Elyria, Ohio ANALYSIS OF IMPEDIMENTS To Fair Housing...

Elyria, Ohio

ANALYSIS OF IMPEDIMENTS

To Fair Housing Choice

January 25, 2010

Prepared by:

McKenna Associates, Inc.

2987 Meadowbrook Boulevard

Cleveland Heights, OH 44118

(330)528-3342 (telephone)

(248)596-0930 (fax)

(888)226-4326 (toll free)

www.mcka.com

Analysis of Impediments to Fair Housing Choice January 25, 2010

City of Elyria, Ohio

Page Left Intentionally Blank

Analysis of Impediments to Fair Housing Choice Page i January 25, 2010


TABLE OF CONTENTS

I. Introduction and Executive Summary of the Analysis.............................................1

A. Who Conducted................................................................................................................1

B. Participants........................................................................................................................1

C. Methodology Used...........................................................................................................1

D. How Funded .....................................................................................................................2

E. Conclusions .......................................................................................................................2

1. Barriers to Affordable Housing.........................................................................2

2. Strategies to Eliminate Barriers to Affordable Housing ................................3

II. Elyria’s Background Data...............................................................................................7

A. Demographic Data ...........................................................................................................7

B. Income Data ......................................................................................................................9

C. Employment Data...........................................................................................................13

D. Housing Profile...............................................................................................................14

E. Maps.................................................................................................................................16

III. Evaluation of Elyria’s Current Fair Housing Legal Status.....................................23

A. Fair housing complaints or compliance reviews where the Secretary has

issued a charge of or made a finding of discrimination ...........................................23

B. Fair housing discrimination suit filed by the Department of Justice or private

plaintiffs ...........................................................................................................................24

C. Reasons for any trends or patterns ..............................................................................24

D. Discussion of other fair housing concerns or problems............................................24

Analysis of Impediments to Fair Housing Choice Page ii January 25, 2010


IV. Identification of Impediments of Fair Housing Choice.........................................27

A. Public Sector ................................................................................................................... 27

1. Zoning and Site Selection ................................................................................ 27

2. Comprehensive Plan ........................................................................................ 31

3. Neighborhood Revitalization, Municipal and Other Services

Employment-Housing-Transportation Linkage........................................... 33

4. PHA and Other Assisted/Insured Housing Provider Tenant Selection

Procedures; Housing Choices for Certificate and Voucher Holders ......... 36

5. Sale of Subsidized Housing and Possible Displacement............................. 42

6. Property Tax Policies........................................................................................ 42

7. Planning and Zoning Boards........................................................................... 43

8. Building Codes (Accessibility) ........................................................................ 43

B. Private Sector.................................................................................................................. 45

1 Fair Housing Practices Questionnaire ........................................................... 45

C. Public and Private Sector .............................................................................................. 47

1. Fair Housing Enforcement............................................................................... 47

2. Informational Programs................................................................................... 51

3. Visitability in Housing ..................................................................................... 54

4. Determination of Unlawful Segregation ....................................................... 55

V. Assessment of Current Public and Private Fair Housing Programs And

Activities in the Jurisdiction........................................................................................57

VI. Conclusions and Recommendations ..........................................................................65

VII. Signature Page ................................................................................................................69

Appendix .....................................................................................................................................71

LMHA Supplementary Information including:

• Tenant Selection and Assignment Policy

• Transfer Policy

• Voucher Demographics Report

• Briefing Packet

• Go Section 8 Brochure

Analysis of Impediments to Fair Housing Choice Page iii January 25, 2010


List of Maps

Map 1: Very Low, Low, and Moderate-Income Households .............................................................11

Map 2: Transit Routes & Major Employers...........................................................................................17

Map 3: Racial Minority Concentration ..................................................................................................19

Map 4: Disabled Population....................................................................................................................21

List of Tables

Table 1: Population Change in Neighboring Cities and Lorain County, 1970-2007..............7

Table 2: Population and Race/Ethnicity by Census Tract, City of Elyria, 2000 ......................8

Table 3: Median Family Income and HUD Income Limits by Census Tract, City of

Elyria, 2000 ........................................................................................................................9

Table 4: Major Employers, City of Elyria, 2008.........................................................................13

Table 5: Occupied Housing Units by Tenure and Age of Structure, 2000 ............................14

Table 6: Mobile Homes as Percentage of Total Housing Units, 2008 ....................................14

Table 7: Residential Tenure and Vacancy Rate by Census Tract, City of Elyria, 2000 ........15

Table 8: Housing Discrimination Complaints, 2005-2009 .......................................................23

Table 9: Required Dimensions for Single-Family Detached Dwelling Units, City of

Elyria Zoning Code ........................................................................................................27

Table 10: Required Dimensions for Duplex Dwelling Units, City of Elyria Zoning Code...27

Table 11: Required Dimensions for Multiple-Family Dwelling Units, City of Elyria

Zoning Code....................................................................................................................28

Table 12: Lorain County Transit Fare Schedule..........................................................................34

Table 13: Most Recent CRA Rating of Examined Banks in Elyria............................................58

Table 14: Elyria Loan Applications Received, by Loan Type ...................................................59

Table 15: Disposition of Applications for FHA, FSA/RHS and VA Home Purchase

Loans by Race and Ethnicity, Cleveland-Elyria-Mentor, OH MSA/MD 2008 .......59

Table 16: Disposition of Applications for Conventional Home-Purchase Loans by Race

and Ethnicity, Cleveland-Elyria-Mentor, OH MSA/MD 2008 .................................60

Table 17: Disposition of Applications on Refinance Loans by Race and Ethnicity,

Cleveland-Elyria-Mentor, OH MSA/MD 2008 ...........................................................60

Table 18: Disposition of Applications for Home Improvement Loans by Race and

Ethnicity, Cleveland-Elyria-Mentor, OH MSA/MD 2008 .........................................61

Table 19: Mortgage Loan Denial Rates- Home Purchases- by Race/Ethnicity and

Income, Cleveland-Elyria-Mentor, OH MSA/MD 2008 ............................................62

Table 20: Mortgage Loan Denial Rates-Refinancing and Home Loans- by

Race/Ethnicity and Income, Cleveland-Elyria-Mentor, OH MSA/MD 2008..........63

Analysis of Impediments to Fair Housing Choice Page iv January 25, 2010



Analysis of Impediments to Fair Housing Choice Page 1 January 25, 2010


I. Introduction and Executive Summary of the Analysis

Equal and free access to residential housing (housing choice) is fundamental to

meeting essential needs and pursuing personal, educational, employment, or other

goals. Because housing choice is so critical, fair housing is a goal that Government,

public officials, and private citizens must achieve if equality of opportunity is to

become a reality.

Entitlement jurisdictions, including the City of Elyria, must become fully aware of

the existence, nature, extent, and causes of all fair housing problems and the

resources available to solve them. Without this information, the City’s Fair Housing

Planning (FHP) will fall short of measurable results. The City may waste energy and

resources that it could have used more effectively with careful planning and

execution. A properly completed Analysis of Impediments to Fair Housing Choice

(AI) provides this information.

The scope of the AI is broad. It covers the full array of public and private policies,

practices, and procedures affecting housing choice. The AI:

• Serves as the substantive, logical basis for FHP

• Provides essential and detailed information to policy makers, administrative

staff, housing providers, lenders, and fair housing advocates

• Assists in building public support for fair housing efforts both within a

Entitlement jurisdiction’s boundaries and beyond

A. Who conducted

The 2009/2010 Analysis of Impediments to Fair Housing Choice (AI) was

prepared by the City of Elyria with assistance from McKenna Associates in

accordance with the Fair Housing Planning Guide, published by the U.S.

Department of Housing and Urban Development (HUD).

B. Participants

Participants in developing the AI included: City of Elyria elected officials,

department heads, and staff; Lorain Metropolitan Housing Authority; Lorain

County Transit; many public service agencies and organizations; the private

sector; and McKenna Associates (consultants).

C. Methodology Used

The Analysis of Impediments involves the following process:

• A comprehensive review of the City’s laws, regulations, and

administrative procedures, policies, and practices

• An assessment of how those laws, etc. affect the location, availability,

and accessibility of housing



• An assessment of conditions, both public and private, affecting fair

housing choice for all protected classes

• An assessment of the availability of affordable, accessible housing in a

range of unit sizes

The information needed for conducting an AI includes the following:

• Public policies, practices, and procedures involving housing and

housing-related activities

• Zoning and Land use policies, tax assessment/abatement practices

• The nature and extent of fair housing complaints/suits or other data

that may evidence the City’s achievement of fair housing choice

• Demographic patterns

• Home Mortgage Disclosure Act (HMDA) data

• Results of testing

• Results of Fair Housing Initiative Program (FHIP) grants

• Patterns of occupancy in Section 8, Public and Assisted Housing, and

private rental housing.

Impediments to fair housing choice include:

• Any actions, omissions, or decisions taken because of race, color,

religion, sex, disability, family status, or national origin which restrict

housing choices or the availability of housing choices

• Any actions, omissions, or decisions which have the effect of

restricting housing choices or the availability of housing choices on

the basis of race, color, religion, sex, disability, familial status, or

national origin.

D. How Funded

The AI was funded using $13,000 of CDBG funds and $7,000 of CDBG-R

funds.

E. Conclusions

1. Barriers to Affordable Housing

Equal and free access to residential housing (housing choice) is fundamental

to meeting essential needs and pursuing personal, educational, employment,

or other goals. Because housing choice is so critical, affordable housing is a

goal the City and the private market must achieve if equality of opportunity

is to become a reality.

Barriers to new housing development over which the City has the greatest

degree of control include:

• Allowable densities and location of multiple family units

• Minimum lot and building sizes, which can affect price and rent

• Location of grocery stores and other essential services



General barriers to the development and provision of affordable housing

include:

• Deposits, utility connection/reconnection fees, utility costs, and rent

fees

• Affordability/Income bracket cut off levels/Rent ratio to income

• For borrowers with lower incomes, marginal credit and little cash for

down-payments

• Lack of good credit and debt problems

• Racial steering or blockbusting by real estate brokers

• Number of bedrooms per unit available

• Lack of quality housing units available for lower-income

• Foreclosures

• Lack of recognition by City leadership of affordable housing issues

• The stigma associated with “affordable” housing

• Availability of safe and decent quality housing

• Lack of and access to funding for new construction of affordable

housing units.

• Loan policies and procedures

• Weatherization needs

• Lack of funding for new rental housing

• Lack of housing for young adults and the elderly

• Historic Preservation requirements

Other barriers preventing the disadvantaged from accessing services include:

• Transportation from housing areas to employment centers and social

services

• Quality education, higher level education, and technological training

• The current economic downturn

• A lack of awareness within the community of all services available

• Access to jobs

• Lack of supportive services

• NIMBYism-“Not In My Back Yard” attitude of some members of the

community to permit affordable housing in their neighborhood

2. Strategies to Eliminate Barriers to Affordable Housing

The following strategies are proposed to address the barriers listed above:

• The City will convene regular focus group meetings, including, but

not limited to: health providers, landlords, homebuilders, banks and

financial institutions, neighborhood organizations, and service

providers to gather feedback on current barriers and to discuss

strategies to eliminate barriers



• Update the Comprehensive Land Use Plan to focus on housing and

housing-related issues and problems from a metropolitan or regional

perspective.

• Review existing transportation routes to link transportation and job

employment centers to where lower-income persons and families

reside.

• The City should pay close attention to the diversity in representation

of citizens in the community, including lower-income racial and

ethnic groups, gender categories, persons with disabilities, and

families with children, on the City’s boards and commissions.

• Review and update the Zoning Ordinance on a regular basis to foster

inclusion of lower-income housing, including housing accessible to

persons with disabilities and families with children in developments

intended for households with higher incomes.

• Provide inclusionary zoning to promote the development of

affordable housing.

• Encourage mixed-use zoning that allows low income residents to

obtain groceries, education, jobs, and other basic services without a

vehicle.

• Identify specific steps that will be taken to strengthen the fair housing

aspect of community revitalization activities in poorer neighborhoods

through equalizing services, revising displacement policies and

procedures, initiating or strengthening agreements with banks and

other lending institutions subject to CRE, creating job-housing and

education-housing linkages in and outside neighborhoods.

• Regularly monitor tenant characteristics data for the HUD-assisted

and HUD-insured housing developments as one means of evaluating

policies, procedures and practices.

• Provide support to the Lorain Metropolitan Housing Authority in

their desegregation efforts.

• Encourage the Lorain Metropolitan Housing Authority to utilize

scattered-site, low-density housing acquisition as a means to de-

concentrate racially impacted public housing.

• Consider initiating or broadening property tax relief provisions as a

means of preserving lower-income home-ownership opportunities,

especially if such provisions would be beneficial to minority

households, elderly households, or households with one or more

members who are disabled.

• Identify specific steps that the City should take based on an

examination of sales and rental practices including real estate broker

practices such as adoption and dissemination of anti-relining or anti-

blockbusting policies, establishing reporting requirements for housing

providers in the City, establishing a stronger public education effort

regarding the protection under fair housing laws, or other actions.



• Offer a first-time homebuyer classes and education program about

loan requirements and budgeting to assist applicants in

understanding how to improve their probability of receiving a

mortgage loan.

• Provide credit counseling and education about good credit.

• Publicize the availability of government guaranteed loans to potential

borrowers.

• Community groups and government officials should take an active

role in encouraging increased CRA compliance activities by local

financial institutions.



II. Elyria’s Background Data

A. Demographic Data

Population. Until the 1980s, Elyria was one of the fastest-growing cities in

Ohio, but has exhibited a slow population loss over the past thirty years. In

2007, the total population of Elyria was estimated at 53,951 persons, a

decrease of 3.58% from the 55,953 persons recorded in the 2000 US Census.

There were an estimated 21,827 households in Elyria in 2007, resulting in an

average household size of 2.47 persons, which is slightly less than the Lorain

County average of 2.73 persons per household.

Table 1: Table 1: Table 1: Table 1: Population Change in Neighboring Cities and Lorain County, 1970Population Change in Neighboring Cities and Lorain County, 1970Population Change in Neighboring Cities and Lorain County, 1970Population Change in Neighboring Cities and Lorain County, 1970----2007200720072007

YearYearYearYear ElyriaElyriaElyriaElyria Lorain cityLorain cityLorain cityLorain city North North North North

RRRRidgevilleidgevilleidgevilleidgeville Lorain CountyLorain CountyLorain CountyLorain County

1970 53,427 78,185 13,152 256,843

1980 57,538 75,416 21,522 274,909

1990 56,746 71,245 21,564 271,126

2000 55,953 68,652 22,338 284,664

2007 53,951 63,859 27,271 302,260

1970-2007 Percent Change

0.98% -18.32% 107.35% 17.68%

2000-2007 Percent Change

-3.58% -6.98% 22.08% 6.18%

Source: US Census Bureau 1990 and 2000; American Community Survey 2007 (est.); US Census Bureau Population Estimates for July 1, 2007

Contrary to the experience in Elyria, the overall population of Lorain County

has grown by 17.68% since 1970, with an increase of over 6% in just the last

decade. Much of this increase is apparently due to growth in the southern

townships (Lagrange, Penfield, Wellington, et al.) and the northeastern cities

of Avon and Avon Lake.

Race and Ethnicity. In the 2007 American Community Survey, an estimated

82.4% of Elyria residents reported their race as ‘white’, consistent with the

county as a whole (85.4% white). Compared to the county overall, Elyria has

a higher proportion of persons reporting as ‘black or African-American’

(13.2% vs. 8.2% for Lorain County), which is typical of older, established

cities. Other races account for less than 2 percent of the population in Elyria.



While Elyria has a higher concentration of African-Americans than the

county overall, persons of Hispanic or Latino ancestry are disproportionately

underrepresented in the city (3.2% in Elyria compared with 7.3% in Lorain

County overall). Historically, persons of Hispanic ancestry have been

concentrated in the City of Lorain, which reported 22.2% Hispanic-origin

residents in 2007.

As shown in the table on the following page, the areas of highest racial

minority concentration (calculated as percentage of residents who reported

their race as anything other than ‘white’) are located in south-central Elyria.

Tract 714 is the only ‘majority-minority’ tract in the city, with a non-white

population of 1,874 persons (50.23% of the total tract population). The next

highest percentage of minority residents is in Tract 709.01, with 46.85% non-

white persons in 2000.

Table 2: Table 2: Table 2: Table 2: Population and Race/Ethnicity by Census Tract, City of Elyria, 2000Population and Race/Ethnicity by Census Tract, City of Elyria, 2000Population and Race/Ethnicity by Census Tract, City of Elyria, 2000Population and Race/Ethnicity by Census Tract, City of Elyria, 2000

Census Tract

Total Persons White Black

Some Other Race

More than One Race

Percent Non-White

Hispanic or

Latino

Percent Hispanic

or Latino

714 3,731 1,857 1,615 97 162 50.2% 142 3.8%

709.01 1,857 987 710 45 115 46.9% 89 4.8%

704 4,880 3,293 1,341 90 156 32.5% 116 2.4%

708 1,269 924 267 30 48 27.2% 55 4.3%

705 3,620 2,749 677 59 135 24.1% 118 3.3%

710 2,463 1,962 373 33 95 20.3% 67 2.7%

709.02 3,451 2,853 464 52 82 17.3% 121 3.5%

713 4,018 3,440 411 88 79 14.4% 117 2.9%

703 3,753 3,258 278 114 103 13.2% 138 3.7%

712 8,784 7,668 815 117 184 12.7% 163 1.9%

701.02 6,169 5,422 497 122 128 12.1% 167 2.7%

702 2,067 1,825 122 66 54 11.7% 103 5.0%

715 2,046 1,820 159 42 25 11.1% 43 2.1%

707 2,563 2,389 74 41 59 6.8% 50 2.0%

711 4,696 4,452 120 45 79 5.2% 116 2.5%

701.01 3,827 3,632 85 75 35 5.1% 75 2.0%

571 4,265 4,065 104 58 38 4.7% 89 2.1%

706 4,432 4,245 86 45 56 4.2% 62 1.4%

911 2,911 2,839 9 42 21 2.5% 54 1.9%

N.B. Individual race categories include persons of Hispanic or Latino ethnicity

Source: US Census Bureau, 2000



B. Income Data

Income and Poverty

Based on the income figures published by the US Department of Housing

and Urban Development, the median family income (HAMFI) for Lorain

County in 2009 was $52,600. A number of calculations in this Consolidated

Plan are based on defined percentages of this median income:

• 30% of the median family income is $15,800 (very-low income)

• 50% of the median family income is $26,300 (low income)

• 80% of the median family income limit is $42,100 (moderate income)

Table 3: Table 3: Table 3: Table 3: Median Family Income and HUD Income Limits by Census Tract, City of Elyria, 2000Median Family Income and HUD Income Limits by Census Tract, City of Elyria, 2000Median Family Income and HUD Income Limits by Census Tract, City of Elyria, 2000Median Family Income and HUD Income Limits by Census Tract, City of Elyria, 2000

Census Census Census Census TractTractTractTract

Total Total Total Total Households Households Households Households (20(20(20(2000)00)00)00)

MedianMedianMedianMedian Family Family Family Family Income Income Income Income (1999)(1999)(1999)(1999)

HAMFI HAMFI HAMFI HAMFI <30%<30%<30%<30%

(very low income)

HAMFIHAMFIHAMFIHAMFI 31313131----50%50%50%50%

(low income)

HAMFIHAMFIHAMFIHAMFI 51515151----80%80%80%80% (moderate income)

Percent of Percent of Percent of Percent of households households households households <80% HAMFI<80% HAMFI<80% HAMFI<80% HAMFI

571 6 $ 53,110 0 0 0 0.0%

701.01 1,546 $ 58,179 64 84 263 26.6%

701.02 2,454 $ 54,960 196 208 470 35.6%

702 384 $ 53,098 34 41 66 36.7%

703 1,225 $ 40,792 152 226 314 56.5%

704 1,850 $ 43,926 191 364 386 50.9%

705 1,405 $ 37,093 226 179 387 56.4%

706 2,029 $ 50,357 188 351 396 46.1%

707 1,076 $ 45,848 104 180 240 48.7%

708 707 $ 22,426 287 135 90 72.4%

709.01 825 $ 22,893 210 146 83 53.2%

709.02 1,613 $ 37,076 232 336 399 60.0%

710 1,151 $ 31,369 242 219 297 65.9%

711 1,845 $ 55,276 98 103 344 29.5%

712 3,408 $ 52,518 451 462 615 44.8%

713 968 $ 47,297 184 115 170 48.5%

714 1,340 $ 34,826 320 170 285 57.8%

715 2 $ 53,690 0 0 0 0.0%

911 7 $ 60,662 0 0 4 57.1%

TotalTotalTotalTotal 23,84123,84123,84123,841 3,1793,1793,1793,179 3,3193,3193,3193,319 4,8094,8094,8094,809 47.4%47.4%47.4%47.4%

13.3% 13.9% 20.2%

Sources: US Dept of Housing and Urban Development analysis of Census 2000 data

HAMFI = HUD-adjusted Area Median Family Income



In Elyria, 13% of households are very-low-income, another 14% are low-

income, and 20% are moderate income; in total, almost half (47.4%) of the

city’s households earn less than 80% of the area median income.

The table on the preceding page lists by census tract the number of

households that are in each of the three categories described above. Note that

some census tracts (e.g., 571, 715, 911) cover a large geographic area outside

the city boundaries of Elyria; the number of households presented in the

table represents the number of households in only the portion of each tract

which is located in Elyria proper.

The map on the following page indicates that the central portion of Elyria

contains the city’s highest percentages of very-low-income, low-income, and

moderate-income households. Tracts 708 and 710 both have more than three

out of every five households below the 80% moderate-income threshold. It

should be noted that Tracts 571 and 715 appear on the map as having no

households classified as low- or moderate-income; for these tracts, no Elyria

residents fall below the eighty-percent threshold, but households located in

areas of these tracts outside the city may qualify.

1/4/10

Elyria, OhioVery Low, Low, and Moderate-Income Households Data Source: HUD 2009 from Census 2000

Base Map Source: City of Elyria, 2009

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Tract911Tract

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Tract 713

Tract712

Tract711

Tract710

Tract709.02

Tract709.01

Tract708

Tract707

Tract706Tract

705

Tract704

Tract703

Tract702

Tract701.02

Tract701.01

Tract571

Tract715

Tract713

NORTHRIDGEVILLE

CITY

SHEFFIELDVILLAGE

ELYRIATOWNSHIP

CARLISLETOWNSHIP

AMHERSTTOWNSHIP

EATONTOWNSHIP

AVONCITYSHEFFIELD

TOWNSHIP

LORAINCITY

NEW RUSSIATOWNSHIP

% Households0%0.1% - 37.5%

37.6% - 50%50.1% - 62.5%62.6% - 72.4%

Neighboring CommunitiesCity of ElyriaAdjacent Census Tracts



C. Employment Data

The following table lists major employers in Elyria, ranked by the number of

total employees in 2008. As businesses expand and relocate to Elyria, the

demand for more housing choices will increase.

Table 4: Table 4: Table 4: Table 4: Major EmployersMajor EmployersMajor EmployersMajor Employers, City of Elyria, 200, City of Elyria, 200, City of Elyria, 200, City of Elyria, 2008888

EmployerEmployerEmployerEmployer Type of BusinessType of BusinessType of BusinessType of Business RankRankRankRank

Lorain County Government County government 1

EMH Regional Medical Center Hospital 2

Invacare Corporation Manufacturer of home medical equipment

3

Elyria Schools Education 4

Lorain County Community College Education 5

Ridge Tool Company Manufacturer of construction tools 6

City of Elyria Government Municipal government 7

Knorr Brake Truck Systems (Bendix)

Manufacturer of heavy-duty brakes 8

Parker Hannifin Corporation Manufacturer of industrial/aerospace motion and control technologies

9

Elyria Foundry Company Manufacturer of custom, semi-production, and production castings

10

Hydro-Aire, Inc. Supplier of critical systems & components for aerospace and defense markets

11

BASF Catalysts, LLC Chemical manufacturing 12

Diamond Products Limited Manufacturer of diamond tools 13

Walmart Associates, Inc. Retailer 14

Wesleyan Senior Living Residential care services 15

Minnesota Mining & Manufacturing Manufacturer of sponge products 16

Nelson Stud Welding, Inc. Manufacturer of weld stud fasteners 17

All-American Sports Corp (Riddell) Design/marketing of sports equipment 18

State of Ohio Payroll Services State government 19

A-D Technologies Manufacturer of communication and energy infrastructure products and systems

20

Source: City of Elyria, 2009

Elyria has experienced a recent rise in unemployment up to 10.5% in October

2009, according to the City of Elyria Economic Development Department.



D. Housing Profile

General Characteristics

The existing housing stock in Elyria is basically sound, thanks in large part to

residential and code enforcement programs that have been in place for over

30 years. The need for regular maintenance and monitoring programs only

increases over the years as the already-old housing stock experiences more

and more problems associated with decades-old structures.

Two-thirds of the housing in Elyria is owner-occupied; of these units, 50%

were built prior to 1960. The median age of rental housing is 44 years, with

less than 15% of rental units built after 1980.

Table 5: Table 5: Table 5: Table 5: Occupied HousinOccupied HousinOccupied HousinOccupied Housing Units by Tenure and Age of Structure, 2000g Units by Tenure and Age of Structure, 2000g Units by Tenure and Age of Structure, 2000g Units by Tenure and Age of Structure, 2000

Owner Occupied

%

Renter Occupied

%

Total Units

1990 and newer

1,508 6.7% 316 1.4% 1,824

1980-1989 970 4.3% 764 3.4% 1,734

1970-1979 2,315 10.3% 2,296 10.2% 4,611

1960-1969 2,497 11.1% 1,327 5.9% 3,824

1950-1959 2,778 12.4% 930 4.1% 3,708

1940-1949 1,552 6.9% 689 3.1% 2,241

1939 or earlier 2,869 12.8% 1,608 7.2% 4,477

TotalTotalTotalTotal 14,48914,48914,48914,489 64.6%64.6%64.6%64.6% 7,9307,9307,9307,930 35.4%35.4%35.4%35.4% 22,41922,41922,41922,419

Source: US Census Bureau 2000

It is interesting to note that the City of Elyria has a significantly larger

proportion mobile homes, or manufactured housing units, as compared to

Lorain or the county as a whole. Often, the operators of manufactured

housing parks are not fully aware of housing assistance programs that may

be available to support residents with special housing needs. Additionally,

many manufactured homes suffer from disrepair and may present a cost

burden to residents.

Table 6 Table 6 Table 6 Table 6 Mobile Homes as Percentage of Total Housing Units, 2008Mobile Homes as Percentage of Total Housing Units, 2008Mobile Homes as Percentage of Total Housing Units, 2008Mobile Homes as Percentage of Total Housing Units, 2008

City of Elyria City of Lorain Lorain County

Total Housing Units 24,130 29,262 122,799

Mobile Homes 1,533 198 2,820

% Mobile Homes 6.35% 0.68% 2.30%

Source: American Community Survey estimates, 2006-2008



The table below displays the percentage of owner-occupied, renter-occupied,

and vacant housing units by Census tract within Elyria, along with the

percentage of households earning less than 80% of HAMFI. General trends in

the data include higher vacancy rates and a greater prevalence of low- and

moderate-income households in tracts with higher percentages of rental

housing units. Some notable exceptions to these trends are Tract 709.01,

which has nearly one out of four units vacant, and Tracts 701.02 and 702,

which have fewer low- and moderate-income families than would be

generally expected for tracts with similar percentages of rental units.

Table 7: Table 7: Table 7: Table 7: Residential Residential Residential Residential Tenure and Vacancy Tenure and Vacancy Tenure and Vacancy Tenure and Vacancy Rate Rate Rate Rate by by by by Census Census Census Census TractTractTractTract, City of Elyria, 2000, City of Elyria, 2000, City of Elyria, 2000, City of Elyria, 2000

TractTractTractTract Total Total Total Total UnitsUnitsUnitsUnits

Owner Owner Owner Owner OccupiedOccupiedOccupiedOccupied %%%%

Renter Renter Renter Renter OccupiedOccupiedOccupiedOccupied %%%% VacantVacantVacantVacant %%%%

<80% <80% <80% <80% HAMFIHAMFIHAMFIHAMFI

708 707 79 11.17% 552 78.08% 76 10.75% 79.6%

710 1151 329 28.58% 693 60.21% 129 11.21% 71.8%

709.01 876 273 31.16% 390 44.52% 213 24.32% 71.4%

714 1410 647 45.89% 658 46.67% 105 7.45% 59.9%

709.02 1702 849 49.88% 733 43.07% 120 7.05% 59.8%

703 1928 1064 55.19% 733 38.02% 131 6.79% 58.4%

702 943 559 59.28% 329 34.89% 55 5.83% 32.9%

705 1405 853 60.71% 464 33.02% 88 6.26% 58.1%

701.02 2454 1592 64.87% 800 32.60% 62 2.53% 32.6%

712 3574 2379 66.56% 1070 29.94% 125 3.50% 42.7%

707 1076 720 66.91% 296 27.51% 60 5.58% 48.6%

704 1994 1395 69.96% 509 25.53% 90 4.51% 49.4%

706 2029 1447 71.32% 491 24.20% 91 4.48% 42.4%

713 1579 1274 80.68% 234 14.82% 71 4.50% 49.0%

715 654 529 80.89% 107 16.36% 18 2.75% 0%

711 1892 1538 81.29% 291 15.38% 63 3.33% 28.4%

571 1613 1352 83.82% 202 12.52% 59 3.66% 0%

911 1047 926 88.44% 107 10.22% 14 1.34% 43.3%

701.01 1546 1468 94.95% 51 3.30% 27 1.75% 23.1%

Source: US Census Bureau 2000



E. Maps

• Housing/Job/Transportation relationships

• Concentration of Racial Minorities

• Geographic Distribution of Disabled Persons

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to Oberlin

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to WestlakePark & Ride

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Amtrak to Chicago

Amtrak to ClevelandNew York, Washington

Local Bus Connections to Downtown Lorain

1/4 MileLocal TransitService Area

NORTHRIDGEVILLE

CITY

SHEFFIELDVILLAGE

ELYRIA TOWNSHIP

ELYRIACITY

CARLISLETOWNSHIP

AMHERST TOWNSHIP

EATONTOWNSHIP

AVON CITYSHEFFIELDTOWNSHIPLORAIN

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NEWRUSSIA

TOWNSHIP

7 1 2

3

4

5

6

8

910

1112

13

14

15

1617

1819

1/04/10

Elyria, OhioPublic Transportation Service Area Data Source: City of Elyria, 2009

0 0.5 1Miles

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date: 1

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Neighboring CommunitiesCity of ElyriaRoads

Local Bus RoutesExpress Bus RoutesAMTRAK Passenger Rail

1 LORAIN COUNTY GOVERNMENT2 EMH REGIONAL MEDICAL CENTER 3 INVACARE CORPORATION 4 ELYRIA SCHOOLS 5 LORAIN COUNTY COMMUNITY COLLEGE6 RIDGE TOOL COMPANY 7 CITY OF ELYRIA GOVERNMENT8 KNORR BRAKE TRUCK SYSTEMS (BENDIX)9 PARKER HANNIFIN CORP 10 ELYRIA FOUNDRY COMPANY

RANK COMPANY/ ORGANIZATION NAME11 HYDRO-AIRE INC 12 BASF CATALYSTS LLC 13 DIAMOND PRODUCTS LIMITED 14 WAL-MART ASSOCIATES INC 15 WESLEYAN SENIOR LIVING 16 MINNESOTA MINING & MFG CO (3M)17 NELSON STUD WELDING INC 18 ALL AMERICAN SPORTS CORP (RIDDELL)19 A-D TECHNOLOGIES (FORMALLY ARNCO)

RANK COMPANY/ ORGANIZATION NAME

Tract911Tract

715Tract714

Tract 713

Tract712

Tract711

Tract710

Tract709.02

Tract709.01

Tract708

Tract707

Tract706Tract

705

Tract704

Tract703

Tract702

Tract701.02

Tract701.01

Tract571

Tract715

Tract713

NORTHRIDGEVILLE

CITY

SHEFFIELD VILLAGE

ELYRIA TOWNSHIP

CARLISLETOWNSHIP

AMHERSTTOWNSHIP

EATONTOWNSHIP

AVON CITYSHEFFIELDTOWNSHIP

LORAINCITY

NEWRUSSIA

TOWNSHIP

1/4/10

Elyria, OhioRacial Minority Concentration Data Source: Census 2000

Base Map Source: City of Elyria, 20090 0.5 1 1.5Miles

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Percent Non-WhiteLess than 12.5%12.6% - 25%

25.1% - 37.5%37.6% - 50%Greater than 50%

Adjacent Census TractsNeighboring CommunitiesCity of Elyria

Tract911Tract

715Tract714

Tract 713

Tract712

Tract711

Tract710

Tract709.02

Tract709.01

Tract708

Tract707

Tract706Tract

705

Tract704

Tract703

Tract702

Tract701.02

Tract701.01

Tract571

Tract715

Tract713

NORTHRIDGEVILLE

CITY

SHEFFIELD VILLAGE

ELYRIA TOWNSHIP

CARLISLETOWNSHIP

AMHERSTTOWNSHIP

EATONTOWNSHIP

AVON CITYSHEFFIELDTOWNSHIP

LORAINCITY

NEWRUSSIA

TOWNSHIP

12/07/09

Elyria, OhioDisabled Population Data Source: Census 2000

Base Map Source: City of Elyria, 20090 0.5 1 1.5Miles

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% with Any Disability20.8% - 22.4%22.5% - 33.1%

33.2% - 40.3%40.4% - 50.8%50.9% - 64.9%

Adjacent Census TractsNeighboring CommunitiesCity of Elyria



III. Evaluation of Elyria’s Current Fair Housing Legal Status

A. Fair housing complaints or compliance reviews where the Secretary has issued a

charge of or made a finding of discrimination

Table 8: Table 8: Table 8: Table 8: Housing Discrimination Complaints, 2005Housing Discrimination Complaints, 2005Housing Discrimination Complaints, 2005Housing Discrimination Complaints, 2005----2009200920092009

HUD Date FiledHUD Date FiledHUD Date FiledHUD Date Filed BasisBasisBasisBasis DescriptionDescriptionDescriptionDescription Why ClosedWhy ClosedWhy ClosedWhy Closed

8/19/05 Retaliation Marcus and Joanne Jackson vs. Frank and Mary Engel

No Jurisdiction

11/1/05 Race Lorain County Reinvestment Coalition vs. Rizca E. Palmer, Trustee; Palmer AP

Settlement with Benefits

2/23/06 Disability Sean Stipe vs. New Sunrise Properties Charging Party Failed to Cooperate

9/25/06 Familial Status, Sex, Race

Deidre Jones vs. William Ryals Withdrawal with Benefits

9/29/06 Sex Sheila Kaminski vs. William Ryals Withdrawal with Benefits

12/19/06 Sex, Race Bryan Copeland vs. RJ Gordon Manor Settlement with Benefits

7/5/07 Religion, Retaliation, Race

Benjamin Simmons vs. South Park Apartments

No Cause Finding Issued

8/9/07 Sex Vivian Mcneal vs. Condor Garden Apartments Withdrawal with Benefits

12/24/07 Familial Status

Housing Research & Advocacy Center vs. John Abraham


3/13/09 Disability Sharon Musgrave vs. Arlington Square Apartments


5/14/09 Race Mallori Lake vs. Shaneque Brown, Manager Charging Party Failed to Cooperate

8/7/09 Familial Status

Unknown- OCRC unable to disclose due to charge still being open

Pending

8/18/009 Disability Tashanda Collins vs. New Level Properties, LLC.

Withdrawal with Benefits

Source: State of Ohio, Civil Rights Commission (OCRC)

The preceding Table 8, Housing Discrimination Complaints, 2005-2009,

indicates the number of housing discrimination complaints filed with the

State of Ohio, Civil Rights Commission (OCRC) since January 2005.



Elyria Fair Housing Practices Ordinance

Elyria’s Fair Housing Practices Ordinance was passed in May, 1996 and

generally provides protection from discrimination in the sale, rental, leasing,

and financing of a dwelling or housing unit because of race, color, creed, sex,

familial status, religious belief, national origin or handicap. The ordinance

also established a Fair Housing Board, which has the power to:

1. investigate complaints of unlawful housing practices;

2. initiate complaints of unlawful housing practices on the basis of

studies carried out by its staff or volunteers;

3. endeavor, by conciliation, to resolve unlawful housing complaints;

4. hold hearings, subpoena witnesses and required the production of

any books or papers relating to any matter under investigation;

5. render a full written report to the Mayor on an annual basis all of the

Boards activities and recommendations;

6. recommend to the Mayor educational or other programs designed to

promote fair housing;

7. adopt rules and procedures for the conduct of its business; and

8. complete such other acts that are necessary to perform other duties

charged under the Ordinance.

B. Fair housing discrimination suit filed by the Department of Justice or

private plaintiffs

None known of at this time.

C. Reasons for any trends or patterns

There does not appear to be any trends or patterns in discrimination

complaints.

D. Discussion of other fair housing concerns or problems

The two organizations dedicated to mitigating fair housing impediments,

investigating fair housing complaints and increasing awareness of fair

housing in Elyria are: Fair Housing Board (the City contracts with the Lorain

County Urban League (LCUL) to process complaints) and the Ohio Civil

Rights Commission.

Neighborhood opposition to the development of affordable rental housing is

a serious impediment, not unique to Elyria. The City needs to work with

neighborhood groups and organizations to help remove the stigma

associated with affordable housing and promote integration and diversity. At



the same time, the City and Lorain Metropolitan Housing Authority need to

develop and maintain quality housing that is integrated into the existing

housing stock in terms of scale, density, and historic character.

The Fair Housing Board, LCUL and LMHA should increase its public

information and education activities to highlight its affordable housing

accomplishments, and to publicize research on the positive impact of

affordable housing.

The City can encourage integration and diversity by promoting mixed-use

and mixed-income developments, which permit both residential and

commercial uses.



IV. Identification of Impediments of Fair Housing Choice

A. Public Sector

1. Zoning and Site Selection

A review of the Planning and Zoning Code of Elyria, Ohio was conducted

to determine if City zoning regulations limit or exclude housing facilities

for persons with disabilities or other housing for homeless people from

certain residential areas.

Below is a summary of existing residential districts (except the

Manufactured Home Park district and Planned Unit Development)

located within the City:

Table 9: Table 9: Table 9: Table 9: Required DimeRequired DimeRequired DimeRequired Dimensions for Singlensions for Singlensions for Singlensions for Single----Family Detached Dwelling Units, City of Elyria Family Detached Dwelling Units, City of Elyria Family Detached Dwelling Units, City of Elyria Family Detached Dwelling Units, City of Elyria Zoning CodeZoning CodeZoning CodeZoning Code

Minimum Setbacks

Minimum Lot Area

Minimum Lot Width Front

One Side

Total of Two Sides

Max. Lot Coverage

COS 1 acre 120 ft 50 ft 20 ft 50 ft 20%

R-LD 8,750 sf 70 ft 30 ft 8 ft 18 ft 30%

R-MD 7,500 sf 60 ft 30 ft 6 ft 16 ft 30%

R-UD 4,000 sf 40 ft 20 ft 4 ft 8 ft 40%

R-TH 7,500 sf 60 ft 30 ft 6 ft 16 ft 30%

R-MHL Use Not Permitted

R-MHH 1 acre 150 ft 35-50 ft 20 ft 50 ft 30%

Table 10: Table 10: Table 10: Table 10: Required Dimensions for DuplexRequired Dimensions for DuplexRequired Dimensions for DuplexRequired Dimensions for Duplex Dwelling Units, City of Elyria Zoning Code Dwelling Units, City of Elyria Zoning Code Dwelling Units, City of Elyria Zoning Code Dwelling Units, City of Elyria Zoning Code

Minimum Setbacks

Minimum Lot Area

Minimum Lot Width Front

One Side

Total of Two Sides

Max. Lot Coverage

COS

R-LD

R-MD

Use Not Permitted

R-UD 10,000 sf 70 ft 20 ft 8 ft 18 ft 40%

R-TH 10,000 sf 80 ft 30 ft 8 ft 20 ft 30%

R-MHL 10,000 sf 80 ft 35-50 ft 8 ft 20 ft 40%

R-MHH 1 acre 150 ft 35-50 ft 20 ft 50 ft 30%



Table 11: Table 11: Table 11: Table 11: Required Dimensions for MultipleRequired Dimensions for MultipleRequired Dimensions for MultipleRequired Dimensions for Multiple----Family Dwelling Units, City of Elyria Zoning CodeFamily Dwelling Units, City of Elyria Zoning CodeFamily Dwelling Units, City of Elyria Zoning CodeFamily Dwelling Units, City of Elyria Zoning Code

Minimum Setbacks

Minimum Lot Area

Minimum Lot Width Front One Side

Total of Two Sides

Max. Lot Coverage

COS

R-LD

R-MD

R-UD

R-TH

Use Not Permitted

R-MHL 22,000 sf to 2 acres

120-200 ft 35-50 ft 12-20 ft 30-40 ft 40%

R-MHH 22,000 sf to 2 acres

120-200 ft 35-50 ft 12-20 ft 30-40 ft 50-60%

After review of the minimum street frontage, front yard setbacks, side

yard dimensions and maximum lot coverage, there do not appear to be

significant restrictions that may limit new housing development for

lower-income residents (with the exception of the COS district, which

requires large-lot residential development as an open space preservation

measure).

The lack of access to grocery stores and fresh foods has been a common

complaint nationwide among residents of low income neighborhoods.

Ultimately, the location of grocery stores or lack thereof may have an

impact on where people chose to live.

Based on a review of the permitted and conditional uses in the City’s

Zoning Ordinance, we find the following:

• “Neighborhood Retail Businesses,” which could include food

stores, are permitted in the B-N, B-D, and B-G districts;

• “Convenience Businesses,” which may sell groceries, are

permitted in the B-D, B-G, and B-AO districts;

• “Farmer’s Markets” are permitted in the B-D district.

In the central and northern sections of Elyria, there is a good distribution

of commercial zoning districts which permit food stores near higher-

density residential districts, suggesting that there is the potential for

lower-income residents to access fresh groceries. In the extreme northeast

and southeast corners of the City, however, there are high-density

residential districts isolated from commercial areas. Similarly, there is a

very large high-density residential area on the west side of the City which

(from a zoning perspective) appears to be underserved by commercial

establishments, including food stores.



Zoning Interview with Angela Byington, AICP, Director, Office of Community Development and Planning:

Site selection for construction of public (e.g. assisted) and private housing

is subject to the City’s design review procedures, which, in essence, are

equivalent to site plan review procedures.

When asked about the concentrations of low-and moderate- income

housing in one or more localities within the City, Ms. Byington identified

the following neighborhoods: South Elyria, Central Business District, and

Far West portions of the City. Current zoning and other City policies are

not promoting this pattern, but this pattern can be explained by the

tenure (renter vs. owner occupied) and vacancy rates in these areas.

When asked if the City is aware of and has it evaluated the management

policies and procedures of assisted housing providers (those providing

housing to persons with disabilities and homeless persons) to determine

if problems exist that have led or could lead to general public, specific

neighborhood, or other types of opposition to such housing, the City

stated that it is not aware, nor has it evaluated the management policies

and procedures of assisted housing providers. The City reviews housing

type based upon zoning, design review (applicable to residential uses

except single two-family and three-family units), and building permits.

Further, the City has a positive impact on the quality of lower-income

housing through zoning and code enforcement.

Medium and high density residential developments are permitted in the

Residential-Medium Density (R-MD) District, Residential-Urban Density

(R-UD) District, Residential Two-Household (R-TH) District, Residential-

Multi-Household Low Density (R-MHL) District, and Residential-Multi-

Household High Density (R-MHH) District. If there is large vacant land

available for multi-family development in areas outside the R-MD, R-

MHL, and R-MHH districts, then a zoning district amendment can be

requested and approved if supported by the Elyria 2015 Plan.

The Zoning Ordinance provides a Residential - Planned Unit

Development (R-PUD) option for tracts of land of 4 acres or greater for

attached single household units in groupings of not more than four (4)

units. Multi-household dwellings are not permitted in the R-PUD District.

The Planned Unit Development (PUD) District provides for tracts of land

with a minimum gross land area of 50 acres (exclusive of rights-of-way,

railroad rights-of-way, and public utility easements). Multi-household

dwellings and neighborhood retail businesses are uses permitted by right

in a PUD District.



The Zoning Ordinance does not include a definition for “Family”, but

does define “Household” in the following terms:

"Household" means one (1) or more persons customarily living

together as a single housekeeping unit and using common

cooking facilities, as distinguished from persons occupying a

hotel, club, boarding or lodging house, motel, sorority house,

fraternity house, group home or transitional housing unit.

Thus, the City permits unrelated individuals to share the same home.

1) Do zoning, subdivision, or occupancy regulations include

provisions that permit housing facilities for persons with

disabilities in a wide array of locations to prevent their

concentrations?

Yes, conditionally permitted throughout.

2) Should zoning, occupancy or building ordinances, codes or

regulations be changed to provide for more inclusive

development of housing for lower-income people and families,

including persons with disabilities?

No, the regulations are already inclusive.

3) Should the City adopt incentives to promote mixed-income

housing development, such as increasing the number of new units

that can be built in a given development in exchange for

dedication of a certain percent of the units for low and moderate–

income households?

No.

4) Are there court decisions or settlements that affect the

jurisdiction’s zoning, building, occupancy, or other policies and

regulations relating to the provision of housing for lower-income

households and persons with disabilities?

None that I am aware of.

5) The City is a member of the Northeast Ohio Areawide

Coordinating Agency, which is the Metropolitan Planning

Organization for Cuyahoga, Geauga, Lake, Lorain, and Medina

Counties. Do these organizations focus on housing and housing

related issues and problems from a metropolitan or regional

perspective?

No, NOACA is responsible for the region’s Long Range Transportation

Plan, the Transportation Improvement Program, the region’s water quality



plan and an Overall Work Program which carries out national planning

guidance, air quality, watershed planning and special studies.

Strategies:

• Review and update the Zoning Ordinance on a regular basis to foster

inclusion of lower-income housing, including housing accessible to

persons with disabilities and families with children in developments

intended for households with higher incomes.

• Increase the scope and provision for inclusionary zoning to include

the R-PUD District to further promote the development of affordable

housing.

• Continue to encourage mixed-use zoning that allows low income

residents to obtain groceries, education, jobs, and other basic services

without a vehicle.

2. Comprehensive Plan

The Elyria Plan 2015 (adopted January 2009) was reviewed for policies

and recommendations that support housing choice and the provision of

equitable housing and strong neighborhoods. One of the working groups

established for the plan development process concerned itself with

Neighborhood Development; the recommendations of this working

group are as follows:

Goal 1: Maintain and/or revitalize properties in order to provide

vibrant neighborhoods with quality housing throughout the city.

Goal 2: Provide streets and sidewalks that are structurally sound

and safe for motorists, conducive to pedestrian traffic and

attractive and inviting for those wanting to explore the

neighborhoods of our city.

Goal 3: Provide a well-maintained water distribution system and a

properly functioning sanitary and storm sewer system for all areas

of the city and Elyria Township.

Goal 4: Prioritize Middle Avenue as the highest need on a list of

Elyria’s improvement projects and make it the most beautiful

gateway and a source of pride in the city.

Goal 5: Increase citizen involvement in our neighborhoods and

provide more information to the residents of our neighborhoods.

Goal 6: Decrease street crime (drug, violence and gang activity)

and other crimes (littering and loitering) that impact the quality of

life in our neighborhoods.

Goal 7: Have a variety of activities available to youth.



Goal 8: Establish mechanisms to insure accountability for the

implementation of Elyria Plan 2015.

Other priorities and initiatives focused on improving neighborhood

safety and quality include:

• Create new housing minimum standards to ensure sustainable

high quality homes and neighborhoods

• Improve maintenance and amenities in neighborhood parks

• Require residents to repair their sidewalks or install new

sidewalks where they do not exist

• Replace deteriorated curbs and aprons, assess property

owners and provide modest city financial assistance

• Create real estate “Point of Sale” code compliance program

• Provide city-wide code enforcement

• Implement rental housing registration and inspection program

to enforce code compliance

• Develop ticketing procedure to enforce property maintenance

standards.

• Develop self-funded housing court for code violations and

tenant disputes

• Allocate funds toward demolishing blighted structures to

increase property values and decrease crime

• Hire additional police officers to patrol neighborhoods with a

focus on Community Oriented Policing and make the

Neighborhood Impact Unit a permanent program of the Elyria

Police Department

• Charge fee for multiple nuisance calls to same property

• Improve connectivity of neighborhoods, parks, schools and

other community amenities through maintained sidewalks,

recreational trails and signage

• Provide city support to neighborhood watch groups

• Encourage block watch groups to urge residents to maintain

their houses, lawns and landscaping

• Rename parks for neighborhood unity

• Study the feasibility of a city-wide public transportation

system as well as shuttle to Cleveland Hopkins and RTA



Conclusions: Major neighborhood and housing issues identified in the

2015 Master Plan include residential property maintenance (and

enforcement) and improved transportation options throughout the City.

Local citizen involvement is anticipated to be a critical component of

neighborhood pride, accountability to the objectives of the 2015 Plan, and

increased safety/decreased crime.

Strategies:

• Review the City’s Plan regularly to focus on housing and housing-

related issues (i.e., homelessness, housing choice) from both a

metropolitan and regional perspective.

• Design and implement a region-wide Fair Housing Planning (FHP)

process.

3. Neighborhood Revitalization, Municipal and Other Services

Employment-Housing-Transportation Linkage

One aspect of fair housing choice is neighborhood revitalization and the

provision of good services to areas in which low and moderate income

families live. Blacks, Hispanics, and other urban minorities and persons

with disabilities who are most concentrated in such neighborhoods will

benefit from better neighborhood environments so critical to good

housing.

Frequently, the quality or extent of public services and facilities varies

dramatically among residential neighborhoods. Public services and

facilities included schools, recreational facilities and programs, social

service programs, parks, roads, transportation, street lighting, trash

collection, street cleaning, crime prevention, and police protection

activities. Lower-income, densely populated residential areas too often

lack the level and array of services that are provided in less impacted,

more affluent neighborhoods. Elyria should strive to equalize services as

part of FHP.

Job Training. The Employment Network is a local organization which

helps facilitate companies and their training needs, in partnership with

Lorain County Community College and the Lorain County Joint

Vocational School Adult Career Center. Contact information for these

entities was provided by the City’s Economic Development Director:

The Employment Network

Don Graves

42495 North Ridge Rd.

Elyria, OH 44035

440-284-4642 or 440-328-2363



Lorain County Community College

Entrepreneurship Innovation Institute

Julie Cantrell, Sales Manager

151 Innovation Dr., Suite 120

Elyria, OH 44035

440-366-4301

Lorain County Joint Vocational School Adult Career Center

Chris Fletcher, Director

15181 State Route 58

Oberlin, OH 44074

440-774-1051 ext. 2241

Transportation Linkage. Lorain County Transit provides local bus

transportation to the City of Elyria and throughout the county, with 12

fixed-route schedules operating from 5 AM to 10:30 PM on weekdays and

8 AM to 5PM on Saturdays and Sundays. In addition, LCT operates two

express bus routes to the Cleveland Airport and the Westlake Park and

Ride, which connects with RTA, Cleveland’s local transit authority.

LCT also provides Dial-a-Ride service for the general public, as well as

seniors and disabled persons, to cover locations not directly served by the

fixed routes. Dial-a-Ride service operates during most of the hours that

fixed-route service is running, although pick-ups must be scheduled a

day in advance.

The following table describes the fare schedule as of 12/2009:

Table 12: Lorain County Transit Fare ScheduleTable 12: Lorain County Transit Fare ScheduleTable 12: Lorain County Transit Fare ScheduleTable 12: Lorain County Transit Fare Schedule

Rider TypeRider TypeRider TypeRider Type FaresFaresFaresFares

Age 2 & Under Free

Regular Fare $2.05

Senior Citizens with ID $1.00

Handicapped $1.00

Children 3-12 years old $1.00

As part of the current Analysis of Impediments, existing local bus routes

were plotted and analyzed to determine access from residential

neighborhoods to major employers (listed in section II C, above). A

quarter mile radius was used, which is a typical 5-minute walking

distance for the average person.



Nelson Stud Welding appears to be located more than ¼ mile from an

existing bus route. In addition, Westwood Middle School and Oakwood

and Prospect Elementary Schools are all located more than ¼ mile outside

of a major bus route. Residential areas located in the northeastern and

southeastern portions of the City (except those near Abbe Road) do not

have bus service within a ¼ mile of homes. The lack of convenient access

via public transit from residential areas to major employers could be an

impediment to housing choice for some individuals.

Intercity rail service is provided by Amtrak, which maintains a station in

Elyria. Direct rail connections are available to Toledo and Chicago to the

west and Pittsburgh, New York City, and Washington DC to the east. The

nearest passenger airport is Cleveland Hopkins International; Lorain

County Transit operates a shuttle bus from Elyria to the airport terminal.

Strategies:

• Review existing public transportation routes to link transportation and

job employment centers to where lower-income persons and families

reside.

Non-Motorized Transportation. Elyria adopted a Greenway and Trail

Master Plan in September 2009. The plan calls for a major spine through

the heart of the City, connecting to the regional North Coast Inland Trail.

A secondary loop trail is planned around the perimeter of the City,

linking a number of local parks and recreation areas to the primary spine.

A system of spur trails further connects the outer loop to the central

north-south spine.

In general, the non-motorized plan covers Elyria well, with multiple

connections between residential (including low-income) areas, parks, and

commercial centers. A number of the major industrial employers in the

City, particularly north of Broad Street along the railroad, are located

more than ¼ mile from the proposed trail system, potentially limiting

employment access from persons dependent on non-motorized

transportation.

Strategies:

• Implement the non-motorized Greenway and Trail Master Plan to

connect all neighborhoods with destinations such as jobs, schools, social

service agencies and parks.

• Investigate additional spur or loop trail routes to connect major

employers to the City-wide greenways system.



4. PHA and Other Assisted/Insured Housing Provider Tenant Selection

Procedures; Housing Choices for Certificate and Voucher Holders

Responses to the following questions regarding tenant selection and

housing choice in public housing were provided by the Lorain

Metropolitan Housing Authority in December 2009.

1) What are the application and tenant selection and assignment

policies of the Housing Authority?

See “Tenant Selection and Assignment Plan”

2) Is there a pattern in one or more assisted housing developments of

concentration of tenants by race or ethnicity?

No.

3) Do the tenant selection policies and procedures of HUD-assisted

multifamily housing providers, including PHA’s, exclude-or limit

the participation of –persons with disabilities in housing

developments they manage?

No.

4) If the answer to either of the two preceding questions is yes, how

do these policies and procedures specifically affect the manner in

which applications for housing are treated and applicants rejected

or selected as tenants?

N/A

5) Are the policies and procedures consistent with the requirements

of Federal, State, and local law and HUD regulations and

guidelines?

Yes.

6) If a HUD-assisted (including PHAs) or HUD-insured housing

provider has been found in non-compliance with one or more civil

rights laws or regulations, has the provider initiated appropriate

corrective actions?

N/A

7) Are there any court suits involving the tenant application,

selection, and assignment policies and procedures of any of these

providers?

No.



8) If court orders relate to any of these policies or practices, what is

the status of actions to comply with the orders, and what are the

results?

N/A

9) If there are concentrations of racial or ethnic groups in one or

more public housing developments, has the Housing Authority

undertaken any efforts designed specifically to desegregate these

developments, such as make changes to its tenant selection and

assignment plan (TSAP)?

No.

10) If there are racial or ethnic concentrations does the Housing

Authority policy permit applicants or transfers to state a

preference for one or more projects or developments?

See “LMHA Transfer Policy”

11) Does Housing Authority policy permit applicants to reject several

unit offers without losing their place on the waiting list? What are

the bases for rejecting an offer of a public housing unit? Are they

narrowly construed, or so broad that an applicant could easily

reject a unit in a project in which his or her race does not

predominate?

See “Tenant Selection and Assignment Plan”

12) What is the pattern, by location and family type, of minority and

non-minority certificate and voucher holders who rent units

under the Section 8 certificate and voucher housing assistance

program?

The majority of voucher holders live in the City of Lorain. See also “Voucher

Demographics Report” reflecting the distribution of current residents.

13) Are minorities located primarily in minority neighborhoods and

Whites in predominately White neighborhoods regardless of

family type (large, small, or elderly family)?

No; individual families can choose where they live.

14) If the answer to the previous question is yes, what specific steps

does the Housing Authority take to promote housing choice for

certificate and voucher holders?

N/A



15) Are certificate and voucher holders using the certificates and

vouchers they receive from the Housing Authority (local PHA)

outside its geographic jurisdiction?

Yes, voucher holders have the option to port anywhere in the United States.

When the receiving housing authority bills LMHA, LMHA is still

administering the voucher.

16) Are Section 8 certificates and vouchers transportable across PHA

(and other administering agency) boundaries? Does the PHA (or

other agency) that administers these programs in the jurisdiction’s

area actively promote mobility through cooperative efforts with

other agencies in the metropolitan area? What are the results of

these efforts?

Yes. LMHA interacts with other counties as well as out-of-state agencies,

with positive results.

17) Does the City actively support any of the efforts enumerated

above?

The City does not actively support actions of LMHA with regard to voucher

mobility. However, the City would be willing, if called upon and able to do

so, particularly from a non-monetary perspective, provide assistance to

facilitate cooperation amongst agencies.

18) If so, in what ways? Do they include cooperative efforts with

surrounding jurisdictions?

As noted above the City supports the efforts of LMHA in an indirect

manner.

19) Do the policies and procedures of the Housing Authority (or other

administering agency) in the City’s jurisdiction, or PHAs or

agencies administering one or more assisted housing programs in

neighboring jurisdictions, discourage or reject applications from

lower income households that do not reside in their jurisdiction

by imposing residency or other local preferences?

Per the City’s Community Development Director, there is no residency

requirement. There is no knowledge of applications being rejected by Elyria

that originate in adjacent jurisdictions.

20) Does the Housing Authority assist certificate or voucher holders

who have received their certificates or vouchers from PHAs in

other jurisdictions? In what ways?



Yes. LMHA receives vouchers from incoming ports and maintains a list of

available rental units; the rental list is available at LMHA’s office as well as

online. LMHA allows landlords to post units for rent in the lobby for anyone

coming to the office.

21) Does the Housing Authority assist certificate or voucher holders

who are persons with disabilities?

Yes. LMHA makes reasonable accommodations for families upon request.

LMHA has performed annual interviews at residents’ homes when they are

unable to come in to the office, mailed documents for signatures, hired

interpreters for the Deaf, etc.

22) Does the Housing Authority help all certificate and voucher

holders find suitable housing?

The Section 8 department does not help people find housing, but provides

listings, makes the office bulletin board available for postings, and promotes

the website www.gosection8.com.

23) Does this help include providing up-to-date information-to

minority homeseekers in particular-about the various facilities

and services that are available in all neighborhoods in which

housing suitable to the needs of certificate or voucher holders is

available?

Yes, the attached Briefing Packet is given to families at their initial

orientation to the public housing program.

24) Does the Housing Authority encourage certificate and voucher

holders, particularly minorities, to look for housing in

neighborhoods that are not traditional residential areas for the

holder in question?

Yes, and de-concentration is discussed in the initial orientation meeting.

25) Does the Housing Authority assist the search process in other

ways, such as:

• Calling to confirm the availability of units located in

nontraditional neighborhoods? No.

• Helping with transportation costs or providing transportation

services for those interested in housing in nontraditional

neighborhoods? No.

• Providing a master list of the names and addresses, number of

units, and other data on multifamily developments in a

metropolitan or other regional area that makes units available



to Section 8 participants? Yes, via the GoSection8 website. See

attached brochure.

• Providing clear information to all participants concerning their

housing rights and the steps they should take, including

requesting assistance from the Housing Authority in the

housing search, if they believe they have encountered housing

discrimination? Yes. HUD’s “Fair Housing” booklet is

distributed to program participants.

26) Has the City evaluated the performance of the agency that

administers the Section 8 certificate and voucher programs in its

area to determine what results have been achieved under the

equal housing opportunity component of the Administrative

Plan?

No, an evaluation has not been performed. The City has nothing to do with

LMHA, nor would they know how to assist. The City doesn’t know who

oversees LMHA. When a complaint is filed the Fair Housing Board

investigates in the manner in which it investigates all complaints filed.

27) What steps does the Housing Authority take to promote the

availability of accessible housing resources for Section 8

participant families in which one or more persons are mobility

impaired?

LMHA maintains a bulletin board in the office lobby, where the public can

post available housing.

28) What steps does the Housing Authority take to help certificate or

voucher holders with other types of disabilities find housing and

to promote housing choice for such persons?

Landlords are able to list any special features of a home, including handicap

accessibility, on the Go Section 8 website.

29) What are the Housing Authority and other assisted/insured

housing provider policies for admitting persons with mental or

other nonphysical disabilities? Are these persons restricted to

certain projects? Are the policies consistent with HUD guidance

and requirements: Does the City actively support these steps? In

what ways?

In order to apply for the HCV program, a person must meet the criteria on

the application and pass a background check. LMHA does not deny an

applicant based on type of disability.



30) Has the Housing Authority completed its Section 504 (of the

Rehabilitation Act of 1973) assessments of need for housing or

other assistance among households with members who are

disabled and the plans for meeting these needs?

Yes, LMHA has developed a transition plan.

31) Has the City completed its self-evaluation consistent with Section

504 of the Rehabilitation Act of 1973?

Yes, a self evaluation was completed by the City on or around 1995/1996.

The evaluation was completed by the City ADA Advisory Board with

assistance from City staff.

32) Has the Housing Authority (or HUD assisted housing provider)

completed a self-evaluation of its policies, procedures and

practices to determine whether they may adversely impact

persons with disabilities during the application or tenanting

process? If so, has the recipient corrected all identified

deficiencies, pursuant to 24 CRG 8.51?

Yes.

33) Has the Housing Authority conducted a needs assessment to

identify need for accessible units and does it have a transition plan

to assure access?

Yes, a needs assessment is an on-going task. LMHA’s current transition

plan is dated December 19, 2007.

34) Have HUD-assisted housing providers reviewed their housing

program as required by Section 504 and has it carried out the

steps in its transition plan to assure full accessibility of the

program?

Yes. LMHA is in the ongoing process of incorporating ADA-compliant or

universal design improvements to meet their goal of 5% total LMHA-owned

units (new or existing). LMHA is in the process of converting 18 zero to 1-

bedroom row house units into 1 and 2 bedroom ADA-compliant housing

units in Lorain and remodeling a 4 bedroom scattered site home into a 3

bedroom ADA-compliant unit utilizing a universal design as a template.

Planned, but not yet initiated upgrades at Riverview Apartments in Elyria,

include upgraded elevators and alarm systems. The facility currently has

electric doors.

35) What steps has the Housing Authority taken to assure that

persons with disabilities have access to the same range of housing

choices and types as are offered to persons without disabilities?



LMHA provides a listing of units available for rent to any interested

families, including those with disabilities.

36) What steps has the Housing Authority taken to identify funding

resources and develop programs, in partnership with other public

or private agencies and with private landlords participating in

Section 8 certificate and voucher program, to provide funds and

incentives for making privately-owned housing units accessible to

persons with disabilities?

LMHA has collaborated with another agency (LEAP/CIL). Funding follows

the person.

37) Has the Housing Authority implemented policies and procedures

for assuring that Fair Market Rents are adjusted, as permitted by

HUD regulations, to allow persons with disabilities to use

certificates and vouchers in order to rent accessible, private sector

housing units?

Yes, through an Annual Review.

Strategies:

• Provide support to Lorain Metropolitan Housing Authority in their

desegregation efforts.

• Encourage Lorain Metropolitan Housing Authority to utilize scattered-

site, low-density housing acquisition as a means to de-concentrate

racially impacted public housing.

• Incorporate universal design elements into the City’s fair housing

ordinance.

5. Sale of Subsidized Housing and Possible Displacement

If displacement occurs due to a Housing and Urban Development (HUD)

or Ohio Office of Housing and Community Partnerships (OHCP) assisted

project, then the City of Elyria shall provide relocation assistance to

displaced persons in accordance with the federal Uniform Relocation

Assistance and Real Property Policies Act of 1970, as amended.

6. Property Tax Policies

According to the Lorain County Treasurer’s office, there are no property

tax reductions available for low-income individuals. Property tax

reductions are available for disabled or elderly persons only.

Although no reduction exists for low income persons, the Treasurer

accepts incremental or partial property tax payments from all individuals.

However, per Ohio Revised Code Section 323.121, Ohio law requires that



a 10% penalty be levied on any unpaid property tax balance at the end of

each year.

Strategies:

• Consider initiating or broadening property tax relief provisions as a

means of preserving lower-income home-ownership opportunities,

especially if such provisions would be beneficial to minority households,

elderly households, or households with one or more members who are

disabled.

7. Planning and Zoning Boards

Diversity in representation of citizens in the community, including lower-

income racial and ethnic groups, gender categories, persons with

disabilities, and families with children should be a basic element of the

City’s efforts to affirmatively further fair housing.

Planning Commission. The Planning Commission consists of seven

members, with the Mayor serving as chairman. The current Planning

Commission includes two African-Americans and five Caucasians. Six of

the Commissioners are male, five are married, and all members are 45

years old or older. The disability status of the Planning Commission

members is not known.

Planning Commission meetings are held at 11:00 AM on the first and

third Tuesday of each month in the Council Chambers at City Hall.

Board of Zoning Appeals. Five members (one African-American woman

and four Caucasian men) comprise the Board of Zoning Appeals in

Elyria. None of the members have any known disabilities, and familial

status is only known for two members (one widowed, one married).

Strategies:

• The City should pay close attention to the diversity in representation of

citizens in the community, including lower-income racial and ethnic

groups, gender categories, persons with disabilities, and families with

children, on the City’s boards and commissions.

8. Building Codes (Accessibility)

The Elyria Building Department works to identify substandard housing

conditions that could be hazardous to health and safety through code

enforcement activities. The following information was summarized

following a phone interview with Mr. Phillip Lahetta, Chief Building

Inspector:

Applicable Codes. Elyria adheres to the 2007 Ohio Building, Mechanical,

and Plumbing Codes, 2008 National Electrical Code, 2006 Residential

Code of Ohio, and 2003 International Property Maintenance Code. The



City’s Property Maintenance Code has been modified to account for local

weather conditions.

ADA Accessibility. The State Building Code includes provisions from the

Americans with Disabilities Act (ADA) and requires that all new

construction of multifamily units include units that are easily convertible

to accessible units for persons with disabilities. The City follows the

ADA-Accessibility Guidelines for all new or altered construction projects

within the City, including Multi-Household Dwellings (4 or more

household units).

Smoke Detectors. The Ohio Building Code requires that smoke detectors

be installed for all new or altered structures. Smoke detectors in existing

structures are addressed as part of the Property Maintenance Code.

Inspection of rehabilitation projects completed using CHIP or CDBG

funding would note the presence or absence of smoke detectors. The City

Fire Department currently has 90 smoke detectors, which it received from

the Red Cross, and has been looking for means of effectively marketing

their availability to the public. The Fire Chief has expressed a desire to

initiate a program where community organizations donate smoke

detectors to keep the program going. It has also been discussed that the

program would include personnel from the fire department going to

senior citizens homes and properly installing the detectors. No such

program has been initiated to date.

Access for Inspection Purposes. In general, City building inspectors

receive very good cooperation from multi-household and two-household

dwelling complexes in terms of gaining access for inspection or complaint

follow up purposes. Single household dwellings can sometimes pose

difficulties, particularly in cases where ownership of such units was

gained through inheritance or land contracts.

Rental Registration. The City has explored the possibility of initiating a

rental registration program and analyzed the logistics of such programs

being administered by the cities of Akron, Toledo, Lorain, and Sheffield

Lake. The City would prefer a program which is financially self-

supported through fee collection.

Recent changes in the housing market have precipitated a decrease in

“flipping” and conversion of owner-occupied single-household dwellings

to two-household rental units. In addition, staffing cut backs and the

demands associated with NSP-funded demolition and code compliance

have caused the City to shift its focus away from rental registration.

Nature of Inspections. The City requests interior and exterior

inspections, however, inspections are geared toward the nature of the

complaint received. Most complaints concern the exterior of a structure.



If inspectors are provided access to the interior of a structure they will

note visible interior code violations. From January 2008 to present, the

City has received full compliance on 70% of all inspection cases.

Strategies:

• As noted in the Elyria 2015 Plan and at 2010-2014 Consolidated Plan

public input sessions, the City should establish a rental registration and

inspection program.

• Complete interior and exterior inspections for all complaints, regardless

of the nature of the complaint.

• Work with the County to secure funding necessary to provide smoke

detectors to low income families. Following receipt of necessary funding,

actively market and distribute smoke detectors to income eligible families

and provide information related to proper maintenance and installation

of smoke detectors.

B. Private Sector

Government policies and procedures that regulate, monitor, or otherwise

impact rental, sales, and property insurance practices can play a significant

role in promoting fair housing choice. The City should consider reviewing

their current policies and procedures in light of private sector practices to

determine what, if any, changes might be made to strengthen their role

where private sector practices appear to discriminate or otherwise contribute

to restrict housing choice.

Until the recent past, many mortgage lending and real estate appraisal

policies and practices were openly discriminatory. Decisions as to property

values, lending criteria, and related factors frequently rested on the race or

ethnicity of the applicant and the racial or ethnic identity of the

neighborhood in which the subject property was located. Lending policies

and practices also treated applicants differently based on gender. Because of

the close relationship between mortgage lending and appraisal activities, the

policies and practices in one area significantly impact those in the other area.

Studies show the need for affirmative action by lenders themselves to look at

their policies and practices and change the manner in which judgments are

made by every person who plays a role in lending process.

1. Fair Housing Practices Questionnaire

A list of fair housing-related questions that surveyed existing operations

and actions being taken to ensure that fair housing practices were being

applied by the private sector was distributed to several local financial

institutions and real estate professionals. The lists were distributed



electronically to individuals as recommended by the City’s Office of

Community Development.

Prior to distribution of the list of questions, phone contact was made to

explain the purpose for the questions and the need for detailed responses.

Recipients were given sufficient time to respond and a deadline for

providing requested information. Unfortunately, no responses were

received from the private sector after several attempts were made to

follow up via e-mail and phone contact.

Strategies. The Fair Housing Board/City should consider the following

strategies with regard to the private sector:

• Perform periodic (quarterly) examinations of sales and rental practices

including real estate broker and financial institution practices, through

formal surveys and informal means.

• Establish reporting requirements for housing providers in the City.

• Due to a lack of responses, it is unclear whether redlining or

blockbusting is occurring throughout the City, however, the Fair

Housing Board should consider adoption and dissemination of anti-

redlining or anti-blockbusting policies.

• Work with contracted entities to establish a stronger public education

effort regarding the protection under fair housing laws, or other actions.

Identify areas of where existing outreach can be supplemented and new

forms of media can be explored to increase the efficiency of such outreach.

Provide training to loan officers, other lending personnel, appraisers, and

private insurance staff in how to apply HUD’s Fair Housing policies and

standards.

• Develop performance measures or other testing mechanisms to gauge

private sector understanding and application of Fair Housing laws and

practices.

• Encourage lenders to examine their conventional mortgage and home

improvement loan profiles to determine whether there are neighborhoods

that are underrepresented or not represented in these profiles.

• Encourage lending institutions to aggressively market the availability of

mortgage and home improvement loans in minority neighborhoods and

encourage minorities to apply.

• Establish a steering committee made up of representatives of local banks,

financial institutions, mortgage companies, realtors, and appraisers to

identify problems and provide solutions that promote fair housing.



C. Public and Private Sector

1. Fair Housing Enforcement

Effective fair housing enforcement lies at the heart of a comprehensive

program to affirmatively further fair housing.

To assure good standing for HUD’s Community Planning and

Development (CPD) programs, the City should address any and all

concerns expressed by HUD in contract conditions that relate to fair

housing and equal opportunity performance as required by the laws and

regulations governing these programs. These concerns include any and

all court decisions relating to fair housing and other civil rights laws to

which the City or LMHA is subject.

Answers to the following questions are summarized from responses

received from LaTaunya Conley, Director for the City of Elyria Office of

Equal Opportunity and City Liaison to the Elyria Fair Housing Board,

and Mindy Wright from the Lorain County Urban League, the contracted

fair housing provider for the City of Elyria.

1) What is the structure and process of the City’s fair housing

enforcement program?

The five-member Elyria Fair Housing Board ensures that the fair housing

practices codified by local ordinance are consistently applied. Through a

combination of education and enforcement programs, the Fair Housing

Board investigates complaints of unlawful housing practices and endeavors

to resolve issues that may arise. When necessary, the Board may hold

hearings and recommend further enforcement action to the Mayor. Fair

housing complaints, depending on the circumstances, may also be referred to

the Ohio Civil Rights Commission, with the Lorain County Urban League

serving as a mediator and to maintain open communication between the

complainant and the OCRC.

2) Is it the most appropriate structure and process for the City and

does it conform fully to HUD requirements (e.g. enforce a

substantially equivalent fair housing law)?

The current fair housing enforcement procedure does conform to HUD

requirements, both at the City level and through the contracted services

provided by the Lorain County Urban League. Regular reports from the

LCUL are presented to the City for review and a representative from the

League attends Fair Housing Board meetings. Room for improvement exists

in the eyes of LCUL in the form of a more effective referral process, whether

through new marketing strategies to advertise the services of the FHB and



LCUL or through targeted presentations to selected sub-populations and

neighborhoods.

3) Is the enforcement program efficient and effective in providing

complainants and respondents with an objective and fair process

for pursuing and settling housing complaints?

Generally, the City’s program of fair housing enforcement has been effective,

although underused the past few years. There have been a total of 13 fair

housing complaints filed between 2005 and 2009, all but one of which is

currently closed. An objective process exists, with cases unable to be resolved

by the Fair Housing Board at the City level being referred to the Ohio Civil

Rights Commission and HUD. On rare occasions, the City has involved civil

rights attorneys to assist in resolving a complaint.

4) Does the City require reports regarding fair housing complaints

from the enforcement agency and use them in fair housing

enforcement-related activities such as audits or Government-

supported education and outreach activities?

The Lorain County Urban League provides reports of fair housing

enforcement at each meeting of Elyria’s Fair Housing Board. An annual

summary report allows the FHB to confirm that local, state, and federal

regulations are effectively implemented and program goals are being

achieved.

5) Has a court determined that housing discrimination has occurred

in any aspect of the City’s Community Development or housing

programs, or the programs administered by the Public Housing

Authority (PHA) in the City?

Based on the responses received, neither the City nor LMHA has been found

at fault in a housing discrimination complaint.

6) What have the CDBG grantee and sub-recipients done to bring

their programs into compliance with Section 504 of the

Rehabilitation Act of 1973, as amended?

The City of Elyria and the Lorain County Urban League currently comply

with all Section 504 requirements. Anti-discrimination statements are on file

and continuing education efforts ensure that all applicable laws, rules, and

regulations continue to be observed.

7) Has HUD made a finding of violations of the Fair Housing Act,

Title VI, or Section 504, or regulations implementing these laws, in

any federally funded housing or housing related activities in the

City? If so, please explain?



No violations were reported by the City or the LCUL.

8) If so, has the City designed and implemented appropriate actions

to address the court determination or HUD finding?

N/A

9) Has the City ensured that all appropriate officials and employees,

including sub-grantee and PHA officials and employees, are fully

aware of the required actions and their responsibilities? How?

Required actions and responsibilities are stated in all sub-recipient contracts

and periodic updates refresh elected and appointed officials on the duties of

the City regarding fair housing enforcement. It is the City’s continuing

policy to secure equal housing opportunities for all citizens, without regard

to race, color, creed, gender, familial status, religious belief, national origin,

or disability.

10) If HUD has placed contract conditions on grants or loans awarded

to the City, or denied funding because of evidence of a violation of

one or more applicable civil rights laws, has the City taken all the

steps required to meet the stipulations in these contract conditions

or to remove the basis for funding denial?

HUD has not placed any conditions on City funding nor has the agency

denied funding because of any civil rights violation.

Ohio Civil Rights Commission. Under Ohio law, all citizens are

guaranteed protection against discrimination in housing accommodation,

giving all persons, without regard to race, color, religion, sex, national

origin/ancestry, disability, or familial status, the right to live wherever

they can afford to buy a home or rent an apartment. OCRC is the state

agency that enforces anti-discrimination laws and the Fair Housing Act.

Any person who feels they have been discriminated against under the

Fair Housing Act and/or Ohio Fair Housing Law may file a complaint

with OCRC. OCRC is equipped to take complaints in person at their

regional office in Cleveland or through the mail. The complaints must be

in writing and notarized. OCRC staff can provide assistance to those who

need assistance in drafting and filing their complaints. After complaints

are filed, they are investigated by OCRC on both the part of the

complainant and the respondent.

A complaint may be resolved in a number of ways. OCRC first offers to

resolve the dispute through mediation, if all parties agree. If mediation is

not agreed upon or a resolution cannot be found, the complaint proceeds

through the investigative process and is then reviewed by the regional



director of OCRC. The Commission makes the final determination of

probable cause that an illegal act of discrimination occurred. If no

probable cause is found, the complainant may ask for reconsideration of

the complaint within 10 days of the determination.

If probable cause is found, the complaint proceeds through the resolution

process. A complaint may be resolved through a settlement between the

parties. If a settlement cannot be reached, OCRC issues a formal

complaint and a public hearing takes place before the state Attorney

General. After the hearing, OCRC issues an order to either cease and

desist the discriminatory practice or dismiss the case. Appeal for judicial

review in the Court of Common Pleas is available to a complainant or

respondent who is not satisfied with the OCRC’s final order.

The Ohio Civil Rights Commission, Cleveland Regional Office, can be

reached at:

Frank Lausche Building

615 W. Superior Avenue, Suite 885

Cleveland, Ohio 44113-1897

(216) 787-3150

(216) 787-3549 (TTY)

HUD Office of Fair Housing and Equal Opportunity. The mission of the

HUD Office of Fair Housing and Equal Opportunity is to enforce the Fair

Housing Act and other civil rights laws. HUD and OCRC jointly work in

carrying out investigative and enforcement functions. If a right to fair

housing is being violated, a complaint can be submitted to the nearest

HUD office in Chicago, IL. HUD’s Chicago office is responsible for fair

housing oversight in the Midwest region, including Illinois, Indiana,

Michigan, Minnesota, Ohio, and Wisconsin.

Complaints based upon alleged violations of fair housing law are filed

directly with HUD in Denver or brought to HUD’s attention by OCRC.

HUD’s Chicago office then investigates the allegations.

HUD’s Chicago office can be reached at:

U.S. Department of Housing and Urban Development

Ralph H. Metcalfe Federal Building

77 West Jackson Boulevard, Room 2101

Chicago, Illinois 60604-3507

Phone: (312) 353-7776 or 1-800-765-9372

Fax: (312) 886-2837

TTY: (312) 353-7143



2. Informational Programs

The City should be conducting education and outreach activities to

supplement its fair housing practices. FHP is not comprehensive if it fails

to address the lack of knowledge in the general public and among

Government and other community officials and leaders about actions

constituting discriminatory behavior, fair housing laws, and fair housing

objectives.

Answers to the following questions are summarized from responses

received from LaTaunya Conley, Director for the City of Elyria Office of

Equal Opportunity and City Liaison to the Elyria Fair Housing Board,

and Mindy Wright from the Lorain County Urban League, the contracted

fair housing provider for the City of Elyria.

1) What specific types of activities have been undertaken by the City,

and other entities in the City- such as human relations

commission and other fair housing organizations- to provide

information to the general public, Government officials and staff,

community leaders, and others regarding fair housing laws and

objectives?

Through the City’s contract with the Lorain County Urban League, the Fair

Housing Board disseminates brochures and other literature about fair

housing and non-discrimination on a quarterly basis. This information is

available from local libraries, social service agencies (Lorain County Job &

Family Services, Neighborhood House, Salvation Army, Employment

Network), and government facilities (Health Department and Board of

Mental Retardation and Developmental Disability); fair housing messages

are also broadcast on local cable and radio stations, as well as the Internet

(LCUL website and LorainCounty.com). Presentations are also given at

Council meetings, Neighborhood House, the Board of Mental Retardation

and Developmental Disability, and Catholic Charities. The City’s Fair

Housing Ordinance is codified in Chapter 725 of the Code of Ordinances.

2) Are these activities confined largely to National Fair Housing

Month (April), or is there a comprehensive set of activities going

on throughout the calendar year? If throughout the year, please

list activities?

Outreach on fair housing issues occurs throughout the year in Elyria. In

addition to year-round availability of brochures and other literature, radio

and cable ads, and online resources, the City engages in more targeted efforts

multiple times per year.



• In January, the Fair Housing Board participates in the community-

wide Martin Luther King Jr. holiday celebrations.

• Radio ads, including contact information, about fair housing

resources run on local radio stations in February in conjunction with

“Moments in Black History” informational spots.

• The Lorain County Urban League hosts an annual conference in

conjunction with National Fair Housing Month in April.

• National Homeless Awareness Month in November brings more

opportunities to distribute information on fair housing practices

through the events of the Lorain County Urban League.

• Billboard advertisements have been used in the past to raise

awareness of resident rights, and public forums at libraries and

community centers occur throughout the year as part of the City’s

educational and informational outreach efforts.

3) How effective is each of these activities in increasing knowledge

of the laws, reducing discriminatory behavior, or achieving other

worthy results?

While the distribution of fair housing informational materials has likely

increased knowledge of the law throughout the community, it is difficult to

determine any measurable results as there is no testing program in place.

Differentiation between fair housing complaints and landlord/tenant issues

remains a challenge for local providers; most resident contacts do not involve

Fair Housing violations.

Presentations and information dissemination alone has not proved sufficient

to generate fair housing referrals, but additional collaboration with area

housing providers (including interaction at the annual Fair Housing

Conference) is expected to achieve greater results.

4) Has the City implemented specific fair housing information

programs for officials and employees having duties that impact on

fair housing such as developing zoning policies, planning assisted

housing, and community and economic development activities? If

so, please explain?

The City does not currently have a specific Fair Housing education program

for officials and/or employees, although local official are invited to attend

(and have attended in the past) the annual Fair Housing Conference.

Training is conducted annually for Fair Housing Board members regarding

both their duties and updates to fair housing laws and regulations, and

quarterly meetings (open to the public) are held between the Fair Housing

Board and City staff.



5) Are there areas in the City where conflict between different racial

or ethnic groups is evident? Between persons with and without a

disability? If so, please explain?

The Lorain County Urban League reports that there have been issues in the

past in three areas of Elyria (South Park Apartments, Westway Gardens, and

Kensington Square). A former property manager informed the Urban League

that Hispanics were often placed on a longer waiting list for housing and

would be overlooked in favor of non-Hispanic tenants, but no corroboration

could be gathered to pursue the case.

6) Are there effective outreach, education, and information programs

in the City designed to create a good understanding among civic

leaders, educators, and other citizens of all ages to reduce the

adverse effects and force of negative attitudes among segments of

the community concerning people who are different racially,

ethnically, and culturally or who are disabled? If so, please give

examples?

The city’s Fair Housing Administrative Liaison and Lorain County Urban

League Housing Coordinator welcome invitations to speak to civic leaders,

community organizations (e.g., Rotary, Kiwanis, and Lions Club), educators,

and other interested parties regarding Fair Housing laws and regulations.

Accessibility requirements, structural renovations/retrofits for disabled

persons, and tenant rights and obligations are frequent topics for community

presentations.

The Fair Housing Board will consider greater involvement with Elyria City

Schools to reach children concerning fair housing and what it means to be

discriminated against because of race, color, national origin, religion, sex, or

disability.

Strategies:

• The City should regularly assess the effectiveness of such activities in

informing people of their rights and responsibilities and in reducing the

kinds of prejudices and intolerance that lead to discriminatory actions.

• The City should develop new outreach, education, or information

programs and activities to promote housing opportunities for particular

segments of the community (such as racial or ethnic minority groups or

persons with disabilities low or moderate income individuals, and

renters). This should be done in cooperation with the City’s Fair

Housing Board and Lorain County Urban League.

• Work to enable victims of discrimination to come forward with

complaints through increased outreach and education of fair housing



rights. Implement previously considered actions such as advertising on

Lorain County Transit vehicles and local billboards.

• Testing of applicants (individuals who attend Fair Housing

presentations or seminars) to evaluate the effectiveness of current

outreach activities.

• Work with LMHA and other subsidized housing facilities to broaden the

scope of outreach efforts and identify new outlets for fair housing-related

materials.

3. Visitability in Housing

“Visitability” means that: (1) at least one entrance is at grade (no step),

approached by an accessible route, such as a sidewalk and (2) the

entrance door and all interior doors on the first floor are at least 34 inches

wide, offering 32 inches of clear passage space.

Visitability allows mobility impaired residents to visit families and

friends where this would not otherwise be possible. A visitable home also

serves persons without disabilities (e.g. a mother pushing a stroller, a

person delivering large appliances, a person using a walker, etc.). One

difference between “visitability” and “accessibility” is that accessibility

requires that all features of a dwelling unit be made accessible for

mobility impaired persons. A visitable home provides less accessibility

than an accessible home, and is meant to be designated for only those

units not required to be accessible.

1) Has the Housing Authority/City incorporated the concept of

visitability in a homeownership or rental project recently built?

There are no projects currently being built in the City of Elyria; however,

visitability elements have been incorporated in LMHA projects in Oberlin

and Lorain city.

2) Has the Housing Authority/City incorporated the concept of

visitability into rehabilitation projects which has resulted in

visitability units throughout the project?

LMHA is embracing universal design for substantial rehabilitation in new

housing.

3) Has the entity developed a written visitability policy and/or a

visitability transition plan in place to make all or a significant

percentage of its units visitable?

LMHA is preparing a policy as part of its Annual Plan.



4. Determination of Unlawful Segregation

Where there is a determination of unlawful segregation or other housing

discrimination by a court, or a finding of noncompliance by HUD under

Title VI of the Civil Rights Act of 1964 or Section 504 of the Rehabilitation

Act of 1973, or where the Secretary has issued a charge under the Fair

Housing Act regarding assisted housing within a recipient’s jurisdiction,

an analysis should be performed of the actions which could be taken by

the recipient to help remedy the discriminatory condition, including

actions involving the expenditure of funds by the jurisdiction.

To the best knowledge of the analysis preparers, there has been no

determination of unlawful segregation or other housing discrimination in

the City of Elyria.



V. Assessment of Current Public and Private Fair Housing Programs and

Activities in the Jurisdiction

Effective fair housing enforcement lies at the heart of a comprehensive program to

affirmatively further fair housing.

A. CRA Compliance

Passed by Congress in 1977, the Community Reinvestment Act (CRA) states

that “regulated financial institutions have continuing and affirmative

obligations to help meet the credit needs of the local communities in which

they are chartered.” The act then establishes a regulatory regime for

monitoring the level of lending, investments, and services in low-and

moderate-income neighborhoods. According to the National Community

Reinvestment Coalition:

“Approximately once every two years examiners from four federal agencies assess and ‘grade’ lending institutions activities in low- and moderate-income neighborhoods. If a regulatory agency finds that a lending institution is not serving these neighborhoods, it can delay or deny that institution’s request to merge with another lender or to open a branch or expand any of its other services. The financial institution regulatory agency can also approve the merger application subject to specific movements in a bank’s lending or investment record in low and moderate-income neighborhoods.”

While denials of bank applications are rare, federal agencies can make

approvals conditional upon specific improvements in a bank’s CRA

performance. Also, dialogue between banks and community organizations

often result in bank commitments to increase lending and/or start affordable

housing and small business lending programs.

The CRA requires that financial institutions progressively seek to enhance

community development within the area they serve. On a regular basis,

financial institutions submit information about mortgage loan applications as

well as materials documenting their community development activity. The

records are reviewed to determine if the institution satisfied CRA

requirements. The assessment includes a review of records as related to the

following:

• Commitment to evaluating and servicing community credit needs;

• Offering and marketing various credit programs;

• Record of opening and closing offices;

• Discrimination and other illegal credit practices; and

• Community development initiatives



The data is evaluated and a rating for each institution is determined. Ratings

for institutions range from substantial noncompliance in meeting credit

needs to an outstanding record of meeting community needs. The table

below summarizes the most recent CRA Compliance rating for the nine

major financial institutions subject to CRA in Elyria.

Table 13: Table 13: Table 13: Table 13: Most Recent CRA Rating of Examined Banks in ElyriaMost Recent CRA Rating of Examined Banks in ElyriaMost Recent CRA Rating of Examined Banks in ElyriaMost Recent CRA Rating of Examined Banks in Elyria

Examined Banks Rating

Number Percent

Outstanding 3 33%

Satisfactory 6 66%

Needs to Improve 0 0%

Substantial

Noncompliance

0

0%

Source: FFIEC Interagency CRA Ratings, 2009

All institutions identified in Elyria currently have a rating of satisfactory or

higher. This compares well with the national average, as does the fact that

not a single financial institution reviewed in Elyria was found to need

improvement or was substantially noncompliant with the CRA.

B. HMDA Data Analysis

HMDA data consists of information about mortgage loan applications for

financial institutions, savings and loans, savings banks, credit unions and

some mortgage companies. The data contains information about the location,

dollar amount, and types of loans made, as well as racial and ethnic

information, income, and credit characteristics of all loan applicants. The

data are available for government loans, home purchases, loan refinances,

and home improvement loans.

HMDA data can provide a picture of how different applicant types fare in the

mortgage lending process. These data can be used to identify areas of

potential concern that may warrant further investigations. For example, by

comparing loan approval rates of minority applicants with non minorities

that have similar income and credit characteristics, areas of potential

discrimination may be detected. HDMA was also enacted by Congress to

provide investors and public agencies with information to guide investments

in housing. Likewise, HMDA analysis can be used to forge partnerships

among banks and community organizations in under saved minority or low-

income neighborhoods.

The Federal Reserve is the primary regulator of compliance with fair lending

regulations. When federal regulators examine financial institutions, they use



HMDA data to determine if applicants of a certain gender, race or ethnicity

are rejected at statistically significant higher rates than applicants with other

characteristics. The Federal Reserve uses a combination of sophistical

modeling and loan file sampling and review to detect lending discrimination.

The HMDA data tables in this section present summary HMDA data by

Metropolitan Statistical Areas/Metropolitan Divisions (MSA/MD).

Examinations of denial rates and general applicant characteristics can suggest

areas for further examination.

Table 14: Table 14: Table 14: Table 14: Elyria Loan Applications Received, by Loan Type, 2008Elyria Loan Applications Received, by Loan Type, 2008Elyria Loan Applications Received, by Loan Type, 2008Elyria Loan Applications Received, by Loan Type, 2008

Government Guaranteed Home Purchase

Conventional Home Purchase

Refinance Home Improvement

Loan originated 272 246 600 136

Approved, not accepted

13 31 81 29

Denied 36 89 541 229

Withdrawn 22 21 175 15

Determined incomplete

1 6 62 8

Loans on 1-4 Family and MHD, FFIEC HMDA Aggregate Reports, 2008

Table 15: Table 15: Table 15: Table 15: Disposition of ApplicatDisposition of ApplicatDisposition of ApplicatDisposition of Applications for FHA, FSA/RHS and VA Home Purchase Loansions for FHA, FSA/RHS and VA Home Purchase Loansions for FHA, FSA/RHS and VA Home Purchase Loansions for FHA, FSA/RHS and VA Home Purchase Loans b b b by y y y Race and EthnicityRace and EthnicityRace and EthnicityRace and Ethnicity, , , , ClevelandClevelandClevelandCleveland----ElyriaElyriaElyriaElyria----Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008

Race Apps.

Received Apps. Denied

Percent Denied Ethnicity

Apps. Received

Apps. Denied

Percent Denied

American Indian/Alaskan Native

7 2 29% Hispanic or Latino

286 46 16%

Asian 58 11 19%

Not Hispanic or Latino

8,026 1,093 14%

Black or African American

1,947 481 25%

Joint (Hispanic/ Latino & Not Hispanic or Latino

67 9 13%

Native Hawaiian/ Other Pacific Islander

24 3 13% Ethnicity Not Available

488 102 21%

White 6,262 635 10%

2 or More Minority Races

8 2 25%

Joint (White/Minority Race)

80 17 21%

Race Not Available

481 99 21%

FFIEC HMDA Aggregate Reports, 2008



Table 16: Table 16: Table 16: Table 16: Disposition of Applications for Conventional HomeDisposition of Applications for Conventional HomeDisposition of Applications for Conventional HomeDisposition of Applications for Conventional Home----PurchaPurchaPurchaPurchase Loansse Loansse Loansse Loans b b b by Race and y Race and y Race and y Race and EthnicityEthnicityEthnicityEthnicity, , , , ClevelandClevelandClevelandCleveland----ElyriaElyriaElyriaElyria----Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008

Race Apps.



Apps. Received

Apps. Denied

Percent Denied

American Indian/Alaskan Native 32 9 28%

Hispanic or Latino 301 63 21%

Asian 396 45 11%

Not Hispanic or Latino 14,588 1,984 14%

Black or African American 1,440 459 32%

Joint (Hispanic/ Latino/Not Hispanic or Latino 115 10 9%

Native Hawaiian/Other Pacific Islander 20 1 5%

Ethnicity Not Available 1,454 277 19%

White 12,959 1,539 12%

2 or More Minority Races 20 4 20%

Joint (White/Minority Race) 150 12 8%

Race Not Available 1,441 265 18%


Table 17: Table 17: Table 17: Table 17: Disposition of Applications on Refinance Loans by Race and Ethnicity, ClevelandDisposition of Applications on Refinance Loans by Race and Ethnicity, ClevelandDisposition of Applications on Refinance Loans by Race and Ethnicity, ClevelandDisposition of Applications on Refinance Loans by Race and Ethnicity, Cleveland----ElyriaElyriaElyriaElyria----Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008

Race Apps.



Apps. Rec’d

Apps. Denied

Percent Denied



Asian 475 182 38% Not Hispanic or Latino 35,271 13,276 38%

Black or African American 5,778 3,233 56%

Joint (Hispanic/ Latino & Not Hispanic or Latino 281 113 40%


Ethnicity Not Available 4,987 2,099 42%

White 29,553 10,059 34% 2 or More Minority Races 71 43 61% Joint (White/Minority Race) 275 108 39% Race Not Available 5,177 2,227 43%




Table 18: Table 18: Table 18: Table 18: Disposition of Applications for Home Improvement Loans by Race and Ethnicity, Disposition of Applications for Home Improvement Loans by Race and Ethnicity, Disposition of Applications for Home Improvement Loans by Race and Ethnicity, Disposition of Applications for Home Improvement Loans by Race and Ethnicity, ClevelandClevelandClevelandCleveland----ElyriaElyriaElyriaElyria----Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008

Race Apps. Received

Apps. Denied

Percentage Denied Ethnicity

Apps. Received

Apps. Denied

Percentage Denied



Asian 91 49 54%

Not Hispanic or Latino 9,394 4,723 50%

Black or African American 2,588 1,758 68%

Joint (Hispanic or Latino/Not Hispanic or Latino 75 31 41%


Ethnicity Not Available 1,745 1,026 59%

White 7,168 3,180 44%

2 or More Minority Races 13 10 77%

Joint (White/Minority Race) 94 56 60%

Race Not Available 1,659 966 58%


For government guaranteed home purchase loans, all minorities had

considerably higher denial rates than whites. Ethnicity appeared not to affect

denial rates noticeably, with 16% of Hispanics denied compared to 14% of

non-Hispanics.

Blacks (32%) and American Indians/Alaskan Natives (28%) had the highest

denial rates for conventional loans among applicants for whom race was

available; for comparison, only 12% of whites were denied for conventional

mortgages. One in five Hispanics (21%) were denied for conventional loans,

compared to 14% of non-Hispanics.

For home improvement loans, minority applicants (54-76%) were denied

more frequently than whites (44%). Both Hispanics (61%) and non-Hispanics

(50%) showed high denial rates in this loan category.

A better picture is provided by analysis of refinance loan denial rates during

2008 because there are more applications for most racial and ethnic groups.

Blacks (56%) and American Indians/Alaskan Natives (54%) had similarly

high denial rates, while relatively lower denial rates were found in the



categories of Asian (38%) and White (34%). Nearly half of Hispanics (47%)

were denied for refinances, while non-Hispanics were lower at 38%.

Denial rates by race and income. The table below presents the percentage of

mortgage loan applicants denied by race and ethnicity, categorized by

income level land loan type. It is important to note that for all groups other

than African American and white, the number of loan applications were

relatively small. As such, caution should be used in interpreting data about

racial and ethnic groups.

Table 19: Table 19: Table 19: Table 19: Mortgage Loan Denial RatesMortgage Loan Denial RatesMortgage Loan Denial RatesMortgage Loan Denial Rates---- Home Purchases Home Purchases Home Purchases Home Purchases---- by Race/Ethnicity and Income by Race/Ethnicity and Income by Race/Ethnicity and Income by Race/Ethnicity and Income, , , , ClevelandClevelandClevelandCleveland----EEEElyrialyrialyrialyria----Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008

Government Guaranteed Home Purchases Conventional Home Purchases

Race/Ethnicity Low Income

Applicants

(<50% of Median)

Moderate, Middle and Upper Income

Applicants (50-79% if Median or Greater)

Apps Denied

Low Income

Applicants

(<50% of Median)

Moderate, Middle and upper Income Applicants (50-79% if Median or Greater)

Apps. Denied

American Indian/ Alaskan Native

1 1 50% 5 16 33%

Asian 9 20 31% 28 70 20%


436 827 27% 289 391 33%

Native Hawaiian/Other Pacific Islander

6 6 17% 2 5 0%

White 852 2,076 12% 1,257 2,675 16%

Ethnicity

Hispanic or Latino

100 113 17% 77 89 25%


1,207 2,795 17% 1,514 3,098 18%

Joint (Hispanic or Latino/Not Hispanic or Latino

3 18 14% 7 7 29%




Table 20: Table 20: Table 20: Table 20: Mortgage Loan Denial RatesMortgage Loan Denial RatesMortgage Loan Denial RatesMortgage Loan Denial Rates----Refinancing and Home LoansRefinancing and Home LoansRefinancing and Home LoansRefinancing and Home Loans---- by Race/Ethnicity and by Race/Ethnicity and by Race/Ethnicity and by Race/Ethnicity and IncomeIncomeIncomeIncome, , , , ClevelandClevelandClevelandCleveland----ElyriaElyriaElyriaElyria----Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008Mentor, OH MSA/MD 2008

Refinances Home Improvement Loans

Race/Ethnicity Low Income Applicants

(<50% of Median)

Moderate, Middle and Upper Income Applicants (50-79% if Median or Greater)

Applicants Denied

Low Income Applicants

(<50% of Median)

Moderate, Middle and upper Income Applicants (50-79% if Median or Greater)

Apps. Denied

American Indian/ Alaskan Native

22 31 64% 10 20 60%

Asian 47 87 51% 16 11 81%


1,051 1,673 60% 666 830 70%

Native Hawaiian/Other Pacific Islander

10 18 50% 17 10 67%

White 2,886 6,038 40% 1,070 1,587 51%

Ethnicity

Hispanic or Latino

184 304 49% 155 143 68%


3,878 7,625 45% 1,606 2,274 58%

Joint (Hispanic or Latino/Not Hispanic or Latino

11 38 53% 3 12 33%


A higher denial rate for minorities does not necessarily indicate fair housing

problems. It can be explained, in part, by minorities often having lower

incomes than non-minorities. It is also possible that credit histories vary

among applicants with different racial/ethnic characteristics. Without a

detailed analysis of each applicant (such data are unavailable in the HMDA

records due to confidentiality), it is unclear if the reason for the difference is

due to variables other than income that are considered in making the lending

decision (e.g., credit history, debt to income ratios) or if discrimination in

lending could be occurring.

Strategies:

• Offer a first-time homebuyer classes and education program about loan

requirements and budgeting to assist applicants in understanding how to

improve their probability of receiving a mortgage loan.



• Provide credit counseling and education about good credit.

• Publicize the availability of government guaranteed loans to potential borrowers.

• Community groups and government officials should take an active role in

encouraging increased CRA compliance activities by local financial institutions.

• Identify specific steps that will be taken to strengthen the fair housing aspect of

community revitalization activities in poorer neighborhoods through equalizing

services, revising displacement policies and procedures, initiating or

strengthening agreements with banks and other lending institutions subject to

CRA, creating job-housing and education-housing linkages in and outside

neighborhoods.

• Regularly monitor tenant characteristics data for the HUD-assisted and HUD-

insured housing developments as one means of evaluating policies, procedures

and practices.



VI. Conclusions and Recommendations

Placement of new or rehabilitated housing for lower-income people is one of the

most controversial issues communities face. If fair housing objectives are to be

achieved, the goal must be to avoid high concentrations of low-income housing.

“NIMBYism” seriously affects the availability of housing for low-income families,

persons with disabilities, homeless persons, or lower-income minorities and is one of

the most difficult challenges jurisdictions encounter in promoting fair housing

objectives. The attitude of local government officials, public pronouncements of

general policy, and careful planning and implementation of individual housing

efforts by providers are key aspects for overcoming resistance of this kind. In

addition, contextual planning of new affordable housing with relationship to scale,

size, density, and architectural character of the neighborhoods where it will be

located is vital to integration and success.

The City of Elyria should convene regular focus group meetings, including, but not

limited to, health providers, landlords, homebuilders, banks and financial

institutions, neighborhood organizations, and service providers to gather feedback

on current barriers and to discuss strategies to eliminate barriers. In addition, the

City should develop new outreach, education, or information programs and

activities to promote housing opportunities for particular segments of the

community (such as racial or ethnic minority groups, low-moderate income persons,

and persons with disabilities). This should be done in cooperation with fair housing

organizations and organizations working on this common goal.

One aspect of fair housing choice is neighborhood revitalization and the provision of

good services to areas in which low and moderate income families live. African-

Americans, Hispanics, other urban minorities and persons with disabilities who are

most concentrated in such neighborhoods will benefit from better neighborhood

environments so critical to good housing. Public services and facilities include

schools, parks and recreational facilities & programs, social service programs,

transportation, public safety, street lighting, good maintenance and code

enforcement. Lower income, densely populated residential areas often lack the level

and array of services that are provided in more affluent neighborhoods. The City

should strive to equalize services as part of FHP.

In a recent study “Where will the jobs come from?” by Dane Stangler and Robert E.

Litan, sponsored by the Ewing Marion Kauffman Foundation, the data shows that

from 1980-2005, nearly all net job creation in the US occurred in firms less than five

years old (e.g start up firms and young firms, ages one to five). Thus, it is clear that

new and young companies and the entrepreneurs that create them are the engines of

job creation and eventual economic recovery. In conclusion, Elyria and the private

sector should develop programs and identify funding opportunities to support job

incubators and start up companies.



Linking strategies to expand lower income housing opportunities in nontraditional

areas with activities to create new or expanded job opportunities not only helps

lower-income families, but may help control local labor shortages. On a regular

basis, the City and Lorain County Transit should review existing transportation

routes to ensure linkages between employment centers and neighborhoods where

lower-income persons and families reside. The City should also strive to secure good

services and facilities in neighborhoods where economic development efforts for

creating jobs and enhancing small business opportunities are underway.

The City should coordinate with adjacent communities and Lorain County to focus

future land use planning efforts on housing and housing related issues and problems

from a metropolitan and regional perspective. Mixed-use zoning should be

encouraged, which allows low income residents to obtain groceries, education, jobs

and other basic services without a vehicle.

LMHA currently provides Section 8-eligible persons with access to a list of approved

landlords throughout the City via the GoSection8 website. To make the program

more effective, the City is encouraged to work with LMHA to establish effective

resources for persons without adequate Internet access to search for available and

eligible properties. In addition, the City or LMHA could help with transportation

costs or providing transportation service for those interested in housing in

nontraditional neighborhoods.

HUD encourages cities to adopt initiatives that will expand housing choices for

persons with disabilities so that persons with disabilities will have the same ranges

of housing choices as persons without disabilities. For example, the City, LMHA,

and private landlords that participate in the Section 8 Certificate and Voucher

program, and the Ohio and City CDBG programs, could join resources to provide

funds for the removal of architectural barriers in housing operated by private

landlords to make these projects accessible to people with disabilities.

In the sale of subsidized housing, the objective should be to preserve lower-income

housing opportunities to the maximum extent feasible. However, if any

displacement of current minority or disabled low-income families occurs, the

objective then should be to provide other housing opportunities to displaced

households by giving them a real choice to relocate inside and outside minority

neighborhoods or in buildings that are predominately occupied by minorities or

persons with disabilities. Because a relocation plan often places sole reliance on the

provision of certificates or vouchers to displaced households, a good program to

promote real choice in the use of certificates and vouchers is essential.

The concept of “visitability” allows mobility impaired residents to visit families and

friends where this would not otherwise be possible. A visitable home also make it

easier on mothers pushing strollers, a person delivering large appliances, a person

using a walker, etc. The City and LMHA should encourage the inclusion of visitable

features in future homeownership and rental projects.



Tax forgiveness, delay, or other tax relief policies can help lower-income

homeowners keep their homes. Programs of this kind can be part of an overall, much

larger strategy to promote fair housing because they help to preserve

homeownership opportunities for groups like minority families and elderly

homeowners who otherwise would have only rental options.

Tax relief can take the form of delayed payments. Property taxes become, in effect, a

lien on the property to be paid at the time of sale or inheritance. Alternatively,

interest-free payments can be spread over months, permitting smaller monthly

payments for those who qualify. Elyria, in conjunction with the Lorain County

Treasurer, should explore these various options.

The City should pay closer attention to the importance of the relationship between

the membership of planning and zoning boards and the decisions they make

regarding neighborhood revitalization activities and lower-income housing site

selection. Diversity in representation of citizens in the community, including lower-

income racial and ethnic groups, gender categories, persons with disabilities, and

families with children should be a basic element of the City’s efforts to affirmatively

further fair housing. A more conscious and dedicated effort to include representation

of these groups on City boards and commissions is paramount.

The City needs to do more in reviewing their current policies and procedures in light

of private sector (e.g. banking, financial institutions, real estate brokers, and

insurance companies) practices to determine what, if any, changes might be made to

strengthen their role where private sector practices appear to discriminate or

otherwise contribute to restricted housing choice. Thus, Elyria should review

lending and appraisal practices through formal surveys or informal means to

examine their policies, procedures, and practices for possible differential treatment

of home mortgage loans, home insurance, or home improvement loans based on

race, ethnicity, gender, disability status, and familial status.

Ultimately, providing adequate housing and improving existing neighborhoods are

vital functions and should always be encouraged. When steps are taken to assure

that the housing is fully available to all residents of the community regardless of

race, color, national origin, gender, disability, or familial status, those are the actions

that affirmatively further fair housing.



VII. Signature Page

The City of Elyria, Ohio, as a recipient of CDBG funds and in order to comply

with its certification to Affirmatively Further Fair Housing (AFFH), has

conducted an Analysis of Impediments to Fair Housing Choice update to

assess the availability of fair housing choice within the City of Elyria. We

affirm that the City of Elyria, Ohio will support the activities to assure

nondiscrimination in the provision of housing and its accompanying

transactions.

________________________________ _________________

William M. Grace, Mayor Date

City of Elyria

________________________________ _________________

Angela Byington, AICP Date

Director of Community Development and Planning

City of Elyria



Appendix

LMHA Supplementary Information including:

• Tenant Selection and Assignment Policy

• Transfer Policy

• Voucher Demographics Report

• Briefing Packet

• Go Section 8 Brochure

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