy in areas of racially and ethnically concentrated poverty
Housing Authority
HE- 3.5 3.5 Study the need for a City-wide Universal Design and Visitability Policy.

Building & Safety
Division
Housing Mobility The availability of aƯordable units in a range of sizes (such as lack of
family housing)
Location and type of aƯordable
housing
Private discrimination
HE-2.3 2.3 Prepare a Zoning Code update or series of updates to: • further facilitate development of emergency shelters (including parking requirements per AB 139), transitional housing, permanent supportive housing, residential care facilities, and community care facilities in appropriately zoned areas distributed throughout the City, especially in High and Highest Resource census tracts as identiﬁed by the TCAC Opportunity Mapping Tool; • allow low-barrier navigation centers as a by-right use in mixed-use and non -residential zones that permit housing;, and • update the zoning provisions for emergency shelters to comply with SB-2;. and• review and develop mitigating strategies to eliminate barriers for large group homes in restrictive Zoning districts (RA-5 and RC).

Planning Division
HE-3.3 3.3 Adopt a City-wide policy that encourages the development or adaptation of residential units and communities accessible to people with physical and sensory disabilities.

Housing Authority
HE-3.4 3.4 Adopt a City-wide policy prioritizing wastewater and water services for aƯordable housing development applications in the event of service rationing.

Riverside Public
Utilities

Analysis of Impediments to Fair Housing Choice Appendix B – page 2 City of Riverside March 2025
Fair Housing
Issues Contributing Factors
Meaningful
Actions Action Description Lead
HE-5.4 5.4 Prepare a Zoning Code update to further encourage mixed-use development, including a potential density transfer program allowing densities on properties that are not built to their maximum density to be used on other properties, with transit access that reduces automobile trips, vehicle miles traveled, and associated energy consumption, with a particular focus on racially concentrated areas of aƯluence and census tracts with CalEnviroScreen Scores below the 60th percentile.

Planning Division
HE-6.4 6.4 Complete an evaluation and report of housing development every 5 years to ensure that adequate services and facilities, including water, wastewater, and neighborhood infrastructure are available, including recommendations for prioritization of capital improvements in lower opportunity census tracts.

Planning Division
Place-Based
Strategy to
Encourage
Community
Revitalization
Lack of public investments in
speciﬁc neighborhoods, including
services or amenities
Lack of private investments in
speciﬁc neighborhoods
HE-1.5 1.5 Develop and implement a plan to seek additional funding for the City’s Housing Rehabilitation Program for lower income owners to encourage further homeowner investment, address issues of overcrowding, and ensure housing stability. Where possible, target this program to census tracts with overcrowded conditions in over 20% of households.

Housing Authority
HE-4.1 4.1 Prepare urban design standards that promote the integration of private development and public space and create safe, healthy, complete neighborhoods with quality housing development, services and commercial uses, schools, transit, parks, childcare, and other needs. Explore means to incentivize enhanced public realm improvements and quality design in chronically underinvested neighborhoods and lower-scoring census tracts on TCAC Opportunity Maps.

Planning Division
HE-6.3 6.3 Develop and maintain an up-to-date residential sites inventory and provide to interested developers with information on available housing development opportunities and incentives on a quarterly basis.

Prioritize publicizing speciﬁc opportunities for aƯordable housing development in High and Higher Opportunity tracts as well as those tracts with median incomes higher than the Area Median Income.

Planning Division

Analysis of Impediments to Fair Housing Choice Appendix B – page 3 City of Riverside March 2025
Fair Housing
Issues Contributing Factors
Meaningful
Actions Action Description Lead
HE-EJ 7.1 7.1 Conduct an inventory of existing housing within environmental justice communities to determine the adequacy and condition of existing housing.

Planning Division
HE-EJ 7.2 7.2 On properties where poor-quality housing conditions are identiﬁed in environmental justice communities, facilitate the permitting process for property owners and residents to remedy and retroﬁt unhealthy and unsafe conditions in a timely fashion. If warranted, pilot this program in census tracts with elevated levels of household overcrowding and substandard housing conditions.

Planning Division
HE-EJ 7.5 7.5 Prepare an inﬁll development ordinance and development regulations, including the potential to use pre-approved construction plans, to facilitate housing on smaller lots that are close to needed services and amenities while allowing lot consolidation without discretionary review and with fee reductions. Consider prioritization of development opportunity sites located in census tracts with TCAC Economic Opportunity Scores over 0.50.

Planning Division
HE-EJ 8.1 8.1 Streamline development approvals for opening full-service grocery stores, with particular emphasis on increasing food access in census tracts with CalEnviroScreen scores above the 75th percentile.

Planning Division
HE-EJ 8.2 8.2 Work with retail businesses in environmental justice communities such as local convenience stores and farmers’ markets to increase the availability of fresh produce.

Planning Division
HE-EJ 8.5 8.5 Facilitate transformation of vacant lots within environmental justice communities into community garden sites.

Planning Division
New Housing
Choices in Areas
of High
Opportunity
Lack of public investments in
speciﬁc neighborhoods, including
services or amenities
Lack of private investments in
speciﬁc neighborhoods
HE-1.1 1.1 Prepare an Inclusionary Housing Program to facilitate the integration of aƯordable housing units throughout the City’s housing supply. If warranted, pilot this program in High and Highest Resource census tracts based on TCAC Opportunity Mapping tool.

Housing Authority
HE-5.1 5.1 Develop an Accessory Dwelling Unit (ADU) program that includes pre-approved construction plans, streamlined permitting, and educational materials to facilitate ADU development, including promoting the grants available to homeowners through the California Planning Division

Analysis of Impediments to Fair Housing Choice Appendix B – page 4 City of Riverside March 2025
Fair Housing
Issues Contributing Factors
Meaningful
Actions Action Description Lead
Housing Finance Agency (CalHFA). Target outreach eƯorts in neighborhoods with over 40% of housing overpayment among renter households to help improve aƯordability.

HE-5.2 5.2 Prepare a Zoning Code update to streamline the approval process and develop written procedures for application processing, in adherence with SB 35, and simplify development regulations for new housing development including aƯordable and mixed-income development in High and Highest Opportunity census tracts per TCAC Opportunity Maps.

Planning Division
HE-EJ 7.1 7.1 Conduct an inventory of existing housing within environmental justice communities to determine the adequacy and condition of existing housing.

Planning Division
Housing for
Persons with
Disabilities
Access to publicly supported
housing for persons with disabilities
(Beyond ADA, or speciﬁc housing
types?)
Access to transportation for
persons with disabilities
Lack of aƯordable in-home or
community-based supportive
services
Lack of aƯordable, accessible
housing in range of unit sizes
Lack of aƯordable, integrated
housing for individuals who need
supportive services
HE-3.3 3.3 Adopt a City-wide policy that encourages the development or adaptation of residential units and communities accessible to people with physical and sensory disabilities.

Housing Authority

Analysis of Impediments to Fair Housing Choice Appendix B – page 5 City of Riverside March 2025
Fair Housing
Issues Contributing Factors
Meaningful
Actions Action Description Lead
Lack of assistance for housing
accessibility modiﬁcations
Lack of assistance for transitioning
from institutional settings to
integrated housing
Protecting
Existing
Residents from
Displacement
The availability of aƯordable units in
a range of sizes (such as lack of
family housing)
Displacement of residents due to
economic pressures
Land use and zoning laws
Community opposition
HE-3.1 3.1 Adopt a City-wide policy that prohibits discrimination in the sale or rental of housing regarding characteristics protected under State and Federal fair housing laws.

Housing Authority
HE-5.3 5.3 Prepare an Adaptive Reuse Ordinance to encourage redevelopment of underutilized commercial and industrial properties and allow by-right residential development in exchange for providing a certain number of aƯordable units in non-residential zones. Consider piloting this program, if warranted, in census tracts considered vulnerable to displacement risk with substantial concentrations of commercial uses.

Planning Division
Community
Health Strategies
Access to equitable childcare
Access to equitable healthcare
The availability, type, frequency, and
reliability of public transportation
Lack of private investments in
speciﬁc neighborhoods
Lack of public investments in
speciﬁc neighborhoods, including
services or amenities
Location and type of aƯordable
housing
Private discrimination
HE-1.5 1.5 Develop and implement a plan to seek additional funding for the City’s Housing Rehabilitation Program for lower income owners to encourage further homeowner investment, address issues of overcrowding, and ensure housing stability. Where possible, target this program to census tracts with overcrowded conditions in over 20% of households.

Analysis of Impediments to Fair Housing Choice Appendix B – page 6 City of Riverside March 2025
Fair Housing
Issues Contributing Factors
Meaningful
Actions Action Description Lead
HE-6.3 6.3 Develop and maintain an up-to-date residential sites inventory and provide to interested developers with information on available housing development opportunities and incentives on a quarterly basis.

Prioritize publicizing speciﬁc opportunities for aƯordable housing development in High and Higher Opportunity tracts as well as those tracts with median incomes higher than the Area Median Income.

Planning Division
HE-EJ 7.1 7.1 Conduct an inventory of existing housing within environmental justice communities to determine the adequacy and condition of existing housing.

HE-EJ 7.2 7.2 On properties where poor-quality housing conditions are identiﬁed in environmental justice communities, facilitate the permitting process for property owners and residents to remedy and retroﬁt unhealthy and unsafe conditions in a timely fashion. If warranted, pilot this program in census tracts with elevated levels of household overcrowding and substandard housing conditions.

Planning Division
HE-EJ 8.1 8.1 Streamline development approvals for opening full service grocery stores, with particular emphasis on increasing food access in census tracts with CalEnviroScreen scores above the 75th percentile.

Planning Division
HE-EJ 8.2 8.2 Work with retail businesses in environmental justice communities such as local convenience stores and farmers’ markets to increase the availability of fresh produce.

Planning Division
Environmental
Equity Strategies
Lack of public improvements
Concentration of Environmental
Hazards due to Industrial Uses
Lack of basic services and inclusion
in food deserts
HE-EJ 8.1 8.1 Streamline development approvals for opening full service grocery stores, with particular emphasis on increasing food access in census tracts with CalEnviroScreen scores above the 75th percentile.

Planning Division
HE-EJ 8.2 8.2 Work with retail businesses in environmental justice communities such as local convenience stores and farmers’ markets to increase the availability of fresh produce
Housing Authority

Riverside City CouncilMay 20, 2025

Riverside City Council
May 20, 2025