Cities Index.
Agenda packet

Mayor and City Council
June 4, 2025

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Agenda packet
Meeting
June 4, 2025
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Mayor and City Council
Pages
20
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Text extracted from the city's file for reading and search. Open the original on sanbernardino.primegov.com. That file is the official record.

Describe the number and targeting (income level/type of family served) of units assisted with federal, state, and local programs.

The City has a total of 40 assisted housing projects that provide 3, 658 affordable housing units.

Of these, 17 projects are designated as senior housing with a combined total of 1,448 affordable units (Magnolia at Highland, Lugo Apartments, Vintage at Kendall, Arrowhead Vista, Beautiful Light Inn, Baseline Cop, St. Bernardine Plaza, TELACU Monte Vista, TELACU San Bern. Vista, TELACU Buena Vista, TELACU Sierra Vista, TELACU La Amistad, TELACU Hacienda, AHEPA 3002, San Bernardino Senior Housing, Arrowhead Woods, and Ramona Sr. Project ). Most of the City’s affordable housing was funded by HUD, including Section 202 /811, HAP, HOME, PBV, or Project Homekey. Many projects were also financed through Low Income Housing Tax Credits (LIHTC).

Affordable housing units also received funding through the former redevelopment agency or bonds, as well as CalHFA.

The City falls within the jurisdiction of the HACSB. HACSB administers the HCV program, which provides rental assistance to income -eligible residents of San Bernardino by providing monthly rental assistance to participants who rent from a private landlord but pay only 30 percent of the monthly rental payment, with the rest paid to the landlord by HUD. In 2024, HACSB issued 2,019 HCVs to residents in the City. In addition, the following vouchers are issued: 30 Family Unification, 123 VASH, 139 Emergency, 33 HOPWA, 67 Mainstream, and 85 CoC.

Provide an assessment of units expected to be lost from the affordable housing inventory for any reason, such as expiration of Section 8 contracts.

Many of the City’s affordable housing projects were assisted with project-based Section 8 contracts and a significant number of these units are considered at risk of converting to market- rate housing due to expiration of subsidy contracts. A ccording to the City’s 2021-2029 Housing Element, a total of three projects, with a combined total of 328 affordable units, are at high-risk

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of losing their affordability status , while six projects, with a combined total of 369 affordable units are at low risk of losing their affordability status.

Does the availability of housing units meet the needs of the population? No. As shown in Table 32, there are 29,055 owner units and 30,720 renter units in the City. When evaluated by unit size, the majority of owner units are 3 or more bedrooms, while the majority of renter units are two bedrooms in size. As shown in NA-10, there are 7,490 low-income large family households in the City, with 63 percent of these households being cost burdened. In addition, 5,045 low -income renter households struggle with overcrowding (more than one person per room). This suggests a need for larger rental units to meet the needs of larger families, especially those who are extremely low-, very low-, and low-income.

In addition, dat a shows a lack of available units in the housing stock to meet the affordability level required. This is especially true for extremely low-income renters (0-30% AMI) and very low- income owners (30-50% AMI) . According to 2016-2020 CHAS data, there are only enough available rental units affordable to renter households earning 0 to 30 percent AMI to fulfill 20 percent of the need. Further, units available that meet the affordability for owner households earning between 30 to 50 percent AMI fall short as well, fulfilling 54 percent of current needs.

For a more detailed analysis of housing affordability, see MA-15.

Describe the need for specific types of housing:

According to resident responses to our community survey, there is a pressing need for affordable rental housing in the Cit y: 59 percent of respondents mentioned this. Furthermore, 62 percent of respondents rated the availability of affordable housing options in the City as “poor.” Residents also indicated the need for increased housing for large families ( 12 percent of respondents) , as supported by the analysis above and in NA -10. Further, 42 percent of respondents indicated a desire for first time homebuyer program assistance, signaling a need for more affordable owner- occupied unit development.

Community engagement also revealed a need for senior housing, housing for persons with disabilities, and transitional housing to meet the needs of the City’s unhoused population.

According to the State of California Department of Housing and Community Development, households with disabilities are the most likely population to experience homelessness, be rent burdened, and face the highest rates of housing discrimination. Housing that addresses the needs of persons with disabilities often includes affordable units with appropriate accessibility modifications and units centralized near public transit and supportive services.

Discussion

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See discussion above.

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MA-15 Housing Market Analysis: Cost of Housing - 91.210(a) Introduction
Housing costs have the potential to cause issues, particularly when costs are too high relative to household income and less expensive housing is not available . When this is the case, there are higher rates of both cost burden and overcrowding. According to HUD, households who spend more than 30 percent of their income on housing costs are considered cost burdened and may have difficulty affording other necessities, such as food, clothing, transportation, and medical care. As shown in NA-10, of the City’s 36,310 households earning between 0 to 80 percent AMI, (65 percent) are cost burdened.

The City’s housing market has changed over the last ten years. In 2015, the median home value in the City was $ 159,800 and increased to $272,600 (71 percent) by 2020. Meanwhile, median income has increased by 33 percent to $49,287. While wages have increased, they have not increased enough to match the pace of housing purchase costs. Median contract rent , on the other hand, has increased by 19 percent, from $813 to $970. However, just under 55 percent of renters spend $999 or less on monthly rent.

Cost of Housing
Base Year: 2015 Most Recent Year: 2020 % Change
Median Home Value 159,800 272,600 71%
Median Contract Rent 813 970 19%
Table 32 – Cost of Housing

Data Source: 2011-2015 ACS (Base Year), 2016-2020 ACS (Most Recent Year)

Rent Paid Number %
Less than $500 3,365 11.0%
$500-999 13,415 43.7%
$1,000-1,499 11,044 36.0%
$1,500-1,999 2,405 7.8%
$2,000 or more 480 1.6%
Total 30,709 100.0%
Table 33 - Rent Paid
Data Source: 2016-2020 ACS

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Housing Affordability
Number of Units affordable to
Households earning
Renter Owner
30% HAMFI 2,010 No Data
50% HAMFI 6,335 2,020
80% HAMFI 20,969 7,094
100% HAMFI No Data 11,904
Total 29,314 21,018
Table 34 – Housing Affordability
Data Source: 2016-2020 CHAS

Monthly Rent
Monthly Rent ($) Efficiency (no
bedroom)
1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom
Fair Market Rent $1,281 $1,398 $1,751 $2,376 $2,922
High HOME Rent $1,040 $1,116 $1,341 $1,540 $1,699
Low HOME Rent $816 $874 $1,048 $1,211 $1,352
Table 35 – Monthly Rent
Data Source: HUD FMR and HOME Rents (2023)

Is there sufficient housing for households at all income levels? No. Findings in the data reflect a lack of available housing units to meet the affordability needs for several different income and tenure categories.

For extremely low-income households (0 to 30 percent AMI):
• There are enough affordable units available to fulfill 20 percent of renter needs. • Data was unavailable for owner units.

For very low-income households (30 to 50 percent AMI):
• There are enough affordable units available to fulfill 92 percent of renter needs. • There are enough affordable units available to fulfill 54 percent of owner needs. • Without accounting for tenure, there are enough affordable units available to meet the needs for 78 percent of very low-income households.

For low-income households (50 to 80 percent AMI):
• There is a 205 percent surplus of affordable available units to fulfill renter needs. • There is an 18 percent surplus of affordable available units fulfill owner needs.

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• Without accounting for tenure, there is a 117 percent surplus of affordable units available to meet the needs of low-income households.

For median-income households (80 to 100 percent AMI):
• No data was available for rental units.
• There is a 239 percent surplus of affordable available units to fulfill owner needs.

How is affordability of housing likely to change considering changes to home values and/or rents?
Based on market data for home prices and rental units, it can be expected that costs will continue to increase.

According to data published by the State of California’s Department of Finance , the number of San Bernardino County households is projected to grow by almost four percent (approximately 85,000 individuals) between 2025 and 2030. This growth is likely to be concentrated in the county’s urban areas, such as the City . As the population grows, the for -sale housing supply will continue to be pressured as housing stock becomes more in demand. This is likely to increase housing costs in the City. As reflected in Table 33, the City’s median home value increased by 71 percent between the 2015 and 2020 ACS 5-Year Estimates.

Simultaneously, the City’s median contract rent increased by 19 percent between 2015 and 2020 ACS 5-Year Estimates. According to 2016 -2020 ACS data, 45.4 percent of the City’s renters are spending $1,000 or more on monthly rent. This marks a significant change from the data examined in the 2020-2025 ConPlan. At that time, 2011-2025 ACS data showed 28.2 percent of renters spending $1,000 or more on monthly rent.

How do HOME rents / Fair Market Rent compare to Area Median Rent? How might this impact your strategy to produce or preserve affordable housing? According to the 2023 ACS 1 -Year Estimate, the gross rent for the City was $1, 561. Meanwhile, the HUD fair market rent (FMR) for a three -bedroom unit was $2,376, or $815 above the gross rent. The low HOME rent limit for 2023 was $1,211 and the high HOME rent limit was $1,540 for a three-bedroom unit.

Considering the number of units available, there is a need to develop more affordable units for extremely low- to very low-income households. With cost burden defined as 30 percent or more of a household’s income spent on housing, including utilities, affordable housing would therefore cost 30 percent or less of a household’s income, including utilities. The HAMFI for the Riverside- San Bernardino-Ontario, CA MSA in 2023 was $94,500. The maximum affordable rent (MAR) for a family of four earning 80 percent of the area median income (80% AMI), or $74,550, would be

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$1,863.75; for a family of four earning very low -income (30-50% AMI), or $46,600 , MAR would be $1,165; and for a family of four earning extremely low-income (0-30% AMI), or $30,000, MAR would be $750.

Allocating CDBG and HOME funds toward affordable housing development and housing subsidies would help address the increasing cost of rental and ownership housing while alleviating cost burden for the City’s lowest income households.

Discussion
See discussion above.

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MA-20 Housing Market Analysis: Condition of Housing – 91.210(a) Introduction
This section of the ConPlan discusses the City’s existing housing supply, the age and condition of housing, the number of vacant and abandoned units, and the risks posed by lead -based paint (LBP).

According to 2016 -2020 CHAS data, approximately 61 percent of the City’s housing units were built prior to 1980. LBP was popularized in the early twentieth century but was banned for use in public housing through the Lead -Based Paint Act of 1971 due to health concerns . According to the U.S. Environmental Protection Agency (EPA), LBP can be found on window frames, walls, the outside of homes, or on other surfaces. While LBP in good condition typically does not pose a threat, chipped paint or paint dust is harmful when ingested. Young children are considered most at-risk because they routinely place their hands and feet in their mouths. San Bernardino residents living in older housing are at higher risk of LBP hazards, especially children.

Table 37 of this section portrays the conditions of housing stock in the City. HUD defines housing “conditions” similarly to the definition of “housing problems” discussed in the Needs Assessment.

These housing conditions are:

1. More than one person per room

2. Cost burden greater than 30 percent

3. Lack of complete plumbing; and

4. Lack of complete kitchen facilities.

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

In the City, substandard housing conditions may consist of the following: structural hazards, poor construction, inadequate maintenance, faulty wiring, plumbing, fire hazards, and inadequate sanitation. Substandard units suitable for rehabilitation are those units wher e the total rehabilitation costs do not exceed 25 percent of the after-rehabilitation value.

The data in this section is reliant on the American Community Survey’s definition of substandard housing. These conditions include lacking complete plumbing, lacking complete kitchen facilities, overcrowding (having more than one person per room), and cost burden (spending 30 percent or more of income on housing costs).

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Condition of Units
Condition of Units Owner-Occupied Renter-Occupied
Number % Number %
With one selected Condition 9,295 32% 17,000 55%
With two selected Conditions 820 3% 3,450 11%
With three selected Conditions 0 0% 60 0%
With four selected Conditions 0 0% 0 0%
No selected Conditions 18,930 65% 10,214 33%
Total 29,045 100% 30,724 99%
Table 36 - Condition of Units
Data Source: 2016-2020 ACS

Year Unit Built
Year Unit Built Owner-Occupied Renter-Occupied
Number % Number %
2000 or later 3,055 11% 1,940 6%
1980-1999 6,725 23% 9,049 29%
1950-1979 13,805 48% 15,125 49%
Before 1950 5,465 19% 4,600 15%
Total 29,050 101% 30,714 99%
Table 37 – Year Unit Built
Data Source: 2016-2020 CHAS

Risk of Lead-Based Paint Hazard
Risk of Lead-Based Paint Hazard Owner-Occupied Renter-Occupied Number % Number %
Total Number of Units Built Before 1980 19,270 66% 19,725 64% Housing Units build before 1980 with children present 5,075 17% 2,050 7% Table 38 – Risk of Lead-Based Paint
Data Source: 2016-2020 ACS (Total Units) 2016-2020 CHAS (Units with Children present)

Vacant Units
Suitable for
Rehabilitation
Not Suitable for
Rehabilitation
Total
Vacant Units N/A N/A N/A
Abandoned Vacant Units N/A N/A N/A
REO Properties 18 N/A N/A
Abandoned REO Properties N/A N/A N/A
Table 39 - Vacant Units

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Data Source: Auction.com, accessed February 7, 2025

Describe the need for owner and rental rehabilitation based on the condition of the jurisdiction's housing
The City’s housing stock is aging. Overall, approximately 61 percent of occupied housing units were built before 1980. Further, nearly 16 percent of the City’s housing stock was built before 1950. Aging housing stock signifies a need for rehabilitation. Only 11 percent of owner-occupied and 6 percent of renter-occupied units were built in 2000 or later. According to 2016-2020 CHAS data, 32 percent of owner-occupied and 55 percent of renter -occupied units have one selected condition.

In the Community Needs Survey, City residents rated housing rehabilitation as a high CDBG priority (41.67 percent of respondents). During the City’s ConPlan Public Community Meeting, residents indicated a need for LMI homeowner housing rehabilitation and cited that changing weather patterns and seasonal impacts are causing home damage such as roof leaks to occur.

Estimated Number of Housing Units Occupied by Low- or Moderate-Income Families with LBP Hazards
This plan uses the number of units built before 1980 as a proxy for LBP hazard. As shown in Table 39, 38,995 housing units in the City, or almost 61 percent, were built prior to 1980. Around 18 percent of these units are occupied by households with children present.

According to 2016-2020 CHAS data, there are 24,810 LMI households occupying units built prior to 1980 , representing approximately 68 percent of the City’s total LMI households. These households are at-risk of exposure to LBP hazards. Of the 24,810, approximately 38 percent are owner-occupied, and 62 percent are renter -occupied. Almost 27 percent of all LMI households occupying housing units built prior to 1980 contain one or more children aged six or younger.

Discussion
San Bernardino’s housing stock faces aging infrastructure and other concerns discussed throughout this section’s narratives. Rehabilitation efforts can help all residents, regardless of income, have access to safe and decent housing. Community engagement efforts reflect the findings of a need for homeowner rehabilitation in the City.

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MA-25 Public and Assisted Housing – 91.210(b)
Introduction
. Based on the HASCB FY2025 Moving to Work (MTV) Annual Plan, HACSB manages the HCV Program and plays a crucial role in providing affordable housing in the jurisdiction, supporting approximately 27,000 individuals. This includes seniors, people with disabilities, veterans, and children. As of June 30, 2024, more than 11,500 households cu rrently benefit from housing assistance payments or reside in properties owned and managed by HACSB.

Total Number of Units
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project-
Based
Tenant-
Based
Special Purpose Vouchers
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
# of
Vouchers
Available
- - 1 11,510 2,242 7,508 420 118 0
# of
Accessible
Units
- - - - - 550 123 5,555 1,777
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 40 – Total Number of Units by Program Type
Data
Source:

PIC (PIH Information Center)

Describe the supply of public housing developments:

The HUD Appropriations Act of 2012 introduced the Rental Assistance Demonstration (RAD) program, enabling public housing agencies (PHAs) to transition their public housing units to project-based Section 8 contracts. Under this program, tenants eligible based on income pay 30 percent of their earnings, with rental assistance covering the gap between what they can afford and the approved rent. Tenants can apply to renew their Section 8 contracts.

HACSB has fully converted its Public Housing portfolio to RAD project -based vouchers (PBV), except for one single-family home. The planned project-based voucher properties include:

• Family Community, New Development – 285 units
• Family Community, Existing Development – 415 units
• RAD Conversion, Existing Public Housing Community – 1,004 units

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• Senior Community, Existing Development – 397 units
• Family & Senior Community, New Development – 11 units • Project-Based Voucher Program – 70 units
• Chronically Homeless, Existing Development – 69 units

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

As previously mentioned, all HACSB units will be converted to project -based vouchers. The RAD program allows these properties to secure private financing, enabling owners to address deferred maintenance issues that have plagued public housing nationwide. HACSB refers to these housing projects as Asset Management Projects.

HACSB has received approval to convert its entire Public Housing portfolio under the RAD program. As of Fiscal Year (FY) 2024, only one single-family public housing unit remains, with no plans to convert or remove it in FY 2024 -2025. This unit is not located in the City. Additionally, HACSB does not plan to add any new public housing units during this period.

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Public Housing Condition
Former Public Housing (pre-RAD)
Public Housing Development Average Inspection Score
Arrowhead Grove 64
Table 41 - Public Housing Condition

Arrowhead Grove is under the HUD Rental Assistance Demonstration project (RAD). The score is based on HUD required portfolio inspection standards at last required inspection. Physical inspection scores start at 100 points for all properties. Each observed deficiency reduces the score based on its importance and severity, the number of buildings and units inspected, the items present for inspection, and the relative weights of these items and areas.

Describe the restoration and revitalization needs of public housing units in the jurisdiction:

HACSB has been approved to transform its entire Public Housing portfolio through the RAD program. As of FY 2024, only one single-family Public Housing unit remains, which is not located in the City. Furthermore, HACSB does not intend to add any new public housing units during this time.

Describe the public housing agency's strategy for improving the living environment of low- and moderate-income families residing in public housing:

In 2023, HACSB adopted a strategic plan with five Aspirational Statements that guide the agency's direction and align with MTW objectives. These long-term strategies include:

1. Cultivating a culture that values effective communication, learning opportunities, work - life balance, professional development, and a shared passion for the mission.

2. Being recognized as a provider of safe, dignified, and desirable homes and environments that enhance the community, ensuring financial stability, monitoring, and accountability as stewards of limited funding.

3. Using research and technology to drive innovative programs and processes, enhancing responsiveness and advancing the families served.

4. Creating and utilizing partnerships that provide opportunities and make a meaningful difference in the lives of the families served.

5. Maximizing resources by leveraging community partners' talents.

To help families and individuals become self -sufficient and financially independent, HACSB implemented the following strategies:

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1. Operational Efficiency through Innovation – Maximized HACSB’s economic viability and sustainability through:
• Researched, implemented, and maintained technology to improve service delivery and enhance external communication.
• Used software systems to streamline processes and increase productivity. • Utilized Moving to Work (MTW) flexibilities and research -informed policy decisions to drive and expand innovation.
• Fostered a collaborative, diverse, equitable, and inclusive work environment that offered opportunities for interaction.
• Identified, reorganized, and implemented financial processes to assist in monitoring HACSB’s major programs and portfolio.
• In addition to non-MTW activities, HACSB has implemented 12 MTV activities to address this strategy.

2. Develop Economically Independent Clients – Facilitated opportunities for families and individuals to become self-sufficient and financially independent through:
• Created an internal partnership management structure that supported, strengthened, and evaluated partnerships to improve program outcomes. • Worked with customers and staff to identify resource needs, gaps, and priorities, focusing on partnerships that effectively addressed customers’ needs. • In addition to non-MTW activities, HACSB has implemented nine MTV activities to address this strategy.

3. Ensure Freedom of Housing Choice – Provided quality affordable housing opportunities in mixed-income communities with access to an excellent quality of life through:
• Created a Road Map for real estate developments.
• Developed and implemented an internal Repair and Replacement plan that assessed and prioritized the needs of all properties and established a finance plan to fund these needs. • Ensured that leasing efforts aligned with voucher/funding utilization for all rental assistance programs.

In addition to non-MTW activities, HACSB has implemented nine MTV activities to address this strategy.

Discussion:

See discussion above.

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MA-30 Homeless Facilities and Services – 91.210(c)
Introduction
The City assists homeless populations through funding supportive service providers in the community. The City has traditionally provided funding through the ESG program to support services that include emergency shelter, rapid rehousing, homelessness prevention, street outreach, and HMIS costs.

Detailed information on strategic action for homeless facilities and services is described in the County’s 2022 Homeless Strategic Action Plan. A range of services, from permanent supportive housing to rental assistance, are detailed.

Facilities and Housing Targeted to Homeless Households
Emergency Shelter Beds Transitional
Housing Beds
Permanent Supportive Housing
Beds
Year-Round Beds
(Current & New)
Voucher /
Seasonal /
Overflow Beds
Current & New Current & New Under
Development
Households with Adult(s) and
Child(ren)
368 32 258 712 N/A
Households with Only Adults 517 - 158 937 N/A
Chronically Homeless Households N/A - N/A 614 N/A
Veterans 0 - 18 778 N/A
Unaccompanied Youth 12 - 2 0 N/A
Table 42 - Facilities and Housing Targeted to Homeless Households Data Source Comments: 2024 San Bernardino City and County CoC Housing Inventory Count

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Describe mainstream services, such as health, mental health, and employment services to the extent those services are used to complement services targeted to homeless persons The San Bernardino County Homeless Partnership (SBCHP) consists of community and faith - based organizations, educational institutions, non -profit organizations, private industry, and federal, state, and local governments. SBCHP was developed to promote a strong collaboration between agencies to direct the planning, development, and implementation of the County’s 10- year Strategy to end chronic homelessness. SBCHP provides leadership in creating a comprehensive countywide network of service delivery to the ho meless and near homeless families and individuals through facilitating better communication, planning, coordination, and cooperation among all entities that provide services and/or resources for the relief of homelessness in San Bernardino County. This includes a bilingual Coordinated Entry System, which is available by calling 211.

In addition to SBCHP, m any organizations in the City , including businesses, civic groups, corporations, educational institutions, faith -based organizations, local government, and nonprofit agencies, provide financial assistance, food, health care, clothing, legal assistance, public assistance, rental assist ance, and utility assistance , are available at little or no cost.

Mainstream benefit programs such as CalFresh, Medicaid/Medi -Cal, Social Security Disability Income, Supplemental Security Income, and Veteran’s Benefits are available to homeless persons in the City.

Additionally, the Homeless Provider Network (HPN) acts as an advocate for homeless populations and those at risk of becoming homeless. The HPN facilitates the collaboration between the public and private sectors to coordinate services to assist and prevent homelessness. Member organizations of the HPN meet monthly.

Additional information about the SBCHP can be found on the County’s website.

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

The City works with various agencies and provides referrals for services to homeless populations and those at risk of homelessness:
• Community Action Partnership of San Bernardino County – provides homeless persons and those at risk of homelessness with temporary rental assistance, financial literacy education, and linkages to other support services.

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• Family Service Association of Redlands – provides emergency shelter (motel vouchers), wraparound services, and case management to prevent homelessness. • Lutheran Social Services – provides emergency shelter as a "bridge" to permanent housing, and wrap-around services to help homeless men 18 years and older to achieve self-sufficiency.
• Step Up on Second – provides supportive services which begin with engagement and street outreach activities.
• The Salvation Army Hospitality House – provides emergency shelter, referrals to permanent housing services, and meals to families and single females experiencing homelessness.
• Restoration House of Refuge – provides emergency shelter to adult men and women. • Operation Grace – provides emergency shelters, transitional housing, and supportive services to families.
• Foothill AIDS Project – provides comprehensive services to those infected and affected by HIV/AIDS.
• Family Assistance Program – provides transitional housing to individuals and families. • Mary’s Mercy Center – provides food, showers and clothing; also provides 12-24 month transitional living programs for men and separately, women and children. • Time for Change Foundation – provides emergency shelter services to women and children, as well as permanent housing.
• Keys Nonprofit – provides rapid re-housing assistance to veterans and families. • The Hub for Urban Initiatives – consists of several community- and faith-based institutes that respond to the economic, housing, and social needs of neighborhoods, cities, and counties from local community, regional, national, international, and faith -based perspectives. Urban Initiatives has completed over 100 assessments for local government and private organizations throughout Southern California that have focused on affordable housing, business development and education for micro -businesses, fair housin g, homelessness, migrant farming, and street vending.
• Helping Hands Pantry – a food bank, serves the communities of the County of San Bernardino; programs include a mobile food pantry and the College Student Food Assistance Program for students who do not have the resources to buy enough food. • The San Bernardino County Office of Homeless Services (OHS) serves as a “clearinghouse” of homeless issues for all County departments. Any homeless issues encountered by County staff can be referred to this office for resolution. OHS staff plays a vital ro le in SBCHP as the administrative support unit to the organization. OHS ensures that SBCHP’s vision, mission, and goals are carried into effect.

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Other agencies in the County providing services to address homelessness include:
• Catholic Charities San Bernardino
• High Desert Homeless Services, Inc.
• Victor Valley Family Resource Center
• Lighthouse Social Service Centers
Motel vouchers in San Bernardino County, California are available through a number of organizations, including the Salvation Army, Mercy House, Community Action Partnership of San Bernardino County, and Redlands Family Service. These vouchers can help people experiencing homelessness find temporary housing while they work towards a permanent solution.

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MA-35 Special Needs Facilities and Services – 91.210(d) Introduction
This section outlines the supportive housing needs and programs for special populations in the City. These populations include those who have disabilities, elderly, individuals living with HIV/AIDS, female-headed households, veterans, persons with drug and alcohol addition, and survivors of domestic violence.

There are 11 residential elder care facilities in the City that accommodate 454 persons.

According to the 2023 5-year ACS, 27,678 residents of San Bernardino have a disability, which is

12.8 percent of the total population.

Based on Point-in-Time Count data, 866 of the 3,012 unsheltered homeless individuals counted in 2024, or about 28 percent, were substance users. The PIT Count also revealed there were 90 persons living with HIV/AIDS experiencing homelessness.

The City’s low -moderate income and /or homeless veterans are primarily housed and assisted through the Veterans Assistance and Supportive Housing (VASH) Program in conjunction with the Veterans Administration (VA).

Including the elderly, frail elderly, persons with disabilities (mental, physical, developmental), persons with alcohol or other drug addictions, persons with HIV/AIDS and their families, public housing residents and any other categories the jurisdiction may specify, and describe their supportive housing needs
Elderly and fail elderly: seniors are much more likely to have a disability than non-seniors. Based on data from the ACS, 36 percent of residents 65 and older have a disability compared to 11 percent of residents under the age of 65. As such, the supportive needs and housing needs of the elderly are often aligned with those of the disability community , such as accessible housing and access to transit. In addition, seniors typically need access to health service s, home health care options, and support related to aging in place such as home modification, home repair, and assistance with maintenance. Frail elderly require assistance with three or more activities of daily living, such as bathing, walking, and performing light housework. This population requires more intensive supportive housing, such as home health aides, paratransit, or assisted living.

Licensed community care facilities offer housing and specialized services for children and adults that have special needs. According to the State Department of Social Services’ Community Care Licensing Division, there are 41 adult residential facilities in the City. Such facilities provide safe and secure places for the elderly and persons with disabilities to stay while their primary caretakers work or run errands. As of April 2025, the adult residential facilities in the City had the capacity to accommodate a total of 297 persons. The state’s Community Care Licensing Division

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serves the most vulnerable people of California, and its mission is to promote the health, safety, and quality of life of each person in community care through the administration of an effective and collaborative regulatory enforcement system.

Residential care facilities for the elderly are family homes, group care facilities, or other similar facilities in which non -medical care is provided 24 hours per day to support daily activities and ensure personal security of the elderly. There are 11 residential elder care facilities in the City that accommodate 454 persons.

Persons with disabilities: Supportive services are a critical component of creating equitable opportunities in the community for people with disabilities. These services are particularly important for residents transitioning out of institutional care.

In typical housing markets, persons with disabilities have difficulty finding housing that accommodates their needs. Persons with self -care and mobility limitations may also require housing design features such as wheelchair ramps, grab bars, special bathroom designs, and/or wider doorway openings. Regulatory barriers on group living arrangements, transit access, housing accessibility and visitability, and proximity to health services, are just some of the issues that people with disabilities face.

According to the 2023 5-year ACS, 27,678 residents of San Bernardino have a disability, which is

12.8 percent of the total population. Those aged 65 and older have the highest rate of reported disability at 41.3 percent, while the rate for reported disability for children under 18 i s 4.7 percent. While California has long been a national leader in prioritizing social and health supports to allow residents with disabilities to live in independent, integrated settings, more than a decade of deep state budget cuts has stretched the available support s leading to housing insecurity for this vulnerable population.

A major challenge facing the City is the availability of housing stock with accessible features that meet the needs of disabled residents and their families. The ACS 2023 5 -Year estimates showed that 6,332 residents were both above the age of 65 and living below the poverty level , or 2.8 percent of the population . Living below the poverty level further limits resources and puts an additional constraint on the already limited housing options available to seniors with a disability.

Persons with alcohol or drug addictions: Alcohol or other drug addiction supportive services are needed to provide a safe and stable environment that facilitates recovery . Based on Point -in- Time Count data, 866 of the 3,012 unsheltered homeless individuals counted in 2024 , or about 28 percent, were substance users. Treatment of alcohol and drug addiction is critical to resolve and prevent homelessness in the City.

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The County of San Bernardino provides alcohol and drug services through the Substance Use Disorder and Recovery Services (SUDRS) program . Services are available to all County residents and include components such as recovery centers, perinatal treatment programs, narcotic treatment programs, and connection to outpatient treatment providers.

Additionally, Community Supervised Treatment After Release (CSTAR) is a treatment component of the Mental Health Court System of Care. CSTAR is a court -referred outpatient program for adults with serious and persistent mental illness. CSTAR helps address the mental health and substance use disorder needs of adults who have repeated contact with the criminal justice system. Individuals are generally referred while incarcerated in the West Valley Detention Center.

Persons living with HIV/AIDS : AIDSVu estimates that there are 5,240 persons living with HIV/AIDS (PLWHA) in Sa n Bernardino County. In the 2024 Point -in-Time Count, there were 90 persons living with HIV/AIDS experiencing homelessness. The National HIV/AIDS Housing Coalition notes that persons with HIV/AIDS are at increased risk of becoming homeless due to their illness, lack of income or other resources, and having a weak support network. Persons with HIV/AIDS may also require a broad range of services, including counseling, medical care, in-home care, transportation assistance, and food provision.

Challenges to housing for those with HIV/AIDS include securing stable employment and income, rental history, criminal history, and co -occurring circumstances. It is difficult for people with HIV/AIDS to retain employment due to their health and the side ef fects of drug treatment therapies. Many have mental health issues/substance abuse issues as well. Given the high medical costs associated with HIV/AIDS, it is critical that facilities, rental assistance, and mortgage assistance remain available for these r esidents. The primary housing resource for persons living with HIV/AIDS is the Ryan White HIV/AIDS Program which provides emergency housing assistance (hotel/motel vouchers), both of which the Count ies of Riverside and San Ber nardino receive as part of a joint service area.

Veterans: Public housing, primarily through the Veterans Assistance and Supportive Housing (VASH) Program, offers housing vouchers with wrap around supportive services in conjunction with the Veterans Administration (VA) for former members of the armed services tha t need assistance. Former service members are more likely to become homeless than the population as a whole. In San Bernardino County, veterans make up 4.6 percent of the population accessing CoC services according to HDIS data. Veterans often suffer from specific service-related physical and mental disabilities and, as such, have specific special needs for housing.

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Describe programs for ensuring that persons returning from mental and physical health institutions receive appropriate supportive housing
The City has worked with St. Bernadine Hospital to transition homeless individuals who are being discharged from the hospital into transitional housing and ultimately transition into permanent housing. The City will continue to support the regional Continuum of Care’s efforts to implement the San Bernardino County 10 -Year Strategy for Ending Homelessness. This Plan includes a recommendation to focus on discharge planning to prevent people from becoming homeless when they are discharged from correctional, fo ster care, health care, or mental health care systems. The McKinney -Vento Act requires that state and local governments have policies and protocols in place to ensure that persons being discharged from a publicly funded institution or system of care are not discharged immediately into homelessness.

To meet HUD’s requirements, the 10 -Year Strategy has established a Discharge Planning Committee to focus on improving coordination between discharge planning agencies, local government, and homeless service providers in order to implement a “zero tolerance” plan that will prevent persons from being discharged into homelessness. As part of its FY 2025 –26 ESG program, the City has awarded funding to two key service providers: the Family Service Association of Redlands and The Salvation Army. These organizatio ns will deliver targeted services to address homelessness and prevent housing instability among vulnerable populations.

The Family Service Association of Redlands will administer Rapid Rehousing activities, providing move-in assistance, short- to medium-term rental subsidies, and supportive services such as case management, income assessment, and housing navigation to help individuals and families secure and sustain permanent housing.

The Salvation Army will utilize ESG funding to operate emergency shelter services and provide homelessness prevention support through rental assistance and stabilization services. Their program will also offer case management and linkages to community resources to help residents maintain housing and avoid future episodes of homelessness.

Together, these ESG -funded efforts support the City's ongoing commitment to addressing the needs of people experiencing or at risk of homelessness and align with the regional goals of the San Bernardino County Continuum of Care (CoC) and the 10-Year Strategy to End Homelessness.

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On June 27, 2024, the Office of Homeless Services received the Homeless Discharge Planning Grant (Grant No. 165429) from Kaiser Foundation Hospitals in the amount of $200,000. The grant award helps fund the Homeless Discharge Planning project which will be implemented through the San Bernardino County Office of Homeless Services, to coordinate and streamline access to services and housing for homeless patients discharged from hospital and emergency room settings, purposefully engaging patients to enhance the continuity of care.

Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals. 91.315(e)
Through CDBG, ESG, and other available resources, the City traditionally funds organizations that provide services to residents in need. Such funding support includes ADA accessibility for public spaces and service organizations providing assistance and re ferrals to low -income persons in need of various supportive services.

For entitlement/consortia grantees: Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals. (91.220(2)) See above discussions.

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MA-40 Barriers to Affordable Housing – 91.210(e)
Negative Effects of Public Policies on Affordable Housing and Residential Investment Certain public policies can create challenges for developing affordable housing and residential investments in the City, leading to higher costs and directly preventing affordable housing from being built. As explained in the City’s 2021-2029 Housing Element and in tandem with the 2025- 2029 Analysis of Impediments to Fair Housing Choice (AI), these barriers affect every stage of the planning and development process. The follow ing barriers and impediments to affordable housing include:

1. Environmental Reviews & Land Use Regulations:

Environmental evaluations can be time -consuming and expensive, especially when a thorough examination is needed according to the California Environmental Quality Act (CEQA) or the National Environmental Policy Act (NEPA). If a developer wants to rezone a p arcel or area, it necessitates a change to the General Plan or Zoning Ordinance, categorizing it as a project under CEQA. This initiates further environmental evaluations, possibly resulting in an extended and frequently contentious procedure. Such delays and increased expenses can greatly discourage developers from engaging in affordable housing initiatives.

Furthermore, the City's land use and zoning rules, although encouraging diverse housing options, still impose some limitations. The Residential Land Use Element defines nine residential zoning districts with density caps varying from one unit per acre (RE) to 130 units per acre (CR -2), yet numerous high-density zones are constrained to commercial regions or necessitate mixed -use development, potentially raising expenses and complications for developers.

2. Community Opposition & Density Restrictions
Changes to land use density, parking rules, lot coverage limits, minimum unit dimensions, and height limitations might all possibly contribute to making housing more affordable. Nevertheless, there is frequently significant community resistance to modifica tions that would permit denser housing. As stated in the Housing Element, This "Not In My Backyard" (NIMBY) attitude has led to delays in development, higher expenses, and in certain instances, the complete blockage of new affordable housing units.

For instance, minimum parking mandates can greatly affect affordable housing initiatives by diminishing the availability of buildable land and elevating construction expenses. The City acknowledges this challenge and has implemented lower parking standards in transit -served areas to ease restrictions, yet parking policies still pose a hurdle in regions with limited transit access.

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3. Zoning Limitations on Emergency Shelters & Transitional Housing The zoning regulations concerning emergency shelters and transitional housing additionally pose obstacles for at-risk groups. Although the City has created an Emergency Shelter Overlay Zone, emergency shelters are only allowed by -right in specified industrial and commercial areas—not in residential zones where they could be more reachable for those facing homelessness. This restricts the practicality of shelter construction and decreases the number of available locations.

Furthermore, single-room occupancy (SRO) units, boarding houses, and other temporary housing alternatives encounter extra zoning obstacles. SROs, seen as a budget -friendly housing option, can only be allowed with a Conditional Use Permit (CUP) in restricte d commercial areas (CG -2 and CR-2), thus imposing additional bureaucratic and financial challenges on developers.

4. Constraints on Multi-Family & Supportive Housing
Although the City allows multi -family residences in various zones, further limitations may obstruct affordable housing construction. Numerous multi -family projects need discretionary approvals, introducing an additional review stage and possible delays.

Likewise, although small community care centers (housing six or fewer residents) are permitted by-right in all residential areas, larger residential care centers (catering to seven or more individuals) typically need a Conditional Use Permit ( CUP) in most areas. This establishes a regulatory obstacle to broadening housing alternatives for seniors, people with disabilities, and those requiring supportive housing.

5. Regional Housing Needs Allocation (RHNA) Challenges
The City has been assigned 8,123 housing units through the 2021 -2029 Regional Housing Needs Assessment (RHNA), which includes 2,512 units set aside for very low - and low-income families.

Though the City is not required to construct these units on its own, it must find and designate suitable locations for their placement. Nonetheless, obstacles like land access, infrastructure limitations, zoning laws, and financial viability restrict the construction of affordable housing to achieve this goal.

6. Accessibility Barriers for Individuals with Disabilities Federal and state regulations mandate that new homes adhere to accessibility guidelines, yet difficulties persist in adapting current housing to accommodate individuals with disabilities. The City’s Reasonable Accommodation Ordinance establishes a procedur e for individuals to seek adjustments to zoning and land use rules to support a disability. Nonetheless, there are no specific financial aid programs offered for low -income people requiring home alterations to ensure their current residences are accessible.

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Furthermore, senior housing, congregate care, and supportive housing alternatives encounter zoning restrictions and approval requirements, restricting choices for individuals with disabilities seeking specialized accommodations.

7. Financial Constraints & Development Costs
The expenses for land, labor, and materials in housing development have consistently risen, resulting in challenges for creating affordable housing without substantial incentives or subsidies.

Although the City's Density Bonus Ordinance permits developers to raise unit totals by as much as 25 percent by including affordable housing, other financial obstacles —including impact fees, infrastructure expenses, and prevailing wage mandates—persist in complicating the financing of affordable projects.

Although the City has made efforts to lower regulatory obstacles for affordable housing —like allowing various housing types, creating an Emergency Shelter Overlay Zone, and providing density bonuses —considerable challenges persist. Environmental assessments, zoning restrictions, community resistance, emergency shelter shortages, accessibility obstacles, and financial barriers all hinder the development of affordable housing. To overcome these obstacles, it will be necessary to impl ement policy reforms, enha nce incentives, and foster community involvement to guarantee that affordable housing is attainable and available for every resident.

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MA-45 Non-Housing Community Development Assets – 91.215 (f) Introduction
Based on the EDD Major Employers in San Bernardino data , the top employers in the City are the Amazon Fulfillment Center, San Bernardino County Sheriff’s Department, California State University San Bernardino, and Inland Regional Center.

Economic Development Market Analysis
Business Activity
Business by Sector # of Workers # of Jobs Share of
Workers
%
Share of
Jobs
%
Jobless workers
%
Agriculture, Mining, Oil & Gas Extraction 761 208 1 0 -1 Arts, Entertainment, Accommodations 8,171 7,641 11 11 -1 Construction 4,891 2,893 7 4 -3
Education and Health Care Services 13,114 15,824 18 22 4 Finance, Insurance, and Real Estate 2,416 3,159 3 4 1
Information 788 281 1 0 -1
Manufacturing 6,128 3,668 9 5 -4
Other Services 2,275 2,360 3 3 0
Professional, Scientific, Management
Services 3,215 4,047 5 6 1
Public Administration 0 0 0 0 0
Retail Trade 8,760 8,958 12 12 0
Transportation and Warehousing 8,769 15,628 12 22 9
Wholesale Trade 4,066 3,060 6 4 -1
Total 63,354 67,727 -- -- --
Table 43 - Business Activity
Data
Source:
2016-2020 ACS (Workers), 2020 Longitudinal Employer-Household Dynamics (Jobs)

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Labor Force
Total Population in the Civilian Labor Force 95,074
Civilian Employed Population 16 years and over 86,840
Unemployment Rate 8.66
Unemployment Rate for Ages 16-24 22.14
Unemployment Rate for Ages 25-65 4.68
Table 44 - Labor Force
Data Source: 2016-2020 ACS

Occupations by Sector Median Income
Management, business and financial 10,655
Farming, fisheries and forestry occupations 3,515
Service 11,565
Sales and office 18,195
Construction, extraction, maintenance and
repair 10,590
Production, transportation and material
moving 10,335
Table 45 – Occupations by Sector
Data Source: 2016-2020 ACS

Travel Time
Travel Time Number Percentage
< 30 Minutes 49,850 61%
30-59 Minutes 22,015 27%
60 or More Minutes 9,707 12%
Total 81,572 100%
Table 46 - Travel Time
Data Source: 2016-2020 ACS

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Education
Educational Attainment by Employment Status (Population 16 and Older) Educational Attainment In Labor Force
Civilian Employed Unemployed Not in Labor
Force
Less than high school graduate 16,209 1,855 13,690
High school graduate (includes
equivalency) 21,175 1,360 10,530
Some college or Associate's degree 21,590 1,075 7,925
Bachelor's degree or higher 10,120 795 2,320
Table 47 - Educational Attainment by Employment Status
Data Source: 2016-2020 ACS

Educational Attainment by Age
Age
18–24 yrs 25–34 yrs 35–44 yrs 45–65 yrs 65+ yrs
Less than 9th grade 330 1,340 3,335 7,344 3,950
9th to 12th grade, no diploma 2,700 5,250 6,529 7,945 3,075 High school graduate, GED, or
alternative 9,194 11,225 8,175 13,690 5,610
Some college, no degree 10,385 8,964 5,285 8,630 4,640
Associate's degree 1,015 2,755 1,915 3,074 1,555
Bachelor's degree 1,300 3,450 2,349 3,445 1,285
Graduate or professional degree 105 1,140 930 1,920 794 Table 48 - Educational Attainment by Age
Data Source: 2016-2020 ACS

Educational Attainment – Median Earnings in the Past 12 Months Educational Attainment Median Earnings in the Past 12 Months Less than high school graduate 24,549
High school graduate (includes equivalency) 28,946
Some college or Associate's degree 82,707
Bachelor's degree 104,518
Graduate or professional degree 123,313
Table 49 – Median Earnings in the Past 12 Months
Data Source: 2016-2020 ACS

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Based on the Business Activity table above, what are the major employment sectors within your jurisdiction?
The main employment sectors in the City are Education and Health Care Services, Transportation and Warehousing, Retail Trade, Arts, Entertainment, and Accommodations, and Manufacturing.

• Education and Health Care Services employ the largest share, with 13,114 workers and 15,824 positions, making up 18 percent of the workforce and 22 percent of total jobs. • Transportation and Warehousing follow closely, with 8,769 workers and 15,628 jobs, accounting for 12 percent of the workforce and 22 percent of total jobs. • Retail Trade represents 12 percent of both the workforce and employment opportunities, with 8,760 workers and 8,958 positions.
• The Arts, Entertainment, and Accommodations sector employs 8,171 individuals and offers 7,641 positions, accounting for 11 percent of the workforce and job opportunities. • The Manufacturing sector includes 6,128 employees and 3,668 positions, representing nine percent of the workforce and five percent of total jobs.

Describe the workforce and infrastructure needs of the business community:

The City has a civilian workforce of 95,074 but contends with a n unemployment rate of 8.66 percent, with 4.68 percent among those aged 25-65. This exceeds the national rate of 6.7 percent and the 7.2 percent rate for comparably sized cities.

An analysis of the community survey carried out as part of this plan highlighted the following workforce and infrastructure needs:
• Economic Development Requires Enhancement : 15. 9 percent of respondents (23 individuals) reported a need for improvement in economic development, particularly concerning jobs and businesses. This indicates that a notable segment of the community believes the existing economic framework is inadequate for fostering job growth and business expansion.
• Work Attainment Services for the Homeless: 20.6 percent of respondents (30 individuals) recognized work attainment services as a key necessity for tackling homelessness. This demonstrates a significant connection between job opportunities and the decrease of homelessness, highlighting the importance of effective job placemen t and support services.

When residents were asked to identify the top three most critical economic development needs, their top responses were:

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1. Job Creation/Job-Generating Businesses: 75.17 percent of respondents (109 out of 215) emphasized this as the highest priority need. This significant majority highlights the pressing need for efforts that promote job creation and draw in companies that can produce employment opportunities.

2. Job Readiness Programs : 44.14 percent of respondents (64 out of 215) identified job readiness programs as an essential requirement. This underscores the importance of training and educational initiatives that equip individuals for the job market, guaranteeing they possess the skills needed by employers.

3. College Readiness Initiatives : 34.48 percent of respondents (50 out of 215) identified college readiness initiatives as crucial. This highlights the significance of higher education and the necessity for initiatives that assist students in moving from high school to college, ultimately fostering a more knowledgeable and skilled workforce.

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

In 2023, the City launched the Downtown Specific Plan (DTSP) to rejuvenate the downtown region, highlighting its importance in education, economic growth, and culture. The proposal envisions over 15,000 residential units, featuring a key project on the 43 -acre Carousel Mall location. A goal of the plan is to utilize the Carousel District’s potential to draw in visitors through its arts and entertainment facilities by further enhancing the area.

California State University, San Bernardino (CSUSB) plays a crucial role in the local economy, producing more than $536 million in yearly expenditures in California and supporting over 2,000 jobs in the area. The university's existence fosters job opportunities in education, administration, and diverse sup port services, helping to reduce unemployment rates for graduates relative to individuals with just a high school diploma.

These modifications generate multiple requirements for workforce enhancement, business assistance, and infrastructure. The elevated unemployment rate signifies a demand for job creation and training programs to prepare residents with essential skills. Furthermore, the focus on economic growth and employment services underscores the significance of aiding enterprises and offering strong job placement assistance to mitigate unemployment and homelessness.

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How do the skills and education of the current workforce correspond to employment opportunities in the jurisdiction?
As discussed, the Education and Health Care Services sector employs the largest share of the workforce, making up 18 percent of the workforce and 22 percent of total jobs. The presence of institutions like California State University, San Bernardino (CSUSB) and various health care facilities ensures a steady supply of educated professionals in education, administration, and health care services.

Additionally, the City's focus on revitalizing the downtown area and developing the Carousel District enhances opportunities in arts, entertainment, and hospitality. This sector encompasses 8,171 individuals and offers 7,641 positions, accounting for 11 percent of the workforce and job opportunities.

Furthermore, in the Manufacturing sector, which includes 6,128 employees and 3,668 positions, representing nine percent of the workforce and five percent of total jobs, the InTech Center's hands-on training programs in advanced manufacturing, industrial maintenance, and robotics help bridge the skills gap in this sector, supporting local businesses and enhancing employment opportunities.

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

The City has a notably large lower -income community that could benefit significantly from increased economic opportunities, many of which are linked to educational and job prospects.

As explained in the 2021-2029 Housing Element , the City can and does actively promote economic development initiatives that enhance workforce training efforts.

In 2023, the California Workforce Development Board granted $20 million to the San Bernardino Community College District for the enhancement of career training programs in fields such as water, health, logistics, trucking, and energy -utility line clearance. This initiative aligns with the ConPlan's goal of enhancing workforce development and reducing unemployment.

In 2019, the Citadel Community Development Corporation, a nonprofit located in San Bernardino, was awarded a $1.5 million grant by the U.S. Department of Labor. This funding reinforces Citadel's goal to assist former inmates in the Inland Empire in rejoining the workforce by providing financial support for job training and assistance for new employees. This effort supports the ConPlan's objective of providing economic opportunities through job training and employment assistance.

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In 2017, the San Manuel Band of Mission Indians (SBBMI) contributed $3.4 million to Goodwill to train and employ as many as 1,580 residents via Goodwill's Career Pathways Program. In 2021, SBBMI contributed another $4.0 million. These contributions align w ith the ConPlan's focus on providing support services that help residents overcome barriers to employment.

Does your jurisdiction participate in a Comprehensive Economic Development Strategy (CEDS)? No.

If so, what economic development initiatives are you undertaking that may be coordinated with the Consolidated Plan? If not, describe other local/regional plans or initiatives that impact economic growth.

Not applicable.

Discussion
See discussion above.

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MA-50 Needs and Market Analysis Discussion
Are there areas where households with multiple housing problems are concentrated? (include a definition of "concentration")
In the City, several census tracts show a notable clustering of households facing various housing issues as identified in the HUD AFFH Map per. Numerous regions exhibit notably elevated concentrations, with over 70 percent of homes impacted. Included are Census Tract 55 (75.71 percent) and Census Tract 56 (75.62 percent), both showing the highest percentages, together with Tract 63.01 (73.70 percent) and Tract 41.03 (73.31 percent). Moreover, Tract 49 (71.88 percent) and Tract 69.04 (70.84 percent) also show significant housing issues. Between 65 percent and 70 percent is seen in other various regions. These consist of Tract 65 (68.23 percent) and Tract 4104 (68.28 percent), along with Tract 76.01 (66.49 percent) and Tract 706.01 (66.94 percent). In the same way, Tract 62.03 (66.10 percent) and Tract 54 (65.03 percent) also lie within this range, indicating a potential common problem in these areas.

Table 50 – HUD AFFH Mapper
Finally, some census tracts have between 60 percent and 65 percent of households affected, indicating regions that, although somewhat less severe, still encounter considerable housing difficulties. This encompasses Tract 53 (62.18 percent), Tract 58 (63.68 percent), Tract 64.01 (64.12 percent), Tract 42.01 (64.52 percent), and also Tract 74.08 (61.94 percent). Even though

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these regions show a lower percentage compared to the highest -concentration zones, they still reflect a significant demand for focused housing support and intervention.

This indicates that housing issues are not limited to one specific area but are spread throughout different sections of the City, with some neighborhoods experiencing particularly elevated levels of housing instability.

Are there any areas in the jurisdiction where racial or ethnic minorities or low-income families are concentrated? (include a definition of "concentration") A minority concentration denotes census tracts in which the proportion of individuals belonging to racial or ethnic minority groups exceeds the City average by a minimum of 20 percent. The City contains two regions recognized as areas with concentrated rac ial or ethnic minorities: Census Tract 48.00 and Census Tract 57.01.

An LMI (low - to moderate-income) concentration is characterized as a census tract where the median household income is at or below 80 percent of the state median family income, the median family income is at or below 80 percent of the median family income for the metropolitan area, or the federal poverty rate is 20 percent or more.

Several census tracts show a significant presence of low-income family households. These consist of Census Tract 79.01, Tract 74.01, and Tract 74.09, which show a substantial presence of low - income families. Furthermore, Tract 45.03 and Tract 45.04 exhibit compar able patterns, signifying areas of economic hardship that might need specific support measures. Additionally, Tract 27.06 and Tract 46.01 showcase significant concentrations of low -income families, highlighting the necessity for targeted assistance in these neighborhoods.

What are the characteristics of the market in these areas/neighborhoods? In Tract 57.01, there are two sites identified by the U.S. EPA as brownfields, which are properties where redevelopment or reuse might be hindered due to the presence or potential presence of hazardous substances, pollutants, or contaminants. Both tracts, like other parts of the City, have high area deprivation indexes, reflecting disadvantages compared to the rest of the State.

As of February 27, 2025 and based on the information on Zillow, there are approximately 155 houses in various states of foreclosure throughout the City. Housing units in foreclosure generally overlap with LMI neighborhoods.

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Are there any community assets in these areas/neighborhoods? The County runs an Employment Resource Center in central San Bernardino close to City Hall within a low-to-moderate income area. California State University, San Bernardino is situated in a low-income community as well.

Are there other strategic opportunities in any of these areas? The City possesses various economic benefits, such as contemporary industrial structures, easy freeway access, and typically reduced labor expenses. Moreover, the City persists in promoting economic growth and will keep supporting nonprofits that enhance residents' skills through job training and small business development.

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MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income Households - 91.210(a)(4), 91.310(a)(2)

Describe the need for broadband wiring and connections for households, including low- and moderate-income households and neighborhoods.

The City is currently mostly covered by existing fiberoptic infrastructure owned and serviced by Internet Service Providers (ISPs). The FCC broadband data from June 2023 shows the level of service available throughout the City, ranging from well served to unserved, including areas where there is no provider available. Gaps exist along the mountainous regions to the north, but the City itself is entirely covered. The areas with lines indicate where fiber internet is available.

Table 51 - Broadband
Describe the need for increased competition by having more than one broadband Internet service provider serve the jurisdiction.

Having several ISP options potentially results in improved prices and services for consumers. As the competition within the broadband industry intensifies, service providers are continuously seeking innovative strategies to retain their customer base and e xpand their market share.

Broadband bundling not only responds to this competitive demand but also addresses the diverse

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needs of the population and can help broadband access make financial sense for broader swaths of the population.

According to BroadbandNow, the following ISPs currently have plans available in the City: AT&T, Spectrum (Charter Communications, Inc.), EarthLink, Frontier, Hughesnet, One Ring Networks, Starlink, T-Mobile US, XNET WiFi, Verizon, and Viasat Inc. Plans sta rt at $29.99 per month with Frontier, followed by $30 with Spectrum.

The City held three Broadband Strategic Master Plan Public Meetings in September 2024. The City found that, although it is generally well served, hurdles to broadband adoption and reliability issues exist. Attendees spoke about connectivity challenges in different neighborhoods, affordability concerns, and the impacts of the lack of competition. It was also mentioned that costs keep going up, even with bundling and multiple ISPs serving the City.

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MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3)

Describe the jurisdiction’s increased natural hazard risks associated with climate change.

It is expected that increased weather variability will increase natural hazard risks and increase the City’s need for environmental resilience. The City published the 2024 local Hazard Mitigation Plan (HMP) for public review on April 17, 2024. The purpose is to reduce or eliminate long -term risk to people and property from natural or human -caused hazards and their effects. The City found the following links between extreme weather events and increased natural hazard risks:
• Liquefaction: Changes in precipitation and groundwater levels increase uncertainty regarding subsurface stability, making liquefaction risks unpredictable. • Earthquake-Induced Landslides : Increased intense rainfall and higher temperatures, leading to more frequent wildfires, destabilize soil, making landslides more likely. • Flooding: Projected doubling in intense rainy days by the end of the century suggests more frequent floods, requiring significant infrastructure upgrades and maintenance. • Dam Inundation : Aging dams are at increased risk due to projected higher intensity storms and altered precipitation patterns, posing heightened flooding risks. • Severe Wind: Stronger storms are likely to bring more intense winds to the region, while Santa Ana wind events' future frequency remains uncertain. • Extreme Heat: As temperatures rise, extreme heat events will become more common and severe, increasing demands for cooling solutions and placing additional strain on resources.
• Drought: Climate models forecast more frequent and prolonged droughts, adversely impacting water supply, increasing reliance on imported water, and elevating wildfire risks.
• Wildfires: Higher temperatures, more drought conditions, along with high winds, increase wildfire risks, particularly in areas already prone to fires. • Hazardous Materials Release: Intense weather events like floods and extreme heat can lead to increased releases and leaks of hazardous materials. For example, heavier rains could lead to more runoff from contaminated sites.

For more information on the LHMP, please visit sbcity.org/460/Local-Hazard-Mitigation-Plan.

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

Low- and moderate-income households in the City face compounded risks from natural hazards due to factors like limited financial resources and lack of mobility. Homes of lower -income residents may not be properly retrofitted to withstand seismic shaking du ring earthquakes, and

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the cost of repairs or relocation can be prohibitive. Similarly, those living close to hazardous sites or major transportation infrastructure have a higher risk of exposure to hazardous materials release, and financial constraints often prevent effective retrofitting or relocation.

Residents in low-income households, including seniors, persons with disabilities, and those who rely primarily on walking or biking, face significant challenges during flooding events, with many living in the higher -risk 500 -year flood zones. Additionally, the financial impact of water conservation during droughts can disproportionately affect lower -income households if higher water rates or additional fees are imposed during a severe drought event.

Overall, low-income households in San Bernardino are especially vulnerable to natural hazards due to economic limitations that hinder their ability to prepare for, respond to, and recover from such events.

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Strategic Plan
SP-05 Overview
Strategic Plan Overview
This Strategic Plan discusses the City’s priority needs, five-year goals, anticipated resources, and projected outcomes for the funding from HUD. The Strategic Plan also discusses the City’s current efforts and five-year strategy for increasing affordable housing production, reducing barriers to affordable housing, alleviating the condition of homelessness and poverty, as well as the strategy for improving the overall condition of existing housing stock across the City. The plan also describes how HUD federal funding will invest in public facilities and infrastructure improvements in the City.

Through data analysis and community engagement, it has been determined that the priority needs of the City are as follows:
• Preserve and rehabilitate housing
• Development and Preservation of Affordable Housing and Expanded Housing Types • Increase Affordable Housing Options
• Provide Homeless and Homeless Prevention Services
• Infrastructure Improvements
• Responsible Resource Management and Community Preparedness • Fair housing
• Administration and Planning
Over the next five years, the City anticipates funding projects related to all these needs, although available funding resources, community-based organization partnerships, and market conditions may ultimately limit the City’s ability to fund some project types.

Consolidated Plan SAN BERNARDINO 121

SP-10 Geographic Priorities – 91.215 (a)(1)
Geographic Area
- Geographic Priority Areas
1 Area Name: Citywide
Area Type: Local Target area
Other Target Area Description:

HUD Approval Date:
% of Low/ Mod: For LMA eligible areas, LMI/LMC/LMLC
Revital Type: Other
Other Revital Description: Housing, Public Services, Community development and Infrastructure
Identify the neighborhood boundaries
for this target area.

Citywide focused on LMA eligible CT/BG and LMI/LMC
persons depending on eligible activity type
Include specific housing and commercial
characteristics of this target area.

The City's commercial corridors are considered major
hub areas of activity (routes 10, 215 and 210 and W.
5th Street). Dense residential and nonresidential
development including multi-family and multi-story
commercial buildings, exists in the southern half of
the City in the downtown, while less dense residential
neighborhoods exist in the northern most areas of the
City. Around the periphery of the downtown there are
medium density neighborhoods containing
townhomes, apartments, doubles and dense single
family housing units.

How did your consultation and citizen
participation process help you to
identify this neighborhood as a target
area?
The consultation process did not pinpoint any specific
region. Stakeholders and service agencies noted they
assist homeless and or LMI residents located
throughout the City and provide LMA and LMLC
activities in eligible areas and for eligible projects.

Identify the needs in this target area. Citywide affordable housing is an issue, particularly for extremely low- and low-income families. Aging sewer
and water infrastructure, park equipment,
accessibility of public streets and sidewalks, and
community facilities are key identified needs as well.

Lack of affordable housing and housing rehabilitation
needs are also required in the city.

Consolidated Plan SAN BERNARDINO 122

What are the opportunities for
improvement in this target area?
The City's housing rehabilitation, housing access and
unit development, and infill development programs
are the right tools to create more available affordable permanent housing units. In addition, there is an
opportunity to improve aging facilities that could, if
left go, affect the health and safety of the community
residents. There are ADA needs in public
infrastructure, as well as needs for public facilities.

Are there barriers to improvement in
this target area?
Yes, there is an ongoing issue of funding, assistance,
both private and public, for these activities. The top
barrier remains having sufficient funding to fully-fund eligible activities.

Table 52 – Geographic Priority Areas
General Allocation Priorities
Describe the basis for allocating investments geographically within the jurisdiction (or within the EMSA for HOPWA)
The City will spend at a minimum, 70 percent of its federal funding to finance projects targeted to low- to moderate-income households throughout the City, including those in special needs categories. Based on 2017-2021 ACS 5-Year estimates and 2017-2021 CHAS data, 5 5 percent of households in the City are low - to moderate -income households. Because more than half of residents would qualify for CDBG assistance and there are no concentrated areas of poverty, the City is taking the approach of allocating CDBG funds across the whole City.

Consolidated Plan SAN BERNARDINO 123

SP-25 Priority Needs - 91.215(a)(2)
Priority Needs

1 Priority Need
Name
Preserve and Rehabilitate Housing
Priority Level High
Population Low
Moderate
Large Families
Families with Children
Elderly
Persons with Disabilities
Geographic Areas
Affected
Citywide
Associated Goals Increase Affordable Housing Options
Description The preservation and rehabilitation of single-family owner-occupied housing and multi-family rental units.

Basis for Relative
Priority
As discussed in MA-20, 65 percent of occupied housing units were built prior to 1980. In general, housing begins to require major repairs after 30 or 40 years of age. Those repairs could include important health and safety repairs such as for heating/air systems, roof, kitchen appliances, bathroom or kitchen plumbing, and insulation. Many low- to moderate-income households may be unable to afford these needed repairs.

Community engagement efforts also identified a need for housing rehabilitation.
2 Priority Need
Name
Preserving and rehabilitating housing, Expanding homeownership, Providing homeless services and prevention, Adding new affordable housing, Promoting economic development, Improving facilities and infrastructure and Fair Housing
Priority Level High
Population Low
Moderate
Large Families
Families with Children
Large Families
Seniors

Consolidated Plan SAN BERNARDINO 124

Persons with disabilities
Geographic Areas
Affected
Citywide
Associated Goals Increase Affordable Housing Options
Description New affordable rental housing (new construction, adaptive reuse, or rehabilitation) in a variety of types, and new affordable rental housing with supportive services for homeless individuals and veterans.

Basis for Relative
Priority
There is a significant mismatch between housing supply and affordability within the City. As discussed in MA-15, there is an affordable housing supply gap of 80 percent for renter households earning between 0 and 30 percent AMI and a 22 percent gap for households earning between 30 and 50 percent AMI.

Additionally, 16,875 low-income renter households are paying more than 30 percent of their income toward housing costs
3 Priority Need
Name
Provide Homeless and Homeless Prevention Services
Priority Level High
Population Extremely Low
Low
Moderate
Families with Children
Elderly
Public Housing Residents
Chronic Homelessness
Individuals
Chronic Substance Abuse
veterans
Victims of Domestic Violence
Unaccompanied Youth
Frail Elderly
Persons with Mental Disabilities
Persons with Physical Disabilities
Persons with Developmental Disabilities
Persons with Alcohol or Other Addictions
Persons with HIV/AIDS and their Families
Geographic Areas
Affected
Citywide
Associated Goals Provide Homeless and Homeless Prevention Services

Consolidated Plan SAN BERNARDINO 125

Description Provide targeted support aimed at preventing and reducing homelessness, such as emergency shelters, rapid rehousing, and homelessness prevention services to homeless individuals and persons at risk of homelessness.

Basis for Relative
Priority
As discussed in NA-40, the 2024 PIT Count identified 1,417 homeless individuals living in the City. Discussions with the San Bernardino County Homeless Partnership identified that homeless individuals are in need of services to alleviate or prevent homelessness.
4 Priority Need
Name
Community Development
Priority Level High
Population Extremely Low
Low
Moderate
Families with Children
Elderly and Frail Elderly
Persons with Disabilities
Geographic Areas
Affected
Citywide
Associated Goals Infrastructure Improvements
Description Investing in roads, sidewalks, parks, and public facilities in qualifying neighborhoods and providing ADA access for disabled residents of the City.

Basis for Relative
Priority
Community engagement efforts found that the top needs for Public Improvements are street/alley/sidewalk, street lighting and traffic calming for safety, tree planting and urban greenery, parks, safe routes to school, graffiti removal and water/sewage improvements.
5 Priority Need
Name
Responsible Resource Management and Community Preparedness Priority Level High
Population Extremely Low
Low
Moderate
Families with Children
Elderly and Frail Elderly
Persons with Disabilities

Consolidated Plan SAN BERNARDINO 126

Persons experiencing Homelessness
Geographic Area
Affected
Citywide
Associated Goals Resource Efficiency and Risk Mitigation Description Encouraging efficiencies in housing and community development project that also promote self-reliance and responsible planning and recovery Basis for Relative
Priority
Enhancing the ability to protect lives and property, reduce long term operating costs for low to moderate income persons, improve long term economic stability and community well-being
6 Priority Need
Name
Fair Housing
Priority Level High
Population Extremely Low
Low
Moderate
Large Families
Families with Children
Elderly
Persons with Mental Disabilities
Persons with Physical Disabilities
Persons with Developmental Disabilities
Housing Authority residents (voucher)
Other
Geographic Areas
Affected
Citywide
Associated Goals Fair Housing
Description Promote fair housing and support fair housing services.

Basis for Relative
Priority
Discrimination was mentioned repeatedly in the community needs survey as a barrier to equal access and fair housing.
7 Associated Goals Planning and Administration
Description Implement goals of ConPlan.

Basis for Relative
Priority
Compliance with all HUD ConPlan and CDBG, HOME, and ESG program regulations is a requirement for participation in this program.

Table 53 – Priority Needs Summary

Consolidated Plan SAN BERNARDINO 127

Narrative (Optional)
In establishing the above priorities, the City has considered input from community engagement efforts, including surveys, stakeholder interviews, engagement meetings, as well as demographic and data analysis. Activities that address high priority needs will be funded using CDBG, HOME, and ESG funds as eligible and appropriate during the ConPlan period and activities that address low priority needs may be funded by these funds, pending availability.

Consolidated Plan SAN BERNARDINO 128

SP-30 Influence of Market Conditions – 91.215 (b)
Influence of Market Conditions
Affordable
Housing Type
Market Characteristics that will influence
the use of funds available for housing type
Tenant Based
Rental Assistance
(TBRA)
Based on existing and anticipated market conditions, the City will be investigating the feasibility and types of TBRA it can offer under the HOME program as an element of expanding housing access and opportunity TBRA for Non-
Homeless Special
Needs
The City will determine, based on market need and opportunities, the ability of HOME TBRA to serve non-homeless special needs persons
New Unit
Production
As discussed in the 2021-2029 Housing Element – The City has received a final housing planning target of 8,123 housing units for the 6th cycle housing element, which spans from 2021 to 2029. The allocation comprises 708 units for extremely low income (0 –30% of AMI), 707 units for very low income (31 –50% of AMI), 1,097 units for low income (51 –80% of AMI), 1,448 units for moderate income (81–120% of AMI), and 4,163 units for above moderate income (over 120% of AMI), summing up to 8,123 units. As part of that, the City is focused on expanding housing types, development, and opportunity
Rehabilitation Approximately 61 percent of the occupied housing units in the city were constructed prior to 1980, with almost 16 percent built before 1950, emphasizing the necessity for renovation. Typically, homes start needing significant repairs after they are 30 or 40 years old. The Owner-Occupied Rehab program is proposed to be funded through the CDBG program.

Acquisition,
including
preservation
The City is working with partners and others on opportunities to preserve existing affordable housing and use other tools, such as acquisition, to affect its goal of expanding access to housing and to a wider variety of housing types.

Currently, while there are cost and clean up constraints within the City, there is sufficient land to accomplish this task.

Table 54 – Influence of Market Conditions

Consolidated Plan SAN BERNARDINO 129

SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2) Introduction
Over the five-year period covered by this ConPlan FY 2025–2029, the City anticipates receiving an estimated total of approximately $19,023760 million in federal entitlement grants from HUD, CDBG, HOME , and ESG funds. These funding sources provide essential support for a wide range of eligible housing, community development, and homelessness prevention activities.

Over a three-year period, the City will spend no less than 70 percent of CDBG funds on activities that benefit low-and-moderate income persons, in accordance with HUD statutory requirements.

The City will coordinate these investments with other local and regional funding sources —including state housing programs, Continuum of Care funding, and private sector investments —to ensure a comprehensive and sustainable approach to meeting the needs of low- and moderate -income residents. Resources will be aligned with the priority needs, goals, and outcomes identified through the planning process, including community engagement and market analysis.

Anticipated Resources
Program Source of
Funds Use of Funds
Expected Amount Available Year 1 Expected
Amount
Available
Remainder
of ConPlan
Narrative
Description Annual
Allocation
Program
Income
Prior Year
Resources Total
CDBG Public-
Federal
Acquisition Admin &
Planning
Economic
Development
Housing
Public
Improvements
$2,712,293 0 $0 $2,712,293 $10,059,530
The est.
amount of
CDBG funds
available is
based on
allocations

Consolidated Plan SAN BERNARDINO 130

Public Services for FY 2025-
2026
HOME Public-
Federal
Site Acquisition
Site Improvement
Rehabilitation
Homebuyer
Assistance
Rental Assistance
$1,149,833.55 $0 $0 $1,149,833.55 $4,264,578
The est.
amount of
HOME funds
available is
based on
allocations
for FY 2025-
2026
ESG Public-
Federal
Street Outreach
Emergency Shelter
Prevention Activities
Rapid Rehousing
Data Collection
(HMIS)
$241,347 $0 $0 $241,347 $895,123
The est.
amount of
ESG funds
available is
based on
allocations
for FY 2025-
2026
Table 55- Anticipated Resources

Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied
Leverage refers to the strategic combination of diverse funding sources, including local, state, or further federal financial support, with HUD funding to improve project efficiency and take advantage of economies of scale. The City seeks to utilize its fe deral resources alongside state, local, and private funding to create high -quality, affordable housing for its residents. Extra resources to meet the requirements of low- and moderate-income residents are obtained from several sources, including:

Consolidated Plan SAN BERNARDINO 131

Federal Resources
• Section 8 Housing Choice Voucher Program
• Federal Low-Income Housing Tax Credit Program
• Tax Exempt Bond Financing
• Community Investment Funds from Dignity Health

State Resources
• Tax Exempt bonds
• State Low-Income Housing Tax Credit Program
• No Place Like Home
• Community Reinvestments Funds
• Permanent Local Housing Allocation (PLHA) from California State Department of Housing • Veteran Housing and Homeless Prevention Program

Local Resources
• San Bernardino County Continuum of Care
• HACSB

Private Resources
• Dignity Health
• San Manuel Band of Mission Indians
• San Bernardino Unified School District
• City of San Bernardino Successor Housing Agency

Consolidated Plan SAN BERNARDINO 132

According to HUD regulations, ESG recipients are required to match their annual ESG allocation at a rate of 100 percent. Agen cies receiving ESG funds fulfill the match requirement by utilizing volunteer efforts, in-kind donations, and funding from various local, state, and federal initiatives.

The City will us e its HOME funds alongside additional housing resources as needed. HOME non-federal match funds will be tracked, including all additional funds spent in excess of necessary match will be recorded by the City and submitted to HUD as a component of the CAPER annually.

If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan
The City’s 2021-2029 Housing Element update revealed that many vacant residential sites downtown are surplus. The city plans to collaborate with nonprofits to sell these sites for deed-restricted affordable housing. Most of these vacant lands are zoned for multi- family use or can be upzoned for higher density. All moderate and lower-income sites are infilled, meaning they have access to water, sewer, and dry infrastructure, with priority given for affordable housing connections. Sites for above -moderate income are spread across the southern, central, and northern areas of the district.

The City will maintain funding for its Infill Housing Program and the Owner -Occupied Residential Rehabilitation Program (OORP). Via the City’s Infill Housing Program, the City intends to purchase, renovate vacant and/or underused land parcels and develop housing accessible to low- and moderate-income families. The Owner-Occupied Residential Rehabilitation Program will offer funding for the renovation of single-family homes owned by low- and moderate-income families.

Discussion
See discussion above.

Consolidated Plan SAN BERNARDINO 133

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

Responsible Entity Responsible Entity
Type
Role Geographic Area Served
San Bernardino City Government
Economic
Development
Homelessness
Non-Homeless
Special Needs
Planning
Neighborhood
Improvements
Public Facilities
Public Services
Jurisdiction
Housing Authority of the
County of San Bernardino
(HACSB)
PHA Public Housing
Rental Region
San Bernardino County
Homeless Partnership
(SBCHP)
CoC Homelessness Region

Assess of Strengths and Gaps in the Institutional Delivery System The City uses its CDBG, HOME, and ESG funding to make significant investments ; however, community needs far outpace available funding.

San Bernardino is a participant in the San Bernardino County Homeless Partnership (SBCHP) through the Central Valley Steering Committee of the Interagency Council on Homelessness.

SBCHP was instrumental in creating the county's Continuum of Care and a stra tegy to eliminate homelessness.

Consolidated Plan SAN BERNARDINO 134

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

HIV/AIDS X X
Life Skills X X
Mental Health Counseling X X
Transportation X X
Other

Consolidated Plan SAN BERNARDINO 135

Describe how the service delivery system including, but not limited to, the services listed above meet the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) In addition to CDBG funding, ESG funding is likewise utilized to address homelessness in the city.

This encompasses funding for outreach to individuals experiencing homelessness, enhancing, delivering, and managing shelters; offering crucial services to those in shelters; swiftly re-housing homeless individuals; and preventing homelessness.

The City offers various services to support unhoused individuals and families through several organizations:
• U.S. VETS Veteran Housing: Approved in March 2022, this facility provides 30 residential units for low -income veterans, including housing, case management, and supportive services. It's the first of two veteran housing projects in the city. • Operation Grace : Since 1993, this organization has provided emergency shelter for women and children, permanent supportive housing, and programs to prevent homelessness. They partner with local organizations to offer a range of community services.
• Central City Lutheran Mission (CCLM) : Established in 1994, CCLM offers emergency services, case management, life -skills training, employment and education referrals, health and wellness services, housing counseling, and rapid rehousing. They are developing a wellness campus in San Bernardino.
• Step Up: Since 2016, Step Up's Inland Empire Housing First Programs have worked with property managers and landlords to provide housing for the homeless. They recently converted the Allstar Motel into 75 units of permanent supportive housing for formerly homeless seniors.

These organizations play a crucial role in addressing homelessness and providing essential services in San Bernardino.

Moreover, the San Bernardino County Homeless Partnership ( SBCHP) organizes services for the homeless and housing across the County, including in the City . The SBCHP also launched initiatives aimed at providing housing for the elderly and those who are chronically homeless.

Consolidated Plan SAN BERNARDINO 136

Describe the strengths and gaps of the service delivery system for special needs population and persons experiencing homelessness, including, but not limited to, the services listed above
Tackling the lack of emergency shelter, transitional housing, permanent supportive housing, and various housing options presents a notable challenge in San Bernardino. As stated in the 2021- 2029 Housing Element, the City endorsed a Homelessness Solutions Action Plan and designated $24.5 million in American Rescue Plan Act (ARPA) funds to address this matter.

In February 2023, the City Council announced a local Homelessness State of Emergency and shelter crisis in accordance with GC § 8698. Subsequently, in May 2023, the City Council enacted a homeless emergency action plan to offer more housing alternatives and support services. These efforts seek to create 535 additional beds, fulfilling 65 percent of the overall demand for homeless individuals.

Individuals experiencing homelessness frequently encounter increased rates of medical, disability, and substance use issues, affecting their capacity to secure employment and access housing and healthcare. The County provides various resources for homeless people with HIV/AIDS, such as permanent supportive housing.

Numerous unhoused individuals have gone through considerable trauma, including escaping unsafe living situations, domestic abuse, substance abuse problems, long -term homelessness, and military service. The Inland Empire Health Plan supports chronically hom eless people, identified as those who have been homeless for more than one year or four or more times within three years, and have a disabling health condition.

Provide a summary of the strategy for overcoming gaps in the institutional structure and service delivery system for carrying out a strategy to address priority needs To address the gaps in the service delivery system, the City plans to allocate resources to develop more affordable housing units, particularly for extremely low -income and very low -income households. Improving transportation options is also a priority to ensure homeless individuals can access essential services. Expanding mental health and substance abuse services by providing integrated treatment and support for co-occurring disorders is another key focus.

Additionally, the City aims to boost employment and education services by offering more job training, employment opportunities, and educational support to help individuals achieve stability. Finally, increasing the supply of permanent supportive housing is crucial to provide long- term stability for chronically homeless individuals. By addressing these gaps and leveraging existing strengths, the city can more effectively meet the needs of homeless individuals and special needs populations.

Consolidated Plan SAN BERNARDINO 137

SP-45 Goals Summary – 91.215(a)(4)
Goals Summary Information
# Goal Name Start
Year
End
Year Category Geograp
hic Area
Needs
Addressed Funding Goal Outcome
Indicator
1 Preserve and
Rehabilitate
Housing
2025 2029 Affordable
Housing Citywide
Low- to
moderate-
income
homeowne
rs
HOME:
$2,500,000
Homeowner
housing units
rehabilitated:50

Multi-family
housing units
rehabilitated:10
0-150
2 Development
and
Preservation
of Affordable
Housing
2025 2029 Affordable
Housing Citywide
Low- to
moderate
income
families
needing
affordable
housing
rental
options
HOME:
$4,338,664
Renter
households
assisted: 50-100
3 Provide
Homeless and
Homeless
Prevention
Services
2025 2029 Homeless Citywide
Those
persons
experienci
ng
homelessn
ess or who
are at risk
of being
unhoused
ESG:
$1,051,235

750 shelter-
persons assisted
750 shelter/
transitional
housing
4 Community
Development 2025 2029
Non-
Housing
Communit
y
Developm
ent
Citywide
Improvem
ents to
streets,
sidewalks,
ADA
improveme
nts, parks,
and
community
spaces for
CDBG:
$9,119,053
160,000
persons
assisted
through
community
facilities
projects

Consolidated Plan SAN BERNARDINO 138

low- to
moderate-
income
persons
5 Responsible
Resource
Management
and
Community
Preparedness
2025 2029
Non-
Housing
Communit
y
Developm
ent
Citywide
Support for
efficiency
in housing
and
community
developme
nt to
promote
self-
reliance,
responsible
planning,
and
responsible
recovery
CDBG:
$1,515,77
Persons
Assisted:
2,500
6 Support Fair
Housing 2025 2029
Fair
Housing Citywide
San
Bernardino
City
residents
who need
access to
fair
housing
informatio
n and
advocacy
CDBG:
$400,000
Persons
Assisted: 5,000
7 Planning &
Administratio
n
2025 2029 Administr
ation Citywide
Planning &
Administra
tion
CDBG:
$2,554,364
HOME:
$541,441
ESG: $85,235
Other
(planning
and
administrati
on)

Consolidated Plan SAN BERNARDINO 139

Goal Descriptions
1 Goal Name Preserve and Rehabilitate Housing
Goal
Description
To provide funding for the preservation and rehabilitation of single-family owner- occupied housing units and multi-family rental units.
2 Goal Name Development and Preservation of Affordable Housing Goal
Description
To provide funding for the development of new affordable rental housing (new construction, adaptive reuse, or rehabilitation) in a variety of types, and new affordable rental housing with supportive services for homeless individuals and veterans.
3 Goal Name Provide Homeless and Homeless Prevention Services Goal
Description
To provide targeted support aimed at preventing and reducing homelessness, such as emergency shelters, rapid rehousing, and homelessness prevention services to homeless individuals and persons at risk of homelessness. 4 Goal Name Community Development
Goal
Description
To invest in roads, sidewalks, parks, and public facilities in qualifying neighborhoods and to provide ADA access to disabled residents of the City. 5 Goal Name Responsible Resource Management and Community Preparedness Goal
Description
To provide funding that encourages efficiency in housing and community development projects and to promote self-reliance and responsible planning and recovery.
6 Goal Name Support Fair Housing
Goal
Description
To provide funding for fair housing support services.
7 Goal Name Planning and Administration
Goal
Description
To provide funding to implement the goals and objectives of the ConPlan, comply with planning and reporting requirements, and monitor the use of funds.

Table 58 – Goals Summary

Estimate the number of extremely low-income, low-income, and moderate-income families to whom the jurisdiction will provide affordable housing as defined by HOME 91.315(b)(2)

The City estimates that HOME funds will provide affordable housing to approximately 100 households over the ConPlan timeframe.

Consolidated Plan SAN BERNARDINO 140

SP-50 Public Housing Accessibility and Involvement – 91.215(c) Need to Increase the Number of Accessible Units (if Required by a Section 504 Voluntary Compliance Agreement)
Not required as there is no Voluntary Compliance Agreement (VCA) in San Bernardino City.

Activities to Increase Resident Involvements
The HACSB Board of Commissioners conducts regular meetings two times a month, welcoming public remarks on agenda topics. Moreover, HACSB operates a Family Self Sufficiency Program that enables residents to engage in establishing self -sufficiency objectives , job training, and utilizing various supportive services.

Is the public housing agency designated as troubled under 24 CFR part 902? No.

Plan to remove the ‘troubled’ designation
Not applicable.

Consolidated Plan SAN BERNARDINO 141

SP-55 Barriers to Affordable Housing – 91.215(h)
Barriers to Affordable Housing
Several factors act as barriers to acquiring and constructing affordable housing. The primary obstacle is the shortage of funding, with local, state, and federal financial support declining over the past 10 years. Based on the 2021-2029 Housing Element and FY2024-2029 Analysis of Impediments to Fair Housing Choice, the barriers and impediments to affordable housing are as follows:

1. Environmental Reviews & Land Use Regulations:

2. Community Opposition & Density Restrictions

3. Zoning Limitations on Emergency Shelters & Transitional Housing

4. Constraints on Multi-Family & Supportive Housing

5. Regional Housing Needs Allocation (RHNA) Challenges

6. Accessibility Barriers for Individuals with Disabilities

7. Financial Constraints & Development Costs
Strategy to Remove or Ameliorate the Barriers to Affordable Housing The City has undertaken notable initiatives to remove restrictions linked to land use regulations by creating and implementing a new Development Code that consolidates and streamlines the City's development rules and procedures. This initiative was succeeded by restructuring the City to consolidate multiple development -oriented departments into a unified Community Development Department and creating a centralized permit counter.

Furthermore, the City has implemented the following changes to the Municipal Code to further decrease obstacles to affordable housing:

1. General Lot Consolidation Incentive : Small, separate lots offer limited development opportunities and typically cannot support onsite property management. Development potential can be enhanced through a small -lot consolidation initiative that provides a 15 percent density bonus for projects with a residential component that commits to a maintenance plan and onsite management. The city plans to amend the Development Code to encourage lot consolidation.

2. Density Bonus Provisions : Projects that utilize density bonuses can be a vital source of housing for low - to moderate -income households. The city intends to update the Development Code to reflect the latest amendments to State density bonus laws.

3. Transitional and Supportive Housing: The City plans to amend the Development Code to adequately define transitional and permanent supportive housing and permit these uses based on unit type, in accordance with Senate Bill 2.

Consolidated Plan SAN BERNARDINO 142

4. Streamlined Processing: The City remains committed to further simplifying development activities and regulations and will continue to evaluate potential initiatives aimed at removing land use limitations, particularly concerning the construction of new housing and the renovation of existing housing. In 2012, the City revised its Development Code to enhance usability and reduce confusion among staff and the development community.

As part of this update, the City introduced a new simplified form of Conditional Use Permit known as the Minor Use Permit (MUP). The Development/Environmental Review Committee assesses the MUP instead of the Planning Commission, requiring less staff involvement (resulting in a comparatively quicker process for developers), reduced fees, and serving as a substitute for a CUP for specific qualified projects.

To tackle housing affordability and the scarcity of financial resources for affordable living, the ConPlan advocates for the allocation of CDBG and/or HOME funds to maintain and improve housing units and offer homeownership prospects to low - and moderate-income families. Even though the City has lost access to redevelopment funds, it will still utilize its CDBG and HOME funds to draw in private and other public resources, including land transferred to the City, to develop affordable housing for low- and moderate-income families.

Consolidated Plan SAN BERNARDINO 143

SP-60 Homelessness Strategy – 91.215(d)
Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
While efforts to shelter as many people as possible and house them quickly are being expanded, efforts to improve the quality of life for people living on the streets, particularly in those areas most impacted by unsheltered homelessness, are also needed. These strategies strengthen outreach and engagement efforts that connect unsheltered people to services and housing and address individual and public health issues that arise. They also emphasize the importance of meeting basic needs for people experiencin g homelessness and making people experiencing homelessness feel comfortable and welcome.

The City provides Emergency Solutions Grant (ESG) funding for FY 2025–26 to the Family Service Association of Redlands and The Salvation Army to deliver critical homelessness and homelessness prevention services. The Family Service Association of Redlands offers Rapid Rehousing assistance, including housing placement, short- to medium-term rental subsidies, and case management for individuals and families experiencing homelessness. The Salvation Army provides emergency shelter services, homelessness prevent ion through rental assistance, and supportive services to help stabilize at -risk households and connect them to long -term housing solutions.

Addressing the emergency and transitional housing needs of homeless persons The City operates a Motel Voucher Program as part of its broader strategy to address emergency and transitional housing needs for individuals and families experiencing homelessness. For FY 20244–25, the program is supported by a combined total of $2.75 million in federal and state funding from the American Rescue Plan Act (ARPA), Community Development Block Grant – CARES Act (CDBG -CV), and Permanent Local Housing Allocation (PLHA). This funding supp orts temporary shelter placements across multiple motel sites, offering a total of 130 rooms and 200 beds. The program is designed with low -barrier access and provides immediate stabilization services, including case management, transportation assistance, and housing navigation to connect participants to long-term housing solutions.

In addition to the motel voucher initiative, the City allocates Emergency Solutions Grant (ESG) funding to nonprofit organizations that operate emergency shelters and transitional housing programs. These programs provide critical services such as meals, shelter, supportive counseling, medical referrals, job training, and recovery support. Together, these coordinated efforts reflect the City’s commitment to expanding shelter capacity, reducing barriers to access, and supporting vulnerable populations on the path to permanent housing and long-term stability.

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

The City will provide ESG funding for supportive services to assist homeless individuals, including funding for emergency shelters, rapid rehousing, homelessness prevention, and street outreach.

The City will also fund nonprofit agencies that operate emergency she lters and provide services to help homeless individuals stabilize and live independently. The City will continue to fund nonprofits that help homeless individuals transition to permanent housing. In addition, the City has expanded outreach and services for those unhoused individuals encountered by City staff, including special outreach and social services provided by the City’s Public Safety Outreach team.

Help low-income individuals and families avoid becoming homeless, especially extremely low- income individuals and families who are likely to become homeless after being discharged from a publicly funded institution or system of care, or who are receiving assistance from public and private agencies that address housing, health, social services, employment, education or youth needs
As discussed above, the City funds a number of nonprofits that provide homeless prevention services to those at risk of homelessness. Additionally, the Coordinated Entry System (CES) is used to quickly identify, assess, refer, and connect clients to housin g assistance and services in the event they are hospitalized. The City also collaborates with St. Bernardine’s Hospital and Community Hospital in the City to connect homeless patients with bridge housing.

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SP-65 Lead based paint Hazards – 91.215(i)
Actions to address LBP hazards and increase access to housing without LBP hazards The City follows all applicable lead -based paint hazard (LBP) regulations, which primarily affect projects funded by the City’s Housing Rehabilitation Program. All applicants are notified about LBP risk and, if they are low-income and have a child under six at home, are then referred to the County’s LBP Abatement Program for free paint inspections, lead testing for children, information about LBP, and abatement. In general, housing built after 1977, zero-bedroom units, and housing for the elderly or disabled persons (unless children are present) are exempt from this rule.

HCD also addresses lead-based paint hazards by mandating compliance with federal regulations.

HCD mandates that all subrecipients of federal funding for housing purposes (rehab, new construction, shelter, etc.) must comply with federal Lead-Based Paint Poisoning Prevention Act (42 U.S.C. 48214846) regulations. All subrecipients sign a Statement of Assurances with the submission of their application that states they will adhere to the Act’s requirements when applicable. Subrecipients are also required to com ply with the EPA’s Renovation, Repair and Painting Rule as enacted in 2008. Adherence to this requirement is monitored for the CDBG and HOME programs, as well as with ESG when funding is being used for shelter renovations or conversions.

The City will also address childhood lead poisoning by following the recent guidance from Childhood Lead Poisoning Prevention Branch (CLPPB). This guidance helps local health jurisdictions on how to assist California property owners to lower lead abatement costs. It includes strategies for creating lead hazard control plans, options in program development, a comprehensive list of statewide residential lead abatement funding sources from both public and non-profit groups, and allocation amounts for each enti tlement in the State of California, including San Bernardino. This guide is sent to local representatives for technical assistance.

How are the actions listed above related to the extent of lead poisoning and hazards? Housing built before 1980 is one of the main sources of lead hazards and lead poisoning. Units built prior to 1980 may contain LBP, to which children under the age of six years are especially vulnerable. As discussed in MA-20, approximately 38,000 housing units were built prior to 1980, of which approximately 7,000 are occupied by children under six years of age. California contains more housing units built before 1978 than any other state in the country.

San Bernardino’s strategy focuses on housing, which directly relates to the on-the-ground hazard points for lead poisoning.

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How are the actions listed above integrated into housing policies and procedures? The City, as part of its Owner-Occupied Housing Rehabilitation Program, requires that all LBP be controlled or abated and disposed of properly to eliminate or reduce the hazard of environmental or human contamination.

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SP-70 Anti-Poverty Strategy – 91.215(j)
Jurisdiction Goals, Programs and Policies for reducing the number of Poverty-Level Families The City allocates federal funds for economic development programs and activities. Through HUD’s Section 108 Loan Guarantee Program , CDBG recipients receive financing for these activities. The City uses these funds to acquire properties for commercial centers, creating jobs for local residents. The City anticipates their Section 108 Loan will be paid fully repaid in FY2026.

Additionally, the City assigns CDBG, HOME, and ESG funds to support poverty-level families with services and housing assistance. ESG funds are used for homelessness prevention, rapid re - housing, and emergency shelters. CDBG funds go towards public services, infrastructure improvements, and community facilities in low-income neighborhoods. At least 70 percent of CDBG funds must benefit low- to moderate-income families.

How are the Jurisdiction poverty reducing goals, programs, and policies coordinated with this affordable housing plan
The City assigns CDBG and ESG funds to support poverty-level families with services and housing assistance. ESG funds are used for homelessness prevention, rapid re -housing, and emergency shelters. CDBG funds go towards public services, infrastructure impr ovements, and community facilities in low-income neighborhoods. At least 70 percent of CDBG funds must benefit low - to moderate-income families.

Additionally, the City implements economic development initiatives that focus on job creation and workforce development, which are essential components of its anti -poverty strategy.

Programs aimed at improving economic opportunities for residents include job training, small business support, and partnerships with local employers.

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SP-80 Monitoring – 91.230
Describe the standards and procedures that the jurisdiction will use to monitor activities carried out in furtherance of the plan and will use to ensure long -term compliance with requirements of the programs involved, including minority business outreach a nd the comprehensive planning requirements
The City regularly monitors and audits subrecipient records and facilities. This involves reviewing quarterly compliance reports and annual single audits as required by 24 CFR Part 44.6. Risk assessments are based on financial data from subrecipients, and monitori ng is done either by phone or on-site.

Detailed records are kept, including project location, service area boundaries, scope of work, construction schedule, budget, timeline, environmental review, and compliance. Quarterly Performance Reports (QPRs) are submitted to the Housing Division within 10 days after each quarter ends.

The City’s CDBG and ESG monitoring reports include:

1. Background of the agency, program, or project.

2. Review of current findings.

3. Necessary corrective actions (if any).

4. Observations on program operations.

5. Advice and communication to the agency.

By adhering to these standards and procedures, the City ensures effective monitoring and long - term compliance with program requirements, fostering transparency and accountability in grant management.

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Expected Resources
AP-15 Expected Resources – 91.220(c)(1,2)
Introduction
Anticipated Resources
Program Source
of
Funds
Uses of Funds Expected Amount Available Year 1 Expected Amount
Available
Remainder
of
Consolidated
Plan
$
Narrative Description
Annual
Allocation:
$
Program
Income: $
Prior Year
Resources:
$
Total:
$

Table 59 - Expected Resources – Priority Table

Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied

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If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan Discussion

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Annual Goals and Objectives

AP-20 Annual Goals and Objectives
Goals Summary Information
Sort Order Goal Name Start
Year
End
Year
Category Geographic
Area
Needs
Addressed
Funding Goal Outcome Indicator

Table 60 – Goals Summary

Goal Descriptions
Goal Name Goal Description
<TYPE=[pivot_table] REPORT_GUID=[8259A9F3469186F518038A8E2F9CBDBA]>

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Projects
AP-35 Projects – 91.220(d)
Introduction

Projects
# Project Name

Table 61 – Project Information

Describe the reasons for allocation priorities and any obstacles to addressing underserved needs

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AP-38 Project Summary
Project Summary Information
Project Name Target Area Goals Supported Needs Addressed Funding Description Target Date Estimate the number and type
of families that
will benefit from
the proposed
activities
<TYPE=[pivot_table] REPORT_GUID=[54A4ED67473EDAEE248792836A1D83B0]>

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AP-50 Geographic Distribution – 91.220(f)
Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed Geographic Distribution
Target Area Percentage of Funds

Table 26 - Geographic Distribution

Rationale for the priorities for allocating investments geographically Discussion

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Affordable Housing
AP-55 Affordable Housing – 91.220(g)
Introduction
One Year Goals for the Number of Households to be Supported Homeless
Non-Homeless
Special-Needs
Total
Table 27 - One Year Goals for Affordable Housing by Support Requirement

One Year Goals for the Number of Households Supported Through Rental Assistance
The Production of New Units
Rehab of Existing Units
Acquisition of Existing Units
Total
Table 28 - One Year Goals for Affordable Housing by Support Type Discussion

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AP-60 Public Housing – 91.220(h)
Introduction
Actions planned during the next year to address the needs to public housing Actions to encourage public housing residents to become more involved in management and participate in homeownership
If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance
Discussion

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AP-65 Homeless and Other Special Needs Activities – 91.220(i) Introduction
Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including
Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
Addressing the emergency shelter and transitional housing needs of homeless persons Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again
Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs
Discussion

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AP-75 Barriers to affordable housing – 91.220(j)
Introduction:

Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing , such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment
Discussion:

Outdated Zoning and Land Use Policies
Many areas of the city are still governed by zoning codes that limit higher -density housing, accessory dwelling units (ADUs), and mixed -use developments. These limitations restrict the ability to create a diverse housing stock that includes affordable unit s near transit and employment hubs. While the City is currently modernizing its zoning code in response to state housing laws and a recent settlement with the California Department of Housing and Community Development (HCD), these updates are still underwa y and require sustained implementation efforts.

High Development Costs and Construction Constraints
Rising land and construction costs in Southern California, combined with limited available land and aging infrastructure in some neighborhoods, make affordable housing projects financially challenging. These costs are further compounded by requirements for environmental remediation in some redevelopment areas.

Limited Local Subsidy Funding
Despite the availability of federal CDBG, HOME, and ESG funds, the City lacks substantial local revenue streams (e.g., housing trust funds, local bonds) to provide deeper subsidies for affordable housing development. This limits the City's ability to match state or private investment in large-scale housing production.

Aging Housing Stock in Need of Rehabilitation
Much of the city’s existing affordable housing is older and requires reinvestment to meet safety, health, and energy standards. Without targeted rehabilitation assistance, many low -income homeowners are at risk of housing instability or displacement due to substandard conditions.

Credit and Financial Barriers to Homeownership
Many San Bernardino residents face challenges qualifying for mortgages due to poor credit histories, lack of savings, or insufficient access to financial education. These barriers disproportionately affect low -income and minority households, reducing their ability to transition from renting to ownership and build generational wealth.

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AP-85 Other Actions – 91.220(k)
Introduction:

The City of San Bernardino recognizes that achieving the goals outlined in this Consolidated Plan requires not only targeted investments in housing and community development but also sustained efforts to strengthen institutional capacity, foster coordinati on, reduce poverty, and address systemic barriers. This section outlines the additional actions the City will take during the 2025–2029 Consolidated Plan period.

Discussion:

Actions planned to address obstacles to meeting underserved needs The City will take the following steps to address persistent obstacles, particularly among underserved populations such as extremely low -income households, persons experiencing homelessness, seniors, and individuals with disabilities:
• Invest in Homeless Navigation and Support Services: Expand the HOPE Navigation Center and fund subrecipients like Family Service Association and The Salvation Army to provide rapid rehousing and homelessness prevention.
• Enhance Language Access and ADA Compliance: Ensure materials, meetings, and surveys are accessible to non-English speakers and people with disabilities.

Use Data to Drive Equity: Incorporate disaggregated CHAS and PIT Count data to better identify needs by race/ethnicity, income, and geography.

Actions planned to foster and maintain affordable housing • Infill Development: Continue partnering with CHDOs to build affordable owner-occupied housing on vacant lots.
• Housing Rehabilitation: Fund the Owner -Occupied Housing Rehabilitation Program to preserve affordable housing and prevent displacement.
• Preserve Public/Assisted Housing: Support Housing Authority of the County of San Bernardino (HACSB) efforts, including the next phases of Arrowhead Grove.

Actions planned to reduce lead-based paint hazards
• Lead-Safe Rehabilitation: Ensure all HOME and CDBG-funded rehab projects comply with HUD Lead-Safe Housing Rule requirements.
• Training & Monitoring: Continue training City staff and contractors and monitor subrecipients for compliance with lead-based paint hazard regulations. • Public Education: Disseminate materials to residents regarding lead-safe practices during

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rehabilitation and home maintenance.

Actions planned to reduce the number of poverty-level families • Workforce Development: Collaborate with San Bernardino County Workforce Development Board and organizations like Center for Employment Opportunities to connect residents to jobs and training.
• Small Business Support: Use CDBG to support microenterprise development and entrepreneurship, particularly among women- and minority-owned businesses. • Financial Empowerment: Continue partnerships with NHSIE and other nonprofits to deliver financial literacy, homebuyer education, and credit repair services.

Actions planned to develop institutional structure
• Capacity Building: Provide technical assistance to local nonprofits, CHDOs, and ESG subrecipients to strengthen compliance and outcomes.
• Cross-Department Collaboration: Improve coordination between housing, public works, economic development, and public safety to align investment strategies. • Data Sharing: Strengthen data systems and interagency coordination, especially with the Continuum of Care and HMIS providers, to track program impact.

Actions planned to enhance coordination between public and private housing and social service agencies
• Continuum of Care Engagement: Maintain active participation in the Interagency Council on Homelessness and Homeless Provider Network.
• Health and Housing Integration: Coordinate with Dignity Health and San Bernardino County Department of Behavioral Health to link housing investments with mental health and healthcare services.
• Education & Youth Support: Continue work with Uplift San Bernardino to support youth housing stability, education, and future economic mobility.

The City is committed to overcoming institutional and structural barriers to equitable housing and community development. By deepening partnerships, aligning investments, and maintaining compliance with HUD standards, San Bernardino will continue to suppor t the most vulnerable residents while promoting inclusive growth citywide.

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Program Specific Requirements
AP-90 Program Specific Requirements – 91.220(l)(1,2,4)
Introduction:

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

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 817,368.

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

4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan. 0 5. The amount of income from float-funded activities 817,368 Total Program Income

Other CDBG Requirements

1. The amount of urgent need activities 0

HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)

1. A description of other forms of investment being used beyond those identified in Section 92.205 is as follows:

The City of San Bernardino does not intend to use forms of investment other than those described in 24 CFR §92.205(b). All HOME Investment Partnerships Program (HOME) funds will be used in eligible forms including grants, deferred payment loans, interest -bearing loans, and other HUD -approved forms of assistance that comply with HOME regulations.

In addition to HOME -specific investments, the City leverages other resources —such as CDBG, ESG, ARPA, an d State funds—to complement federal housing and community development activities.

These additional investments may be used for site acquisition, infrastructure improvements, or supportive services that enhance housing affordability and sustainability but do not deviate from HUD's defined eligible investment types under §92.205.

If new or alternative investment mechanisms are considered during the Plan period, the City will ensure full compliance with HUD regulations and will submit the necessary amendments and approvals.

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2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows:

HOME Recapture Provision If Buyer at any time during the Period of Affordability sells or transfers the Eligible Property, whether voluntarily or involuntarily due to foreclosure or other circumstances, the following provisions shall apply, pursuant to 24 C.F.R. Part 92.254:

1. If Buyer sells or transfers the Eligible Property within the first two years of the Period of Affordability, City shall recover from the Net Proceeds, if any, the entire amount of the HOME Subsidy, or such lesser amount as the Net Proceeds may permit to be recovered. The Net Proceeds are the sales price paid to the Buyer minus repayment of loans that are superior in priority to this Affordable Housing Covenant and the Deed of Trust securing it, and any closing costs.

2. If Buyer sells or transfers the Eligible Property after occupying the Eligible Property for at least two years (24 months from the Delivery Date), City’s recovery from the Net Proceeds shall equal the amount of the HOME Subsidy, reduced by a percentage determined by dividing the number of Buyer’s full years of occupation of the Eligible Property by the number of years of the Period of Affordability and multiplying the result by 100. In calculating recapture of the HOME subsidy only full 12 -month periods of occupancy will be utilized. For example, if the Buyer sells or transfers the Eligible Property during the third year, before the completion of the full third year of ten years of Affordability, the percentage reduction of the amount of the HOME Subsidy to be recovered by City shall equal 20 percent: (2 years ÷ 10 years) × 100 = 20. Assuming sufficient Net Proceeds, City would recover 80 percent of the HOME Subsidy. If there were not sufficient Net Proceeds, City would recover 80 percent of Net Proceeds, whatever the amount.

3. In no event shall City’s recovery exceed the amount of the Net Proceeds.

The City requires that its CHDO/subrecipients, who carry out HOME funded ownership programs, utilize the noted recapture provisions, which are part of the affordability covenant executed by the homeowner and recorded against the property.

In its homeownership and single family rehabilitation programs the City utilizes the homeownership limits for the San Bernardino Metropolitan/FMR Area provided by HUD.

3. A description of the resale or recapture guidelines that ensure the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows:

Measured from the Delivery Date and determined based on the amount of the HOME Subsidy, as follows: Amount of HOME Subsidy Period of Affordability • Amount of HOME Subsidy: Less than $15,000 Period of Affordability: 5 years • Amount of HOME Subsidy: $15,000 to $40,000 Period of Affordability: 10 years • Amount of HOME Subsidy: More than $40,000 Period of Affordability:15 years

The City's affordability covenant requires that HOME units acquired with HOME funds remain affordable for the period noted based on the amount of HOME subsidy. The City also requires that its CHDO/sub - recipients who carry out HOME-funded ownership programs utilize the recapture provisions noted, which are part of the affordability covenant executed by the homeowner and recorded against the property.

In its homeownership and single-family rehabilitation programs, the City utilizes the homeownership limits for the San Bernardino Metropolitan/FMR Area provided by HUD.

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4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows:

The City will not be refinancing existing debt secured by multifamily housing rehabilitated with HOME funds. The City will not refinish single-family units rehabilitated with HOME funds. With regard to eligible beneficiaries, the City will adhere to the requirements under 24 CFR 2.203 in relation to income determinations; 92.216 with respect to incomes of applicants; 92.253 with regard to tenant protections and selection and other HOME regulatory requirements that ensure beneficiaries are not precluded from participating in HOME funded programs.

The City utilizes Notice of Funding Availability and Requests for Proposals to solicit applications for funding under the HOME program. Applications are solicited as funds are available for various programs and/or when contracts and renewal periods with applicants expire and new NOFAs and RPS are released.

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

If implemented, the City intends to establish a preference for persons with special needs and disabilities, in alignment with 24 CFR §92.209(c)(2)(i). This may include individuals with physical, mental, or developmental disabilities, those at risk of institutionalization, and persons with substance use or behavioral health needs.

The City will consult with local partners, such as the San Bernardino County Department of Behavioral Health, the Office of Homeless Services, and disability advocacy organizations, to structure the program to ensure equity, legal compliance, and service integration.

All preferences will be clearly defined and documented in written TBRA policies and procedures, and will be implemented in a non-discriminatory manner consistent with federal fair housing laws.

6. If applicable to a planned HOME TBRA activity, a description of how the preference for a specific category of individuals with disabilities (e.g. persons with HIV/AIDS or chronic mental illness) will narrow the gap in benefits and the preference is needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2)(ii) and 91.220(l)(2)(vii)).

If such a program is established, the City may adopt a targeted preference for specific categories of individuals with disabilities, particularly those who experience significant service gaps —such as persons with chronic mental illness, HIV/AIDS, or co-occurring disorders.

These populations are often overrepresented in the homeless system and underrepresented in stable housing placements, despite frequent engagement with public systems of care. For example, individuals with chronic mental illness may cycle through shelters, hospitals, and correctional institutions due to a lack of supportive housing options. Similarly, people living with HIV/AIDS may face both housing discrimination and limited access to long-term rental assistance.

A targeted TBRA preference would narrow the gap in housing benefits by:

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• Providing stable rental assistance to individuals who are often ineligible for other long -term subsidies.
• Coordinating with service providers (e.g., Department of Behavioral Health, local HIV/AIDS networks) to ensure access to wraparound supports.
• Preventing institutionalization and promoting independent living in community -based settings.

Any such preference will be carefully structured, with data and stakeholder input used to demonstrate both the need and legal defensibility. The City will ensure all preferences are administered in compliance with fair housing requirements, including a clear showing that the preference is necessary to address a documented disparity in housing access or services.

7. If applicable, a description of any preference or limitation for rental housing projects. (See 24 CFR

92.253(d)(3) and CFR 91.220(l)(2)(vii)). Note: Preferences cannot be administered in a manner that limits the opportunities of persons on any basis prohibited by the laws listed under 24 CFR 5.105(a).

At this time, the City of San Bernardino does not impose any limitations or preferences in its HOME - assisted rental housing projects that would restrict participation based on characteristics prohibited under 24 CFR 5.105(a), including race, color, religion, sex, national origin, disability, or familial status.

However, if preferences are considered during the 2025–2029 Consolidated Plan period, they will be implemented only where supported by local data, consistent with fair housing and civil rights laws, and designed to address a demonstrated housing or service gap. Potential preferences may include:
• Individuals experiencing or at risk of homelessness,
• Veterans,
• Persons with disabilities (in coordination with supportive services), or • Large families needing multi-bedroom units.

Any preference will be applied transparently and uniformly, without violating nondiscrimination requirements, and will be outlined in project -specific agreements and approved underwriting documentation. The City will also ensure that all applicants have eq ual access and meaningful opportunity to apply for all rental units, regardless of their status in relation to any stated preference.

The City will continue to monitor projects for compliance with applicable fair housing laws and HUD’s HOME regulations.

Emergency Solutions Grant (ESG)
Reference 91.220(l)(4)

1. Include written standards for providing ESG assistance (may include as attachment)

Please refer to the attachment included.

2. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system.

The City of San Bernardino is an active participant in the San Bernardino County Continuum

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of Care (CoC), which has established a centralized Coordinated Entry System (CES) in accordance with HUD requirements. The CES is managed by the San Bernardino County Office of Homeless Services (OHS) and serves as the primary tool for connecting individua ls and families experiencing or at risk of homelessness to appropriate housing and supportive services.

The CES is designed to:
• Provide standardized assessment tools and procedures (e.g., VI -SPDAT) to evaluate the needs and vulnerabilities of people experiencing homelessness; • Prioritize clients for housing and services based on vulnerability, length of homelessness, and severity of service needs;
• Ensure fair and equal access to housing resources, including permanent supportive housing, rapid rehousing, and transitional housing;
• Use the Homeless Management Information System (HMIS) to facilitate case coordination, referrals, and outcome tracking;
• Integrate referrals from a broad range of access points, including emergency shelters, outreach teams, hospitals, and law enforcement.

The CES is accessible through multiple physical and virtual entry points across the County, including partners such as The Salvation Army, Family Service Association of Redlands, Lutheran Social Services, and HOPE Navigation Centers, among others. All ESG subrecipients funded by the City of San Bernardino are required to participate in the CES and coordinate service delivery and housing placements through the system.

This coordinated assessment approach enables a system-wide response to homelessness that improves client outcomes, reduces duplication of services, and ensures the most vulnerable populations are prioritized for limited housing resources.

3. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations).

The City of San Bernardino administers its ESG program in alignment with HUD regulations and ensures that funding is equitably accessible to eligible private nonprofit organizations, including community-based and faith-based organizations.

Each program year, the City issues a Notice of Funding Availability (NOFA) or Request for Proposals (RFP) to solicit applications from qualified service providers. The process includes:

A. Public Notification: The City publicly posts the NOFA/RFP on its website and distributes it via email to a wide network of service providers, including those within the San Bernardino County Continuum of Care (CoC). Outreach is inclusive of faith - based and grassroots community organizations.

B. Eligibility and Threshold Review: All proposals are reviewed to ensure applicants meet HUD eligibility criteria for ESG funding and possess the administrative capacity to

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implement programs in compliance with 24 CFR Part 576.

C. Application Evaluation - Proposals are evaluated based on:
a. Experience in serving homeless or at-risk populations; b. Performance outcomes and past compliance history;
c. Program design, including alignment with the CoC’s priorities and CES participation;
d. Cost-effectiveness and leveraging of additional resources.

D. Funding Recommendations: A City review—often including representatives from the Housing and Homelessness Division and outside advisors —scores and ranks proposals. Recommendations are presented to the Mayor and City Council for approval as part of the Annual Action Plan and budget adoption process.

E. Contract Execution and Monitoring: Awarded subrecipients enter into formal contracts with the City. Ongoing technical assistance and monitoring ensure compliance with ESG regulations, eligible uses of funds, and performance outcomes.

The City prioritizes diverse provider representation, including agencies with lived experience expertise, culturally responsive approaches, and demonstrated capacity to serve historically underserved populations.

4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG.

The City of San Bernardino attends and participates, on a quarterly basis, the Interagency Council on Homelessness (ICH). The ICH is a vital component of the San Bernardino County Homeless Partnership.

The ICH serves as the policy making body of the Partnership and oversees the implementation of the 10-Year Strategy to End Homelessness in San Bernardino County. The ICH will focus on resource development to insure the funding of homeless projects and 10 -Year Strategy recommendations. In addition, ICH serves as the HUD -designated primary decision -making group and oversight board of the City of San Bernardino & County (hereinafter referred to as the “geographic area”) Continuum of Care for the Homeless (CA -609) funding process, (hereinafter referred to as the “ CoC”). There are currently former homeless individuals that participate in the policy making decisions of the CoC, regarding facilities or services that receive ESG funding from the City.

The ICH is charged with directing, coordinating and evaluating all of the activities related to implementation of the 10 -Year Strategy to End Homelessness. The ICH members are directed to report progress on the implementation of the 10 -Year Strategy to their colleagues and constituents following each meeting of the ICH. The ICH will promote collaborative partnerships among homeless providers and stakeholders throughout San Bernardino County in order to carry out implementation activities and will develop resources to insure the funding of homeless projects and 10-Year Strategy recommendations.

As the oversight board of the CoC, the ICH's duties are: 1. To ensure that the CoC is meeting all of the

Consolidated Plan SAN BERNARDINO 167

responsibilities assigned to it by the United States Department of Housing and Urban Development (HUD) regulations, including: a. The operation and oversight of the local CoC; b. Designation and operation of a Homeless Management Information System (HMIS); i. Designate a single HMIS for the geographic area; ii. Designate an eligible applicant to manage the CoC’s HMIS, known as the HMIS Lead; iii. Ensure consistent participation of recipients and sub -recipients of CoC and Emergency Solutions Grant (ESG) funding in the HMIS. iv. Ensure the HMIS is administered in compliance with all requirements prescribed by HUD. c. Developing a CoC plan that includes outreach, engagement, assessment, annual gap analysis of the homeless needs and services available, prevention strategies, shelter and housing supportive services, and HUD CoC annual and biennial requirements; 2. To represent the relevant organizations and projects serving homeless subpopulations; 3. To support homeless persons moving from homelessness to economi c stability and affordable permanent housing within a supportive community; 4. To be inclusive of all the needs of all of the geographic area’s homeless population, including the special service and housing needs of homeless sub - populations; 5. To facilitate responses to issues and concerns that affect the agencies funded by the CoC that is beyond those addressed in the annual Co C application process; 6. To consult with recipients and sub -recipients of CoC funding to establish performance targets appropriat e for population and program type, monitor recipient and sub-recipient performance, evaluate outcomes, and take action against poor performers; and 7. To evaluate outcomes of projects funded under the County of San Bernardino CoC program including the ESG.

5. Describe performance standards for evaluating ESG.

ESG Subrecipients must demonstrate the financial management and programmatic expertise to successfully develop, design, implement, and monitor the ESG -funded activities. ESG Subrecipients must participate in HMIS and be able to meet all federal, State of California, and City of San Bernardino requirements relative to the ESG program, specifically those concerning equal opportunity and fair housing, affirmative marketing, environmental review, displacement, relocation, acquisition, labor, lead-based paint, conflict of interest, debarment and suspension, and flood insurance.

Under the City ESG agreement, ESG Subrecipient are required to conduct an initial evaluation to determine the eligibility of each individual or family’s eligibility for ESG assistance and the amount and types of assistance the individual or family needs to regain stability in permanent housing.

All subrecipient providers should meet or exceed project quality goals established by HUD and CoC guidelines which include the following: At least 80 percent of project participants either remained in permanent housing or exited to permanent housing; At le ast 20 percent or more of project participants have employment income (or other sources such as SSI and/or SSDI, for those who are not employable); At least 54 percent of project participants increased their income from sources other than employment in a g iven operating year; At least 56 percent of project participants obtained mainstream benefits; and 100 percent of the project participants came from the street or other locations not meant for human habitation, emergency shelters, or safe havens. In additi on, PSH providers must: Implement a housing first approach. Fill vacant beds with only chronically homeless persons.

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Appendix - Alternate/Local Data Sources

1 Data Source Name
County Homeless Race, HMIS 2019
List the name of the organization or individual who originated the data set.

County Homeless Race, HMIS 2019
Provide a brief summary of the data set.

Various population data sets were used in the Needs Assessment, Market Analysis, and Strategic plan
What was the purpose for developing this data set?
Using updated information is important for the ConPlan.

How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
The data covers the County.

What time period (provide the year, and optionally month, or month and day) is covered by this data set? 2019
What is the status of the data set (complete, in progress, or planned)? complete
2 Data Source Name
Vacant Unit Data
List the name of the organization or individual who originated the data set.

ACS 2013-2017
Provide a brief summary of the data set.

The data provided comes from 2013-2017 housing occupancy data particularly vacant housing units.

What was the purpose for developing this data set?
HUD did not provide any data to assist with their request of vacant and abandoned, REO and abandoned REO data.

How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
Citywide

Consolidated Plan SAN BERNARDINO 169

What time period (provide the year, and optionally month, or month and day) is covered by this data set? 2013-2017
What is the status of the data set (complete, in progress, or planned)? Data found is only for number of vacant units, other data HUD requests was not found. 3 Data Source Name
Households with Children
List the name of the organization or individual who originated the data set.

The data resource is CHAS 2011-2015
Provide a brief summary of the data set.

The CHAS data presents the number of households both renter and owner by AMI categories.

What was the purpose for developing this data set?
This table was not populated by HUD data, however was available.

How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
This data is citywide.

What time period (provide the year, and optionally month, or month and day) is covered by this data set? CHAS 2011-2015
What is the status of the data set (complete, in progress, or planned)? complete
4 Data Source Name
Point in Time Count, County Homeless Race, HMIS 2019
List the name of the organization or individual who originated the data set.

San Bernardino County Homeless Partnership, 2024
Provide a brief summary of the data set.

Summary of the number of homeless persons on a given night and demographic characteristics of these persons, collected by the CoC.

What was the purpose for developing this data set?
Using updated information is important for the ConPlan.

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How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
The data covers the County.

What time period (provide the year, and optionally month, or month and day) is covered by this data set?
2024
What is the status of the data set (complete, in progress, or planned)? Complete
5 Data Source Name

List the name of the organization or individual who originated the data set.

Provide a brief summary of the data set.

What was the purpose for developing this data set?

How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?

What time period (provide the year, and optionally month, or month and day) is covered by this data set?

What is the status of the data set (complete, in progress, or planned)?

6 Data Source Name

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List the name of the organization or individual who originated the data set.

Provide a brief summary of the data set.

What was the purpose for developing this data set?

How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?

What time period (provide the year, and optionally month, or month and day) is covered by this data set?

What is the status of the data set (complete, in progress, or planned)?

ANALYSIS OF

IMPEDIMENTS

TO FAIR HOUSING CHOICE
2025 – 2029

EXECUTIVE SUMMARY
The Analysis of Impediments (AI) to Fair Housing Choice for the City of San Bernardino is a critical examination aimed at identifying and addressing barriers that hinder equal housing opportunities for all residents. This report is part of the City’s commitment to fostering an inclusive community in which everyone has access to housing as a basic human need.

The AI sets out to accomplish several key objectives, beginning with an analysis of the current conditions affecting fair housing in San Bernardino. Next, an evaluation of the impact of existing policies and practices on affordable housing and housing avai lability for special needs households is conducted. Finally, the AI identifies potential impediments to fair housing choice and recommends actions the City can undertake to mitigate or eliminate these barriers.

Data was gathered through surveys, community forums, stakeholder engagement, and comprehensive data analysis from various sources to ensure a thorough understanding of the issues at hand. Major barriers identified include a lack of housing stock, a lack of affordable housing for lower income households, overcrowding, and demonstrates a need for more fair housing education.

To effectively address these challenges, the report recommends five (5) goals and related actions aimed at enhancing the overall accessibility and affordability of housing in the community.

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Table of Contents
Chapter 1: Introduction ...................................................................................................................................... 4 A. What are Impediments to Fair Housing Choice? ................................................................................... 4 B. Fair Housing Defined .............................................................................................................................. 4 C. What is an Analysis of Impediments to Fair Housing Choice? ............................................................... 4 D. What is the Purpose of this Report? ...................................................................................................... 5 E. Legal Framework .................................................................................................................................... 5 F. Methodology & Organization................................................................................................................. 7 Chapter 2: Public Participation ........................................................................................................................ 10 A. Community Survey ............................................................................................................................... 10 B. Stakeholder Interviews Survey ............................................................................................................. 10 D. Reaching Underrepresented Populations ............................................................................................ 12 E. Public Review and Hearings ................................................................................................................. 13 Chapter 3: Community Profile ......................................................................................................................... 14 A. Demographic Summary ........................................................................................................................ 15 B. Population Growth ............................................................................................................................... 15 C. Age Characteristics ............................................................................................................................... 15 D. Race and Ethnicity ................................................................................................................................ 16 E. Household Characteristics.................................................................................................................... 20 F. Income Profile ...................................................................................................................................... 27 G. Housing Profile ..................................................................................................................................... 30 H. Access to Opportunities ....................................................................................................................... 43 Chapter 4: Lending Practices ............................................................................................................................ 46 A. Laws Governing Lending ...................................................................................................................... 46 B. Types of Loans ...................................................................................................................................... 48 C. Home Mortgage Disclosure Act and Data Analysis .............................................................................. 50 Chapter 5: Public Policies ................................................................................................................................. 54 A. Housing Element Law and Compliance ................................................................................................ 54 B. Land Use Element................................................................................................................................. 54 C. Development Code............................................................................................................................... 55 D. Regional Housing Needs Assessment ................................................................................................... 59 Chapter 6: Fair Housing Profile ........................................................................................................................ 60 A. Fair Housing Practices in the Homeownership Market ....................................................................... 60 B. Fair Housing Practices in the Rental Housing Market .......................................................................... 61 C. Fair Housing Complaints and Enforcement .......................................................................................... 62

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Chapter 7: Fair Housing Progress ..................................................................................................................... 65 Chapter 8: Fair Housing Action Plan ................................................................................................................ 72 A. Recommendations for Ongoing Actions .............................................................................................. 72 Appendix A: Federal Fair Housing Laws ........................................................................................................... 76 Appendix B: Community Outreach .................................................................................................................. 77

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Chapter 1: Introduction

The City of San Bernardino (the City) is a recipient of funds from the U.S. Department of Housing and Urban Development (HUD). As such, the City is required to conduct an Analysis of Impediments to Fair Housing Choice (AI).

A. What are Impediments to Fair Housing Choice?
Fair housing is a condition in which people of similar income levels, living in the same housing market, have a similar range of choice regardless of characteristics protected under State and Federal laws.

Traditionally, the U.S. Department of Housing and Urban Development has defined impediments to fair housing choice as:

• Any actions, omissions, or decisions taken because of race, color, national origin, religion, sex, disability, or familial status which restrict housing choices or the availability of housing choices; or
• Any actions, omissions, or decisions which have the effect of restricting housing choice, or the availability of housing choice based on race, color, national origin, religion, sex, disability, or familial status.

These actions or omissions may violate fair housing laws, hinder fair housing choices, or restrict housing opportunities for individuals with legally protected characteristics. For instance, a real estate agent refusing to sell a home to a family of color based on their race is a clear violation of federal and state fair housing laws. Sometimes, however, barriers to fair housing choice are more subtle.

In the pursuit of affirmatively promoting equal housing opportunities, communities must work to remove or to mitigate impediments to fair housing choice. The City of San Bernardino remains committed to providing fair housing access and opportunities to all residents, to complying with all applicable laws, and to conducting business both fairly and impartially. This includes completion of this report, the Analysis of Impediments to Fair Housing Choice (AI). This AI abides by the recommended scheme of analysis and format established in HUD’s Fair Housing Planning Guide.

B. Fair Housing Defined
Fair housing is the right of an individual to freely choose their own housing without unlawful discrimination. These rights are protected by both Federal and State laws, and equal access to housing is a longstanding goal of both the United States and the State of California. Equal access to housing, also referred to as housing choice, remains fundam ental to meeting essential needs and pursuing personal, educational, employment, and other goals.

C. At a national level, federal fair housing laws prohibit discrimination in the sale, rent, lease, and negotiation of real property, based on race, color, national origin, religion, sex, familial status, and disability. What is an Analysis of Impediments to Fair Housing Choice? An Analysis of Impediments (AI) to Fair Housing Choice is an assessment of how laws, policies, real estate practices, and local conditions affect the location, availability, and accessibility of housing. The analysis of their impact on housing choice can highlight areas where corrective actions might broaden the housing options of persons protected by fair housing laws.

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D. What is the Purpose of this Report?
Through the AI, jurisdictions examine the affordability of housing with an emphasis on affordability for households with annual incomes classified as extremely -low-to-moderate income. Moderate income is defined as equal to or less than 80 percent of the adjusted Area Median Family Income (AMI) as most recently published by the U.S. Department of Housing and Urban Development (HUD). Pursuant to 2024 San Bernardino County HUD Income Limits, 80 percent of the AMI in the City of San Bernardino, adjusted for family size, is $82,000 for a family of four.

This AI has three major goals:

Goal 1: Provide an overview of the City and current conditions as they impact fair housing choice.

Goal 2: Review the City’s policies and practices as they impact fair housing choice and the provision of housing, specifically affordable housing, and housing for special needs households.

Goal 3: Identify impediments to fair housing choice and actions the City will take to remove those impediments or to mitigate the impact they have on fair housing choice.

Fulfilling these goals involves:

• A review of the laws, regulations, and administrative policies, procedures, and practices of the City.
• An assessment of how those laws affect the location, availability, and accessibility of housing. • An assessment of conditions, both public and private, affecting fair housing choice.

E. Legal Framework
Fair housing choice seeks to ensure individuals the opportunity to choose where they wish to live. To guarantee that all individuals and families are given the opportunity of equal access to housing, the federal government and the State of California have enacted the following laws to prohibit subtle and overt forms of housing discrimination. HUD’s Office of Fair Housing and Equal Opportunity has played a lead role in enforcing the Act since its adoption in 1968. The Act prohibits discrimination in the sale, rental, and financing of dwellings based on race, color, religion, national origin, sex, fam ilial status (presence of child under the age of 18, and pregnant women), and/or disability.

Federal Laws
Federal Fair Housing Act (Fair Housing Act of 1968 and Fair Housing Amendments Act of 1988) (42 U.S.

Code §§ 3601-3619, 3631)
The Fair Housing Act is the protection against discrimination in housing on the federal level. After a lengthy legislative battle, urban riots, and the assassination of Dr. Martin Luther King Jr., the Act was enacted in 1968. It extended the general discrimination protections included in the 1964 Civil Rights Act into the housing market. The Act prohibits discrimination in housing based on a person’s race, color, religion, sex, disability, familial status, or national origin. Persons who are protected from discrimination by fair housing laws are referred to as members of the protected classes.

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The Act covers “dwellings” which are defined as structures designed or occupied as residences or land offered for sale where a residence will be built. A “dwelling” is broadly defined and can include a homeless shelter or a summer home. In some circumstanc es, exemptions to the Act include the following: owner-occupied buildings with no more than four units, single-family housing sold or rented without the use of a broker, and housing operated by organizations and private clubs that limit occupancy to members.

Equal and unimpeded access to residential housing is a fundamental civil right that enables members of protected classes, as defined in the Act, to pursue personal, educational, employment, or other goals. Other federal laws relevant to fair housing are included in Appendix A.

Reasonable Accommodations and Accessibility
The Fair Housing Amendments Act of 1988 requires housing providers to make reasonable accommodations if it is necessary for people with disabilities to live in and use the housing.

Accommodations may include interior or exterior modifications, such as installation of ramps, or modifications of rules, policies, or practices, such as allowing guide dogs in a building that has a no pet policy.

California Laws
The California Civil Rights Department (CRD), formerly the Department of Fair Employment and Housing (DFEH), is the entity responsible for enforcing the state’s fair housing laws.

Fair Employment and Housing Act (FEHA) (Government Code §§ 12955 et seq.) The California Fair Employment and Housing Act is a California statute that prohibits employment and housing discrimination based on race, color, ancestry, national origin, citizenship, immigration status, primary language, religion, mental or physical disability, sex and gender, sexual orientation, gender identity and expression, genetic information, marital status, familial status, source of income, and age.

FEHA applies to various entities involved in housing, such as landlords, tenant screening companies, property management firms, real estate agents, home sellers, builders, mortgage lenders, and housing authorities.

Unruh Civil Rights Act (California Civil Code §§ 51 et seq.) The Unruh Civil Rights Act prohibits discrimination by all business establishments, including housing accommodations, based on race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, prim ary language, or immigration status. The California Supreme Court has held that protections under this legislation are not necessarily restricted to these specific characteristics.

Ralph Civil Rights Act (California Civil Code § 51.7)
The Ralph Civil Rights Act prohibits discrimination and protects individuals from acts of violence, intimidation, and harassment against themselves or their property based on a person’s actual or perceived protected characteristic. The act provides legal recourse for victims of hate violence which can be graffiti, vandalism, or property damage; assault or attempted assault; and verbal or written threats.

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Bane Civil Rights Act (California Civil Code § 52.1)
The Bane Civil Rights Act prohibits interference or attempted interference through threats, intimidation, or coercion, with someone’s state or federal statutory or constitutional rights, including fair housing. For example, the Act can protect against discriminatory landlords and intentional barriers to equal housing access.

Senate Bill 329
Signed by Governor Gavin Newsom, this bill expands the definition of “source of income” to include income paid to a housing owner or landlord on behalf of a tenant, including federal, state, or local public assistance or subsidies. Therefore, SB 329 expands fair housing protections to recipie nts of Section 8 vouchers.

California Civil Code Section 1940.3
This protects individuals from housing discrimination based on their immigration or citizenship status.

Under the Civil Code , landlords are forbidden from questioning potential residents about their immigration and citizenship status while local jurisdictions are forbidden from passing laws that would direct landlords to do so.

Government Code Section 1135
This prohibits discrimination against individuals based upon their protected characteristics in any state-funded programs.

Government Code Sections 65008 and 65580-65589.8
These sets of Government Code provide increased fair housing and equal access protections. State law requires local jurisdictions to address housing for special needs groups which include:
• Housing for persons with disabilities
• Housing for homeless persons, including emergency shelters, transitional housing, and supportive housing.
• Housing for extremely low-income households. Including single-room occupancy units • Housing for persons with developmental disabilities

F. Methodology & Organization

Pursuant to HUD guidance, jurisdictions are not required to collect new data and can use existing data to analyze potential impediments to fair housing choice. For this AI, the City employed the following data sources:

American Community Survey (ACS) 2007-2011 5-Year Estimates and 2017 -2021 5 -Year Estimates, U.S. Census Bureau. ACS data are obtained from a nationwide survey on population characteristics, including demographic, social, economic, and housing conditions. The 5 -Year Estimate includes 60 months (about 5 years) of collected data for all population size areas. As compared with other sample sizes (1-Year and 3-Year), the 5-Year Estimate utilizes the largest sample size and is the most reliable despite being the least current.

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Community Reinvestment Act (CRA) Rating Search, Federal Financial Institutions Examination Council (FFIEC). CRA ratings for financial institutions include substantial noncompliance, needs to improve, satisfactory, and outstanding. These ratings are supervised by regulatory agencies including the Federal Reserve, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and Office of Thrift Supervision.

Comprehensive Housing Affordability Strategy (CHAS) 2016-2020 5-Year Estimates. Developed by the U.S. Census Bureau for the U.S. Department of Housing and Urban Development (HUD), the CHAS database contains vast information on low- and moderate-income (LMI) households, as well as housing problems (i.e., cost burden, overcrowding, and substandard conditions). In September 202 4, HUD published CHAS data based on the 2017-2021 ACS. This Five-Year (2017-2021) dataset is used by HUD, state governments, and local governments to examine housing needs and make informed funding decisions. CHAS data is available at the state, county, place, and census-tract level. This report utilizes “place” data by examining data specific to the City of San Bernardino.

Decennial Census 2000, 2010, and 2020 U.S. Census Bureau. The Decennial Census provides comprehensive data describing demographic and housing characteristics.

Diversity and Disparities: Residential Segregation, Brown University. The Diversities and Disparities Project provides independent and peer -reviewed research examining changes in American society.

Data on the Index of Dissimilarity, which reflects residential segregation, throughout the last several decades in the City is provided by this source.

Home Mortgage Disclosure Act (HMDA) Data Browser 2022, Federal Financial Institutions Examination Council (FFIEC). Developed by the FFIEC, the HMDA Data Browser provides detailed information about mortgage loan applications and applicants. It includes the status of a loan, such as denied, along with race, age, sex, and ethnicity of the applicant. Users can also examine the name of the lending institution. This data is helpful in assessing the potential existence of discriminatory lending practices.

Point-in-Time Count 2024, County of San Bernardino Homeless Partnership ( SBCHP). The Point-in- Time count seeks to identify how many people are experiencing homelessness, along with other details about the experiences of people currently homeless. For example, the count records people’s shelter situations along with demographic characteristics, such as race, ethnicity, age, and gender.

San Bernardino Consolidated Annual Performance and Evaluation Reports (CAPER). The CAPER is an annual report that the U.S. Department of Housing and Urban Development (HUD) requires from grantees to assess their yearly performance. The CAPER reports on the City’s progress towards meeting its goals through its grant activities.

San Bernardino Housing Element (20 21-2029). The Housing Element is a required component of the City’s General Plan, which is required by the California Department of Housing and Community Development (HCD). It outlines the City’s housing needs and strategies to address those needs.

San Bernardino Zoning Ordinance . The Zoning Ordinance is a system of local laws that dictate how land in the City can be used.

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Organization of the Report
This report is divided into eight chapters, including this introduction, as described below.

Chapter 1: Introduction explains the purpose of the AI, describes its methodology and organization, and outlines its legal framework.

Chapter 2: Public Participation discusses outreach efforts undertaken for the development of the AI .

Outreach results include comments received during the public review draft AI, community engagement and stakeholder meetings.

Chapter 3: Community Profile presents demographic information and income characteristics in the City, including the number and percentage of people by age, ethnicity, familial status, and disability.

The housing profile includes the number of housing units by type, cost, overcrowding condition, and housing cost burden. Income characteristics include the distribution of low - and moderate -income population by census tract.

Chapter 4: Lending Practices assesses the access to financing for different groups. Predatory and subprime lending issues are also discussed.

Chapter 5: Public Policies analyzes public policies and actions that may impede fair housing in the city, such as those contained in the City’s Housing Element, Land Use Element, and Zoning Ordinance.

Chapter 6: Fair Housing Profile provides information on the institutional structure of the homeownership and rental markets in the City. It also includes local, state, and federal data on fair housing complaints.

Chapter 7: Fair Housing Progress evaluates the progress toward recommendations made in the previous AI’s Action Plan.

Chapter 8: Fair Housing Action Plan summarizes the findings regarding fair housing issues in the City and provides recommendations for furthering fair housing practices.

Appendix A: Federal Fair Housing Laws describes additional fair housing laws not covered by this report.

Appendix B: Community Engagement Summary describes the community outreach program and summarizes input from residents, agency representatives, and other stakeholders.

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Chapter 2: Public Participation
The public participation process for the AI sought input from community members and stakeholders.

Methods included on-line surveys for community members, stakeholder interviews, and a community meeting. The AI development engagement process took place during the fall and early winter, through December. The process concluded with a 30-day public review period and a public hearing for adoption of the proposal study.

A. Community Survey

The City prepared a Community Needs Survey in
both English and Spanish and provided online
links and outreach to local community and social
service groups to reach a broad population. The
survey link was posted on the City’s website,
stakeholder newsletters, social media posts and
flyers distributed at community events. The
survey period was from 10/24/24 to 1/17/25 .

The City received approximately 240 responses,
of which 88.25 percent were San Bernardino
residents.

The survey sought community input on the
City’s most pressing needs in the areas of
housing, community facilities, infrastructure,
homelessness, community services, and
economic development.

A summary of the English and Spanish survey results is included in Appendix B –Community Engagement Summary.

B. Stakeholder Interviews Survey
The City also distributed the online Community Needs Survey to stakeholder s to gather critical input from a multitude of perspectives . They represent housing, health, education, employment, faith - based, service delivery, and professional service organizations. The survey posed questions about community facilities, community services, infrastructure, residents with special needs, neighbo rhood services, business and job services, housing services, and housing facilities. It also contained open - ended questions with the purpose of gathering in-depth perspectives from stakeholders.

Stakeholder interviews included representatives from the following organizations:

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• City of San Bernardino Community Department of Community Development & Housing • Rise of A Fallen Angel, INC
• Neighborhood Housing Services of the Inland Empire
• Center for Employment Opportunities
• Neighborhood Partnership Housing Services
• El Sol Neighborhood Educational Center
• NPHS Community Redevelopment
• Inland Fair Housing and Mediation Board
• Vision y Compromiso
• The Salvation Army
• TELACU
• United Contractors, Inc.

Affordable Housing Availability
• Strong concern over lack of affordable rental units, particularly for extremely low -income households and working families.
• High demand for permanent supportive housing for individuals experiencing homelessness.

Homelessness Services & Prevention
• Critical need for more emergency shelter beds, transitional housing, and wraparound services. • Emphasis on mental health, substance use recovery, and job readiness as essential components.

Access to Supportive Services
• Calls for better coordination and availability of services such as case management, food access, legal aid, and financial counseling.
• Need for service hubs located within underserved neighborhoods.

Workforce Development & Economic Stability
• Stakeholders identified job training, youth employment programs, and adult education as critical for breaking poverty cycles.
• Barriers include lack of transportation, childcare, and digital literacy.

Safe and Quality Housing Conditions
• Persistent concerns about substandard housing, overcrowding, and code enforcement in older housing stock.
• Need for rehab programs for low-income homeowners and renters.

Transportation Access
• Limited or no public transportation options in certain areas affect job access and service utilization. • Stakeholders advocated for expanded and subsidized transit options.

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Youth & Family Services
• Critical gaps in after -school programs, early childhood education, and behavioral health support for children and teens.
• Stakeholders highlighted rising youth mental health concerns post-pandemic.

Community Safety and Engagement
• Concerns about rising crime, gang activity, and need for more community policing and prevention programs.
• Need for spaces and programs that build community trust and cohesion.

Fair Housing Education & Enforcement
• Stakeholders noted low awareness of fair housing rights and limited access to complaint resources. • Need for multilingual outreach, workshops, and legal support.

Access to Healthcare and Mental Health
• Emphasis on expanding access to affordable healthcare and mental health clinics, especially in rural and underserved neighborhoods.
• Integration of health services into housing and community programs is recommended.

C. Community Meetings
Community meetings were attended by representatives from Upwards, Neighborhood of Housing Services of Inland Empire (NHSIE), Inland Congregations United for Change, San Bernardino Police Department, Homeless Services, Housing Authority of the County of San Bernardino ( HACSB), and Neighborhood Partnership Housing (NPHS). There was an online community engagement meeting held on December 19th, 2024, at 10:00 am.

Comments from participants fell into the following re-occurring themes: Affordable housing, need for community and homeless/homeless prevention services, jobs and employment, housing rehabilitation needs for low -income homeowners, and infrastructure needs. A summary of the input received is included in Appendix B – Community Engagement Summary.

D. Reaching Underrepresented Populations
To maximize participation, the City employed multiple engagement methods, including online surveys for residents and stakeholders , a community meeting, and public hearings. This multi -faceted approach ensured that different segments of the population had the opportunity to participate in the process, regardless of their preferred method of engagement. The use of both online and in -person methods helped to reach a wider audience and accommodate various preferences and needs.

Limited English Proficiency
To ensure that individuals with limited English proficiency were included in the public participation process, the City prepared the Community Needs Survey in English and Spanish. Outreach efforts included posting the survey link on the City’s website, stakeholder newsletters, social media posts, and distributing flyers at community events. This approach helped to reach a broader population, including Spanish-speaking community members. Additionally, the City ensured that key documents and information were available in both languages to facilitate better understanding and participation.

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Persons with Disabilities or Special Needs
The City made efforts to include persons with disabilities or special needs by engaging with a diverse range of stakeholders through interviews and surveys. Stakeholders represented various sectors, including housing, health, education, employment, and ser vice delivery organizations. These stakeholders provided critical input on the needs of residents with special needs, ensuring their perspectives were considered in the AI development process. The City also ensured that community meetings and public hearings were accessible by providing online methods of engagement.

E. Public Review and Hearings
The AI was completed concurrently with the City’s 2020 -2025 Consolidated Plan. Two public hearings were held on June 4, 2025 , and June 18, 2025. A public review draft and comment of the AI and the Consolidated Plan was available for a 30-day review period from May 1, 2025, through June 1, 2025. A public review draft of the AI and the Consolidated Plan was available for a 30-day public review period from May 1, 2025, through June 1, 2025. Public Hearings were advertised in the San Bernardino Sun and El Chicano . The AI was also made available on the City’s website, City of San Bernardino Public Information Center, Community and Economic Development Department, and Feldheym Central Library. All written comments received relating to impediments to fair housing will be documented and reviewed by the City . The City Council is responsible for holding a public hearing to discuss and adopt the final AI report.

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Chapter 3: Community Profile
Various characteristics affect housing choice for people and households with similar income levels, in the same housing market. Therefore, understanding the social, racial, economic, and other population characteristics and how they change over time is crucial to evaluating current and future housing needs and housing choice among characteristically different populations and households.

The City of San Bernardino is the most populous city in the County of San Bernardino and one of the oldest communities in the State of California.

Throughout the years, the City has experienced economic vitality, built on agriculture, railroads, and distribution. The City experienced significant change i n the latter half of the 1900s, with changing market conditions, high rates of population growth, and other social , economic, and cultural changes throughout the Inland Empire. While these changes have impacted most people, they have had larger impacts on vulnerable populations.

This Community Profile compiles information about population change, incomes, household characteristics, and housing costs, all of which influence housing choice.

Map 1: City of San Bernardino, City Boundaries
Population increase is
in line with County and
State projections

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A. Demographic Summary
Information in this section is primarily based on the 2017-2021 American Community Survey (ACS). In some cases, data from the 2007-2011 ACS estimates and the 20 00 U.S. Census have been used to detect trends.

B. Population Growth
Insight into the changing characteristics of the City’s population will aid in implementing policies that best suit the community's needs and drive data-informed decisions. Population increase over time is shown in Table 1, along with a comparison to the County of San Bernardino and the State of California.

Between 2011 and 2021, each jurisdiction (City, County, and State) saw an increase in population.

According to 2021 ACS data, the City’s population was 220,821, a 5 percent increase from 2011. The County and State experienced 7 percent increases in population, closely in line with the City’s change.

Table 1: Regional Population Increase
2000 2011 2021 % Change
2011-2021
City 185,388 210,100 220,821 5%
County 1,709,434 2,023,452 2,171,071 7%
State 33,871,648 36,969,200 39,455,353 7%
Source: 2000 U.S. Decennial Census, 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates C. Age Characteristics
Age is an important factor when evaluating housing needs of a community. As people age, they pass through different stages associated with changing family types and sizes, education and training that influence earning capacity , physical abilities, mental faculties, and overall independence. Together, these and cultural norms correspond to different housing needs over time. The ability to meet those needs depends on available housing options in both the rental and ownership markets. 220,821
Total Population
68%
Hispanic or Latino
33,820
LMI Households
49%
Homeowners
51%
Renters
$55,372
Median HH Income
Sources: 2017-2021 ACS 5-Year Estimates and 2017-2021 CHAS

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Table 2: Age Characteristics
City City % County County %
Under 5 15,159 6.86% 149,407 6.88%
5 to 17 47,512 21.52% 424,577 19.56%
18-24 24,683 11.18% 219,421 10.11%
25-44 65,557 29.69% 616,301 28.39%
45-64 47,084 21.32% 510,458 23.51%
65 or older 20,826 9.43% 250,907 11.56%
Total 220,821 100.00% 2,171,071 100.00%
Source: 2017-2021 ACS 5-Year Estimates
D. Race and Ethnicity
Race and ethnicity can have implications for housing choice for reasons that can include discrimination or economic variables that tend to correlate with race. While race and ethnicity are similar concepts used to categorize population, race is based on shared physical traits and common ancestry while ethnicity focuses on shared cultural practices such as language and religion. For example, persons who identify as ethnically Hispanic may share characteristics such as a common language, regional origi n, and belief system; however, a person can be both ethnically Hispanic and identify as white or Black.

According to 2021 ACS data, the largest racial population group in the City is white at 45 percent, while 68 percent of the population identified as Hispanic or Latino of any race. Between the years 2011 and 2021, the City experienced significant changes in race populations. The largest increase of population in a single racial group was Native Hawaiians and Pacific Islanders, who experienced a 54 percent increase in change but make up a small portion of the overall population at just 0.3 percent. On the other hand, the largest population decrease in racial groups was Black or Afr ican American at a 12 percent decrease. The most significant change between 2011 and 2021 was the number of people identifying as two or more races, which increased dramatically by 178 percent. Almost 24,000 individuals in the City identify as two or more races, an indication of further cultural integration.

Key Takeaways
Diverse housing options that apply to young and middle-aged adults, families with children, and aging adults are very important to the City's three largest age groups.

Largest Age Groups in Order:
- 25 to 44 (30%)*
- 5 to 17 (22%)*
- 45 to 64 (21%)*
Source: 2017-2021 ACS 5-Year Estimates
*All percentages are rounded up.

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Table 3: Current Race & Ethnicity Comparison
2011 % 2021 % % Change
White 94,041 45% 98,649 45% 4.90%
Black or African American 31,257 15% 27,627 13% (11.61%) American Indian and Alaska Native 1,809 1% 2,304 1% 27.36% Asian 9,227 4% 8,709 4% (5.61%)
Native Hawaiian/Pacific Islander 441 0% 680 0% 54.20%
Some other race 64,741 31% 58,957 27% (8.93%)
Two or more races 8,584 4% 23,895 11% 178.37%
Total 210,100 100% 220,821 100% 5.10%
Hispanic or Latino (of any race) 123,611 59% 149,165 68% 20.67% Not Hispanic or Latino 86,489 41% 71,656 32% (17.15%)
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimate

Index of Dissimilarity
Residential segregation refers to the degree to which groups live separately from one another.

Segregation is complex, difficult to generalize, and influenced by many factors. Individual choices can certainly be a cause of segregation, such as when residents choose to live among people of their own race/ethnic group. This does not mean that they prefer ethnically homogeneous neighborhoods, but that they feel more comfortable where members of their group are commonly found. However, individual choices may also be constrained by factors outside an individual’s control. A large factor in residential segregation is related to housing market dynamics. Availability of affordable housing and discrimination can also affect residential segregation.

The dissimilarity index is the most commonly used measure of segregation between two groups, reflecting their relative distributions across neighborhoods (as defined by census tracts). The index of dissimilarity is a method used to measure segregation between two groups, reflecting the relative distribution of each group across census tracts in the same area. A high dissimilarity reflects separation, meaning that the two groups tend to l ive in different tracts, while a low dissimilarity reflects integration. Dissimilarity ranges from 0 to 100, with a value of 60 or above considered very high segregation, 40 to 50 considered moderate segregation, and 30 or below considered fairly low segregation.

Table 4 represents dissimilarity indices for the City. In 2020, segregation was highest between Asians and Hispanics at an index of 40.4, followed by white and Asian populations, with an index of 34.9. The lowest segregation was between black and Hispanic residents with an index of 24. 5. Between 2010 and 2022, residential segregation was unchanged between the Hispanic and Asian population.

Table 4: Index of Dissimilarity
1980 1990 2000 2010 2020
White - Black 65.1 49.8 37.4 33.1 26.6
White - Hispanic 53.4 49.7 43.1 39.4 34.8

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White - Asian 26.6 32.2 38.4 36.6 34.9
Black - Hispanic 41.7 31.2 25.1 24.6 24.5
Black - Asian 59.5 36.3 35.2 32.8 33.5
Hispanic - Asian 49.5 38.1 38.6 40.4 40.4
Source: Brown University, Diversity and Disparities, American Communities Project Racially or Ethnically Concentrated Areas of Poverty
HUD defines racially or ethnically concentrated areas of poverty (R/ECAPs) as census tracts with a non- white population of 50 percent or more, and a poverty rate that either exceeds 40 percent of the population or is three or more times higher than the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower. Poverty has an adverse impact on housing choice. Limited access to and availability of affordable housing can compromise health, safety, and services that households need to live.

Racially/Ethnically Concentrated Areas of Poverty by Census Tract in the City of San Bernardino are shown in Map 2 and include:
• 4800
• 5701

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Map 2: Racially or Ethnically Concentrated Areas of Poverty (R/ECAP), City of San Bernardino

Language Spoken
Housing may not be refused based on a resident’s birthplace or ancestry, nor can housing providers take advantage of a person’s inability to read, write, speak, or understand English to deny access.

Despite this, those with limited English proficiency (LEP) can face unique challenges in meeting their housing needs. There are several ways in which programs and statute s work to bridge the gap. For example, under Title VI of the Civil Rights Act of 1964, federally assisted housing providers must afford meaningful access to people with LEP. This condition applies to HUD funds that are allocated to the City.

While housing needs do not vary with language spoken, language is an important population characteristic because it may influence discriminatory practices and should be considered when establishing goals and actions to further fair housing. Of the City’s total population, 47.8 percent speak only English, 47.7 percent also speak Spanish, 3.1 percent speak Asian and Pacific Islander languages, and less than one percent speak other Indo-European languages or other non-specified languages. Of the total population, almost 18 percent speak English less than very well.

Table 5: Language Spoken at Home
(persons 5 years and older)
Number % of Population (5+ Years)
Population 5 years and over 205,662 100%
English Only 98,351 47.8%
Language Other than English 107,311 52.2%
Speak English less than "very well" 36,524 17.8%
Spanish 98,066 47.7%
Speak English less than "very well" 32,624 15.9%
Other Indo-European languages 1,328 0.6%
Speak English less than "very well" 324 0.2%
Asian and Pacific Island languages 6,461 3.1%
Speak English less than "very well" 2,838 1.4%
Other languages 1,456 0.7%
Speak English less than "very well" 738 0.4%
Source: 2017-2021 ACS 5-Year Estimates

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Map 3: Limited English Proficiency (HUD AFFH-T Mapping Tool)

E. Household Characteristics
The household profile, which outlines characteristics of San Bernardino’s households, aids in understanding housing needs. Households with different characteristics face different impediments in the housing market. Various household characteristics may affect equal acce ss to housing, including household type, size, and income level. A household, as defined by the U .S. Census Bureau, includes all the persons who occupy a housing unit, which may include a single family, one person living alone, two or more famili es living together, or any other group of related or unrelated persons who share living arrangements.

Household Type and Size
The number of San Bernardino households increased by 1.76 percent between 2011 and 2021, from 60,614 to 61,680 households. As shown in Table 6, the majority of the City’s households are families (75 percent). However, the number of households with children (under the age of 18) decreased by

5.67 percent between 2011 and 2021. Approximately 13 percent of households are female -headed single-parent households living with their own children. In 2011, the average household size in the City was 3.35 persons per household, and in 2021 it was 3.41 . About 34 percent of San Bernardino households included at least one or more persons over the age of 60.

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Table 6: Household Type and Size
2011 2021 % Change
Total Households 60,614 61,680 1.76%
Family Households 44,742 46,224 3.31%
With own children under 18 yrs 25,803 23,944 (7.20%)
Married couple with family 25,486 25,872 1.51%
With own children under 18 yrs 14,447 12,952 (10.35%)
Female householder, no spouse present 13,842 13,831 (0.08%) With own children under 18 yrs 8,377 7,989 (4.63%)
Nonfamily households 15,872 15,456 (2.62%)
Householder living alone 12,586 11,917 (5.32%)
Householder 65 years and over 4,539 4,405 (2.95%)
Households with individuals under 18 years 29,883 28,188 (5.67%) Households with individuals over 60 years 16,911 20,786 22.91% Average household size 3.35 3.41 1.79%
Average family size 3.9 3.91 0.26%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Special Needs Populations
Certain special needs groups may have difficulty finding housing in the City and may require specialized services, assistance, and accommodation. Due to the challenges that accompany special needs, these individuals and households may be more likely to earn extremely low to low incomes. Special needs groups include seniors, people with disabilities (mental, physical, and/or developmental), veterans, persons with HIV/AIDS, single -parent households, large households, homeless persons, and persons who are at-risk of homelessness.

Senior Population
Senior citizens are defined as any person aged 65 or older . Seniors may have special housing needs primarily due to income, healthcare costs, and physical or mental disabilities, particularly those that tend to increase with age. As a result, seniors may face difficulty in finding housing and may become victims of housing discrimination or fraud.

According to the 2017-2021 ACS estimates and as reflected in Table 2 above, approximately 20,826 seniors resided in the City, representing 9.4 percent of the total population. The senior population is growing at a faster pace than the overall population. Between 2011 and 2021, the total number of seniors in San Bernardino increased by 24 percent while the City’s total population between those two years increased by only 5 percent. Table 7, below, shows how the senior population has changed by age group, with the most substantial change, 1.6 percent, occurring in the 65 to 74 years old category.

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Table 7: Elderly Population
Percent of Population
2011 2021
65-74 years old 4.3% 5.9%
75-84 years old 2.6% 2.4%
85 and older 1.0% 1.1%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates

Persons with Disabilities
Physical, mental, and/or developmental disabilities may prevent a person from working, restrict one’s mobility, or make self -care difficult. Disabled persons frequently have special housing needs, often related to a potentially limited ability to earn enou gh income, a lack of accessible and affordable housing, and higher health costs associated with a disability. In addition, people with self-care and mobility limitations may require special housing design features such as wheelchair ramps, grab bars, special bathroom designs, wider doorway openings, and other features.

Disabled persons are often more vulnerable to housing discrimination. This discrimination can take on many forms, including, but not limited to, refusal to rent or sell or refusal to allow reasonable accommodation or modification to the unit. Reasonable accommodation refers to any change, exception, or adjustment that would allow a person with a disability to access, use, or enjoy housing.

Examples of this would include allowing a service animal in a housing unit that does not allow pets or installing ramps for a tenant who uses a wheelchair.

Section 504 of the Rehabilitation Act of 1973 guarantees certain rights to people with disabilities. This legislation was one of the first U.S. Federal civil rights laws offering protections for people with disabilities. HUD’s Section 504 regulation defines a person with a disability as any person who has a physical or mental impairment that substantially limits one or more major life activities. The term physical or mental impairment may include, but is not limited to, conditions such as visual or hearing impairment, mobility impairment, HIV infection, developmental disabilities, drug addiction, or mental illness.

According to 2017-2021 ACS data, 13.2 percent of San Bernardino residents reported a disability. Table 8, below, shows the different types of disabilities reported by residents, with the most prevalent being cognitive and ambulatory difficulties at seven percent of the total population for each. Six percent of the population also experiences independent living difficulty and may face housing discrimination or have trouble finding housing that fits their individual needs.

Table 8: Persons with Disabilities Profile
Number Percent of Population
With a disability 29,295 13%
with a hearing difficulty 6,650 3%
with a vision difficulty 8,372 4%
with a cognitive difficulty 13,193 7%

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with an ambulatory difficulty 13,640 7%
with a self-care difficulty 5,697 3%
with an independent living difficulty 9,954 6%
Source: 2017-2021 ACS 5-Year Estimates
Persons with HIV/AIDS
Individuals with HIV/AIDS are protected against housing discrimination under the Fair Housing Act of 1968 and section 504 of the Rehabilitation Act of 1973 , which protects the rights of Americans living with disabilities. According to the Americans with Disabilities Act of 1990, a disability is defined as a physical or mental impairment that significantly limits the ability to perform major life activities. T he 1998 Supreme Court case of Bragdon v. Abbott upheld that HIV/AIDS is a disability as outlined by the ADA, and that reproduction is a major life activity.

Persons with HIV/AIDS often face housing discrimination due to the stigma associated with their health status. The housing status of an HIV/AIDS patient is crucial to the quality of their care. Each year, HUD investigates complaints of alleged housing discrimination against individuals with disabilities, including HIV/AIDS. The Center for Disease Control (CDC) has historically stated that housing stability is a significant barrier to HIV care and that stable housing is closely linked to successful HIV-related health outcomes.

According to the 2022 California HIV Surveillance Report, the number of new HIV diagnoses across the state increased by 0.4 percent between 2018 and 2022. The number of newly diagnosed people in the County of San Bernardino was 278 in 2018 and 291 in 2022. In 2022, the County had a total of 5,466 people living with a diagnosed HIV infection, of which 67 percent were in care and 57.1 percent had virally suppressed HIV . The total number of people living with HIV in the County increased by 17 percent between 2018 and 2022.

Homeless Population
Homelessness is attributable to challenges resulting from the loss of employment, difficulty finding jobs, the need to develop or redevelop marketable skills, the cost of housing, chronic health problems, physical disabilities, mental health disabilities, drug and alcohol use disorders, and/or a host of other factors. Individuals or families who are homeless have a variety of special needs, including emergency shelter, transitional housing, interim and permanent supportive housing, mental health counseling, and job training.

The 2024 San Bernardino County Point in Time (PIT) Count documented 1,417 homeless individuals in the City of San Bernardino. Between 2019 and 2024, the City’s unhoused population increased by 59 percent. Table 9 summarizes the information available for 2024 across the City and County.

Table 9: 2024 PIT Count Overview
Jurisdiction
Sheltered
Unsheltered Total Sheltered Transitional
Housing
City 337 103 977 1,417
County 844 338 3,055 4,237
Source: 2024 County of San Bernardino Point in Time Count

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Table 10 provides data on the issues experienced by homeless individuals in the City who were surveyed for the 2024 PIT C. This data helps provide a better understanding of what types of services may be needed to better assist the population in becoming housed and to prevent homelessness from occurring in the first place. Approximately 45 percent of homeless people who were surveyed are experiencing chronic homelessness, indicating a severe hurdle with becoming housed or remaining housed.

Table 10: 2024 PIT Count Issues Experienced
# % of pop. surveyed
Chronic Health Condition 84 17.50%
Chronically Homeless 216 44.90%
Developmental Homeless 30 6.20%
Foster Care (ever been) 60 12.50%
Homeless for First Time in 12 months 159 33.10%
HIV/AIDS 8 1.70%
Incarcerated During Last 12 Months 85 17.70%
Mental Health Disability or Disorder* 103 21.40%
Physical Disability* 98 20.40%
Substance Use Problem, Disability, or Disorder* 134 27.90% Veteran 28 5.80%
Victims of Domestic Violence** 41 8.50%
*That seriously limits ability to live independently.
*Including experiencing homelessness due to fleeing domestic violence, dating violence, sexual assault, or stalking.

Source: 2024 County of San Bernardino Point in Time Count

In addition, the PIT C also looks at demographic characteristics of the area’s homeless population.

Approximately 64 percent of the City’s surveyed homeless population identifies as male, while nearly 30 percent are White, 26 percent are Black, African American, or African, and 34 percent are Hispanic or Latino. In terms of age, the majority of the City’s unhoused population is aged from 35 to 64.

Table 11: PIT Count Demographics Summary
Number Percent
Gender
Woman (Girl if child) 168 34.90%
Man (Boy if child) 307 63.80%
Transgender 3 0.60%
Non-Binary 1 0.20%
Other Identity 2 0.40%
Total 481 99.90%*
Race/Ethnicity
American Indian, Alaska Native, or Indigenous 15 3.10%
Asian 6 1.30%

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Black, African American, or African 127 26.40%
Middle Eastern or North African 1 0.20%
Native Hawaiian or Pacific Islander 2 0.40%
White 142 29.50%
Multi-Racial/Other 25 5.20%
Hispanic or Latino 163 33.90%
Total 481 100.00%
Age
18-24 14 2.90%
25-34 90 18.70%
35-44 142 29.50%
45-54 112 23.30%
55-64 100 20.80%
65+ 23 4.80%
Total 481 100.00%
*Slight variance due to rounding to the nearest integer.

Source: 2024 County of San Bernardino Point in Time Count Large Households
Large households are defined as households with five or more members. The size and composition of large households vary from family to family and home to home. Typically, these are households with multiple children or mixed-family arrangements, such as households with more than two generations or immediate families cohabiting.

Large households are considered a special needs group because of the limited availability of adequately sized, affordable housing units. To afford shelter in addition to food, clothing, and medical care, very low- and low-income large households may live in overcrowded conditions.

Table 12 compares the number of large households residing in the City in the years 2011 (13,119) and 2021 (14,070). There was relatively equal distribution between large renter households and large owner households, indicating a need for larger units for both renter and owner units.

Table 12: Large Households
2011 2021
# % # %
Total Occupied Housing Units 60,614 100.00% 61,680 100.00% Owner Occupied 31,320 51.67% 30,121 48.83%
Renter Occupied 29,294 48.33% 31,559 51.17%
Owner & Renter Occupied
5 persons 6,576 10.85% 7,508 12.17%
6 persons 3,783 6.24% 3,663 5.94%
7 or more persons 2,760 4.55% 2,899 4.70%

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Owner Occupied
5 persons 3,314 10.58% 4,004 13.29%
6 persons 2,050 6.55% 1,755 5.83%
7 or more persons 1,407 4.49% 1,590 5.28%
Renter Occupied
5 persons 3,262 11.14% 3,504 11.10%
6 persons 1,733 5.92% 1,908 6.05%
7 or more persons 1,353 4.62% 1,309 4.15%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates

Families with Children
Families with children are protected from discrimination under the Fair Housing Act. These households may face discrimination or differential treatment in the housing market , most commonly from landlords who associate the presence of children with potential property damage or noise disturbances. Discrimination may also include charging large households a higher rent or security deposit, limiting the number of children in a complex, limiting what floors or units a family can occupy, limiting the time children can play outdoors, or choosing not to rent to families with children.

According to 2017-2021 ACS data , there were 61,680 total households in the City, of which 46,224 were families. Within the count of families, 23,944 families had children under 18 years old (or 39 percent of the total household population). The County of San Bernardino trends similarly, with 35 percent of the total household population accounting for families with children.

Table 13: Families with Children
Total Households Total Families
Families with Children
Number %
City 61,680 46,224 23,944 39%
County 651,743 497,496 226,581 35%
Source: 2017-2021 ACS 5-Year Estimates
Single-Parent Households
Single-parent families, particularly female -headed families, often require special consideration and assistance due to one-person household versus a two -person household. There is a greater need for affordable housing and accessible daycare, healthcare, and other supportive services. Because of more limited resources, relatively lower income , and higher burden of living expenses, female -headed families have more limited opportunities to find affordable, decent, and safe housing. Female-headed families may a lso be discriminated against in the rental housing market because some landlords are concerned about the ability of these households to make regular rent payments. Consequently, landlords may require more stringent credit checks for women, of fair housing laws.

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Table 14: Single Parent Households
City County
Total Households 60,614 651,743
# of Single Parent Households 10,992 75,690
% of Single Parent Households 18.13% 11.61%
Source: 2017-2021 ACS 5-Year Households

According to 2017 -2021 ACS data, the City comprises 60,614 households, with 10,992 classified as single-parent households, representing approximately 18 percent of all households. Among these, there are 6,521 male-headed households with no spouse present (10.8 percent of all households) and 13,831 female-headed households with no spouse present (22.8 percent of all households ). Of these demographics, 3,003 male householders (no spouse present) live with their children under the age of 18 (27.3 percent of single -parent households), while 7,989 female householders (no spouse present) live with their children under the age of 18 (72.7 percent of single-parent households).

To address a community's fair housing issues , the existing housing market must be analyzed to distinguish local and current conditions. The following sections provide an overview of the local and regional housing market characteristics.

F. Income Profile
Household income does not directly affect fair housing options. However, perceptions about income to household type and size, race/ethnicity, and other characteristics can result in biases that trigger fair housing concerns. The workforce profile included here is important to help establish data-driven goals and priorities for workforce development to increase access to jobs and economic mobility.

Median Income
In 2021, the City of San Bernardino’s median household income (MHI) was $55,372, while the County’s MHI was $70,287. MHI in the City was approximately 27 percent less than in the County.

Income by Race and Ethnicity
Table 15 shows the breakdown of MHI by race and ethnicity in 2011 and 2021. While Native Hawaiians and other Pacific Islanders have the highest median household income of any group, this population group accounts for less than 1 percent of the City’s total population. Asian households have the second highest MHI and account for a pproximately 4 percent of the City’s total population. White households have the third highest MHI of any racial group, at $58,579, a 33 percent increase from 2011. The City’s Hispanic and Latino population, who can be of any racial group, have an MHI of $58,062, a 54 percent increase from 2011. The only racial group that falls below the MHI in the City is Black or African American households, which have an MHI of $36,762.

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Table 15: Median Household Income by Race
2011 2021
Percent Change
Median Income Median Income
White $44,081 $58,579 33%
Black or African American $31,425 $36,762 17%
American Indian or Alaska Native $48,672 $58,229 20% Asian $41,627 $60,990 47%
Native Hawaiian or Other Pacific Islander $76,418 $80,192 5% Some other race $37,194 $59,296 59%
Two or more races $43,537 $54,270 25%
Hispanic or Latino origin (of any race) $37,772 $58,062 54% Median HH Income (City of San
Bernardino) $40,161 $55,372 37%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Household Income
Median household income in the City increased by almost 38 percent between 2011 and 2021, from $40,161 to $55,372. Table 16 provides a breakdown of extremely low, very low -, and low -income households by tenure. These income classifications constitute HUD’s low - to moderate-income (LMI) category, as further explained in the following section. As reflected in Table 16, LMI homeowners have higher incomes than LMI renters. For example, while 23 percent of LMI homeowners are extremely low-income (0-30% AMI), 77 percent of LMI renters are extremel y low-income (0-30% AMI). Overall, there are 11,250 LMI owners and 33,820 LMI renters in the City.

Table 16: Household Income
Owner Renter Total
# % # % #
Extremely Low Income (0%-
30%) 2,500 23% 8,310 77% 10,810
Very Low Income (30%-50%) 3,395 32% 7,135 68% 10,530
Low Income (50%-80%) 5,355 43% 7,125 57% 12,480
Source: 2017-2021 CHAS
Table 17: Median Household Income
2011 2021 % Change
$40,161 $55,372 37.88%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Low to Moderate Income Target Areas
As established by HUD, low-moderate income (LMI) households refer to those whose incomes do not exceed 80 percent of the area median income (AMI). A low-income area is defined as a census tract or block group comprising at least 51 percent of households in the low - and moderate-income ranges.

LMI is set by HUD and adjusted for the total number of people in the household. There are three income levels for LMI households:

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• Extremely low income: Households earning 30% or less than the AMI • Very low income: Households earning between 30% to 50% of the AMI • Low income: Households earning between 50% to 80% of the AMI

Table 18: HUD Median Income Limits for City of San Bernardino, 2024 Median
Family
Income

FY Income
Limit
Category

Number of Persons in Household
1 Person 2 Person 3 Person 4 Person 5 Person 6 Person 7 Person
8 Person
$97,500
Extremely
Low
(0-30%)

$21,550

$24,600

$27,700

$31,200

$36,580

$41,960 $47,340 $52,720
Very Low
(30-50%)

$35,900

$41,000

$46,100

$51,250

$55,350

$59,450 $63,550 $67,650
Low
(50-80%)

$57,400

$65,600

$73,800

$82,000

$88,600

$95,150

$101,650 $108,250
Source: HUD 2024 Income Limits, County of San Bernardino, CA

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Map 4: LMI Areas, City of San Bernardino

G. Housing Profile
This section provides an overview of the City’s housing stock and market, including the conditions and value of current housing units, occupancy trends, and residents' housing problems . Analyzing these conditions allows for informed, data-driven decisions regarding implementing fair housing practices.

Housing Growth
Most housing development across the City occurred in the mid -to-late 20 th century, as reflected in Figure 1. The increase in the City’s housing stock has been minimal in the last two d ecades. Between 2000 and 2021, there was a 3.6 percent increase in housing units. Most of this change occurred between 2000 and 2011, w hile between 2011 and 2021, the City experienced a loss in housing stock of 1.1 percent. A lack of housing unit growth when there is a need leads to increased costs, making access to affordable housing more challenging for LMI households.

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Table 19: Housing Unit Growth
2000 2011 Change from
2000 - 2011 2021 Change from
2011-2021
Change from
2000-2021
63,535 66,575 4.78% 65,842 (1.10%) 3.63%
Source: 2000 U.S. Census, 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Housing Unit Type
The City of San Bernardino’s housing stock comprises single-family homes, which are housing units that house one household or family. Single -family zoning is largely popularized across the country, while multifamily housing, such a s apartment units and condos, tends to face more significant challenges with zoning. Table 20 below shows a distinction between detached and attached single - family homes, with detached being stand -alone and attached sharing an exterior wall with another unit, such as a townhome. According to 2021 ACS data, approximately 63 percent of housing units in the City are single-family homes. The vast majority, 95 percent, are detached homes.

Table 20: Housing Characteristics
2011 2021
Single-Family Units
1-unit, detached 40,659 39,892
1-unit, attached 1,942 1,907
Multifamily Units
2 units 1,559 949
3 to 4 units 4,016 3,803
5 to 9 units 3,520 4,038
10 to 19 units 4,330 2,964
20 or more units 6,067 7,990
Other Units
Mobile home 4,370 4,292
Boat, RV, van, etc. 112 7
Occupied units 60,614 61,680
Vacant Units 5,961 4,162
Persons per Household 3.35 3.4
Total housing units 66,575 65,842
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates

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Housing Unit Conditions
Age is an indication of the quality of the housing stock. Housing over 30 years old will likely require rehabilitation, such as plumbing, roof, or foundation repairs. In addition, older homes tend to be less energy efficient, which increases utility costs.

Figure 1 displays the age of San Bernardino’s housing stock according to the 2017-2021 ACS estimates.

Of all housing units in San Bernardino, less than 10 percent are under 25 years old, built in 2000 or later. In contrast, 66 percent are more than 46 years old.

Figure 1: Housing Stock by Year Built (2017-2021 ACS 5-Year Estimates)

The City’s data differs from the County’s, whereby the County experienced a higher production of housing units from 1970 onwards. The City, on the other hand, built more housing units from 1950 to 1989. The County saw another increase between 2000 and 2009, while housing production in the City continued to slow down.

Table 21: Year Unit Built- City v. County
Year Unit Built City County
Number % Number %
2020 or later 16 0.02% 1,332 0.18%
2010 to 2019 1278 1.99% 35,596 4.93%
2000 to 2009 4,818 7.51% 103,351 14.33%
1990 to 1999 5,673 8.84% 93,666 12.98%
1980 to 1989 11,588 18.06% 162,358 22.51%
1970 to 1979 10,355 16.14% 122,915 17.04%

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1960 to 1969 9,108 14.19% 74,350 10.31%
1950 to 1959 12,387 19.30% 81,094 11.24%
1940 to 1949 5,690 8.87% 28,051 3.89%
1939 or earlier 4,929 7.68% 25,961 3.60%
Total 65,842 728,674
Source: 2017-2021 ACS 5-Year Estimates
Vacancy Rate
Residential mobility is influenced by tenure. Ownership housing is associated with a much lower turnover rate than rental housing. Tenure preferences are primarily related to household income, composition, and age of the householder.

Table 22 demonstrates the City’s vacancy rates in 2011 and 2021 based on ACS data. A healthy vacancy rate is associated with choice and mobility. Generally, a healthy vacancy rate for owner -occupied housing is 2 to 3 percent vacancy. For rental units, a healthy rate is 5 to 6 percent vacancy.

In 2011, the vacancy rate for owner -occupied housing was 0. 8 percent above range , at 3.8 percent, and in 2021 it was lower by 1.4 percent, at 1.6 percent. In 2011, the renter-occupied rate was above the healthy range by 1.3 percent, at 7.3 percent. By 2021, the rental vacancy was below the healthy range by 2.7 percent.

Table 22: Vacant Units and Vacancy Rates
Tenure 2011 2021
Homeowner Vacancy Rate 3.8% 1.6%
Renter Vacancy Rate 7.3% 2.3%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Lead-Based Paint Hazard
Lead-based paints (LBP) were popularized in the early twentieth century for their durability, appearance, and shorter drying time. Homes, public buildings, and household items such as children’s toys and cribs were coated with LBP. According to the U.S. Environmental Protection Agency (EPA):
“This paint could be on window frames, walls, the outside of your house, or other surfaces. Tiny pieces of peeling or chipping paint are dangerous if eaten. Lead -based paint in good condition is not usually a problem except in places where painted surfaces rub against each other and create dust. (For example, when you open a window, the painted surfaces rub against each other).”
Ingesting chipped paint or paint dust is harmful to both adults and children. For example, toddlers routinely put their hands and sometimes feet in their mouths and can accidentally ingest LBP. Objects may be coated with LBP dust as well and may be placed in the mouths of young children.

The Lead-Based Paint Poisoning Prevention Act of 1971 banned LBP for use in public housing. However, LBP continued to be used in commercial and private residential developments until 1978 when the federal government passed more comprehensive legislation to ban its use in residential housing .

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According to ACS data, approximately 66 percent of the City’s current housing stock was built prior to 1978.

According to the American Healthy Homes Survey conducted from June 2005 through March 2006 and published in 2011 by HUD’s Office of Healthy Homes and Lead Hazard Control, 37.1 million homes in the U.S. have LBP somewhere in the unit. Of those 37.1 million or 35 percent of the country’s housing stock, approximately 23.2 million or 22 percent of all homes contain one or more LBP hazards.

The County of San Bernardino operates a Childhood Lead Poisoning Prevention Program (CLPPP) , providing community education to increase awareness on the potential risks and dangers of lead exposure, home environmental screenings, public health nurse care management, and monitors child health providers to ensure lead testing occurs for high-risk children.

Housing Tenure
Housing tenure refers to whether a household owns or rents the housing unit that it occupies. The U.S.

Census specifically distinguishes between two categories: owner -occupied and renter occupied .

Owner-occupied housing units are owned by the occupants, while renter -occupied housing units are rented from another party, typically known as a landlord.

Whether a household owns or rents their unit depends on a variety of factors, including age of the head of the householder, household size, and household income, among others. To properly accommodate the housing needs of all its residents, it is important that a Ci ty has both rental and ownership units in its housing stock. When thinking about the differences in types of stock, while existing homeowners may experience more issues with the personal responsibilities associated with maintaining property, renters may face more violations of fair housing laws.

According to 2021 ACS data, housing units in San Bernardino are divided almost equally between owner- and renter-occupied, with only a 2.3 percent difference. The majority of residents, by a slim margin, are renters rather than homeowners.

Table 23: Household Tenure – Owner v. Renter
Number Percent
Owner-Occupied 30,121 48.83%
Renter-Occupied 31,559 51.17%
Total Households 61,680 100%
Source: 2017-2021 ACS 5-Year Estimates
As shown in Table 24 below, 4,162 housing units in the City are vacan t, a 30 percent decrease from 2011. In addition, during 2011 there were more owner -occupied households than renter -occupied households, by approximately three percent. While the difference between the number of San Bernardino renters and owners has fluctuated throughout the years, it has remained divided very closely.

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Table 24: Housing Unit Tenure Comparison
Tenure Type 2011 2021
# of Units Percent # of Units Percent
Owner-Occupied 31,320 47.04% 30,121 45.75%
Renter-Occupied 29,294 44.00% 31,559 47.93%
Vacant 5,961 8.95% 4,162 6.32%
Total Housing Units 66,575 - 65,842 -
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates The City’s housing stock is mostly comprised of two-to-three-bedroom units, making up approximately 66 percent of all occupied housing units. According to ACS data, San Bernardino homeowners are typically more likely to live in larger units (four or more bedrooms) as well, with 27 percent of owners and only seven percent of renters occupying large units. While this disparity could indicate a lack of need for large rental units, it may also indicate a lack of availability, resulting in overcrowding. As shown in Table 36, 18 percent of renters and nine percent of owners in the City are experiencing overcrowding issues.

Table 25: Unit Size by Tenure
Rooms Owners Renters
Number % Number %
No bedroom 290 0.96% 1,248 3.95%
1 bedroom 385 1.28% 8,217 26.04%
2 or 3 bedrooms 21,220 70.45% 19,796 62.73%
4 or more bedrooms 8,226 27.31% 2,298 7.28%
Total 30,121 - 31,559 -
Source: 2017-2021 ACS 5-Year Estimates
Housing Costs and Affordability
The cost of housing relative to income is one of the most important factors in evaluating a community’s housing market. If housing costs are relatively high in comparison to household income, housing cost burdens and overcrowding tends to occur. However, housing affordability alone is not necessarily a fair housing issue. Such concern arises when housing affordability is coupled with factors protected under fair housing laws, such as household type, composition, a nd race/ethnicity. Table 26, below, displays the maximum affordable rental and mortgage costs based on HUD income limits for the County of San Bernardino, while Table 27 shows actual housing costs expended by City residents.

Table 26: Affordability Rent and Mortgage Combined
1 Person 2 Persons 3 Persons 4 Persons
Extremely Low (0%-30%)
Annual Income $21,550 $24,600 $27,700 $31,200
Monthly Income $1,795.83 $2,050 $2,308.33 $2,600
Affordable Purchase Price* $58,146 $69,948 $81,944 $95,487 Maximum Affordable Rent** $538.75 $615 $692.50 $780
Very Low (30%-50%)

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Annual Income $35,900 $41,000 $46,100 $51,250
Monthly Income $2,991.67 $3,416.67 $3,841.67 $4,270.83
Affordable Purchase Price* $108,540 $127,312 $144,009 $162,748 Maximum Affordable Rent** $897.50 $1,025 $1,152.50 $1,281.25 Low (50%-80%)
Annual Income $57,400 $65,600 $73,800 $82,000
Monthly Income $4,783.33 $5,466.67 $6,150 $6,833.33
Affordable Purchase Price* $185,126 $211,333 $240,666 $269,999 Maximum Affordable Rent** $1,435 $1,640 $1,845 $2,050
Moderate (80%-120%)
Annual Income $81,900 $93,600 $105,300 $117,000
Monthly Income $6,825 $7,800 $8,775 $9,750
Affordable Purchase Price $269,642 $311,495 $353,349 $386,748 Maximum Affordable Rent** $2,047.50 $2,340 $2,632.50 $2,925 *Affordable Purchase Price assumes a down payment of $20,000, an approved credit score, $250 monthly debt payments, a 1.32% property tax rate, a $945 annual home insurance payment, and a 30-year mortgage. Pricing from Affordability Calculator - How Much House Can I Afford? | Zillow.
**Maximum Affordable Rent refers to a monthly payment that is 30% of monthly income. Any amount over this number is cost - burdened and any amount less than this number is affordable.

Source: 2024 HUD Income Limits for San Bernardino County

Table 27: Changes in Value, Rent, and Income
2011 2021 % Change
Median Housing Value $202,400 $293,000 44.76%
Median Contract Rent $823 $1,058 28.55%
Median Household Income $40,161 $55,372 37.88%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Homeowner Costs
Table 28, below, compares median home purchase prices in the City between 2019 and 2021. The City’s housing market experienced an average median sales price increase of almost 46 percent. The median sales price of single -family homes increased by 47 percent, while the median sales price of condominiums (condos) increased by approximately 29 percent. The COVID-19 pandemic resulted in increased housing costs across much of the nation and state.

Table 28: Housing Sale Prices (2019 and 2021)

2019 2021 % Change
Units Sold Median Sales
Price (Dec) Units Sold Median Sales
Price (Dec) Units Sold Median Sales
Price (Dec)
SF Homes 110 $312,500 146 $460,000 32.73% 47.20%
Condos/Co-ops 14 $164,000 14 $212,000 0.00% 29.27%
Total/Average 128 $300,000 170 $437,500 32.81% 45.83% Source: Redfin Market Trends for San Bernardino, CA: San Bernardino Housing Market: House Prices & Trends | Redfin

Renter Costs
Overall, the average rental price in the City of San Bernardino is more affordable than that of the State of California. The affordability gap for a three-bedroom unit is $1,055 compared to the State average,

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and $852 for a two-bedroom unit. According to Zillow Rental Manager, rent in San Bernardino is 78 percent lower than overall in the State of California while median rent is $50 less than the national average.

Table 29: Average Rental Housing Prices
Studio 1-Bedroom 2-Bedroom 3-Bedroom 4+ Bedroom
City $1,400 $1,500 $1,943 $2,595 $2,167
State $1,800 $2,150 $2,795 $3,650 $9,766
Source: Zillow Rental Manager: Rent Comparison Tool & Rental Market Trends Data | Zillow Rental Manager

An alternative approach to analyzing prices is to examine HUD Fair Market Rents (FMRs), which are set at the 40th percentile of available housing in a community for rent and utilities. As shown in Table 30, FMRs for San Bernardino County increased for all unit sizes from 2020 to 2022 to 2024.

Table 30: San Bernardino County Fair Market Rents by Unit Bedrooms Year Efficiency One-Bedroom Two-Bedroom Three-Bedroom Four-Bedroom FY 2020 FMR $875 $1,030 $1,289 $1,789 $2,216
FY 2022 FMR $1,062 $1,202 $1,509 $2,065 $2,542
FY 2024 FMR $1,517 $1,611 $2,010 $2,707 $3,304
Source: HUD FY 2020, 2022 and 2024 Fair Market Rent Documentation System, San Bernardino County, CA Table 31 below shows available, affordable rental housing units throughout the City in 2011 and 2021, respectively. In 2011, approximately 60 percent of housing units for rent were priced at $999 or less.

In 2021, that number decreased to 30 percent of total units.

Table 31: Affordable Rental Housing Units in City
2011 2021
Number Percent Number Percent
Less than $500 2,819 9.93% 1,769 5.75%
$500-$999 14,177 49.96% 7,536 24.51%
$1,000 or more 11,379 40.10% 21,439 69.73%
Total 28,375 100% 30,744 100%
Source: 2007-2011 ACS 5-Year Estimates, 2017-2021 ACS 5-Year Estimates Housing Problems
Cost Burden
Households allocating 30 percent or more of their income toward housing are considered cost burdened. A cost burden ranging from 30 to 50 percent is considered moderate, while housing expenses exceeding 50 percent of income indicate a severe cost burden. This issue is particularly significant as excessive housing costs reduce the financial resources available for essential needs such as food, daily living expenses, and emergencies.

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Upper-income households generally can spend a larger proportion of their income on housing.

Therefore, estimates of the housing cost burden tend to focus on low —and moderate -income households. As Table 32 shows, the City’s low-income households are primarily renters.

Source: 2017-2021 Comprehensive Housing Affordability Strategy (CHAS) As shown in Table 33 below, renters in the City faced far higher rates of cost burden as compared to owners. The majority of cost -burdened are expending between 30 to 50 percent of their income on housing, however, 2,715 owner households are severely cost-burdened as well, expending 50 percent or more of their income on housing. As shown in Figure 2, a further breakdown of the income of residents experiencing cost burden shows that severe cost burden is most prevalent for the City’s extremely low-income residents.

Table 33: Housing Cost Burden Overview
Cost Burden Factor Owner Renter Total
# % # %
Cost Burden <=30% 21,895 62.08% 13,375 37.92% 35,270
Cost Burden >30% to <=50% 5,370 39.33% 8,285 60.67% 13,655 Cost Burden > 50% 2,715 22.25% 9,485 77.75% 12,200
Source: 2017-2021 Comprehensive Housing Affordability Strategy (CHAS)

Figure 2: Income by Cost Burden: Owners and Renters (2017-2021 CHAS)

Examining the differences between LMI owners experiencing cost burden and LMI renters experiencing cost burden can provide a better picture of which groups may be experiencing more cost Table 32: Income Distribution Overview
Owner Rental Total # % # %
Extremely Low Income (0%-30%) 2,500 23.12% 8,310 76.68% 10,810 Very Low Income (30%-50%) 3,395 32.24% 7,135 67.75% 10,530 Low Income (50%-80%) 5,355 41.70% 7,125 57.09% 12,480

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burden than others. Tables 34 and 35 show a cost burden breakdown by tenure and income. 52 percent of LMI homeowners in the City are experiencing some level of cost burden. Severe cost burden (>50%) for homeowners is more concentrated in very- and extremely low-income households, totaling 910 and 1,160 households, respectively. In all, 19 percent of all homeowner households in the City are experiencing cost burden to some degree.

Table 34: Income by Cost Burden - OWNERS
Cost Burden Factor Cost Burden > 30-50% Cost Burden > 50% Total # % # %
Extremely Low Income (0% - 30%) 395 25.40% 1,160 74.60% 1,555 Very Low Income (30%-50%) 1,005 52.48% 910 47.52% 1,915 Low Income (50%-80%) 1,860 77.50% 540 22.50% 2,400
All LMI Owner Households
Total Households 11,250 % Cost
Burdened 52.17%
Source: 2017-2021 Comprehensive Housing Affordability Strategy (CHAS)

By comparison, 53 percent of all renter households in the City are experiencing cost burden to some degree. Of all LMI renter households, 75 percent are cost burdened. Most severely cost -burdened (>50%) renters are extremely low-income (0-30% AMI), totaling 6,365 households.

Table 35: Income by Cost Burden - RENTERS
Cost Burden Factor Cost Burden > 30-50% Cost Burden > 50% Total # % # %
Extremely Low Income (0% - 30%) 610 8.75% 6,365 91.25% 6,975 Very Low Income (30%-50%) 3,375 54.57% 2,810 45.43% 6,185 Low Income (50%-80%) 3,535 92.66% 280 7.34% 3,815
All LMI Renter Households
Total Households 22,570 % Cost
Burdened 75.21%
Source: 2017-2021 Comprehensive Housing Affordability Strategy (CHAS) Overcrowding
Overcrowding occurs when a housing unit has more than one person per room. Severe overcrowding is defined as more than 1.5 persons per room. This analysis of persons per room includes bedrooms, living rooms, and dining rooms but excludes bathrooms, porches , foyers, halls, or half-rooms. Ideally, each individual household member would have their own room, though small children and married couples are the exception. At times, overcrowding may occur due to a lack of affordable units that fit a family’s size or affordability issues , causing more than two generations from one family to live together. Research from the National Institute of Health shows that overcrowding and a lack of quiet space is also associated with poor school performance in children . Additional research from HUD has corroborated this finding.

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Table 36 below shows that approximately nine percent of owner -occupied housing units and 18 percent of renter -occupied units in San Bernardino are considered overcrowded or severely overcrowded. Most overcrowding is moderate rather than severe, with 1.01 to 1.50 occupants per room.

Table 36: Overcrowding
Household Tenure
Owner-Occupied Renter-Occupied
Occupied Units 30,121 31,559
Overcrowded* 2,148 3,775
Severely Overcrowded** 537 1,956
Percent Overcrowded 8.91% 18.16%
*Overcrowding is defined as 1.01 to 1.50 occupants per room. **Severely overcrowded is defined as 1.51 or more occupants per room.

Source: 2017-2021 ACS 5-Year Estimates
Substandard Housing
According to HUD, substandard housing refers to a dwelling unit that is either dilapidated or unsafe, thus endangering the health and safety of the occupant, or that does not have adequate plumbing or heating facilities.

There are four types of substandard housing problems:

1. Households lacking complete kitchen facilities.

2. Households lacking complete plumbing facilities.

3. Overcrowded households (more than one person per room).

4. Cost burdened households (spending 30 percent of household income or more on housing cost).

According to 2017-2021 CHAS data, 19,630 renter households earning between 0 and 100 percent AMI experienced substandard housing through at least one of four housing problems, while 7,755 owner households did. Overall, significantly more renter households experience substandard housing issues than households who own the unit they reside in.

Table 37: Housing Problems Overview
Substandard Housing:

At Least 1 of 4 Housing Problems
Renter Households
0-30% AMI 7,150
>30-50% AMI 6,435
>50-80% AMI 5,030
>80-100% AMI 1,015
Total Renter Households 19,630
Owner Households

2025 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 41 of 77

0-30% AMI 1,600
>30-50% AMI 2,180
>50-80% AMI 2,780
>80-100% AMI 1,195
Total Owner Households 7,755
Renter and Owner Households
0-30% AMI 8,750
>30-50% AMI 8,615
>50-80% AMI 7,810
>80-100% AMI 2,210
Total Renter and Owner Households 27,385
Source: 2017-2021 Comprehensive Housing Affordability Strategy (CHAS) Housing Vouchers
The City of San Bernardino works with the County of San Bernardino Housing Authority (HACSB) to administer Housing Choice Vouchers (HCVs), also known as Section 8 , along with a myriad of other housing voucher types. As shown in Table 38, there are currently 112,846 County residents on the waiting list for a n HCV and 2,019 total HCVs in use in the City. Most HCV holders, nearly 75 percent, are extremely low-income (0-30% AMI).

The HACSB administers additional housing vouchers currently in use in the City, including Family Unification (30), VASH (123), Emergency (139), HOPWA (33), Mainstream (67), and Continuum of Care vouchers (85).

Table 38: Housing Choice Vouchers
#
Number of Families on Waiting List (County) 112,846
Total HCVs (City) 2,019
Income
Extremely Low Income (0-30% AMI) 1,505
Very Low Income (31-50% AMI) 372
Low Income (51-80% AMI) 129
Types of Families
Families with Children 833
Elderly Families 716
Families with Disabilities 851
Race/Ethnicity
White 796
Black or African American 1,056
Asian 74
American Indian/Alaska Native 40
Hispanic or Latino 690
Native Hawaiian or Other Pacific Islander 12

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Other 41
Source: Housing Authority of the County of San Bernardino Public Housing
The Housing Authority of the County of San Bernardino (HACSB) serves the city. HACSB has one public housing site, a single -family unit in Apple Valley. HACSB converted a 98 -unit public housing site in Upland into a project -based voucher site . There are no public housing units in the City of San Bernardino.

Assisted Rental Housing
The City of San Bernardino has a significant amount of housing stock that receives public subsidies in return for lo ng-term covenants guaranteeing the affordability of units. As shown in Table 39 below, the City currently has 3,804 affordable units receiving public subsidies, with 707 at risk of expiring. 38 percent of these units are limited to senior residents.

Table 39: Assisted Rental Housing Projects
Development Name Target
Residents
Project
Financing Total Units Affordable
Units
Earliest
Expiration At Risk Status
Sterling Village Large Family LIHTC 80 79 2036 Not At-Risk Magnolia at Highland Senior LIHTC 80 79 2041 Not At-Risk Lugo Apartments Senior LIHTC 119 118 2044 Not At-Risk
Vintage at Kendall Senior LIHTC 178 176 2043 Not At-Risk Arrowhead Vista Senior LIHTC 40 39 2069 Not At-Risk
New Zion Manor Family LIHTC 125 125 2071 Not At-Risk
Beautiful Light Inn Seniors LIHTC 100 99 2072 Not At-Risk Pioneer Park Plaza All Ages LIHTC 161 159 2073 Not At-Risk Foothill Villas Large Family LIHTC 239 237 2075 Not At-Risk Baseline Coop Senior 202/811 75 74 Permanent Not At-Risk St. Bernardine Plaza Senior 202/811 150 148 2037 Not At Risk TELACU Monte Vista Senior 202/811 75 74 2057 Not At-Risk TELACU San Bern. V Senior 202/811 75 74 2065 Not At-Risk TELACU Buena Vista Senior 202/811 75 74 2058 Not At-Risk TELACU Sierra Vista Senior 202/811 75 74 2057 Not At-Risk TELACU La Amistad Senior 202/811 89 89 2064 Not At-Risk TELACU Hacienda Senior 202/811 75 74 2064 Not At-Risk
AHEPA 3002 Senior 202/811 90 90 2047 Not At-Risk
Meadowbrook Park Family HAP/HOME 267 210 2033 Not At-Risk Creekside Apartments Family Bonds 304 60 2049 Not At Risk All Star Lodge PSH HOMEKEY 75 75 N/A Not At Risk
Valencia Vista Large Family LIHTC 76 75 2068 Not At-Risk Olive Meadow Large Family LIHTC 62 42 2073 Not At Risk
Crestview Terrace Large Family LIHTC 184 182 2076 Not At Risk Tuscany/Silverwood Family Bond 328 66 2057 Not At Risk
Eastpointe Village Family RDA/NSP 52 52 2046 Not At-Risk

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Phoenix Apartments Transitional CalHFA 9 9 2033 Not At-Risk Golden Apartments PSH HOME 39 38 2057 Not At-Risk
San Bernardino Senior Senior 202/811 80 79 2042 Not At-Risk Pacific Village All Ages HCD -- -- 2033 Not At-Risk
Village Green All Ages LIHTC/HAP 184 181 2042 Not At-Risk Maplewood Home Family PBV 296 296 2026 Low Risk
Arrowhead Woods Senior PBV 51 51 2027 Low Risk
Kendall Drive Apts. Family PBV 37 6 2025 Low Risk
Kendall Park Apts. Family PBV 52 4 2025 Low Risk
Frazee Family HOME 14 13 2029 Low Risk
7 Arrows Family HOME 9 9 2029 Low Risk
Ramona Sr. Project Senior LIHTC/MRB 44 43 2024 High Risk The Waterman Large Family LIHTC 128 127 2030 High Risk
Autumnwood/Millcre. All Ages LIHTC 160 158 2030 High Risk Subtotal by Type Total Units Affordable
Units At-Risk Units Percent
Senior Projects 1,542 1,448 94 6%
Family/All Ages Projects 2,514 2,155 613 24%
Permanent Supportive Housing 123 122 0 0%
Total (All Affordable Units) 4,179 3,804 707 16%
Source: 2021-2029 Housing Element, City of San Bernardino H. Access to Opportunities
Public Transit
The City and surrounding County are served by the San Bernardino County Transportation Authority (SBCTA). SBCTA distributes many of the funds for public transit service in the area and oversees all transit services throughout the County. An extensive public transit system currently serves the County with a connection point at the San Bernardino Transit Center in the City. The SBCTA funds various bus operators in the area as well as rail and rideshare services. Current systems from the Transit Center include:

• Metrolink: Rail service to Los Angeles and Oceanside
• Arrow: Rail service to Redlands and San Bernardino
• Omnitrans: 12 bus routes to destinations throughout San Bernardino County and to Riverside County
• sbX: Omnitrans’ high frequency express service to California State University San Bernardino and Loma Linda Medical Center
• Victor Valley Transit Authority (VVTS): Bus service to Victorville and Barstow • Mountain Transit: Bus service to Crestline and Big Bear • Sunline Transit: 10 commuter link services to Indio
• Riverside Transit Agency (RTA): Route 200 to Riverside and Disneyland • Beaumont Transit: Route 120 to Beaumont and Cabazon

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Below is a general map of the connecting rail and bus services that operate from the San Bernardino Transit Center. For a more detailed map, please visit the SBCTA webpage or go to:
https://www.gosbcta.com/wp-content/uploads/2023/09/regional-system-map-1.pdf

Map 5: San Bernardino Transit Center Regional Connections (SBCTA)

Employment
Employment status throughout the City is reflected in Table 40 below. The total number of employed residents was 90,210, or about 55 percent of the total population. The number of unemployed residents within the City’s labor force was 8,313 or 5 percent. 40 percent of the City’s population is not in the labor force. In comparison, 4.5 percent of the County’s labor force was unemployed during the same period.

Table 40: Employment Status
# %
Employed 90,210 54.5%
Unemployed 8,313 5.0%

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Industry and Job Type
Table 41 summarizes the City’s workforce by
industry. In all, three industries comprise almost
48 percent of the total workforce. These include
(1) educational services, health care and social assistance (18.92%), (2) transportation, warehousing, and utilities (14.66%), and (3) retail trade (14.08%) . Employees in the information industry had the highest median earning s at $53,036 followed by construction at $43,895 and public administration closely following at $43,194. The lowest earning industry category is arts, entertainment, recreation, accommodation, and food services, with median earnings projected at $18,784.

Table 41: Workforce by Industry
# of Total
Industry % Share Median Earnings
Agriculture, forestry, fishing and hunting, and
mining 547 0.63% $27,179
Construction 8,495 9.78% $43,895
Manufacturing 7,012 8.07% $35,337
Wholesale trade 2,934 3.38% $37,122
Retail trade 12,225 14.08% $25,617
Transportation and warehousing, and utilities 12,726 14.66% $32,136 Information 695 0.80% $53,036
Finance and insurance, and real estate and rental
and leasing 3,148 3.63% $43,285
Professional, scientific, and management, and
administrative and waste management services 8,610 9.92% $30,742 Educational services, health care and social
assistance 16,433 18.92% $35,813
Arts, entertainment, recreation, and
accommodation and food services 8,483 9.77% $18,784
Other services, except public administration 4,043 4.66% $25,542 Public administration 4,859 5.60% $43,194
Total Employed Workforce 90,210 - -
Source: 2017-2021 ACS 5-Year Estimates
Public Schools
The City of San Bernardino’s public schools are served and operated by the San Bernardino City Unified School District ( SBCUSD). SBCUSD services 73 schools , including 50 elementary schools, 11 middle schools, 10 high schools, a preschool, an adult education center , and a virtual academy . Schools are widespread and located in various areas throughout the City. In 202 3, SBCUSD had a student enrollment of nearly 46,000, 90 percent of whom are socioeconomically disadvantaged.

Not in labor force 66,486 40.2%
Source: 2017-2021 ACS 5-Year Estimates

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Chapter 4: Lending Practices
Lending practices are a contributing factor to fair housing choice. Loan applicants are at risk of discrimination, predatory lending, and unethical steering. Equity in money lending from financial service organizations is an important element of fair housing choice. Such organizations include credit unions, banks, credit card companies, and insurance companies. Lending is often required to access credit financing for mortgages, home equity, and home repair loans. Access to information regarding financial services is also a concern involving equality.

Gaps in financial services can make residents vulnerable to predatory lending practices, and lack of access to quality banking and financial services may jeopardize an individual’s credit and the overall sustainability of homeownership and wealth accumulat ion. Information regarding lending from financial services is a concern that falls under the umbrella of the Fair Housing Act, as potential discrimination is possible.

This chapter reviews lending practices of financial institutions and financing allowed to all households but emphasizes lending to minority and low-income households. However, a jurisdiction’s control over lending is limited due to federal laws and regulations.

A. Laws Governing Lending
Historically, financial institution lending practices, including credit market distortions and redlining, prevented minority groups from equal access to credit . These barriers contributed to segregated neighborhoods that persist in cities today.

Below are laws governing lending practices that aim to safeguard consumers, promote local economies, prevent housing discrimination, and address fair housing violations. Furthermore, banks receive ratings based on their performance , which the Federal Financial Institutions Examination Council (FFIEC) makes available to the public . This report includes the results of the city's top -rated banks.

Fair Housing Act
The passage of the Fair Housing Act ( FHA) in 1968 sought to end discrimination against protected classes in all aspects of residential real estate related transactions, including mortgage lending. Under the FHA, a lender may not discriminate against a protected class in any aspect of mortgage lending, such as failure to provide information or services, selectively encourag ing or discouraging applicants, varying the terms of credit offered, or refusing to extend credit. Further, the FHA requires lenders to make reasonable accommodations for people with disabilities when such accommodations are necessary to offer equal opportunities to apply for credit.

Equal Credit Opportunity Act
The Equal Credit Opportunity Act (ECOA) was enacted in 1974 and makes it unlawful for a creditor to discriminate against an applicant on the basis of race, color, religion, national origin, sex, marital status, age, because an applicant receives income from a public assistance program, or becau se an applicant has in good faith exercised any right under the Consumer Credit Protection Act. Creditors are also required to notify applicants of action taken on their applications; to report credit history in the names of both spouses on an account; to retain records of credit applications; to collect information about

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the applicant's race and other personal characteristics in applications for certain dwelling -related loans; and to provide applicants with copies of appraisal reports used in connection with credit transactions.

Home Mortgage Disclosure Act
The Home Mortgage Disclosure Act (HMDA) was enacted by Congress in 1975 and was implemented by the Federal Reserve Board’s Regulation C. On July 21, 2011, the rule-writing authority of Regulation C was transferred to the Consumer Financial Protection Bureau (CFPB). HMDA mandates that financial institutions maintain, report, and publicly disclose loan -level information about mortgages. This data serves to assess whether lenders are meeting the housing needs of their communities, reveal lending patterns that may be d iscriminatory, and provide public officials with decision -making insights. To safeguard applicant and borrower privacy, the public data undergo modifications.

Community Reinvestment Act
The passage of the Community Reinvestment Ac t (CRA) in 1977 was designed to improve access to credit for all members of the community, including very low - and low -income persons and neighborhoods. In particular, the CRA counteracted redlining, the historical practice by which banks and other financial inst itutions would not provide loans to lower -income neighborhoods which contributed to the racial wealth gap . Under the CRA, federal regulators assess the performance of banks and other financial institutions in addressing the needs of all community members and neighborhoods. Banks and financial institutions are given a score of Outstanding, Satisfactory, Needs Improvement, or Substantially Noncompliant, which are published publicly.

On October 24, 2023, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) jointly issued a final rule aimed at enhancing and modernizing the regulations governing the implementation of the CRA to fulfill the law’s objectives more effectively. Key objectives of the final rule include:

• Strengthen the achievement of the core purpose of the statute. • Adapt to changes in the banking industry, including the expanded role of mobile and online banking.
• Provide greater clarity and consistency in the application of the regulations. • Tailor performance standards in the application of the regulations. • Tailor data collection and reporting requirements and use existing data whenever possible. • Promote transparency and public engagement.
• Confirm that CRA and fair lending responsibilities are mutually reinforcing. • Promote a consistent regulatory approach that applies to banks regulated by all three agencies.

Banking Regulators for the Federal Reserve
Banks with CRA obligations are supervised by three banking regulators (Federal Reserve Board - Federal Banking Regulators for the CRA ), each of which maintains a dedicated CRA site that provides information about the banks they oversee and their CRA ratings and Performance Evaluations.

Regulators are as follows:

• Federal Deposit Insurance Corporation (FDIC)
• Federal Reserve Board (FRB)

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• Office of the Comptroller of the Currency (OCC)

Federal Reserve’s Role
The Federal Reserve supervises state member banks or state -chartered banks that have applied for and been accepted to be part of the Federal Reserve System for CRA compliance. When doing so, the Federal Reserve considers violations of the Fair Housing Act, the Equal Credit Opportunity Act, other fair lending laws, and other illegal credit practices. To carry out its role, the Federal Reserve must:

• Assess the performance of state member banks under the CRA. • Consider CRA performance alongside other supervisory data when evaluating applications for mergers, acquisitions, and branch openings.
• Disseminate information about community development techniques to both bankers and the public.

Below are the CRA ratings of banks for the City of San Bernardino. An institution’s CRA rating is assigned using a four -tiered rating system : Outstanding, Satisfactory, Needs to Improve, and Substantial Noncompliance.

Figure 4: CRA Ratings for the City of San Bernardino (FFIEC)

B. Types of Loans
Conventional financing comprises market-rate-priced loans from private lending institutions such as banks, mortgage companies, and savings and loans. To support low and moderate-income households facing challenges in securing home mortgage financing from the private market, various government agencies provide loan products with below-market interest rates insured or “backed” by the agencies.

Table 42 below summarizes the disposition of home loan applicants submitted to financial institutions in 2022 in the City of San Bernardino. Most applications, approximately 72 percent, were for conventional loans, while the remainder fell under the umbrella of the various government -backed loan types. Both conventional and government -backed loans are discussed in more detail in the remainder of this section.

Table 42: Loan Type
Loan Type # of Applicants % of Applicants
Conventional 9,353 71.71%
FHA 3,022 23.17%
VA 664 5.09%
FSA/RHS 4 0.03%
Total 13,043 100.00%
Source: Federal Financial Institutions Examination Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Data Browser, 2022

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Government Backed Loans
Many approved loans are government-backed. These encompass various types, such as those offered by the Federal Housing Administration (FHA), the U.S. Department of Veterans Affairs (VA), and the U.S. Department of Agriculture (USDA).

Government-backed loans generally have more lenient credit score requirements and lower down payment requirements and are available to those with recent bankruptcies. However, these loans may also carry higher interest rates and require most homebuyers to purchase mortgage insurance.

Furthermore, government-backed loans have strict limits on the amount the homebuyer can borrow to purchase the home.

Federal Housing Administration (FHA)
FHA loans have helped people become homeowners since 1934. The F HA is part of HUD, insures the loan so that lenders can offer borrowers a better deal. FHA loans are specifically designed to assist low- to moderate-income families in achieving homeownership, making them particularly popular amongst first-time homebuyers. Advantages of FHA loans include:

• Low down payments
• Low closing costs
• Easy credit qualifying

Veterans Affairs (VA) Home Loans
The U.S. Department of Veterans Affairs (VA) guarantees loans to American veterans, military members currently serving in the U.S. military, reservists, and select surviving spouses (provided they do not remarry). Unli ke conventional loans, VA home loans do not typically require a downpayment and have competitive interest rates, making them one of the most significant benefits available to eligible veterans and making homeownership more accessible. VA loans also do not require private mortgage insurance.

Types of VA loans include:

• Purchase Loan: For buying a home, offering better terms than private-lender loans. • Native American Direct Loan (NADL) Program: Assists Native American veterans or veterans married to Native Americans in buying, building, or improving homes on federal trust land. • Interest Rate Reduction Refinance Loan (IRRRL): Helps existing VA-backed home loan holders reduce monthly payments or stabilize payments.
• Cash-Out Refinance Loan: Enables veterans to take cash out of home equity for various needs such as paying off debt or funding education.

Rural Housing Service/Farm Service Agency (RHS/FSA)
The Rural Housing Service (RHS) is an agency of the U.S. Department of Agriculture (USDA) that offers various programs to enhance housing and essential community facilities in eligible rural areas. RH S offers loans, grant s, and loan guarantees for both single and multifamily housing. Furthermore, RH S partners with nonprofit organizations, Native American tribes, state and federal government agencies, and local communities to provide technical assistance for loans and grants. The Farm Service Agency

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(FSA) is also backed by the USDA and offers loans to assist farmers and ranchers with obtaining financing needed to start, expand, or maintain family farms.

Conventional Loans
A conventional loan is a mortgage that is not sponsored by the government but is available through a private lender. Conventional loans are the most common type of mortgage loans, issued by private lenders such as banks, credit unions, and other financial institutions. The most common conventional loans are as follows:

• Conventional conforming loans are mortgages that meet the standards and limits set by Fannie Mae and Freddie Mac, the government-sponsored enterprises that buy and sell mortgages. • Jumbo loans enable borrowers to exceed the maximum lending limit for conforming loans.

However, they usually necessitate a higher credit score, a lower debt-to-income ratio (DTI), and a larger down payment.
• Portfolio loans are conventional loans that a lender retains in its own portfolio instead of selling it on the secondary market. This approach provides the lender with greater flexibility compared to the standards set by Fannie Mae and Freddie Mac, particularly regarding credit scores and debt-to-income ratios (DTIs).
• Subprime loan is a high-interest loan for borrowers with low credit ratings or other risk factors • Amortized conventional loans provide homebuyers with a consistent monthly payment throughout the entire loan repayment period, without any balloon payments. These loans can feature either fixed or adjustable mortgage rates.
• Adjustable-rate loans (ARM) are a type of home loan where the interest rate can vary periodically, typically based on the performance of a specific benchmark. ARMs are also referred to as variable rate or floating mortgages.

It is important to look at loan and mortgage lending in a community to see how available loans are and at what types of terms and rates. Research based on HMDA data reveals that commercial banks and thrift institutions tend to lend less to low -income neighborhoods and areas predominantly inhabited by minorities. This is often a legacy issue based on the discriminatory practice known as redlining. The term “redlining” was coined by a sociologist named John McKnight in the 1960s. The term comes from the practice, used by both the federal government and private lenders, of drawing a red line on maps to show neighborhoods they would not invest in through lending based solely on demographic data .

This practice threatens fair housing choice and can contribute to widening the ever -growing racial wealth gap in America.

C. Home Mortgage Disclosure Act and Data Analysis
The Home Mortgage Disclosure Act (HMDA) was enacted by Congress in 1975 and is implemented by the Consumer Financial Protection Bureau under Regulation C (12 CFR Section 1003). This regulation provides the public loan data that can be used to assist:

• In determining whether financial institutions are serving the housing needs of their communities.
• Public officials in distributing public -sector investments to attract private investment to areas where it is needed.

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• In identifying possible discrimination lending patterns.

Loan Applications
Under the HMDA, lenders are required to disclose information on the disposition of home loan applications and on race, national origin, gender, and annual income of loan applicants. As shown in Table 42 above, 7 2 percent of 2022 applications in the City were for conventional loans, 2 3 percent were for FHA, five percent were for VA, and less than one percent were for FSA/RHS loans.

Refinancing
Refinancing is the process of replacing an existing mortgage with a new loan. Common reasons for refinancing include lowering fixed interest rates, adjusting loan durations, or switching between fixed- rate and adjustable-rate mortgages. People often refinance when in terest rates change significantly, potentially resulting in savings on debt payments.

Home Improvement
A home improvement loan is a type of financing used to cover the costs of home upgrades, renovations, or repairs. Typically, a home improvement loan is secured by borrowing against the value of the home’s equity which provides a lower interest rate than a personal loan or a credit card.

The table below shows the purpose of loans applied for in the City of San Bernardino based on FFIEC HMDA data for 2022. Most loans, approximately 40 percent, were for home purchase, followed by cash out refinancing at approximately 34 percent.

Table 43: Purpose of Loan Applied For
Loan Purpose # of Applicants % of Applicants
Home Purchase 5,255 40.29%
Home Improvement 960 7.36%
Refinancing 1,626 12.47%
Cash Out Refinancing 4,494 34.46%
Other Purpose 624 4.78%
Not Applicable 84 0.64%
Total 13,043 100.00%
Source: Federal Financial Institutions Examination Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Data Browser, 2022

Table 44 provides an overview of the various actions taken by lenders in 2022. Reviewing these actions aids federal, state, and local governments in understanding the lending patterns of the various financial institutions at play. Of all categories, almost 46 percent of loan applications originated, meaning that the application was accepted for processing. Almost 17 percent of applications, however, were denied by the lender. This could be attributed to a variety of factors, such as income or credit history, as well as race. When race is a contributing factor for loan denial, that is discrimination and prohibited by federal and state law.

Table 44: Action by Lender
Action # of Applicants % of Applicants
Originated 5,951 45.63%

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Denied 2,189 16.78%
Rejected by Applicant 404 3.10%
Withdrawn 1,998 15.32%
Incomplete 914 7.01%
Purchased 1,566 12.01%
Preapproval Denied 2 0.02%
Preapproval Rejected 19 0.15%
Total 13,043 100.00%
Source: Federal Financial Institutions Examination Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Data Browser, 2022

Loan Applicants
As described above, the FHA prohibits mortgage lending discrimination based on race, color, national origin, religion, sex, familial status, or disability.

Race and Ethnicity
Table 45 shows that nearly 46 percent of loan applicants in the City of San Bernardino in 2022 identified as white and 43 percent identified as ethnically Hispanic or Latino (meaning of any race). According to 2021 ACS data, 45 percent of the City’s population is white, and 68 percent identifies as ethnically Hispanic or Latino. The rate of applicants is nearly identical to the City’s demographics for most racial and ethnic groups, though African Americans and Hispanic or Latino persons may be underrepresented.

Table 45: Race and Ethnicity of Loan Applicants
Race # of Applicants % of Applicants
White 5,968 45.76%
Black or African American 880 6.75%
American Indian / Alaska Native 150 1.15%
Asian 749 5.74%
Native Hawaiian or Other Pacific Islander 32 0.25%
Joint 169 1.30%
2 or More Minority Races 34 0.26%
Unknown 5,061 38.80%
Total 13,043 100.00%
Hispanic or Latino 5,543 42.50%
Source: Federal Financial Institutions Examination Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Data Browser, 2022 Income
As shown in Table 46 below, the majority of loan applicants were either low or moderate-income, earning between 0 -80% and 80 -120% AMI. While only 14 percent of loan applicants had middle income, 19 percent were upper income, earning at or above 200% AMI. The City’s profile of loan applicants appears to contain a healthy mix of varied incomes.

Table 46: Applicants by Income Level
Income Level Number of Applicants Percentage of
Applicants

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Low (0-80% AMI) 3,432 26%
Moderate (80-120% AMI) 3,483 27%
Middle (120-200% AMI) 1,790 14%
Upper (200% > AMI) 2,436 19%
Unknown/NA 1,902 15%
Total 13,043 100%
Source: Federal Financial Institutions Examination Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Data Browser, 2022 Lenders with Highest Denial Rates
Lenders were examined to determine denial rates using Home Mortgage Disclosure Act (HMDA) data through the FFIEC for all loan applications with census tracts in the City of San Bernardino. The lenders in Table 47 below had the highest number of applications available through the FFIEC for 2022 and are ranked by denial rate. United Shore Financial Services had the highest number of applications, 1,219, and the second -highest denial rate, approximately 42 percent. Meanwhile, Bank of America had the highest denial rate, with 58 percent of their 401 applications being denied a loan.

Table 47: Lenders with Highest Denial Rates
Rank Lender Applications Denials %
1 Bank of America, National Association 401 234 58.35%
2 United Shore Financial Services, LLC 1,219 510 41.84% 3 U.S. Bank National Association 235 93 39.57%
4 Lakeview Loan Servicing, LLC 230 75 32.61%
5 LoanDepot.com, LLC 248 50 20.16%
6 Wells Fargo Bank, National Association 241 48 19.92%
7 Rocket Mortgage, LLC 700 106 15.14%
8 Newrez, LLC 274 34 12.41%
9 PennyMac Loan Services, LLC 316 37 11.71%
10 Broker Solutions, Inc. 233 14 6.01%
Source: Federal Financial Institutions Examination Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Data Browser, 2022

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Chapter 5: Public Policies
Public policies, along with other factors, affect the development of housing. In turn, they impact the range and location of housing options available to residents. Fair housing laws, as described in Chapter 1, are intended to encourage an inclusive living environment and active community participation.

Assessing public policies and related practices helps identify potential impediments to fair housing opportunities. This chapter provides an overview of public policies, regulations, standards, and practices, including housing element law and compliance, land use, and zoning.

A. Housing Element Law and Compliance

California housing element law requires that local governments adequately plan to meet the existing and projected housing needs of all economic segments of the community. 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.

California housing element law requires each jurisdiction to:

• Identify adequate sites that will be made available through appropriate zoning and development standards and with the services and facilities needed to facilitate and encourage the development of a variety of types of housing for all income levels to meet the city’s regional housing needs. • Assist in the development of adequate housing to meet the needs of extremely low -, very low -, low-, and moderate-income households.
• Address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing.
• Conserve and improve the condition of the existing affordable housing stock. • Promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability.

The City’s current Housing Element was adopted on February 21, 2024, and was certified as substantially compliant with State Law by the California Department of Housing and Community Development (HCD) on June 17, 2024.

B. Land Use Element

The Land Use Element of the City’s General Plan designates the general distribution, location, and extent of residential, commercial, industrial, public/quasi-public, and open space uses . Regarding housing, the Land Use Element establishes a range of nine residential land-use designations, specifies densities, and suggests the types of housing appropriate in a community. The Land Use Element is implemented through the Development Code, establishing zones where residential uses are permitted. Development den sity ranges from one unit per acre in single -family designations to 130 dwelling units per acre in the CR-2 zone.

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Table 48: Residential Land Use Designations and Zoning Districts General Plan
Land Use Designation Zoning District Primary Residential Type(s) Du/Ac Residential Estate RE Single-family detached in an estate setting 1 Residential Low RL Single-family detached in low-density setting 3.1 Residential Suburban RS Single-family detached in high quality suburban setting 4.5
Residential Urban RU Single/multi-family attached and detached residences 8
Residential Medium RM Multi-family dwellings, all types 12 Residential Medium
High RMH Multi-family dwellings including apartments and condominiums 24
Residential High RH Multi-family dwellings including apartments and condominiums 31
Commercial Office CO Offices, retail, and senior housing/congregate care 47 Commercial General CG-2 Commercial and multi-family dwellings 12 (west of
I-215); 21
east
Commercial Regional CR-2 Vertical mixed-use 130
Source: City of San Bernardino 2021-2029 Housing Element C. Development Code
The City’s existing Development Code regulates the type, location, density, and scale of residential development and exists to protect and promote the health, safety, and general welfare of residents.

In addition, the Development Code serves to preserve th e character and integrity of existing neighborhoods.

Zoning & Provisions for Diversity Housing Types
Residential uses are allowed in residential and some commercial districts. The City’s zoning permits a range of housing types, which is essential to providing a full range of housing choice. Table 49 lists housing types allowable with approval of a Development Permit or Conditional Use Permit, permitted by-right, or prohibited.

Table 49: Housing Types by Zone
Housing Types RE RL RS RU RM RMH RH RSH CO CG-2 CR-2
Single-Family D D D D D D D X X X X

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Multi-Family X X X D D D D X X C C
Condominium
or Townhouse D D D D D D D X X X X
Manufactured
Housing D D D D D D D X X X X
Mobile Home
Park or
Subdivisions

D D D D D D D X X X X
Senior
Housing/
Congregate
Care

X X X D D D D X C C C
Community
Care Facility (≤
6 persons)

P P P P P P P X C C C
Emergency
Shelters X X X X X X X X X X C
Single Room
Occupancy X X X X X X X X X C C
Mixed Used X X X X X X X X C C C
RE = Residential Estate
RL = Residential Low
RS = Residential Suburban
RU = Residential Urban
RM = Residential Medium
RMH = Residential Medium High
RH = Residential High
RSH = Residential Student Housing
CO = Commercial Office
CG-2 = Commercial General
CR-2 = Commercial Regional
P = Permitted
D = Development Permit
C = Conditional Use Permit
X = Prohibited
Source: City of San Bernardino Development Code, 2023
Density Bonus
In accordance with State Government Code Section 65915, to promote the development of affordable housing, a density increase of 25 percent over the otherwise maximum allowable residential density may be permitted when developers meet conditions. This is known as a “Density Bonus.” The City also has an amenities bonus provision for a density increase of up to 15 percent in zones RU, RM, RMH, RH, CO-1 & 2, CG-2, and CR-2.

Parking
Overly generous parking requirements impose economic and environmental costs. The result is an impact on the availability and affordability of housing, including homeownership. In addition, when

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land availability is constrained, parking structures are often necessary to meet parking requirements for larger projects. As the number of parking spaces required increases, development costs increase as well. The City recognizes these challenges and offers incentives, such as reduced parking standards within areas served by transit, to alleviate potential constraints to development.

Table 50: Parking Standards for Residential Uses
Housing Type Parking Standard Guest Parking
Conventional Housing
Single-Family 2 covered garage spaces per unit None
Planned Residential 2 covered garage spaces per unit 1 space/ 5 du Mobile Home Parks 2 covered garage spaces per unit 1 space/unit Multi-family - Studio 1 space per unit None
Multi-family – 1 bdrm 1.5 covered spaces per unit
1 covered space for each
5 units
Multi-family – 2 bdrm 2 covered spaces per unit
1 covered space for each
5 units
Multi-family – 3 bdrm 2.5 covered spaces per unit
1 covered space for each
5 units
Senior Apartments 1 covered space per unit
1 covered space for each
5 units
Special Needs Housing
Senior Congregate Care 0.75 covered space per unit None Emergency Shelters 1 space/1000 sf of GFA or FTE on largest shift None Transitional Housing,
Supportive Housing,
Residential Care,
Navigation Center,
Accessory Dwellings
Unspecified Unspecified
Source: City of San Bernardino 2021-2029 Housing Element Definitions
Local zoning definitions that should be consistent with the Fair Housing Act include family, group homes, assisted care facilities, boarding homes, single -room occupancy, homeless shelters, second dwelling occupancy units, and reasonable occupancy.

California court cases 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, etc.), or 3) a group of not more than a certain number of unrelated persons as a single housekeeping unit, is invalid. Court rulings state 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

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residency by discrimination between biologically related and unrelated persons. Furthermore, a zoning provision cannot regulate or enforce the number of people constituting a family. The City’s definition does not serve to impede housing choice.

The City’s current “Family” definition is not overly restrictive. This definition was amended or “cured” of any discriminatory language in 2011. The current definition is as follows: “ Family” means o ne or more persons living together in a dwelling unit, with common access to, and common use of all living, kitchen and eating areas within the dwelling unit.

In 2024, the City of San Bernardino Municipal Code was amended to allow group homes or small residential care facilities (RCF) serving six or fewer persons that operate as a single housekeeping unit and that do not provide licensable services in all zones allowing single or multiunit residences. The current zoning ordinance does not include boarding homes.

Assembly Bill 2339 requires an assessment of the suitability of sites for emergency shelters. An emergency shelter is generally defined as any facility, the primary purpose of which is to provide a temporary shelter for the homeless in general or for specific populatio ns of the homeless and which does not require occupants to sign leases or occupancy agreements. Emergency shelters are needed to meet the immediate short-term needs of the unsheltered homeless. Zoning for Emergency Shelters The Emergency Shelter Overlay Zone (Chapter 19.10 -E) permits emergency shelters serving up to 60 persons/shelter without discretionary review in accordance with an administrative permit. The overlay covers five designated areas in the City that may be in one of three zoning districts: Industrial Light, Commercial Heavy, and Office Industrial Park.

Individual with a Disability
Federal law requires that new housing comply with common accessibility standards in the building code. The City regulates reasonable accommodation as stated in Chapter 19.63 , Reasonable Accommodations. This section establishes a procedure for an individual with a disability seeking equal access to housing to request reasonable accommodation as provided by the Federal Fair Housing Amendments Act of 1988 and the California Fair Employment and Housing Act.

A reasonable accommodation is the act of providing flexibility in the application of land use and zoning regulations, including modification or waiver of certain requirements to accommodate the needs of an individual with a disability. Requests may be submitted in writing to be review ed by the Director for approval or denial. The request shall identify the project, the standard that presents a barrier, and the disability that requires reasonable accommodation. The Director may request additional information for deciding, consistent with state and federal fair housing acts and considering privacy rights of the individual. Prior to issuance of permits issued for construction including reasonable accommodation, the Director may require recordation of a disclosure to inform future property owners of the granting of the reasonable accommodation, and whether or not the approval will run with the land. Prior to approval, the Director shall grant a request for reasonable accommodation only if all of the following findings are made: The subject home will be used by an individual with a disability, the requested accommodation is necessary to make specific housing available to an individual with a disability, the requested accommodation would not impose an undue financial or administrative burden on the City, and the requested accommodation would not require a fundamental alteration in the nature of a City program or law, including land use and zoning. There is no fee associated with submitting a request.

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Appeals may be made to the Planning Commission, which may then be appealed by the Mayor and Common Council.

D. Regional Housing Needs Assessment
The Regional Housing Needs Assessment (RHNA) is a component of the 2021-2029 Housing Element.

Every eight years, the State of California provides the Southern California Association of Governments (SCAG) with the number of new housing units that it must plan for by the end of the planning period.

SCAG di vides the allocation among all local governments in the region it represents. The City is allocated 8,123 units divided into income/affordability categories. The number of units for very low- income households is 1,415, 1,097 for low -income, 1,448 for moder ate-income, and 4,163 units for above moderate-income households. While the City is not required to build or finance the construction of these units, it must identify adequate sites to accommodate them.

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Chapter 6: Fair Housing Profile

This section of the AI provides information on the institutional structure of the homeownership and rental markets in the City of San Bernardino. It also includes local, state, and federal data on fair housing complaints. The Fair Housing Act prohibits discrimination concerning the sale, rental, and financing of housing based on race, religion, national origin, sex, familial status, and disability. The Act also states that “it is the policy of the United States to provide, within constitutional limitations, for fair housing throughout the United States.”

A. Fair Housing Practices in the Homeownership Market
This section analyzes potential impediments to fair housing in homeownership. Before buying a home, a potential buyer must first search through advertisements or listings, then obtain a loan, before finally working with a real estate agent to close a deal.

Advertising
Buying a home usually begins with searching through advertised listings of homes. Prospective buyers may choose to work with a Real Estate Agent or conduct a search independently. Homes are typically advertised in newspapers, magazines, or the internet, which has become the most common tool.

Advertisements for homes must avoid using discriminatory language, such as describing current residents or the neighborhood in racial or ethnic terms, resident preferences, lack of accommodations for disabled residents, or the convenience of local religious institutions. Language like this may indicate a preference for certain types of people, such as families or people of a certain religion, and can be discriminatory.

At times, agents may be found guilty of discrimination , even if it is unintentional. The National Fair Housing Alliance provides guidelines for responsible advertising to housing providers . They advise providers to focus on the amenities that the listing has to offer rather than describing their ideal owner or renter, to include the fair housing logo and/or the “Equal Housing Opportunity” slogan, and to avoid statements that exclude any protected classes.

In the analysis of 20 for -sale listings on Trulia, none were found to include potentially discriminatory language.

Table 51: Potentially Discriminatory Language in Listings of For-Sale Homes Discrimination Type Number of Listings
No Discriminatory Language 20
Income Related 0
Household Size/Family Related 0
Disability Related 0
Religion Related 0
Source: www.trulia.com, accessed August 2024

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Lending
Lending institutions determine if a potential buyer will qualify for a loan. As part of the lending process, applicants are asked to provide information such as gender, race, and income, which is then used for reporting required by the Home Mortgage Disclo sure Act and the Community Reinvestment Act.

However, this information may be used to discriminate during the application process. The previous section of this AI discussed lending in more depth, along with the various types of loan types offered by both private and public lenders.

As mentioned previously, the Community Reinvestment Act (CRA) of 1977 was passed to address discrimination in housing practices such as redlining.

Credit Scores
Credit histories are significant factors in lending institutions approving home loans. Applicants with higher scores are more likely to be given conventional loans , while applicants with lower scores are more likely to receive FHA or government-backed loans and pay higher interest rates.

Real Estate Agents
Real estate agents may engage in discriminatory practices against clients or prospective clients, be it intentional or unintentional. An agent may choose not to work with a client due to a protected characteristic, choose not to show all available housing units, or steer a client to a particular neighborhood based on their race, income, or other factors. These practices are discriminatory and illegal.

The National Associated of Realtors (NAR) established a Fair Housing Program to provide guidance and resources to realtors in delivering fair housing services to all individuals thro ugh policy advocacy and legal guidance. The term “realtor” refers to a licensed real estate professional who is a NAR member, though not all licensed real estate brokers and salespersons belong to NAR.

The California Department of Real Estate (DRE) is the licensing authority for real estate brokers and salespersons in California. To renew a real estate license, a licensee is required by DRE to complete 45 hours of training on topics including ethics, fair housing, and implicit bias. This training provides education and resources for agents to i dentify and avoid discriminatory housing practices , thereby promoting fair housing.

The California Association of Realtors (CAR) has many local associations throughout the state. San Bernardino is served by the Inland Valleys Association of Realtors (IVAR). In addition, the Inland Empire Association of Realtist (IEAOR) also serves the San Bernardino area as a chapter under the umbrella of the California Association of Real Estate Brokers (CAREB) and the National Association of Real Estate Brokers (NAREB). A realtist is a real estate professional who is a member of NAREB.

B. Fair Housing Practices in the Rental Housing Market

This section analyzes potential impediments to fair housing in renting. The process of renting a housing unit involves:
• Searching advertisements
• Viewing rental units

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• Completing a credit check and submitting an application • Approval (or denial)
• Payment of a security deposit and signing of a rental agreement/lease (in the case of approval)

Advertising
Similarly to for -sale housing advertisements, rental unit advertisements c annot indicate any preference, limitation, or discrimination based on characteristics protected under the federal Fair Housing Act and other federal and state laws outlined in Chapter 1.

Advertisements for rental units often include discriminatory language. This may involve expressing a preference for families, students, or single individuals and references to the allowance of pets.

Language such as this may indicate a preference for certain types of people, while excluding people who may need a guide dog or emotional -support animal. Like prospe ctive homeowners, prospective renters can also face discrimination when responding to advertisements or viewing a unit based on their perceived race, social class, or sex.

An examination of 20 rental listings through Trulia found three income -related and two disability - related instances of potentially discriminatory language.

Table 52: Potentially Discriminatory Language in Rental Listings Discrimination Type Number of Listings Potentially Discriminatory Language No Discriminatory
Language 15 N/A
Income Related 3
Satisfactory credit and rental history, subjecting applicants to credit, criminal, and rental history checks, no bankruptcies allowed in the past 3 years, and requiring 3 times the rent in gross income.

Disability Related 2 "No pets allowed"
Household Size/
Family Related 0 N/A
Religion Related 0 N/A
Source: www.trulia.com, accessed August 2024

C. Fair Housing Complaints and Enforcement

Several public and private agencies have mechanisms in place to take complaints about and follow up on housing discrimination or unfair housing practices. Analyzing instances or patterns of complaints can assist in assessing the nature and level of potentially discriminatory housing practices in the private sector.

Office of Fair Housing and Equal Opportunity (FHEO)
At the federal level, the Office of Fair Housing and Equal Opportunity (FHEO) of the U .S. Department of Housing and Urban Development receives complaints of housing discrimination. FHEO establishes policies to protect the fair housing rights of Americans and enforces federal laws. Reports of alleged discrimination must be filed within one year of the last date of the alleged act and will be investigated

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by either FHEO or will be referred to another organization. HUD or the Department of Justice (DOJ) may take legal action if it is found that a law was violated.

From 2 019 to 2020 , 4 2 fair housing discrimination c ases in the County of San Bernardino were forwarded to the Office of Fair Housing and Equal Opportunity and published as public data. The table below presents the reasons for and numbers of cases forwarded. Disability was included as a basis for complaint in 59.5 percent of cases. After that, were cases alleging retaliation at 26.2 percent and race at 16.6 percent.

Table 53: Basis for Complaint
# Percent
Race 7 16.6%
Black or African American 6 14.3%
White 1 2.4%
Color 1 2.4%
National Origin 3 7.1%
Hispanic Origin 3 7.1%
Disability 25 59.5%
Sex 5 11.9%
Retaliation 11 26.2%
Familial Status 6 14.3%
Note: Complaints may be made on multiple bases. Therefore, the percentages do not total 100 percent.

Source: 2019 and 2020 U.S. Department of Housing and Urban Development, FHEO Data California Civil Rights Department (CRD)
The California Civil Rights Department operates similarly to the FHEO on the state level, investigating and attempting to settle or escalating complaints of legal violations of discrimination. The CRD has up to one year after an initial complaint is filed to complete their investigation and potentially take the complaint to civil court if necessary . CRD is a participant of and has received funding from HUD’s Fair Housing Assistance Program (FHAP) to enforce fair housing practices in the State of California.

The CRD’s 2022 Annual Report shows 36 housing complaint cases in the County of San Bernardino.

Inland Fair Housing and Mediation Board
The Inland Fair Housing and Mediation Board (IFHMB) is a nonprofit organization that has served San Bernardino County and parts of Riverside and Imperial Counties in Southern California since 1980.

IFHMB’s services are provided to the community free of charge . They are funded through the U .S.

Department of Housing and Urban Development’s Community Development Block Grant (CDBG) program provided by the City of San Bernardino and the County of San Bernardino. The purpose of IFHMB is to help community members resolve housing discrimination, homeownership sustainability, rental complaints, and disputes in court through the provision of resources, recommendations, education, and mediation.

IFHMB provides numerous services including:

• Information, investigation, education, and conciliation and/or referrals of housing discrimination complaints.

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• Fair housing workshops to educate housing providers, tenants, homeowners, and financial and lending institutions.
• Housing counseling, including default and foreclosure prevention counseling. • Information to tenants, landlords, mobile home park owners, and mobile home residents on their rights and responsibilities.
• Mediation as an alternative to resolving housing issues for tenants, property manage rs, and owners.

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Chapter 7: Fair Housing Progress
This section reflects upon the goals and actions set through the City’s 2020 -2025 Analysis of Impediments to Fair Housing Choice report. Progress on each goal or action is presented in the table below.

Table 54: Fair Housing Progress Since 2020
Actions Progress
Goal 1: Provide housing solutions and incentives for special needs populations.

1.1 Work with agencies that assist with the housing needs of the elderly, those with disabilities, and people who are homeless. (Single-parent households make up almost 19% of total
households. 13 % of the population is reported to have a disability. 23% of total homes contain at least one or more seniors).

The City is funding its Homeless
Outreach Prevention Education
Campus (HOPE Campus) to provide
Emergency Shelter. The HOPE
Campus will feature congregate and
non-congregate shelter units,
laundry facilities, kitchen facilities,
secure storage for personal items,
and supportive services. The project
is the recipient of HOME ARP funds.

The City partnered with Hope the
Mission and in early 2025 with the
Salvation Army , two non-profit
agencies that provide dedicated
street outreach services and
intensive case management services.

Additionally, to partnerships with
non-profits, the city created the City’s
Homeless Outreach Team (HOT) to
work with multiple city departments
to engage and assist the unhoused
community. HOT also works with the
County’s Coordinated Entry System
(CES) to prioritize individuals to be
placed in emergency shelter, offer
housing options, motel vouchers,
refer to mental health, and other
essential services. Because
emergency shelter is not always
available, homeless outreach
workers provide motel vouchers
when available.

The City was awarded $ 34.9 million
from the State to construct a 140 -
bed, non -congregate, interim
housing facility called the San
Bernardino Community Wellness
Campus to better assist the city’s
most marginalized population -

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chronically homeless men. In the City,
homeless men outnumber homeless
women two to one. The campus will
assist men who have been
incarcerated, those who are HIV
positive, male veterans and
unsheltered men in general. An array
of onsite supportive services will be
provided, and the campus will have a
Federally Qualified Healthcare Center
(FQHC) that provides comprehensive
medical services. The project
completion date is August 2025.

The City supports HACSB’s efforts to
obtain additional rental assistance
funding, especially for seniors and
lower-income households.

Additionally, the City considers this
population and issue with rental
assistance funding to be a direct issue
with the City's underserved needs.

1.2 Work with housing developers to create affordable housing options for special needs populations.

The City supported, in part, the
construction of the first three phases
of Arrowhead Grove's affordable
housing development.

The City staff engaged with
Community Housing Developer
Organizations and developers to
discuss Infill Housing and multi-family
affordable housing projects.

Goal 2: Increase affordable housing opportunities.

2.1 Support integrated housing approaches near designated employment areas/centers and transit.

In FY 21 -22, the City utilized HOME
program income for Arrowhead
Grove, formerly Waterman Gardens
Public Housing Community, for phase
two of the multi -phase Rental
Assistance Demonstration (RAD)
project. Crestview Terrace Phase III
entails the building of 184 apartment
homes, including one -, two-, and
three-bedroom affordable units for
mixed-income family apartments to
households incomes ranging from
30% to 60% of the area median
income (AMI). This continues to be an
ongoing project for the City. The
Arrowhead Grove Redevelopment is
located near major employment

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centers and serviced by multiple
Omnitrans bus routes, facilitating
easy access to jobs and services.

2.2 Promote building new units containing 2 or 3 bedrooms for larger families.

The city has engaged in public-
private partnerships to preserve and
develop affordable housing. For
example, Standard Communities, in
collaboration with Housing on Merit,
acquired and renovated Foothill
Villas, a 239-unit affordable housing
community. The $20.4 million
renovation included upgrades to
individual units and common areas,
aiming to maintain long-term
affordability for low-income families.

2.3 Encourage innovative low-cost housing materials such as modular construction.

Community Wellness Campus
(2024–2025): In partnership with
Dignity Moves and Lutheran Social
Services, the city is developing 140
modular housing units for
chronically homeless men and
veterans. Supported by a $34.9
million Homekey grant, this project
will offer interim housing and
wraparound services, with
construction beginning in April 2024
and a grand opening planned for
August 2025.

Dignity Moves

Valencia Grove Redevelopment: The
Housing Authority of the County of
San Bernardino utilized modular
construction to transform the aging
Valencia Grove public housing site
into a modern, mixed-income
community. The first phase replaced
62 units with 85 new modular units,
with plans to expand to 228 units.

This project received national
recognition for its innovative design
and cost-effectiveness.

2.4 Identify funding for transitional and permanent supportive housing development.

The City plans to amend the
Development Code to adequately
define transitional and permanent
supportive housing and permit these
uses based on unit type, in
accordance with Senate Bill 2.

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During the FY 2023-24-year, the City’s
ESG program supported four projects
with an Emergency Shelter
component, serving a total of 481
individuals from 340 households.

2.5 Understand the specific redevelopment obstacles related to construction on the local level that can be changed.

The City has also made a major effort
to eliminate constraints, with respect
to land use regulations, by
developing and adopting a new
Development Code that unified and
simplified the City’s development
regulations and processes. That
effort was followed by a
reorganization by the City to unify the
various development -related
departments into a single Community
Development Department and a one-
stop permit counter. The City has
made the follow ing additional
amendments to the Municipal Code
to further reduce barriers to
affordable housing: General Lot
Consolidation Incentive, Density
Bonus Provisions, Transitional and
Supportive Housing, and Streamlined
Processing.

2.6 Explore more ways to work with developers to promote housing construction training opportunities for the homeless.

Not pursued
Goal 3: Increase homeownership opportunities for all ethnicities.

3.1 Work with local banks (particularly Wells Fargo) in expanding downpayment assistance programs for first-time homebuyers.

Partner with lenders to encourage lending to low-income first- time homebuyers.

Not pursued

3.2 Incorporate homeownership education, budgeting, and home maintenance education and skills into housing programs.

The City established a First Time
Homebuyer program (Infill Housing),
which instead of requiring that a
family resell their home to another
low-income household, utilizes
recapture provisions to allow a family
to capture the equity in their house,
thus accumulating wealth which is
the most effective way of reducing
the number of poverty level
households.

The City also collaborated with
Neighborhood Housing Services of
the Inland Empire (NHISE) to provide
different educational forums on the

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topics of homeownership and
financial literacy. Through their
program, NHISE successfully reached
a total of 12 City residents in FY 2023-
24 and an additional 68 City residents
in FY 2024 -25 as they continued
working even after the end of their
agreement.

3.3 Retain existing homeowners by promoting and enhancing funding to the City’s existing Owner-Occupied Housing
Rehabilitation Program, as well as tap into other future housing reinvestment programs and resources that may exist in the region.

Development of Owner Occupied
Residential Rehabilitation Program
that provides financial assistance to
income-qualified San Bernardino
homeowners to make necessary
repairs to their homes.

Goal 4: Create public awareness of fair housing laws and affordable housing advocacy.

4.1 Coordinate with the IFHMB to enhance local outreach about the positive impacts of affordable housing.

The City works with Inland Fair
Housing and Mediation Board and
Neighborhood Partnership Housing
Services, Inc. to provide First Time
Homebuyer workshops to educate
potential borrowers in the complete
process of purchasing a home. These
agencies also provide other services
such as Default/Foreclosure
Prevention and Reverse Mortgage
counseling services; and financial
education workshops that help
homeowners preserve their housing.
1911 people were assisted in PY21 -
22, 1,214 low -income residents in
PY22-23 and 1,281 in PY 23-24.

4.2 Work with IFHMB, as part of its Fair Housing contract, to annually review and report on apartment rental
advertisements released by private housing companies.

Since 2020, the City of San
Bernardino has actively collaborated
with IFHMB to advance fair housing
initiatives, particularly focusing on
public awareness and monitoring
rental advertising practices. IFHMB
provides community workshops. The
city's Housing and Homeless Division
hosts quarterly tenant rights
workshops aimed at educating
residents about their housing rights
and responsibilities. IFHMB provides
free services to low- and moderate-
income individuals, including
education on housing rights and
responsibilities, landlord/tenant
mediation, housing counseling, and
alternative dispute resolution.

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4.3 Enhance local land use and zoning laws.
a. Identify priority goals and target areas for new
housing and/or housing rehabilitation where
employment and transit opportunities exist.

The City is committed to continuing
the streamlining of development
activities and regulations and will
continue to analyze potential
programs that seek to eliminate
land use constraints, particularly as
related to the provision of new
housing and rehabilitation of
existing housing.

4.4 Create regulations conducive to affordable housing needs.

Introduce appropriate building envelope sizes for each zoning district and be inclusive with regards to unit size, building height, reduced parking, transit, and pedestrian connectivity.

Goal 5: Increase earning capacity of low- and moderate-income residents.

5.1 Work with major employers to develop incentives for new housing near their work.

Not pursued

5.2 Improve education and provide skills training in education, healthcare, manufacturing, and construction jobs.
a. Create partnerships with California’s Employment
Development Department, Workforce Development
Board, Workforce Development Aging & Community
Services, California Building Industry Association,
Southern California Building Association, San
Bernardino Valley College, Riverside Vocational
College, Concorde Career College, and the Career
Technical Education.
b. Strive to collaborate with educational and vocational institutions to provide workforce readiness programs.

The San Bernardino Community
Development and Housing
Department will continue consulting
with a wide variety of agencies and
organizations such as HACSB, County
Workforce Development, County
Department of Behavioral Health,
and County Office on Aging and Adult
Services
involved with the delivery of housing,
supportive services, and economic
development to low - and moderate-
income San Bernardino residents.

Workforce Development, for
example, provides job placement
services for people in the County and
provides up to three months of paid
on-the-job training and any
equipment that an employee may
require for their new job.

5.3 Work with higher education systems to create college- readiness programs, financing solutions, and family
preservation programs for first-generation students.

In 2022 and 2023 the City directly
works SBCCD to co -host an annual
mixer and open house for residents
and students to discover accelerated
workforce training programs that
match relevant available jobs.

5.4 Increase opportunities that target “Second Chance,” persons with disabilities, at-risk homeless individuals, and job retraining programs. Agencies such as the Center for
Employment Opportunities, Technical Employment Training, Inc., Department of Workforce Development Board,
America’s Job Centers of California, and San Bernardino County Workforce Investment Board.

Inland Empire Small Business
Development Center to train
prospective future small
business owners. 12 small
businesses were assisted in PY22-23
and 18 businesses in PY23-24.

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Chapter 8: Fair Housing Action Plan
This chapter will discuss the findings from the Analysis of Impediments to Fair Housing Cho ice. The major or high priority contributing factors to fair housing choice, based on community engagement activities and data analysis, include:
• High cost of housing (rental and homeownership)
• High cost of development
• Lengthy permitting process
• LMI homeowner and rental housing rehabilitation
• Senior housing and services
• Cost-burden
• Overcrowding
• Chronic homelessness
• Lack of information about available services
• Fair housing enforcement and education
• Lending
A. Recommendations for Ongoing Actions
The following findings and recommended actions are based on data analysis performed for this report, stakeholder outreach, and community participation. Actions, goals, and categories are not in any particular order of priority.

Expand Affordable Housing Options
Data collected throughout the Analysis of Impediments process , along with stakeholder and resident outreach, indicates a high priority need for additional affordable housing options in the City. As cited in Chapter Three, 52.17 percent of LMI homeowners are cost -burdened and 75.21 percent of LMI renters are cost -burdened. 2021 ACS data reveals that 69.73 percent of rental units in the City cost upwards of $1,000 per month, which is unaffordable to the City’s lowest -income renter households.

Through the Stakeholder Survey, 75 percent of respondents rated affordable housing as a critical priority need.

Overcrowding was also identified as an issue through data analysis conducted in Chapter Three.

Findings show that 8.91 percent of homeowners and 18.16 percent of renters in the City are overcrowded, regardless of income. A significant portion of the City’s households, 22.81 percent, are large households (five or more people). However, only 7.28 percent of rental units and 27.31 percent of current ownership units have four or more bedrooms.

Housing growth has been slow over the past decade, despite growth in population and a local demand for more affordable housing options. Therefore, continuing to work to expand affordable housing options available to San Bernardino residents is critical in the pursuit of affirmatively furthering fair housing.

GOAL 1: SUPPORT THE EXPANSION OF AFFORDABLE HOUSING STOCK.

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Recommended Actions:

1.1 Increase the availability of affordable senior housing options.

1.2 Develop and/or modify existing housing units with four or more bedrooms to support large households, particularly rental units.

1.3 Evaluate vacant housing units for rehabilitation.

1.4 Expand housing and commercial development opportunities by creating housing on in-fill sites.

1.5 Support the development of Accessory Dwelling Units (ADUs) as a source of affordable housing.

1.6 Support owner-occupied and renter-occupied housing rehabilitation.

1.7 Evaluate current permitting processes for areas of improvement/change to shorten length of time and mitigate barriers to development.

Housing Discrimination
Addressing housing discrimination throughout the community is essential to fostering inclusive and equitable neighborhoods. It ensures that residents have equal access to housing opportunities on a community-wide scale, thereby promoting diversity , social integration, and fair housing . Combating discrimination enables households to secure safe, affordable housing, significantly enhancing their quality of life and overall economic stability.

Findings reported in Chapter Six suggest potentially discriminatory language in rental advertisements reviewed online. Simultaneously, lending data analyzed in Chapter Four found that 16.78 percent of all home loan applicants were denied. While these denials do not inherently mean that discrimination occurs, ensuring that community members know their rights and that housing and lending providers have fair housing education promotes equal access and avoids discrimination.

When residents were asked how informed they feel about their tenant and homeowner rights and responsibilities through the Community Needs Survey, only 14 percent cited being very informed .

Conversely, 16 percent of respondents cited not being informed at all , while 29 percent cited being not very informed.

The City can both continue its current efforts to prevent housing discrimination while expanding efforts to address identified issues.

GOAL 2: SUPPORT THE PREVENTION OF HOUSING DISCRIMINATION AND THE PROMOTION OF FAIR HOUSING.

Recommended Actions:

2.1 Continue to support and fund local fair housing service programs.

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2.2 Provide fair housing education seminars and/or workshops to inform the public on tenant and homeowner rights and responsibilities.

2.3 Work with a local fair housing service provider to periodically review housing advertisements for potentially discriminatory language and take appropriate actions to resolve issues when necessary.

Building Housing Partnerships
Feedback through the Community Meeting pointed to barriers to affordable housing development , including costs, permitting times, and the general hurdles associated with housing projects.

Stakeholders who responded to the Community Needs Survey echoed support for fostering partnerships with local businesses, nonprofits, and government agencies to maximize resources and support affordable housing initiatives. With the complexity of affordable housing development, bringing stakeholders from all across the community to work toward a shared vision or goal can further promote equal housing access and mitigate barriers to both access and development for those involved.

GOAL 3: FOSTER PARTNERSHIPS WITH LOCAL AND REGIONAL STAKEHOLDERS.

Recommended Actions:

3.1 Host a roundtable discussion within the housing community with both public and private housing experts to maximize ideas, expertise, and resources.

3.2 Invite public service groups, nonprofits, community leaders, housing developers, lenders, and other stakeholders to participate in community forums to expand partnerships and bolster support and initiatives for affordable housing development.

Lending
Homeownership and lending are directly intertwined. To afford the purchase of a home, the vast majority of households must take on mortgages and other loans, which can be difficult to obtain. Even if a household can attain a loan, the costs associated with homeownership can be difficult to maintain due to changing circumstances , such as the loss of income , the diagnosis of a medical condition, or expensive damage that need to be fixed.

As discussed in Chapter Four, Home Mortgage Disclosure Act (HMDA) data shows that 16.78 percent of applicants were denied in 2022. The highest denial rate of top lenders examined in the City was

58.35 percent, suggesting the potential for discriminatory practices occurring. Overall, 26 percent of applicants had incomes between 0 to 80 percent of the area median income (AMI) and 27 percent of applicants had incomes between 80 to 120 percent AMI. The majority of applicants, 71.71 percent, applied for conventional loans which often have more stringent requirements and higher interest rates as opposed to government-backed loans.

Community outreach efforts, including the Community Needs Survey and the Community Meeting, revealed support for first-time homebuyer assistance for LMI households.

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Supporting fair and equal lending practices in the community can support equal access to homeownership.

GOAL 4: SUPPORT HOMEOWNERSHIP

Recommended Actions:

4.1 Partnerships with CHDOs: The city has collaborated with Community Housing Development Organizations (CHDOs), to develop single-family homes on vacant, city-owned properties. These homes are intended for sale to income-qualified families, aiming to increase homeownership among low- and moderate-income residents.

4.2 Pursue funding for homebuyer assistance and housing rehabilitation assistance for LMI residents.

4.3 Promote FHA and VA loans in any City provided affordable homeownership program.

4.4 Provide financial literacy, lending, and homebuyer education to residents to promote safe lending practices and prevent discrimination. By placing emphasis on reaching the City’s most vulnerable populations, such as extremely low-income households, seniors, persons with limited English proficiency, and persons with disabilities, discrimination can be mitigated.

Resource Accessibility and Integration
Expanding resources and the ease of accessibility can help mitigate impediments to fair housing while promoting all -around community wellbeing. Data analysis and community engagement revealed a need for continued and greater connection to resources, as well as an issue of chronic homelessness.

The City already has numerous initiatives geared toward providing services for LMI residents and reducing homelessness. Expanding and continuing these efforts ensures greater success for the City’s most vulnerable populations.

GOAL 5: CONNECT RESIDENTS WITH LOCAL, STATE, AND FEDERAL RESOURCES ON FAIR HOUSING AND COMMUNITY SERVICES.

Recommended Actions:

5.1 Allocate CDBG funding for public facilities and infrastructure in the City’s designated LMI areas.

5.2 Continue working with and funding local service providers assisting the community with needs such as food insecurity, healthcare, homelessness, youth services, and more.

5.3 Promote the San Bernardino HOPE campus to community members, local businesses, and community organizations so that people are well-informed on resource availability.

5.4 Go above and beyond the Limited English Proficiency (LEP) Plan and conduct outreach and assistance to non-English speakers in the community who do not meet the LEP threshold but would benefit from targeted outreach services.

2025 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 76 of 77

Appendix A: Federal Fair Housing Laws
• Title VI of the Civil Rights Act of 1964 (Title VI): Title VI aims to safeguard the rights of individuals, regardless of race, color, or national origin, in programs and activities that receive federal funding or financial assistance.
• Title VIII of the Civil Rights Act of 1968 (Fair Housing Act): The Fair Housing Act, enacted in 1968 and amended in 1988, prohibits housing discrimination against seven protected classes: race, color, religion, sex, national origin, familial status, and disability. The 1988 amendments added "familial status" and "dis ability" as protected classes and enhanced HUD's authority to enforce compliance with federal law. • Section 504 of the Rehabilitation Act of 1973 (Section 504): Section 504 sets forth guidelines that prevent individuals with disabilities from being denied access to housing under programs and activities that receive federal funding or financial assistance. • Section 109 of Title I of the Housing and Community Development Act of 1974 (Section 109): Section 109 prohibits housing discrimination based on race, color, national origin, sex, or religion in programs and activities that receive federal funding or financial assistance. • Title II of the Americans with Disabilities Act of 1990 (Title II): Title II prohibits discrimination based on disability in public entities' programs, services, and activities. HUD is responsible for enforcing Title II concerning public housing, housing assistance, and housing referrals managed by state and local jurisdictions. • Architectural Barriers Act of 1968 (Architectural Barriers Act): The Architectural Barriers Act requires that buildings and facilities receiving federal funding assistance after September 1969 be accessible to and usable by individuals with disabilities. • Age Discrimination Act of 1975 (Age Discrimination Act): The Age Discrimination Act prohibits programs or activities that receive federal funding from discriminating against individuals based on age, unless federal, state, or local laws permit such discrimination. • Title IX of the Education Amendments Act of 1972 (Title IX): Title IX prohibits educational programs or activities that receive federal funding or financial assistance from discriminating against individuals based on sex.
• In addition to federal fair housing laws that ensure equal access to housing, several presidential executive orders have been issued to reduce discrimination and barriers to obtaining housing.
• In 1988, "disability" and "familial status" (the presence or expected presence of children under 18 in a household) were added as protected classes, further codified in the Americans with Disabilities Act of 1990. In certain situations, the law allows limi ted exceptions for discrimination based on sex, religion, or familial status.

2025 City of San Bernardino – Analysis of Impediments to Fair Housing Choice Page 77 of 77

Appendix B: Community Outreach

Table of Contents

Expected Resources ........................................................................................................................ 3 AP-15 Expected Resources – 91.220(c)(1,2) ............................................................................... 3 Annual Goals and Objectives .......................................................................................................... 8 Projects ...................................................................................................................................... 10 AP-35 Projects – 91.220(d) ........................................................................................................ 10 AP-38 Project Summary ............................................................................................................ 11 AP-50 Geographic Distribution – 91.220(f) ............................................................................... 19 Affordable Housing ....................................................................................................................... 21 AP-55 Affordable Housing – 91.220(g) ...................................................................................... 21 AP-60 Public Housing – 91.220(h) ............................................................................................. 28 AP-65 Homeless and Other Special Needs Activities – 91.220(i) .............................................. 31 AP-75 Barriers to affordable housing – 91.220(j) ..................................................................... 36 AP-85 Other Actions – 91.220(k) ............................................................................................... 38 Program Specific Requirements.................................................................................................... 41

Expected Resources
AP-15 Expected Resources – 91.220(c)(1,2)
Introduction
For the 1-year period covering July 1, 2025 through June 30, 2026, the City has planned for the following allocations:

1. CDBG – $2,712,293

2. HOME – $1,149,833.55

3. ESG – $241,347

Once the annual allocations from HUD are announced, the City will adjust the funding levels accordingly. Each program on the breakdown shows a percentage of the total awarded funding that each program represents. Once allocations are announced, the City

will revise funding levels for CDBG, HOME and ESG according to the percentages.

Anticipated Resources
Program Source
of Funds
Uses of Funds Expected Amount Available Year 1 Expected Amount
Available
Remainder of
ConPlan
$
Narrative Description
Annual
Allocation: $
Program
Income:
$
Prior Year
Resources:
$
Total:
$
CDBG public -
federal
Admin and
Planning
Housing
Public
Improvements
Public Services
$2,712,293 0.00 0.00 $2,712,293 $10,059,530 Amounts represent the annual CDBG allocation
based on the FY 2025-26
program year. This
funding year is the first
year in the 5-Year
Consolidated Plan.

This funding will be
invested in the public
facilities improvement,
recreation facilities,
homeless services, and
the Section 108
Program.

Program Source
of Funds
Uses of Funds Expected Amount Available Year 1 Expected Amount
Available
Remainder of
ConPlan
$
Narrative Description
Annual
Allocation: $
Program
Income:
$
Prior Year
Resources:
$
Total:
$
HOME public -
federal
Multifamily
rental new
construction
$1,149,833.55 0.00 0.00 $1,149,833.55 $4,264,578 Amounts represent the annual HOME allocation
based on the FY 2025-26
program year. This
funding year is the first
year of the 2025-2029
Consolidated Plan. This
funding will be invested
in the development of a
multi-family rental
housing project.

ESG public -
federal
Emergency
shelter
operations
HMIS
$241,347 0.00 0.00 $241,347 $895,123 Amounts represent the annual ESG allocation
based on the FY 2025
program year. This
funding year is the first
year of the 2025-26
Consolidated Plan.

ESG monies will fund
Emergency Shelter (ES)
and Data Collection
Depository.

Table 1 - Expected Resources – Priority Table

Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied
The City will focus on leveraging its federal resources with state, local and private capital to develop quality and decent affordable housing for San Bernardino residents. Additional funds to serve the needs of lower- and moderate-income residents include:

If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan The City has approved single-family residential projects, and many are under construction. These range from infill developments to larger subdivisions on vacant land, according to the City’s 2021- 2029 Housing Element. The City is partnering with Neighborhood Partnership Housing Services (NPHS) to build affordable single -family housing on infill parcels. The goal is to make homeownership more accessible. Presently, four manufactured housing units are approved for construction. NPHS deed restricts these units as affordable to lower income households through long-term affordability covenants. As of 2023, three housing units have been built and additional units are anticipated to be built through 2029. An unspecified number of units will also be ADUs.

Discussion
According to the City’s 2021 -2029 Housing Element, the City has enough available land and residential designations to meet the affordable housing needs of the community. However, the lack of funding plays a crucial role in meeting the needs of the community. More than 2,000 housing units, affordable and market rate, are in the development pipeline. The City will continue to leverage other funding sources to provide services to populations in need.

FY2025 HOME funds will assist, in part, Jamboree project, a multi-unit rental housing positioned on 3.5 acres of city -owned land designated to affordable housing development. This project contains 8 units reserved for individuals facing homeless, 101 affordable rental units for families earning at or below 60% of AMI. Amenities on the site will include: community room and kitchen, computer lounge, basketball court, swimming pool, and tot lot. Unit construction for Phase 1 and Phase are as follows:

Phase I
• (2) one-bedroom units
• (24) Two-bedroom units
• (25) Three-bedroom units
Phase II
• (2) one-bedroom units
• (24) Two-bedroom units
• (24) Three-bedroom units

Annual Goals and Objectives

AP-20 Annual Goals and Objectives
Goals Summary Information
# Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
2 Increase
Affordable
Housing Options
2025 2029 Affordable
Housing Citywide
Preserving and
rehabilitating
housing,
Expanding
homeownershi
p, Providing
homeless
services and
prevention,
Adding new
affordable
housing,
Promoting
economic
development,
Improving
facilities and
infrastructure
and Fair
Housing
HOME:
$1,034,850.20

Renter households
assisted: 101

3 Provide
Homeless and
Homeless
Prevention
Services
2025 2029 Homeless Citywide
Provide
Homeless and
Homeless
Prevention
Services
ESG: $241,347

4,140 people will
be provided with
homeless-related
services
ESG-255 homeless
individuals assisted
4 Community
Development 2025 2029
Non-Housing
Community
Development
Citywide Infrastructure
Improvements
CDBG:
$1,762,991
850 persons
assisted
through 2
community
facilities project
5 Resource
Efficiency and
Risk Mitigation
2025 2029
Non-Housing
Community
Development
Citywide
Responsible
Resource
Management
and
Community
Preparedness
CDBG:
$327,828
Persons
Assisted: 200
6 Support Fair
Housing 2025 2029 Fair Housing Citywide Fair Housing CDBG: $79,015 Persons Assisted:
2,700
7 Planning &
Administration 2025 2029 Administration Citywide Planning & Administration
CDBG:
$542,458
HOME:
$114,983.35
ESG:
$18,101

Other (planning
and
administration)
Table 2 – Goals Summary

Projects
AP-35 Projects – 91.220(d)
Introduction
The City intends to spend their annual allocation of CDBG, HOME, and ESG funds, on eligible projects in the following categories: promote fair housing, new affordable rental housing, provide supportive services to homeless individuals and those with special needs, and program planning and administration. CDBG funding also includes the repayment of the City's Section 108 Loan.

FY2025-26 HOME funding will be dedicated to funding a large affordable rental multi -unit housing development.

Projects
# Project Name
1 CDBG FY25/26 HOPE Campus
2 CDBG FY25/26 Section 108 Debt Repayment
3 CDBG FY25/26 Inland Fair Housing Mediation Board
4 CDBG FY25/26 San Bernardino PD Quality of Life Team
5 CDBG FY25/26 Cedar House
6 CDBG FY25/26 Pearl Transit
7 CDBG FY25/26 Whole Person Care Clinic
8 HOME FY25/26 Jamboree Project
9 FY25/26 ESG
10 FY25/26 CDBG Program Administration
11 FY25/26 HOME Program Administration
Table 3 - Project Information

Describe the reasons for allocation priorities and any obstacles to addressing underserved needs
Projects in AP-35 are consistent with the 2025-2029 Consolidated Plan priority needs and goals.

These projects, activities and programs have been identified by community engagement program and needs derived from data analysis. The City continues to support the development of HOPE Campus, Police Department neighborhood engagement program, and fair housing promotion and discrimination mediation. Public services CDBG and ESG funding was awarded to applicants who best serve the homeless and at-risk for homelessness populations.

AP-38 Project Summary

Project Summary Information
1 Project Name CDBG FY25/26 SB HOPE Campus
Target Area Citywide
Goals Supported Provide Homeless and Homeless Prevention Services Needs Addressed Provide Homeless and Homeless Prevention Services Funding CDBG: $1,074,214.00
Description The development of San Bernardino Navigation Center (HOPE Campus) Homeless Outreach Prevention Education Campus.

Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
250 homeless individuals and families
Location Description 796 E. 6th Street, San Bernardino City. This parcel of land is currently owned by the City.

Planned Activities Provide Homeless and Homeless Prevention Shelter. Temporary emergency shelter space for households and individuals. 2 Project Name CDBG FY25/26 SB Section 108 Debt Repayment Target Area Citywide
Goals Supported Infrastructure improvements
Needs Addressed Community development
Funding CDBG: $688,777.60
Description Section 108 Loan Repayment Program to pursue physical and economic revitalization that will provide jobs. Full repayment is expected 2026.

Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
It is estimated that there will be 600 jobs created

Location Description 17.43-acre commercial property located along Highland Avenue between Arden Street and Guthrie Street in the City.

Planned Activities The City has moved forward with the sale of the property and using a Section 108 loan for the repayment of the Arden Guthrie Project. The City is currently in legal review for a one-year renewal with Rich Development, to develop the properties. The timeline of 6-12 months from executing the agreement to move into a disposition agreement. The developer has secured letters of interest and lease commitments from several major retailers directly associated with the project.
3 Project Name CDBG FY25/26 Inland Fair Housing Mediation Board Target Area Citywide
Goals Supported Fair Housing
Needs Addressed Fair Housing
Funding CDBG: $79,015.00
Description Inland Fair Housing Mediation Board will provide activities that will assist the City in furthering fair housing.

Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
2,700 Individuals
Location Description Citywide
Planned Activities IFHMB will provide investigation, education, reconciliation, and/or referral of housing discrimination complaints free of charge in the City. IFHMB offers workshops to educate housing providers, tenants, homeowners, and financial and lending institutions on fair housing laws.
4 Project Name CDBG FY25/26 San Bernardino PD Quality of Life Team Target Area Citywide
Goals Supported Provide Homeless and Homeless Prevention Services Needs Addressed Provide Homeless and Homeless Prevention Services

Funding CDBG: $194,489.00
Description Support Quality of Life Team salaries and equipment needs including an appropriate vehicle needed to assist local businesses, the homeless, and homeless encampments as well as participate in community cleanup activities related to homeless encampment areas.

Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
100 individuals
Location Description Citywide
Planned Activities The Quality-of-Life Team members will work with City Police Department to engage with and support to local nonprofits and residents of LMI areas.
5 Project Name CDBG FY25/26 Cedar House
Target Area Citywide
Goals Supported Provide Homeless and Homeless Prevention Services Needs Addressed Provide Homeless and Homeless Prevention Services Funding $24,692
Description Recovery services for drug and alcohol addiction. Outreach to area organizations and businesses offering to share our Overdose Prevention Training and information on our residential and outpatient services with their employees and clientele.

Target Date 06/30/26
Estimate the number
and type of families
that will benefit
from the proposed
activities
240 individuals
Location Description 18612 Santa Ana Ave, Bloomington, CA 92316

Planned Activities The Cedar House Life Change Center will use CDBG funds to pay for staff salaries and program administration that will provide addiction treatment and outreach of Overdose Prevention Training services.
6 Project Name CDBG FY25/26 Pearl Transit
Target Area Citywide
Goals Supported Provide Homeless and Homeless Prevention Services Needs Addressed Provide Homeless and Homeless Prevention Services Funding $59,262
Description Their services include registration, mobile or in-home digital dental scanning, and the 3D printing of custom dentures, aligners, and bite guards.

Target Date 06/30/26
Estimate the number
and type of families
that will benefit
from the proposed
activities
3,800 individuals
Location Description Homeless population areas
Planned Activities Pearl Transit will use CDBG funds for staff salaries and program administration for a no-cost dental prostheses to low-income and or homeless individuals.
7 Project Name CDBG FY25/26 Whole Person Care Clinic
Target Area Citywide
Goals Supported Resource Efficiency and Risk Mitigation Needs Addressed Responsible Resource Management and Community Preparedness
Funding $49,385
Description Facilitate the Term Post-Hospitalization Program is an interim housing site designed to support individuals experiencing homelessness with complex medical or behavioral health needs as they recover and begin their journey of housing stabilization.

Target Date 06/30/26
Estimate the number
and type of families
that will benefit
from the proposed
activities
200 individuals
Location Description 1410 N. Garey Ave, Pomona, CA 91767 Planned Activities WPCC will provide short-term post-hospitalization housing services at their 160-bed capacity interim housing site. At this site, WPCC will provide up to six months of stability, ensuring members receive medical, behavioral health, and housing support they need during their recovery.
8 Project Name HOME FY25/26 Jamboree Project
Target Area Citywide
Goals Supported Increase Affordable Housing Options
Needs Addressed Adding new affordable housing
Funding $1,034,850.20
Description Develop 101 affordable rental units for low-income families as well as 8 units designated for homeless individuals and families.

Target Date 6/30/27
Estimate the number
and type of families
that will benefit
from the proposed
activities
101 households
Location Description 5th and Meridian Streets, San Bernardino Planned Activities FY2025/26 HOME funds will assist the construction of a multi- unit affordable rental housing located on 3.5 acres of city-owned land designated to affordable housing development. Ultimately Jamboree project will contain 8 units reserved for individuals facing homeless and 101 affordable rental units for families earning at or below 60% of AMI.
9 Project Name FY25/26 ESG
Target Area Citywide

Goals Supported Provide Homeless and Homeless Prevention Services Needs Addressed Provide Homeless and Homeless Prevention Services Funding $241,347
Description The City will continue to comply with the service and reporting requirements outlined in the Annual Action Plan and other ESG administrative regulations. For the FY 2025/26 allocation:
- $18,101 administration costs
- Salvation Army:
o $139,265 Emergency Shelter operations
o $13,997 Homeless Prevention
o $13,997 HMIS
- Family Services of Redlands:
o $55,987 Rapid Rehousing
Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
255 homeless individuals
Location Description Citywide
Planned Activities Grant and project management for emergency shelter and HMIS services.
10 Project Name FY25/26 CDBG Program Administration
Target Area Citywide
Goals Supported Planning and Administration
Needs Addressed Planning and Administration
Funding CDBG: $542,458.00
Description The City will implement the goals and objectives of the ConPlan by delivering a variety of housing and community development programs and activities. The City will also continue to comply with the planning and reporting requirements of the activities and programs stated in the Annual Action Plan as well as other CDBG administration regulations.

Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
1 Location Description Citywide
Planned Activities CDBG Planning and grant administration and compliance. 11 Project Name FY25/26 HOME Program Administration
Target Area Citywide
Goals Supported Planning and Administration
Needs Addressed Planning and Administration
Funding $114,983.35
Description The City will implement the goals and objectives of the ConPlan by delivering a variety of housing programs and activities. The City will also continue to comply with the planning and reporting requirements of the activities and programs stated in the Annual Action Plan as well as other HOME administration regulations.

Target Date 6/30/2026
Estimate the number
and type of families
that will benefit
from the proposed
activities
1 Location Description Citywide
Planned Activities HOME Planning and grant administration and compliance.

AP-50 Geographic Distribution – 91.220(f)
Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed The city will use its funding for FY2025 -2026 to finance projects targeting low - to moderate - income individuals and families throughout the City. Funding will also be used for a variety of housing, community development, economic development, and capital improvement projects.

CDBG, HOME and ESG funds benefit individuals, families, households and homeless populations throughout the City. Public facilities projects assist residents in census blocks and tracks where 51 percent or more of the households are low- to moderate-income.

According to the U.S. 2020 Census, approximately 66.2 percent of the population is of Hispanic Origin, 14.4 percent is Non -Hispanic, White, 13.2 percent is Black, 4.1 percent is Asian, and 8.1 percent is comprised of two or more races.

While the City has been home to different race and ethnic groups, significant demographic changes have occurred since 2000. For instance, Whites declined from the majority group (53 percent) in 2000 to only 35 percent by 2019. Hispanics have become the maj ority at 65 percent of the population. Blacks and Asians have remained generally stable in number during this time. 2020 Census figures indicate that Hispanics have continued to increase in number and proportion. Many residents were also born outside the U nited States; more than one in five are foreign born, and of those, 80 percent are from Latin America. Because of the City’s race and ethnic composition, a larger proportion of residents than in other communities speak languages other than English.

Geographic Distribution
Target Area Percentage of Funds
Citywide 30
LMI Areas of the City 70
Table 4 - Geographic Distribution

Rationale for the priorities for allocating investments geographically As part of the development of the 2025-2026 Action Plan, the City established priority needs based on an in-depth analysis of several factors such as housing, homelessness, poverty, special needs, lead hazards, institutional structure, etc. The City will utilize its federal funding to pursue goals and objectives listed in the section “AP-20 Annual Goals and Objectives” of this document.

The City’s primary intent is to spend its CDBG funds in predominantly low-income neighborhoods where residents have the greatest need for housing/ services. Projects are evaluated on a case -

by-case basis, while considering emergency needs, cost effectiveness, feasibility, and availability of other funding to address the specific needs.

Discussion
The City will allocate its funds to organizations that will provide housing and support services to low-income households. The process for every annual action plan requires the City in prioritizing the use of its CDBG funding for housing and community development activities, including the preservation and conservation of affordable housing, activities, public improvements and public facilities.

Affordable Housing
AP-55 Affordable Housing – 91.220(g)
Introduction
According to the city’s 2021 -2029 Housing Element, t he size of housing is often determined by market demand and the development regulations imposed (density, unit size, lot coverage) or incentives (regulatory and financial) offered for different types of housing. Offering an appropriate size of unit helps t o ensure that single-person households, small families, and large families have housing best suited to their needs and do not have to overcrowd into small units or pay too much for housing not suited to their needs.

An assessment of housing stock by bedroom number reveals distinct patterns of development that likely influence the type and size of household occupying the home. • Single-family homes predominantly consist of three - and four -bedroom units (80 percent), which is expected given the purpose of the homes and the desire to accommodate families with children. Approximately 15 percent of these units are two - bedroom homes.
• Condos, townhomes, and mobile homes are predominantly two - and three -bedroom units (80 to 90 percent). The primary difference is that the first two multi -family types contain more one-bedroom units, and mobile homes have more four-bedroom units. • Apartments are predominantly (95 percent) one - or two -bedroom units. Most studio units are likely senior units. Of note, only 4 percent of the stock has three or more bedrooms, suitable for large families. Deed-restricted projects often have 8 to 10 percent large-family units.

Based on this assessment and the demographics of San Bernardino, there appears to be a lack of rental apartments that are large enough to accommodate large families, particularly lower income families. Given that more than two -thirds of the City’s single -family, condominiums, townhomes, and mobile homes are two- and three-bedroom units, it stands to reason that larger families of more than five members could have a difficult time finding vacant and affordable housing stock.

Housing affordability refers to how much a household can afford to pay for a home and is defined as the ratio of housing expenses to income (“cost burden”). The housing industry typically assumes that the “affordable” payment for a homeowner should range from 30 to 40 percent of gross monthly income, with the latter figure being used in the California Association of Realtors’ first-time homebuyers’ index. For renters, the appropriate cost burden varies from 30 to 40 percent, with the latter being used under the Federal housing choice voucher program. This

Housing Element uses a midpoint of 35 percent cost burden for ownership (many expenses are tax deductible) and 30 percent for renters as the threshold for housing overpayment.

The table below shows the amount that households of different incomes can afford for a home in the City, and the following descriptions compare housing affordability for different incomes.

Special housing needs refer to needs that are not typical of most households in a City. For instance, special needs may refer to housing accommodations (units that are larger, accessible, or affordable) or supportive services essential for a particular type of household. Section 65583(a)(7) of the Government Code requires that the housing e lement contain an analysis of the special housing needs of seniors, female-headed households, single-parent families, disabled persons, developmentally disabled persons, large families, farmworkers, and unhoused persons.

Certain special needs groups may have difficulty finding housing in the City and may require specialized services, assistance, and accommodations. Due to the challenges that accompany special needs, these individuals and households may be more likely to earn extremely low to low incomes. Special needs groups include seniors, persons with disabilities (mental, physical, and/or developmental), veterans, persons with HIV/AIDS, single -parent households, large households, homeless persons, and persons who are at-risk of homelessness.

Senior citizens are defined as any person aged 65 or older. Seniors may have special housing

needs primarily due to income, healthcare costs, and physical or mental disabilities, particularly those that tend to increase with age. As a result, seniors may face difficulty in finding housing and may become victims of housing discrimination or fraud.

According to the 2017 -2021 ACS estimates approximately 20,826 seniors resided in the City, representing 9.4 percent of the total population. The senior population is growing at a faster pace than the overall population. Between 2011 and 2021, the total num ber of seniors in San Bernardino increased by 24 percent while the City’s total population between those two years increased by only 5 percent.

Physical, mental, and/or developmental disabilities may prevent a person from working, restrict one’s mobility, or make self -care difficult. Disabled persons frequently have special housing needs, often related to a potentially limited ability to earn enou gh income, a lack of accessible and affordable housing, and higher health costs associated with a disability. In addition, persons with self -care and mobility limitations may require special housing design features such as wheelchair ramps, grab bars, spec ial bathroom designs, wider doorway openings, and other features.

Disabled persons are often more vulnerable to housing discrimination. This discrimination can take on many forms, including, but not limited to, refusal to rent or sell, or refusal to make a reasonable accommodation or modification to the unit. Reasonable accommodation refers to any change, exception, or adjustment that would allow a person with a disability to access, use, or enjoy housing. Examples of this would include allowing a service animal in a housing unit that does not allow pets or installing ramps for a tenant who uses a wheelchair.

Section 504 of the Rehabilitation Act of 1973 guarantees certain rights to people with disabilities.

This legislation was one of the first U.S. Federal civil rights laws offering protections for people with disabilities. HUD’s section 504 regulation define s a person with a disability as any person who has a physical or mental impairment that substantially limits one or more major life activities. The term physical or mental impairment may include, but is not limited to, conditions such as visual or hearing impairment, mobility impairment, HIV infection, developmental disabilities, drug addiction, or mental illness.

According to 2017-2021 ACS data, 13.2 percent of San Bernardino residents reported a disability with the most prevalent being cognitive and ambulatory difficulties at seven percent of the total population for each. Six percent of the population also experiences independent living difficulty and may face housing discrimination or have trouble finding housing that fits their individual

needs.

Individuals with HIV/AIDS are protected against housing discrimination under the Fair Housing Act of 1968 and section 504 of the Rehabilitation Act of 1973 which protects the rights of Americans living with disabilities. According to the Americans with Dis abilities Act of 1990, a disability is defined as a physical or mental impairment that significantly limits the ability to perform major life activities. The 1998 Supreme Court case of Bragdon v. Abbott upheld that HIV/AIDS is a disability as outlined by the ADA, and that reproduction is a major life activity.

Persons with HIV/AIDS often face housing discrimination due to the stigma associated with their health status. The housing status of an HIV/AIDS patient is crucial to the quality of their care.

Each year, HUD investigates complaints of alleged housing discrimination against individuals with disabilities, including HIV/AIDS. According to the CDC, housing stability is a significant barrier to HIV care and stable housing is closely linked to successful HIV-related health outcomes.

According to the 2022 California HIV Surveillance Report , the number of new HIV diagnoses across the state increased by 0.4 percent between 2018 and 2022. The number of newly diagnosed people in the County of San Bernardino was 278 in 2018 and 291 in 2022. In 2022, the County had a total of 5,466 persons living with a diagnosed HIV infection, of which 67 percent were in care and 57.1 percent had virally suppressed HIV. The total number of persons living with HIV in the County increased by 17 percent between 2018 and 2022.

Homelessness is attributable to challenges resulting from the loss of employment, difficulty finding jobs, the need to develop or redevelop marketable skills, the cost of housing, chronic health problems, physical disabilities, mental health disabilities, drug and alcohol addiction, and/or a host of other factors. Individuals or families who are homeless have a variety of special needs, including emergency shelter, counseling, job training, transitional housing, and permanent supportive housing.

The 2024 San Bernardino County Point in Time (PIT) Count documented 1,417 homeless individuals in the City. Between 2019 and 2024, the City’s unhoused population increased by 59 percent.

Large households are defined as households with five or more members. The size and composition of large households varies from family to family and from home to home. Typically, these are households with multiple children or mixed -family arrangements, such as households

with more than two generations or immediate families cohabitating.

Large households are considered a special needs group because of the limited availability of adequately sized, affordable housing units. To afford shelter in addition to food, clothing, and medical care, very low- and low-income large households may live in overcrowded conditions.

Single-parent families, particularly female -headed families, often require special consideration and assistance due to the limited resources necessary to have one person head up the household versus two. There is a greater need for affordable housing and a ccessible daycare, healthcare, and other supportive services. Because of more limited resources, relatively lower income, and higher burden of living expenses, female-headed families have more limited opportunities to find affordable, decent, and safe housing. Female-headed families may also be discriminated against in the rental housing market because some landlords are concerned about the ability of these households to make regular rent payments. Consequently, landlords may require more stringent credit checks for women, violating fair housing laws.

According to 2017-2021 ACS data, the City comprises 60,614 households, with 10,992 classified as single-parent households, representing approximately 18 percent of all households. Among these, there are 6,521 male -headed households with no spouse present ( 10.8 percent of all households) and 13,831 female-headed households with no spouse present (22.8 percent of all households). Of these demographics, 3,003 male householders (no spouse present) live with their children under the age of 18 (27.3 percent of single-parent households), while 7,989 female householders (no spouse present) live with their children under the age of 18 (72.7 percent of single-parent households).

One Year Goals for the Number of Households to be
Supported
Homeless: 600
Non-Homeless
Special-Needs
Total: 600
Table 5 - One Year Goals for Affordable Housing by Support Requirement

One Year Goals for the Number of Households Supported
Through
Rental Assistance:

The Production of New Units: 101
Rehab of Existing Units: 10
Acquisition of Existing Units: 0
Total: 111
Table 6 - One Year Goals for Affordable Housing by Support Type

Discussion
California’s housing crisis is a half century in the making. Decades of underproduction combined with exclusionary policies have left housing supply far behind need and costs soaring. As a result, millions of Californians, disproportionately lower income a nd people of color, must make hard decisions about paying for housing at the expense of food, health care, childcare, and transportation. This crisis is affecting every region of the state, including southern California.

State and local agencies are working to support housing development to lower -income households. Every eight years, the state of California sets a target for homes needed for each income level to meet the housing needs of all Californians. Local governments must plan for enough housing to meet the housing need in their communities. As described in Chapter 4, SCAG finalized a RHNA allocation for each member jurisdiction. The City was assigned a future need for 1,415 very low-income units, of which half (703 units) are the projected need for extremely low- income households from 2021 to 2029.

The City is facilitating and encouraging the development and rehabilitation of existing housing to meet the needs for ELI housing. Projects from groups such as National Core— which is currently replacing the 400 -unit Waterman Gardens public housing project with new affordable housing and supportive services on-site—are providing much-needed housing options for extremely low- income residents. Organizations like NHPS, Mary Erickson, and many other nonprofit and for - profit organizations are building infill housing that is affordable to lower income households.

Accessory dwelling units can also provide affordable housing. Recent state laws have streamlined the development of ADUs, making them increasingly affordable and accessible to build. ADUs can provide free housing and lodging for relatives or be rented at affordable rates.

The city will continue to partner with the Housing Authority of the County of San Bernardino (HACSB), the public housing authority (PHA) for the county, which issues rental vouchers to bridge the gap between income, affordability, and market rate housing. The two forms of

vouchers provided to aid tenants throughout the city are tenant based and project-based vouchers issued to residents in San Bernardino City.

AP-60 Public Housing – 91.220(h)
Introduction
California’s housing crisis is a half century in the making. Decades of underproduction combined with exclusionary policies have left housing supply far behind need and costs soaring. As a result, millions of Californians, disproportionately lower income a nd people of color, must make hard decisions about paying for housing at the expense of food, health care, childcare, and transportation. This crisis is affecting every region of the state, including Southern California.

State and local agencies are working to support housing development to lower -income households. Every eight years, the state of California sets a target for homes needed for each income level to meet the housing needs of all Californians. Local governments must plan for enough housing to meet the housing need in their communities. The Southern California Association of Governments (SCAG) finalized a RHNA allocation for each member jurisdiction.

The City was assigned a future need for 1,415 very low -income units, of which half (703 units) are the projected need for extremely low-income households from 2021 to 2029.

The Housing Authority of the County of San Bernardino (HACSB) serves the city. HACSB has one public housing site, a single-family unit in Apple Valley. HACSB converted a 98-unit public housing site in Upland into a project-based voucher site. There are no public housing units in the City.

The City has a significant amount of housing stock that receives public subsidies in return for long-term covenants guaranteeing the affordability of units. As shown in the table below, the City currently has 3,804 affordable units receiving public subsidies, with 707 at risk of expiring. 38 percent of these units are limited to senior residents.

Assisted Rental Housing Projects
Development Name Target
Residents
Project
Financing
Total
Units
Affordable
Units
Earliest
Expiration
At Risk
Status
Sterling Village Large Family LIHTC 80 79 2036 Not At-Risk Magnolia at
Highland Senior LIHTC 80 79 2041 Not At-Risk
Lugo Apartments Senior LIHTC 119 118 2044 Not At-Risk
Vintage at Kendall Senior LIHTC 178 176 2043 Not At-Risk Arrowhead Vista Senior LIHTC 40 39 2069 Not At-Risk
New Zion Manor Family LIHTC 125 125 2071 Not At-Risk
Beautiful Light Inn Seniors LIHTC 100 99 2072 Not At-Risk Pioneer Park Plaza All Ages LIHTC 161 159 2073 Not At-Risk Foothill Villas Large Family LIHTC 239 237 2075 Not At-Risk

Baseline Coop Senior 202/811 75 74 Permanent Not At-Risk St. Bernardine Plaza Senior 202/811 150 148 2037 Not At Risk TELACU Monte Vista Senior 202/811 75 74 2057 Not At-Risk TELACU San Bern. V Senior 202/811 75 74 2065 Not At-Risk TELACU Buena Vista Senior 202/811 75 74 2058 Not At-Risk TELACU Sierra Vista Senior 202/811 75 74 2057 Not At-Risk TELACU La Amistad Senior 202/811 89 89 2064 Not At-Risk TELACU Hacienda Senior 202/811 75 74 2064 Not At-Risk
AHEPA 3002 Senior 202/811 90 90 2047 Not At-Risk
Meadowbrook Park Family HAP/HOME 267 210 2033 Not At-Risk Creekside
Apartments Family Bonds 304 60 2049 Not At Risk
All Star Lodge PSH HOMEKEY 75 75 N/A Not At Risk
Valencia Vista Large Family LIHTC 76 75 2068 Not At-Risk Olive Meadow Large Family LIHTC 62 42 2073 Not At Risk
Crestview Terrace Large Family LIHTC 184 182 2076 Not At Risk Tuscany/Silverwood Family Bond 328 66 2057 Not At Risk
Eastpointe Village Family RDA/NSP 52 52 2046 Not At-Risk Phoenix Apartments Transitional CalHFA 9 9 2033 Not At-Risk Golden Apartments PSH HOME 39 38 2057 Not At-Risk
San Bernardino
Senior Senior 202/811 80 79 2042 Not At-Risk
Pacific Village All Ages HCD -- -- 2033 Not At-Risk
Village Green All Ages LIHTC/HAP 184 181 2042 Not At-Risk Maplewood Home Family PBV 296 296 2026 Low Risk
Arrowhead Woods Senior PBV 51 51 2027 Low Risk
Kendall Drive Apts. Family PBV 37 6 2025 Low Risk
Kendall Park Apts. Family PBV 52 4 2025 Low Risk
Frazee Family HOME 14 13 2029 Low Risk
7 Arrows Family HOME 9 9 2029 Low Risk
Ramona Sr. Project Senior LIHTC/MRB 44 43 2024 High Risk The Waterman Large Family LIHTC 128 127 2030 High Risk
Autumnwood/Millcr
eek All Ages LIHTC 160 158 2030 High Risk
Subtotal by Type Total
Units
Affordable
Units At-Risk Units Percent
Senior Projects 1,542 1,448 94 6%
Family/All Ages Projects 2,514 2,155 613 24%

Permanent Supportive Housing 123 122 0 0%
Total (All Affordable Units) 4,179 3,804 707 16%

Actions planned during the next year to address the needs to public housing The City is facilitating and encouraging the development and rehabilitation of existing housing to meet the needs for ELI housing. Projects from groups such as National Core— which is currently replacing the 400 -unit Waterman Gardens public housing project with new affordable housing and supportive services on-site—are providing much-needed housing options for extremely low- income residents. Organizations like NHPS, Mary Erickson, and many other nonprofit and for - profit organizations are building infill housing that is affordable to lower income households.

The City will maintain contact with the owners of at-risk units, encourage the owner to keep the at-risk units affordable, and utilize, if feasible, local incentives to preserve any at -risk units. To develop or preserve the City’s affordable housing stock, the City will provide technical and/or financial assistance to local non-profit organizations that provide affordable housing.

Actions to encourage public housing residents to become more involved in management and participate in homeownership
The City will continue their partnership with NPHS to build affordable single -family housing on infill parcels. The goal is to make homeownership more accessible. Presently, four manufactured housing units are approved for construction. NPHS deed restricts these units as affordable to lower income househol ds through long -term affordability covenants. As of 2023, and three housing units have been built, and additional units are anticipated to be built through 2029. An unspecified number of units will also be ADUs.

The City collaborates with the HACSB to encourage public housing residents to utilize City housing services and area homeownership programs, particularly residents of public housing . HACSB administers the Housing Choice Voucher (HCV) program for the City. Public housing residents would be assisted with HCVs upon availability and if needed.

If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance
HACSB has not been designated as troubled. HACSB was designated a Moving To Work Agency by Congress in 2008. This is a limited designation to PHAs across the country.

AP-65 Homeless and Other Special Needs Activities – 91.220(i) Introduction
The County of San Bernardino is required to conduct a biennial Homeless Count , the Point -In- Time Count (PITC) to identify persons who are not living in adequate housing facilities, led by the Continuum of Care (CoC). There were 4,255 adults and children who were counted as homeless during the 2024 PITC. The previous PITC was completed in 2023 during which 4,195 persons were counted. A comparison of the last two counts reveals that:

• 42 more persons were counted in 2024, which represents an increase of 1.4%; • 79 more persons were counted as unsheltered in 2024 when compared to the unsheltered count in 2023, which represents an increase of 2.6%; and • 19 less persons were counted as sheltered in 2024 when compared to the sheltered count in 2023, which represents a decrease of 1.6%.

Specifically for the City it was found:
• 337 Sheltered persons
• 103 Transitional housing
• 977 Unsheltered
• Total of 1,417

Overall, 85 persons were less 150,000 in ESG funds to emergency shelters and $60,000 to Rapid Re-Housing, $15,000 to Homeless Prevention and $15,000 to HMIS system. In 2024 ESG funds assisted 295 homeless individuals through emergency shelter funds and 8 households through homeless prevention programs . Looking ahead to FY 2025, the City anticipates providing Emergency Shelter assistance to approximately 150 households and serving 20 households or approximately 75 individuals through the Rapid Rehousing program and 10 households through homelessness prevention services.

Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including: Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
A top priority need in the City is to be able to provide sufficient homeless and prevention services.

The City will continue to support the CoC’s coordinated entry system, 2 - 1-1 San Bernardino County. The Coordinated Entry System will provide people who are at imminent risk of becoming homeless (HUD Homeless definition (Category 2)) with problem-solving support to retain current housing or to locate and get housing placement. Results of the community outreach completed

for the ConPlan include supporting efforts to:
- Increase affordable housing units
- Increase homeless prevention services
- Support mental health and substance use services

Addressing the emergency shelter and transitional housing needs of homeless persons.

The City intends to adaptively reuse a vacant property for the conversion of the former School of Hope campus. Formerly a special education school will be reimagined into a homeless navigation facility to provide low barrier, noncongregate, interim housing and supportive services for homeless individuals and households at risk of becoming homeless. The Proposed Project would involve the rehabilitation of two existing buildings, and the demolition of three existing buildings and ancillary structures, to accommodate 180 housing units, an administrative building, a laundry facility, and cafeteria/assembly area. In addition to the rehabilitation of two existing structures, the Project would install 11 prefabricated structures on proposed concrete pads. In total, the Proposed Project would provide approximately 17,380 sqft of residential housing, 2,900 sqft of shared spaces and common areas, a dog kennel, and 15,200 sqft of surfacing parking consisting of 34 parking spaces.

Hope Campus will contain 180 non-congregate transitional housing units with beds with storage spaces underneath the beds, bathrooms (with a sink, toilet, and shower), fire sprinklers, and heating, ventilation, and air conditioning (HVAC) systems. These 180 units would accommodate 200 individuals. Sixteen units would be Americans with Disabilities Act (ADA) accessible, ensuring accessibility for future residents with disabilities. The facilities will include a cafeteria with a fully equipped commercial kitch en able to serve 120 residents per meal. The cafeteria would also serve as an assembly area and would include moveable dividers to divide the cafeteria into four smaller areas for activities. The campus will have free Wi-Fi access and outdoor spaces for all occupants.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again
The City actively participates in the County of San Bernardino CoC by attending meetings to discuss how to establish performance measures that benefit the broader goals of the region.

Some of the tasks recently undertaken by the City include: assisting with the 2024 Point-In-Time- Count conducted by the County of San Bernardino. The City recognizes that homelessness is a

regional issue that impacts every community in the region. As the largest community in the County, the City also serves as a hub for service providers. The City supports the efforts of the network of agencies working to end homelessness through the Regiona l Continuum of Care Strategy. The Continuum of Care Strategy involves four key components, one of which is homeless prevention. The provision of preventative services will decrease the number of households and individuals who will become homeless and requi re emergency shelters and assistance. The City is working to prevent persons from becoming homeless by funding emergency rental assistance for households at-risk of homelessness.

Annually the City funds organizations through the ESG programs that provide street outreach, emergency shelter, homeless prevention services, rapid rehousing, and HMIS such as Salvation Army and Family Services of Redlands. The City is breaking ground in 2025 and 2026 on the San Bernardino HOPE Campus a full -service homeless navigation center and shelter that features needed services as part of its operation located on 6th Street (see Discussion below).

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs
In San Bernardino County , several organizations and programs work to help low -income individuals and families avoid homelessness, particularly those at risk due to discharge from a public institution or receiving assistance from agencies that address housing, health, social services, employment, education, or youth needs. The San Bernardino County Workforce Development Department (WDD) administers programs funded by the Department of Labor’s Workforce Innovation and Opportunity Act (WIOA). WDD implements comprehensive strategies tailored to meet the demands of local businesses for skilled workers. These initiatives provide avenues for job seekers to acquire necessary skills and access well-paying career opportunities.

The City will continue to support the regional CoC’s efforts to implement the San Bernardino County 10-Year Strategy for Ending Homelessness. This plan includes a recommendation to focus on discharge planning to prevent people from becoming homeless when they are discharged from correctional, foster care, health care, or mental health care systems. The McKinney -Vento Act requires that State and local governments have policies and protocols in place to ensure that persons being discharged from a publicly funded institution or system of care are not discharged immediately into homelessness. To meet HUD’s requirements, the 10 -Year Strategy has established a Discharge Planning Committee to focus on improving coordination between

discharge planning agencies, local government, and homeless service providers to implement a “zero tolerance” plan that will prevent persons from being discharged into homelessness.

Discussion
HOPE Campus
The City is constructing a Navigation center at the former "School of Hope" campus to provide low-barrier, non-congregate, interim housing to help address the root causes of homelessness.

The HOPE C ampus has 200 beds and will connect homeless men, women and families to resources, medical respite, mental health, substance disorder counseling, individualized case management, job training and placement, and expanded access to permanent housing. It will also assist individuals who are at risk of becoming homeless as loca l agencies will be onsite to provide rental assistance and utility assistance to eligible households.

HomeKey - San Bernardino with Lutheran Social Services of Southern California (LSSSC) In collaboration with Lutheran Social Services of Southern California (LSSSC), the City has embarked on a State of California HomeKey Project to establish the San Bernardino Community Wellness Campus - a non-congregate interim housing facility comprising 150 beds. This initiative aims to address the pressing need for such a campus, especially considering that the number of homeless men in the City surpasses that of homeless women by a ratio of two to one. The current Central City Lutheran Mission will be transformed into a supportive campus that will provide an onsite medical clinic and comprehensive, onsite social services to address educational, social, physical, and mental health needs that will be available to campus residents and the larger community.

Legal Aid Society of San Bernardino (Legal Aid) Tenant Protection Program Legal Aid will host a two -year program that would only serve City residents free of charge with direct legal representation on matters concerning tenant rights through education to prevent or avoid displacement and homelessness.

Homeless Outreach
The City has joined forces with Hope the Mission, a non -profit dedicated to tackling homelessness, to extend vital assistance five days a week. Their collaborative outreach team is committed to offering transportation services to those seeking shelter, accessing crisis support, pursuing rehabilitation, or reconnecting with their families through reunification programs.

The outreach team will be made up of emergency crisis workers that can immediately assist with multiple family/individual crisis as they arise. The team will assist with case mgmt., motel vouchers, basic needs, medical and transportation , in addition to providing a diverse range of

resources, including access to longer-term shelters, rehabilitation programs, and assistance with family reunification. The team will also deliver essential services to individuals experiencing homelessness. Their priority is to ensure that housing opportunities are prioritized for residents of San Bernardino.

AP-75 Barriers to affordable housing – 91.220(j)
Introduction:

The City recognizes that barriers to affordable housing exist and continues to employ strategies to overcome them. As noted in the ConPlan’s SP-55, barriers and impediments to affordable and accessible housing are:

1. Environmental Reviews & Land Use Regulations:

2. Community Opposition & Density Restrictions

3. Zoning Limitations on Emergency Shelters & Transitional Housing

4. Constraints on Multi-Family & Supportive Housing

5. Regional Housing Needs Allocation (RHNA) Challenges

6. Accessibility Barriers for Individuals with Disabilities

7. Financial Constraints & Development Costs

Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment
The City has undertaken notable initiatives to remove restrictions linked to land use regulations by creating and implementing a new Development Code that consolidates and streamlines the City's development rules and procedures. This initiative was succeeded by restructuring the City to consolidate multiple development -oriented departments into a unified Community Development Department and creating a centralized permit counter.

Furthermore, the City has implemented the following changes to the Municipal Code to further decrease obstacles to affordable housing:

1. General Lot Consolidation Incentive : Small, separate lots offer limited development opportunities and typically cannot support onsite property management. Development potential can be enhanced through a small -lot consolidation initiative that provides a 15 percent density bonus for projects with a residential component that commits to a maintenance plan and onsite management. The city plans to amend the Development Code to encourage lot consolidation.

2. Density Bonus Provisions : Projects that utilize density bonuses can be a vital source of housing for low - to moderate -income households. The city intends to update the Development Code to reflect the latest amendments to State density bonus laws.

3. Transitional and Supportive Housing: The City plans to amend the Development Code to adequately define transitional and permanent supportive housing and permit these uses based on unit type, in accordance with Senate Bill 2.

4. Streamlined Processing: The City remains committed to further simplifying development activities and regulations and will continue to evaluate potential initiatives aimed at removing land use limitations, particularly concerning the construction of new housing and the renovation of existing housing. In 2012, the City revised its Development Code to enhance usability and reduce confusion among staff and the development community.

As part of this update, the City introduced a new simplified form of Conditional Use Permit known as the Minor Use Permit (MUP). The Development/Environmental Review Committee assesses the MUP instead of the Planning Commission, requiring less staff involvement (resulting in a comparatively quicker process for developers), reduced fe es, and serving as a substitute for a CUP for specific qualified projects.

To tackle housing affordability and the scarcity of financial resources for affordable living, the ConPlan advocates for the allocation of CDBG and/or HOME funds to maintain and improve housing units and offer homeownership prospects to low - and moderate-income families. Even though the City has lost access to redevelopment funds, it will still utilize its CDBG and HOME funds to draw in private and other public resources, including land transferred to the City, to develop affordable housing for low- and moderate-income families.

Discussion:

For FY 2025 -2026, the City will continue to fund its Infill Housing Program and the Owner - Occupied Residential Rehabilitation Program (OORP). Through the City’s Infill Housing Program, the City will acquire, rehabilitate vacant and/or underutilized parcels of land and create housing affordable to low - and moderate -income households. The Owner - Occupied Residential Rehabilitation Program will pro vide deferred loans for the rehabilitation of single -family units owned by low and moderate-income households. The City will continue to leverage its CDBG and HOME funds to attract private and other available public resources, including land conveyed to the City to create affordable housing for low- and moderate- income households.

AP-85 Other Actions – 91.220(k)
Introduction:

This section discusses the City’s efforts in addressing underserved needs, expanding and preserving affordable housing, reducing lead -based paint hazards, and developing institutional structure for delivering housing and community development activities.

Actions planned to address obstacles to meeting underserved needs.

The City is directly tackling the needs of those underserved through several key actions: 1) HOPE Campus, 2) revitalization of the City’s community centers and parks, 3) support for existing shelters and fair housing actions, 4) support for needed infrastr ucture improvements in low - income neighborhoods, and 5) renewal of housing preservation program Owner -Occupied Housing Rehabilitation Program through NPHS. The infusion of ARPA funding has helped the City tremendously to fight homelessness and improve qual ity of life conditions through the development of HOPE Campus, implementation of a Violence Intervention Program, and needed street repairs in low-income neighborhoods.

In the very near future a major obstacle to addressing underserved needs will be the lack of adequate funding, especially for affordable housing activities. Post pandemic state and federal funding reductions will lessen the City's ability to address the extensive needs in the community is seriously compromised. The City will continue efforts leverage available funds to meet underserved needs. The City relies on the 2021-2029 Housing Element, on its commitment to pursue state, federal, and other funding opp ortunities to increase the supply of safe, decent, affordable housing in the City for extremely low, very low and low-income households .

Particularly senior, veteran and disabled households as well as those households at risk of homelessness.

Actions planned to foster and maintain affordable housing.

The City has several programs in place to increase and preserve the supply of affordable housing for lower-income households. One of these programs produces affordable housing through the acquisition and rehabilitation of existing housing units, as well as the con struction of new units.

In the past, the City has partnered with nonprofit organizations and housing developers to accomplish this goal. Increased sustainability of existing single -family housing is accomplished through the provision of grants to low-income residents and home repair programs.

Actions planned to reduce lead-based paint hazards
The City has an aggressive policy to identify and address lead-based paint hazards in HUD-funded housing rehabilitation projects. Housing constructed prior to 1978 and assisted through the City’s Owner-Occupied Residential Rehabilitation Program will be tested for lead -based paint hazards

by a licensed professional . The City ensures lead based -paint hazards are found, safe work practices or abatement procedures will be included in the scope of work for the rehabilitation of the housing unit. All procedures will be in compliance with 24 CFR Part 35.

Actions planned to reduce the number of poverty-level families For FY 2024-2025, the City will support:
• Service providers can provide street outreach, rapid re -housing, homeless prevention, emergency shelter, and other essential services to homeless and near-homeless persons and families.
• Public facilities projects having the greatest impact on the neighborhoods. • The efforts of HACSB provide rental assistance and housing choice vouchers to low - income households.
• The efforts of the CoC, San Bernardino County Behavioral Health Administration, Office of Homeless Services, and various Homeless Service Agencies to provide public and social services to residents living in poverty, including health services, counseling, educational programs, food distribution, academic and vocational training, youth services, and senior services.
• The Goals and Objectives of San Bernardino County's 10 -Year Strategy to End Homelessness.
• A Tenant Protection Program to assist City residents to prevent homelessness and avoid displacement.
• Street reconstruction improvements, sidewalk replacement, and Americans with Disabilities Act improvements.
• Further, the development of the HOPE Campus to assist homeless or at-risk for homeless individuals and families.
• The CoC’s coordinated entry system, 2-1-1 San Bernardino County provides persons who are at imminent risk of becoming homeless with problem -solving support to retain current housing or to locate another housing placement.

Actions planned to develop institutional structure
Successful program implementation requires coordination, both internally and with outside agencies. The City makes changes, as needed, to its staff assignments to address the administrative, planning, and reporting needs of CDBG, HOME, and ESG funds. Proje ct management improvements have included strengthened project eligibility review and staff training of regulatory compliance and procedures. The City ’s Community and Economic Development Department serves as the lead agency in the administration and compli ance of CDBG, HOME, and ESG programs and grant management. The San Bernardino Community Development and Housing Department coordinates activities related to CDBG, HOME, and ESG

funds, including coordination of internal departments, outside agencies, and grant recipients.

The City's ongoing efforts in its institutional structure include strengthening project designs through negotiating stronger and more specific performance goals for project contracts. This includes ongoing education and technical assistance for program sta keholders including fellow City Departments implementing HUD -funded programs, outside contractors, City Council, and the public.

During the next year, the San Bernardino Community Development and Housing Department will continue consulting with and inviting a wide variety of agencies and organizations (i.e., CoC, HACSB, National CORE, County of San Bernardino Community Development and Housing Agency, etc.) involved with the delivery of housing and social services to low - and moderate-income San Bernardino residents. This continued collaboration will allow the City to coordinate its activities by not duplicating efforts for maximum benefits. The City continues to work with the Center for Community Investment and Dignity Health (Accelerating Investments for Healthy Communities).

The City's collaboration with CCI and Dignity Health has resulted in an investment of $1.2 million in permanently affordable rental housing in the City. These types of collaborations build the capacity for the City to continue providing affordable housing.

Actions planned to enhance coordination between public and private housing and social service agencies
During the next year, the San Bernardino Community Development and Housing Department will continue consulting with a wide variety of agencies and organizations such as HACSB, County Workforce Development, County Department of Behavioral Health, and County Office on Aging and Adult Services involved with the delivery of housing, supportive services, and economic development to low- and moderate-income San Bernardino residents. Workforce Development, for example, provides job placement services for people in the County and also provides up to three months of paid on -the-job training and any equipment that an employee may require to carry their new job. The program partners with the Small Business Administration and the City’s Micro Enterprise program to provi de Spanish language training for persons interested in launching a small business or expanding an existing small business.

Discussion:

The implementation of the FY 2025-2026 Action Plan will invest federal resources to address obstacles to meeting underserved needs, foster and maintain affordable housing, reduce lead - based paint hazards, and inspection of HOME units, reduce the number of families living in poverty, develop in stitutional structure, and enhance coordination between public and private housing and social service agencies.

Program Specific Requirements
AP-90 Program Specific Requirements – 91.220(l)(1,2,4)
Introduction:

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

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 0 2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan
0 3. The amount of surplus funds from urban renewal settlements 0

4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan. 0 5. The amount of income from float-funded activities 0 Total Program Income

Other CDBG Requirements

1. The amount of urgent need activities 0

HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)

1. A description of other forms of investment being used beyond those identified in Section

92.205 is as follows:

The City and housing developers are leveraging HOME funds California Permanent Local Housing Allocation Program (PLHA) funds , Low-Income Housing Tax Credit Program (LIHTC), traditional bank funds for construction loans, San Bernardino County HOME funds, private equity group fund ing and, Section 8 Project Based Vouchers and private developer general funding.

2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows:

HOME Recapture Provision If Buyer at any time during the Period of Affordability sells or

transfers the Eligible Property, whether voluntarily or involuntarily due to foreclosure or other circumstances, the following provisions shall apply, pursuant to 24 C.F.R. Part 92.254:

A. If Buyer sells or transfers the Eligible Property within the first two years of the Period of Affordability, City shall recover from the Net Proceeds, if any, the entire amount of the HOME Subsidy, or such lesser amount as the Net Proceeds may permit to be recovered.

The Net Proceeds are the sales price paid to the Buyer minus repayment of loans that are superior in priority to this Affordable Housing Covenant and the Deed of Trust securing it, and any closing costs.

B. If Buyer sells or transfers the Eligible Property after occupying the Eligible Property for at least two years (24 months from the Delivery Date), City’s recovery from the Net Proceeds shall equal the amount of the HOME Subsidy, reduced by a percentage det ermined by dividing the number of Buyer’s full years of occupation of the Eligible Property by the number of years of the Period of Affordability and multiplying the result by 100. In calculating the recapture of the HOME subsidy only full 12 -month periods of occupancy will be utilized in the calculation. For example, if Buyer sells or transfers the Eligible Property during the third year, before the completion of the full third year of a ten -year Period of Affordability, the percentage reduction of the amo unt of the HOME Subsidy to be recovered by the City shall equal 20 percent: (2 years ÷ 10 years) × 100 = 20. Assuming sufficient Net Proceeds, City would recover 80 percent of the HOME Subsidy. If there were not sufficient Net Proceeds, City would recover 80 percent of Net Proceeds, whatever the amount.

C. In no event shall City’s recovery exceed the amount of the Net Proceeds. The City requires that its CHDO/subrecipients, who carry out HOME -funded ownership programs, utilize the noted recapture provisions, which are part of the affordability covenant executed by the homeowner and recorded against the property.

D. The City’s homeownership and single -family rehabilitation programs utilize the homeownership limits for the San Bernardino Metropolitan/FMR Area provided by HUD.

3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows:

Beginning at project completion and determined based on the amount of the HOME Subsidy, as follows:

A. Amount of HOME subsidy and p eriod of affordability for homebuyer and rental

rehabilitation projects:
• Less than $15,000 - 5 years
• $15,000 to $40,000 - 10 years
• More than $40,000 - 15 years

B. Amount of HOME subsidy and period for new rental construction – 20 years

The City's affordability covenant requires that HOME units acquired with HOME funds remain affordable for the period noted based on the amount of HOME subsidy. The City requires that its CHDO/subrecipients who carry out HOME funded ownership programs utili ze the noted recapture provisions, which are part of the affordability covenant executed by the homeowner and recorded against the property.

In its homeownership and single -family rehabilitation programs the City utilizes the homeownership limits for the San Bernardino Metropolitan/FMR Area provided by HUD.

4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows:

The City will not be undertaking any refinancing of existing debt secured by multifamily housing that is rehabilitated with HOME funds. The City will not undertake the refinancing of single-family units rehabilitated with HOME funds. With regard to eligibl e beneficiaries, the City will adhere to the requirements under 24 CFR 2.203 with regard to income determinations; 92.216 with respect to incomes of applicants; 92.253 with regard to tenant protections and selection and other HOME regulatory requirements that ensure beneficiaries are not precluded from participating in HOME funded programs.

The City utilizes Notice of Funding Availability and Requests for Proposals to solicit applications for funding under the HOME program. Solicitations for applications are conducted as funds are available for various programs and/or when contracts and renew al periods with applicants expire and new NOFAs and RPS are released.

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

Not applicable.

6. If applicable to a planned HOME TBRA activity, a description of how the preference for a

specific category of individuals with disabilities (e.g. persons with HIV/AIDS or chronic mental illness) will narrow the gap in benefits and the preference is needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2)(ii) and

91.220(l)(2)(vii)).

Not applicable.

7. If applicable, a description of any preference or limitation for rental housing projects. (See 24 CFR 92.253(d)(3) and CFR 91.220(l)(2)(vii)). Note: Preferences cannot be administered in a manner that limits the opportunities of persons on any basis prohibited by the laws listed under 24 CFR 5.105(a).

Not applicable.

Emergency Solutions Grant (ESG)
Reference 91.220(l)(4)

1. Include written standards for providing ESG assistance (may include as attachment)

The City’s Emergency Solutions Grant Policies and Procedures are an attachment to the 2025- 2029 ConPlan (see AD-26)

2. If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system.

The City participates in the San Bernardino County Continuum of Care system (CoC). The San Bernardino County CoC has established the San Bernardino County Homeless Management Information System (HMIS), an online database used by homeless and at -risk service providers that records demographic and service usage data and produces an unduplicated count of the people using those services.

211 San Bernardino County is available 24 hours a day, 7 days a week by dialing 2 -1-1 in San Bernardino County or by dialing the toll -free number at 1 -888-435-7565. Bilingual staff is available to assist English and/or Spanish -speaking callers. However, if another language is needed, 211 San Bernardino County, utilizes a translation line that can assist in disseminating information in over 150 languages. 211 San Bernardino County is also available by going to https://inlandsocaluw.org/211.

Within the City’s ESG written agreement, the Subrecipient must agree to coordinate and integrate, to the maximum extent practicable, ESG -funded activities with other programs

targeted to homeless people in the area covered by the Continuum of Care or area over which the services are coordinated to provide a strategic, community-wide system to prevent and end homelessness.

3. Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations).

The City will competitively procure services that will meet the goals and objectives of the City’s Consolidated Plan and San Bernardino Continuum of Care’s (CoC) 10 -Year Plan to End Homelessness.

The application review process has three phases. In the first phase, all applications are reviewed by the Community and Economic Development Department staff for completeness and eligibility under the Federal program guidelines. Eligible programs and proje cts are then reviewed according to their contribution to the goals and objectives of the City’s approved Consolidated Plan and CoC’s 10-Year Plan to End Homelessness. Preference is given if a program has the ability to help the City meet federal program ob jectives and local priorities. Organizational capacity, experience, and past performance are also considered.

Based on this review, the Community and Economic Development Department staff prepare general funding recommendations. Lastly, a public hearing before City Council will be held to consider the 2025-2026 Draft Annual Action Plan. The City Council approves the Annual Action Plan, which acts as the CDBG, HOME, and ESG program annual budget. Upon completion of this process, the City forwards the adopted Annual Action Plan to the U.S. Department of Housing and Urban Development for approval.

4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG.

The City consults with the Continuum of Care, which has former homeless individuals as members. Subrecipients who run the shelters and the rapid re-housing programs in the community have former homeless individuals in their organizations who help shape policies and make decisions about services and programs that receive ESG funding.

5. Describe performance standards for evaluating ESG.

ESG Subrecipients must demonstrate the financial management and programmatic expertise to

successfully develop, design, implement, and monitor ESG -funded activities. ESG Subrecipients must participate in HMIS and be able to meet all federal, State of California, and City requirements relative to the ESG program, specifically those concerning eq ual opportunity and fair housing, affirmative marketing, environmental review, displacement, relocation, acquisition, labor, lead-based paint, conflict of interest, debarment, and suspension, and flood insurance.

Under the City ESG agreement, ESG Subrecipients are required to conduct an initial evaluation to determine the eligibility of each individual or family eligibility for ESG assistance and the amount and types of assistance the individual or family needs to regain stability in permanent housing.

In alignment with the federal and state strategic plans to end homelessness, the City has established performance measures that require the collection of housing status data at the time of program exit and six months after program exit. Sub-Recipients are required to report on two measures:
• Increased housing stability as measured by the percentage of total program participants served who reside in permanent housing at the time of exit from the program; and • Increased housing stability as measured by the percentage of program participants who at program exit reside in permanent housing and maintain permanent housing for six months from the time of exit.

Both measurements should be entered into the HMIS. Preliminary performance benchmarks have been set at 30% for all program participants who exit to permanent housing and 80% for those exiting to permanent housing that remain in permanent housing at a six-month follow-up.

These outcome measurements will be in addition to reporting of required universal data elements that track client characteristics and service data.

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