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Analysis of Impediments to Fair Housing Choice
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Executive Summary
This document presents the City of Union City's Analysis of Impediments to Fair Housing Choice, an assessment of fair housing concerns within the city. The report evaluates laws, regulations, and conditions that may affect an individual's or household's access to housing. It builds on the city's previous AI from 2012 and incorporates data from various sources, including the U.S. Census, HUD, and local plans. The study addresses discrimination in the housing market, fair housing advocacy, lending bias, limited affordable housing, and government policies, providing recommendations to eliminate impediments to fair housing choice. This analysis is intended to inform policies that ensure equal housing opportunities for all residents, regardless of race, color, religion, sex, national origin, handicap, or familial status.
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--- Document: Analysis of Impediments to Fair Housing Choice Document ---
ANALYSIS OF IMPEDIMENTS TO
FAIR HOUSING CHOICE
& Language Assistance Plan
________________________
CITY OF UNION CITY, NEW JERSEY
HON. BRIAN P. STACK, MAYOR
1
PURPOSE
The Fair Housing Act of 1990 states that it is the policy of the United States to
provide for fair housing throughout the country and the Act prohibits any person
from discriminating in the sale or rental of housing, the financing of housing or
the provision of brokerage services, including or otherwise making unavailable or
denying a dwelling to any person because of race, color, religion, sex, national
origin, handicap or familial status. The State of New Jersey supports these goals
and has also adopted legislation that protects equal access to housing.
Nationally, fair housing and impediments to fair housing are monitored by the
United States Department of Housing & Urban Development (HUD) through the
use of funds from the Community Development Block Grant (CDBG) program for
fair housing advocacy groups. The role of HUD as the administrator of fair
housing programs originated in 1968 with the passage of the Civil Rights Act,
described further below.
Each grantee that receives CDBG funding under Title 1 of the Housing &
Community Development Act is required to further fair housing and fair housing
planning by conducting an analysis to identify impediments to fair housing choice
within its jurisdiction. The grantee will also take appropriate actions to overcome
the effects of any identified impediments and will maintain records which reflect
the analysis and actions taken in this regard.
The City of Union City has consistently supported the concept of fair housing for
it’s residents without regard to race, color, religion, sex, national origin, handicap
or familial status. To that end, the City has, at least since the beginning of the
CDBG program, used a portion of its CDBG funding to support activities which
benefit low and moderate income households in the provision of fair housing. The
fundamental fair housing goal is to make housing choice a reality through fair
housing planning, which includes the following:
o Preparing an Analysis of Impediments to Fair Housing Choice (AI)
o Acting to eliminate identified impediments
o Providing fair housing records.
This report presents the City of Union City’s efforts to make an objective
assessment of the nature and extent of fair housing concerns in the City and the
potential impediments to making fair housing choice available to its residents.
The City’s last AI was completed in 2012 in conjunction with the preparation of
the Hudson County Consortium’s Five-Year Consolidated Plan. This AI is related
solely to activities within the City of Union City as it related to fair housing choice
for the residents of the City.
2
DEFINITION OF FAIR HOUSING
Federal Laws
The Fair Housing Act of 1968 and Fair Housing Amendments Act of 1988 (42
U.S. Code Sec. 3601-3619, 3631) are federal fair housing laws that prohibit
discrimination in all aspects of housing such as the sale, rental, lease or
negotiation for real property. The Fair Housing Act prohibits discrimination based
on race, religion and national origin. In 1988, the Fair Housing Act was amended
to extend protection to familial status and people with disabilities (mental or
physical). In addition, the Amendment Act provided for “reasonable
accommodations”, allowing structural modifications for persons with disabilities, if
requested, at their own expense, and sets housing code standards for new multi
family dwellings to accommodate the physically disabled.
New Jersey Laws
The Fair Housing Act (FHA) of 1985 and the New Jersey Law Against
Discrimination, as amended, are the key New Jersey fair housing laws. The FHA
prohibits discrimination in all aspects of housing including sales and rentals, sets
requirements for accessible design, covers multi family dwellings for first
occupancy after March 1991 and establishes elevator requirements for multi
story buildings. The FHA prohibits discrimination based on all of the
classifications covered under the federal Fair Housing Act plus the following
classes: marital status; ancestry; sexual orientation and; income source (added
in 2002). These laws require housing providers to make reasonable
accommodations to permit persons with disabilities to live and enjoy a dwelling
and allow persons with disabilities to make reasonable modifications of the
premises.
Fair Housing Defined
In light of the various pieces of fair housing legislation passed at the federal and
state levels, fair housing throughout this analysis is defined as follows:
Fair housing is a condition in which individuals of similar income levels in
the same housing market having a like range of housing choice available
to them regardless of race, color, ancestry, national origin, religion, sex,
disability, marital status, familial status, source of income, sexual
orientation or any other arbitrary factor.
3
Impediments Defined
Within the legal framework of federal and state laws and based on the guidance
provided by the U.S. Department of Housing & Urban Development (HUD) Fair
Housing Planning Guide, impediments to fair housing choice are defined as:
Any actions, omissions or decisions taken because of race, color,
ancestry, national origin, religion, sex, disability, marital status, familial
status, source of income, sexual orientation or any other arbitrary factor
which restrict housing choices or the availability of housing choices; or
Any actions, omissions or decisions which have the effect of restricting
housing choices or the availability of housing choice on the basis of race,
color, ancestry, national origin, religion, sex, disability, marital status,
familial status, source of income, sexual orientation or any other arbitrary
factor.
To affirmatively promote equal housing opportunity, a community must work to
remove impediments to fair housing choice.
Fair Housing & Affordable Housing
The terms fair housing and affordable housing are often used interchangeably.
However, it is important to distinguish between the two in order to clearly identify
issues and reduce discrimination in the provision of fair housing. In the context of
the preparation of an Analysis of Impediments to Fair Housing Choice (AI), the
term “fair housing” refers to persons (families, seniors, individuals and special
needs populations) who are members of protected classes, as specified by
Federal statutes. It is illegal to discriminate against persons on the basis of their
membership in a protected class in the sale, rental, financing and insuring of
housing. On the other hand, “affordable housing” generally refers to the ability of
households to afford, based on income, to buy or rent housing. Specifically, more
Federal, State and local funding programs to support the increase in the supply
of affordable ownership and rental housing are targeted to low or moderate
income households. Low income households are typically defined as those
earning less than 50% of the HUD determined area median income, with
moderate income households defined as those who earn 50% to 80% of the area
median income.
Because the two concepts are different, methods to address fair housing are
different from those to increase the supply of affordable housing. One difference
4
is that issues of discrimination regarding fair housing can apply to all income
levels, because protected classes are represented in all income groups.
Clearly, there are many actions that can, and should, be taken that are directly
aimed at the elimination of discrimination against federally and locally protected
groups in the selling, renting, financing and insuring of housing, as recommended
in this AI report. Those actions include education of prospective homebuyers and
tenants as to their rights to access to housing and; the enhancement of the
system to study, receive, investigate and resolve complaints and/or bring
charges and prosecute violations of Federal and local fair housing laws. While
robust implementation of these actions will decrease discrimination in housing, it
is not likely that these actions taken alone will eliminate housing discrimination.
It is difficult to talk about addressing impediments to fair housing, and actions to
eliminate discrimination in housing, without simultaneously talking about the
development of policies, plans, programs and projects to increase the supply of
affordable housing opportunities and choices made affordable to all income
groups in all segments of the population, especially low or moderate income
households.
Certain protected classes have a disproportionate representation in the low or
moderate income households in Union City and so it is reasonable to expect that
as the supply of affordable housing is increased throughout the City, greater
numbers of protected class members will have access to housing without
discrimination.
5
SCOPE OF THE ANALYSIS
This Analysis of Impediments to Fair Housing Choice provides an overview of
laws, regulations, conditions of other possible obstacles that may affect an
individual’s or a household’s access to housing. The AI involves:
• A comprehensive review of the laws, regulations and administrative
policies, procedures and practices;
• An assessment of how those laws, regulations, policies, procedures and
practices affect the location, availability and accessibility of housing; and
• An assessment of conditions, both public and private, affecting fair
housing choice.
Data and Methodology
The following are key data sources that were used to complete the AI:
• 2000 and 2010 U.S. Census
• Hudson County Consortium Consolidated Plan
• Union City Consolidated & Annual Plan
• Union City Housing Authority plans
• U.S. Department of Housing & Urban Development data
• Union City Housing Element & Fair Share Plan
6
COMMUNITY OUTREACH AND PARTICIPATION
As with the development of the City’s Consolidated Annual Plan, this Analysis of
Impediments to Fair Housing Choice results from a process of consultation and
citizen participation, which builds upon existing participation mechanisms and
venues. Citizens, not-for-profit organizations, and other interested parties were
afforded a variety of opportunities to participate.
The continued participation by citizens in the formulation and implementation of
Union City's Community Development Block Grant program and the AI has been
one of direct involvement. It is the City's belief that the results show a two way
communication process between the City and the public.
Basic Requirements
The HUD citizen participation requirements (which were used to develop the AI)
are summarized as follows:
A grant may be made only if the grantee certifies that it is following a
detailed citizen participation plan which provides for and encourages
citizen participation, with particular emphasis on participation by persons
of low and moderate income who are residents of slum and blight areas
and of areas in which funds are proposed to be used, and provides for
participation of residents in low and moderate income neighborhoods.
This Citizen Participation Plan states the formal process which the City employs
to involve the residents of Union City in the community development process.
• Citizens are given information on the goals and objectives of the AI.
• Public hearings are held to obtain the views of citizens and organizations.
• Citizens and organizations have an opportunity to participate in the
development of the process to provide fair housing choice.
Scope of Public Participation
The City of Union City provided for and encouraged the expression of citizen's
views and proposals regarding the creation of the AI on a neighborhood level.
Representatives of the various neighborhoods that comprise the City, particularly
lower income residents and those of blighted neighborhoods, help to identify
needs and to set priorities as they generally relate to the Analysis of
Impediments. Citizen participation extends to the implementation of the AI after it
has been approved by HUD during public hearings on modifications to the plan.
7
In addition, the plan provides the opportunity for citizens to monitor and submit
comments on all aspects of the program, including the performance of project
execution.
Submission of Views and Proposals
The submission of citizens' views and proposals were transmitted to the
Community Development Agency as follows:
• Directly to the City Community Development Agency staff during the
planning process prior to the required public hearings on the AI.
• To recognized, locally based organizations, either a City wide citizens
organization or a neighborhood or project area organization; this will be
either in writing or informally to the Community Development Agency staff
followed by a proper recording.
• At any neighborhood or other citizens' meetings before the required
public hearings.
• At the formal public hearings.
8
DEMOGRAPHIC CHARACTERISTICS
Population
Fair housing is concerned with ensuring that a range in types and prices of
housing is available and that all people are treated equally in the rental, sales or
occupancy of housing. This section of the AI examines the population, housing
and special needs characteristics and trends in Union City that may affect equal
housing opportunity.
This community profile provides insights for identifying potential impediments to
fair housing choice. While not definitive indicators of impediments to fair housing
choice, the data points to conditions or situations that could be indicators of
impediments to fair housing choice.
The population trends for Union City, Hudson County, and New Jersey are
shown below. The population of Union City experienced a steady decline
between 1930 and 1980, rebounding only in the 1960’s due to Cuban
immigration. Since 1980, Union City has shown two decades of population
increases, reaching 67,088 in 2000, a 15.6% increase over the 1990 population.
The statistics for Hudson County are similar, showing percentage declines
between 1930 and 1990 but rebounding with 10% growth between 1990 and
2000. Unlike both the County and the State, Union City experienced a population
loss between 2000 and 2010. However, both Union City and Hudson County are
different from New Jersey, which has experienced steady population growth over
the past 70 years that largely reflects the overall population trends in the US,
such as the ‘baby boom’ and the ‘birth dearth.’ Since 1930 the population of the
State of New Jersey has more than doubled.
Populations Trends 1930 to 2010
Year
Union City
Hudson County
New Jersey
Population
Change
Population
Change
Population
Change
Number Percent
Number Percent
Number Percent
1930
58,659
-
-
690,730
-
-
4,041,334
-
-
1940
56,173
-2,486
-4.2%
652,040
-38,690 -5.6%
4,160,165 118,831
2.9%
1950
55,537
-636
-1.1%
647,437
-4,603 -0.7%
4,835,329 675,164 16.2%
1960
52,180
-3,357
-6.0%
610,734
-36,703 -5.7%
6,066,782 1,231,453 25.5%
1970
57,305
5,125
9.8%
607,839
-2,895 -0.5%
7,171,112 1,104,330 18.2%
1980
55,593
-1,712
-3.0%
556,972
-50,867 -8.4%
7,365,011 463,899
2.7%
1990
58,012
2,419
4.4%
553,099
-3,873 -0.7%
7,730,188 365,177
5.0%
2000
67,088
9,076
15.6%
608,975
55,876 10.1% 8,414,350 684,162
8.9%
2010
66,455
-633
-.94%
634,266
25,291 4.2%
8,791,894 377,544
4.5%
9
Population Composition by Age
The changes between 2000 and 2010 indicate that Union City has an aging
population. Each age cohort below 45 years of age saw a reduction and each
cohort from 45 to 65 and older experienced an increase. The largest rate of
decrease occurred in the 5-14 cohort, which decreased by 10.9% and the largest
increase was in the 45 to 54 cohort, which rose by 18.7%. Despite the overall
decrease in the population, the overall age distribution of the Union City
population remains approximately the same.
Population by Age, 2000 and 2010, Union City
2000
2010
Change 2000 to
2010
Population
Number
Percent
Number
Percent
Number
Percent
Under 5
4,945
7.4
4,845
7.3
-100
-2.0
5 to 14
9,268
13.8
8,255
12.4
-1,013
-10.9
15 to 24
10,122
15.1
9,736
14.7
-386
-3.8
25 to 34
12,074
18.0
11,559
17.4
-515
-4.3
35 to 44
10,949
16.3
9,958
15.0
-991
-9.1
45 to 54
7,641
11.4
9,066
13.6
1,425
18.7
55 to 64
5,395
8.0
6,078
9.2
683
12.7
65 and over
6,694
10.0
6,958
10.5
264
3.9
Total
67,088
100
66,455
100
-633
-0.9
Like Union City, Hudson County experienced shifts in the age composition of its
population to support an aging population. The 45 to 54 and 55 to 64 cohorts
experienced the largest increases in population, growing 14.7% and 25.2%
respectively between 2000 and 2010. The 25 to 34 age group also experienced
large growth, growing at 10.4%. While both for Union City and Hudson County,
the 5 to 14 age group declined in population, Hudson County also saw increases
in the other cohorts below 34.
10
Population by Age, 2000 and 2010, Hudson County
2000
2010
Change, 2000 to
2010
Population
Number Percent
Number Percent Number
Percent
Under 5
38,756
6.4
42,586
6.7
3,830
9.9
5 to 14
76,700
12.6
66,584
10.5
-10,166
-13.2
15 to 24
85,412
14.0
85,641
13.5
229
0.3
25 to 34
119,073
19.6
131,508
20.7
12,435
10.4
35 to 44
97,727
16.0
96,716
15.2
-1,011
-1.0
45 to 54
72,379
11.9
82,985
13.1
10,606
14.7
55 to 64
49,657
9.1
62,180
9.8
12,523
25.2
65 and over
69,271
11.4
66,066
10.4
-3,205
4.6
Total
608,975
100.0
634,266
100
25,291
4.2
According to the 2010 Census, the median age of residents in Union City was
33.9 years. Analysis of age group characteristics provides insight into the actual
changes in population. This comparison is helpful in determining impacts these
changes have on housing needs, community facilities and services for the
municipality and the County overall.
Households
A household is defined as one or more persons, either related or not, living
together in a housing unit, which includes rental apartments, condominiums,
houses, etc. Households in Union City tend to be larger than the County as a
whole, with an average household size of 2.88. Union City and Hudson County
have similar breakdowns of household size, although Union City has a higher
percentage of households with 5 or more persons, at 16.2%
11
Household Size – Occupied Housing Units
Union City and Hudson County
Union City
Hudson County
Number
Percent
Number
Percent
Total
22,814
100.0
246,437
100.0
1-person household
5,441
23.8
73,741
29.9
2-person household
5,852
25.7
71,762
29.1
3-person household
4,350
19.1
42,935
17.4
4-person household
3,465
15.2
31,581
12.8
5-person household
1,969
8.6
15,098
6.1
6-person household
931
4.1
6,401
2.6
7-or-more-person household
806
3.5
4,919
2.0
Average Household Size
2.88
2.54
Family households are defined as two or more persons living in the same
household, related by blood, marriage or adoption. Most households in Union
City are family households, comprising 76.2% of all households. The majority of
family households are married couples, with a little more than half having
children under the age of 18. A total of 21.8% of the households are headed by a
female.
In providing more detail of American households, the 2010 Census included the
sub-groups of non-traditional households or “Non-family” households. Non-
family households comprise 32% percent of all households in Union City, with
23.8% being persons living alone and 7.5% being householders 65 years or
older.
12
Household Size and Type Union City
Total
Percent
Total Households
22,814
100.0%
1-person household
5,441
23.9%
Male householder
2,690
49.4%
Female householder
2,751
50.6%
2 or more person household
17,373
76.1%
Family households
15,512
89.3%
Husband-wife family
8,368
54.0%
With own children under 18 years
4,156
50.0%
No own children under 18 years
4,212
50.0%
Other family, no spouse present
7,144
46.0%
Male householder
2,170
30.4%
With own children under 18 years
936
43.1%
No own children under 18 years
1,234
56.9%
Female householder
4,974
69.6%
With own children under 18 years
2,720
54.7%
No own children under 18 years
2,254
45.3%
Nonfamily households
1,861
8.2%
Male householder
1,167
62.7%
Female householder
694
37.3%
Population by Race
The 2010 Census reveals that a majority (58.0%) of Union City residents classify
themselves as white, with the second largest group being some other races
(27.4%). Because the US Census did not define Hispanic as a separate race for
the 2010 Census, the percentage breakdown of the US Census racial
classifications sheds little light Union City. When asked, 84.7% of Union City
residents classified themselves as Hispanic.
The following table breaks down the specific country or regional origins of those
who reported being Hispanic/ Latino on the 2010 Census. As the chart shows,
Cubans and South Americans represent the largest subgroups in Union City. Yet,
while these subgroups are the largest, the overall distribution of ethnic origins is
relatively even, with only Mexicans as a smaller percentage of the total Hispanics
population.
13
Detailed Summary, Hispanic or Latino Population, Union City
Total
Amount
Percentage of City
Population
Percentage of
Latino/Hispanic
Population
Total Reporting
Hispanic or Latino
56,291
84.7
100
Puerto Rican
6,643
10.0
11.7
Mexican
5,189
7.8
9.2
Cuban
7,511
11.3
13.3
Dominican
10,020
15.1
17.8
Central American
9,160
14.0
16.3
South American
13,925
20.9
24.7
Other Hispanic or
Latino
3,849
5.8
6.8
Union City has developed into a Hispanic enclave dating back to the early waves
of Cuban immigration into the City during the 1960’s. Therefore, Union City
maintains higher percentages of Hispanics in the local population than do
Hudson County or the State of New Jersey, even as the origins of the Hispanic
population living in Union City have changed.
Disability
The Census Bureau definition of disability will be used in this analysis, as that is
the basis for the available data. The Bureau defines disability as a long-lasting
physical, mental or emotional condition, which can make it difficult for a person to
do activities such as walking, climbing stairs, dressing, bathing, learning or
remembering. Such conditions also impede a person from being able to go
outside the home alone or to work at a job or business.
The American Community Survey (ACS) provides population estimates of
persons with disabilities. The data from 2014 indicates that 747 person or 4.7
percent of persons under 18 years of age had some type of disability. Of the
14
population age 65 or older, 2,893 persons or 43.7 percent reported some form of
disability.
Income
According to the 2014 American Community Survey, households in Union City
earned a lower income when compared to both Hudson County and the State of
New Jersey. As measured in 2014, the median household income in Union City
was $40,949, which was $18,024 less than Hudson County and $31,113 less
than the State’s median income.
Per Capita and Household Income 2014,
Union City, Hudson County, New Jersey
2014 Per
2014 Median
Capita ($)
Household ($)
Union City
19,834
40,949
Hudson County
32,678
58,973
New Jersey
36,359
72,062
The distribution of household income for Union City and Hudson County in 2014
is shown below. The most common income bracket Union City was $35,000 to
$49,999, which was earned by 17.3% of households. 74.1% of Union City
households versus only 43.5% of Hudson County households earned less than
$50,000. Union City also had a much higher percentage of households earning
less than $10,000.
Households Income In 2014
Union City and Hudson County
Union City
Hudson County
Number
Percent
Number
Percent
Total households
22,786
100.0
246,135
100.0
Less than $10,000
2,312
15.2
19,369
7.9
$10,000 to $14,999
1,649
9.3
13,485
5.5
$15,000 to $24,999
3,181
16.4
25,349
10.3
$25,000 to $34,999
2,933
15.9
21,415
8.7
$35,000 to $49,999
3,062
17.3
27,280
11.1
$50,000 to $74,999
3,988
14.2
40,123
16.3
$75,000 to $99,999
2,386
6.2
29,170
11.9
$100,000 to $149,999
2,149
3.9
34,713
14.1
$150,000 to $199,999
667
0.9
16,346
6.6
$200,000 or more
459
0.8
18,885
7.7
15
Poverty status
Of the 66,560 people in Union City, 22.4% were in poverty in 2010. 63.2% of
those in poverty were between 18 and 65, while 29% of those less than 18 were
in poverty. While Hudson County has a much lower percentage of the total
population in poverty, the rough age distribution of those in poverty remains the
same.
Poverty Status 2010, Union City and Hudson County
Union City
Hudson County
Number
Percent
Number Percent
Total persons
66,560
100
629,505
100
Total persons below poverty
level
14,930
22.4
103,825
16.5
Under 18
4,325
29.0
30,207
29.1
18 to 65
9,440
63.2
64,471
64.0
Over 65
1,165
7.8
9,147
8.8
Household costs
The tables below show the costs as a percent of income for homeowners and
renters in Union City. When looking at these numbers, it is important to
remember that the vast majority of households rent in Union City. With respect to
owner occupied units, more than 54% spent 35% or more of their income on
housing. Among renter-occupied households, nearly 48% of households spend
more than 30% of their income on housing costs. General affordability standards
are set at spending approximately 30 percent of gross income for housing costs.
Monthly Owner Costs as a Percentage of Household
Income
Union City, 2014
Number
Percent
Less than 20 percent
419
14.4
20 to 24 percent
357
12.3
25 to 29 percent
205
7.1
30 to 34 percent
348
12.0
35 percent or more
1,574
54.2
16
Gross Rent as a Percentage of Household Income
Union City, 2014
Number
Percent
Less than 15 percent
2,092
16.2
15 to 19 percent
1,717
9.6
20 to 24 percent
2,005
11,2
25 to 29 percent
1,915
10.7
30 to 34 percent
1,633
9.1
35 percent or more
8,578
47.8
Not computed
594
3.3
17
EXISTING HOUSING CHARACTERISTICS
Housing unit data
The majority of Union City’s housing stock is comprised of older rental housing
structures. Almost 80% of occupied Union City housing units are renter occupied.
Nearly 42% of all occupied housing units were built before 1950. Since 1939, the
1960-1969 decade represents the next greatest growth in the local housing
stock.
Housing Data, 2010 & 2014
Union City
Total
Percent
Housing Units
24,931
Total- Occupied Units
22,814
91.5
Tenure
Owner occupied
4,583
20.1
Renter occupied
18,231
79.9
Year Structure Built
Total Units (2014)
25,604
Built 2010 or later
222
0.9
Built 2000 to 2009
2,840
11.1
Built 1990 to 1999
1,117
4.4
Built 1980 to 1989
1,263
4.9
Built 1970 to 1979
2,397
9.4
Built 1960 to 1969
3,854
15.1
Built 1950 to 1959
3,232
12.6
Built 1940 to 1949
2,368
9.2
Built 1939 or earlier
8,311
32.5
Housing type and size
Only 8.8% of the housing stock in Union City was single-family housing. The
majority of housing structures (22.9%) had more than 20 units and 21.4% had
three or four units. The largest single unit categories were 2 family, 3-4 family,
and 20 units or more.
The median number of rooms within housing units in Union City was 3.9, with the
largest percentage of structures having 4 rooms (31.7%). More than half of all
housing units had 3 to 4 rooms (56.6%). 7.8% of units had only 1 room and 1.2%
of units had more than 9 rooms.
18
Housing Type and Size, 2014
Union City
Units in Structure
Total
Percent
Total
25,604
100
1-unit, detached
1,300
5.1
1-unit, attached
955
3.7
2 units
4,693
18.3
3 or 4 units
5,478
21.4
5 to 9 units
4,566
17.8
10 to 19 units
2,755
10.8
20 or more units
5,850
22.9
Mobile home
7
.03
Boat, RV, van, etc.
0
0
Rooms
1 room
2,009
7.8
2 rooms
1,259
4.9
3 rooms
6,365
24.9
4 rooms
8,118
31.7
5 rooms
5,302
20.7
6 rooms
1,632
6.4
7 rooms
383
1.5
8 rooms
233
0.9
9 or more rooms
303
1.2
Median number of rooms
3.9
Occupancy
With 96.3% of housing units in Union City occupied in 1999, most vacant units
were for rent, seasonal, recreational, or occupational use or ‘other vacant’ uses.
54.5% of Union City’s vacant units are for rent and 19.2% are for ‘other vacant’
uses.
19
Occupancy Status, 2014
Union City
Total
Percent
Total
24,931
100
Occupied
22,814
91.5
Vacant
2,117
8.5
Vacancy Status
Total
2,117
100
For rent
474
54.5
For sale only
125
14.4
Rented or sold, not occupied
31
3.6
For seasonal, recreational, or
occasional use
72
8.3
For migrant workers
0
0.0
Other vacant
167
19.2
Housing values and contract rents
The data below details the housing values and the financing methods used for
owner occupied housing units. In 2014 the median home value was $292,200,
with 37.4% of units valued between $200,000 and $299,999. The second most
common house value was between $300,000 and 499,999 (36.7%). 63.8% of
homes were financed with a mortgage, contract to purchase or similar debt, while
only 31.7% had no mortgage at all.
Value For All Owner Occupied Housing Units
Union City
Total
Percent
Total
4,252
100
Less than $50,000
62
1.5
$50,000- $99,999
77
1.8
$100,000- $149,999
107
2.5
$150,000- $199,999
417
9.8
$200,000 to $299,999
1,589
37.4
$300,000 to $499,999
1,561
36.7
$500,000 +
439
10.3
Median Value
$292,200
Mortgage Status
4,252
100.0
Housing units with a mortgage
2,903
68.3
Housing units without a mortgage
1,349
31.7
20
As stated earlier, 79.9% of all occupied Union City housing units were rental
units. In 2014, the median monthly rent in Union City was $1,095, with 43.3% of
renter paying between $1,000 and $1,499 per month and 23.2% of renter paying
between $750 and $999.
Contract Rent 2014,
Union City
Total
Percent
Total renter occupied units
18,305
100
Less than $200
168
0.9
$200 to $299
332
1.8
$300 to $499
787
4.3
$500 to $749
1,862
10.2
$750 to $999
4,255
23.2
$1,000 to $1,499
7,932
43.3
$1,500 or more
2,969
16.2
No cash rent
229
1.3
Median Rent (dollars)
1,095
Housing conditions
The table below details the condition of housing within Union City based on
heating fuel, overcrowding, plumbing facilities, kitchen facilities, and telephone
service. These factors are utilized in determining housing deficiency. Nearly 15%
of occupied housing units in Union City are over crowded (more than one person
per room) and 5.9% have more than 1.51 persons per room. Only 1.2% of
residents lacked complete plumbing facilities and only 1.5% lacked complete
kitchen facilities. The majority (77%) of occupied housing units use gas as their
primary heating fuel, while sizable numbers of residents use electricity and fuel
oil or kerosene.
21
Housing Conditions 2014
Union City
Total
Percent
House Heating Fuel- Occupied housing units
Total
22,786
100
Utility gas
17,536
77.0
Bottled, tank, or LP gas
455
2.0
Electricity
3,184
14.0
Fuel oil, kerosene, etc.
1,340
5.9
Coal or coke
0
0
Wood
0
0
Solar energy
0
0
Other fuel
115
0.5
No fuel used
156
0.7
Occupants per Room-Occupied housing
units
Total
22,786
100
Occupants per Room (1 or less)
19,408
85.2
Occupants per Room (Over 1.01)
2,028
8.9
Occupants per Room (Over 1.51)
1,350
5.9
Facilities
Total
22,786
100
Lacking complete plumbing facilities
275
1.2
Lacking complete kitchen facilities
342
1.5
Telephone Service- Occupied housing units
Total
22,786
100
No service
516
2.3
22
FAIR HOUSING PRACTICES
The section provides an overview of the institutional structure of the housing
industry in governing the fair housing practices of its members. The oversight,
sources of information, and fair housing services available to residents in Union
City are described and their roles explained.
Oversight Organizations
As described above, City residents are protected from housing discrimination by
Federal and state laws. These laws are enforced by the Department of Housing
& Urban Development and the Department of Justice, as well as by the New
Jersey Department of Law and Public Safety, Division of Civil Rights. Reports
and complaints are filed with these agencies and the Department of Justice may
take legal action in some cases. Typically, fair housing service providers work in
partnership with HUD and state agencies to resolve problems. However, in some
cases where litigation is necessary, the case may be resolved through
administrative filing with HUD or the state; referred for consideration to the
Department of Justice, Civil Rights Division, Housing and Civil Enforcement
Section; or referred to a private attorney for possible litigation.
New Jersey has its own law, which provides protections to individuals with
disabilities in the sale or rental of housing. This state law, known as the Fair
Housing Act, covers most housing. The act is bolstered by the provisions of the
New Jersey Law Against Discrimination, which was amended in 2002 to make it
illegal to discriminate against persons based on source of income.
The state law does not specifically exclude any individuals from its coverage. The
Federal Fair Housing Amendments Act does, however, exclude individuals from
protection who are currently using illegal drugs, individuals connected with the
illegal manufacture of a controlled substance and individuals who are a direct
threat to themselves or others. The Law Against Discrimination does address the
topic of reasonable accommodation in some detail. The processes for enforcing
one’s rights are explained in several publications from the Department of Law’s
Division of Civil Rights. Persons who feel that they have been discriminated
against may file a complaint with the Division of Civil Rights.
Persons who feel that they have been discriminated against may seek assistance
or file complaints through one of several avenues. HUD maintains a Fair Housing
Enforcement Center in New York City. The State Division of Civil Rights is
located in Trenton and there is a Newark Regional office as well.
Residents of Union City, and Hudson County in general, have several sources of
assistance for fair housing concerns. The Hudson County Housing Resource
23
Center is a HUD Certified Housing Counseling Agency that can provide
residents, municipalities and housing organizations with information, assistance
and counseling on a wide range of issues including security deposit refunds,
substandard conditions, rent increases, foreclosure and imminent homelessness.
The Center can offer advice, represent clients in court and refer clients to other
agencies as necessary. The Center has operated continuously since 1990 and
while serving clients of all income levels, has focused on low or moderate income
families.
The Fair Housing Council of Northern New Jersey, based in Hackensack,
provides a number of services in the fair housing area. The organization is also a
HUD certified counseling agency and offers clients housing and financial
counseling for both sales and rentals. The group also:
• Protects people who experience discrimination based on race, religion,
national origin, disability, family or marital status or sexual orientation.
• Provides information, educational programs and assistance to housing
and lending consumers, real estate professionals, schools and
government.
• Works with county, state and federal governments to assist first time
homebuyers.
• Assists businesses and corporations in locating housing for transferees.
• Assists low income families in finding affordable housing, works to expand
the supply of affordable housing and offers counseling to prevent
foreclosures.
• Provides homelessness prevention assistance.
• Monitors realtors and lending institutions for compliance with the Fair
Housing laws.
While this group is not actively involved in Hudson County, it is able to conduct
testing in the County and Union City. Efforts to identify other housing assistance
or service entities in the City or County have not proven successful.
The Federal Financial Institutions Examination Council (FFIEC) is a formal
interagency body empowered to prescribe uniform principles, standards and
report forms for the federal examination of financial institutions by the Board of
Governors of the Federal Reserve System, the Federal Deposit Insurance
Corporation, the National Credit Union Administration, the Office of the
Comptroller of the Currency and the Office of Thrift Supervision and to make
recommendations to promote uniformity in the supervision of financial
institutions. The FFIEC provides data on loan originations, loan denials and other
aspects of the home loan process, as well as preparing Community
Reinvestment Act rating reports on financial institutions.
24
COORDINATION AND SUPERVISION IN THE HOMEOWNERSHIP MARKET
Many agencies are involved in overseeing real estate industry practices and the
practices of the agents involved. A portion of this oversight involves ensuring that
fair housing laws are understood and complied with. The following organizations
have limited oversight within the real estate market and some of their policies,
practices and programs are described.
National Association of Realtors
The National Association of Realtors (NAR) is a consortium of realtors, which
represent the real estate industry at the local, state and national level. As a trade
association, members receive a range of membership benefits. However, to
become a member, NAR members must subscribe to its Code of Ethics and a
Model Affirmative Fair Housing Marketing Plan developed by HUD. The term
“Realtor” thus identifies a licensed real estate professional who pledges to
conduct business in keeping with the spirit and letter of the Code of Ethics.
Realtors subscribe to the NAR’s Code of Ethics which imposes obligations upon
realtors regarding their active support for equal housing opportunity.
Diversity Certification
The NAR has created a diversity certification, “At Home with Diversity: One
America”, to be granted to licensed real estate professionals who meet eligibility
requirements and complete the NAR “At Home with Diversity” course. The
certification signals to customers that the real estate professional has been
trained to work with the diversity present in today’s real estate market.
New Jersey Association of Realtors
The New Jersey Association of Realtors is a trade association of realtors
statewide. As members of the Association, realtors follow a strict code of ethics.
The Association also offers the “At Home with Diversity: One America”
certification course as part of its graduate education program.
New Jersey Real Estate Commission
The New Jersey Real Estate Commission is a licensing authority for real estate
brokers and salespersons. Established in 1921, the New Jersey Real Estate
Commission (REC), a Division of the New Jersey Department of Banking and
Insurance, was created to administer and enforce New Jersey’s real estate
licensing law. The REC issues licenses to real estate brokers and salespersons,
real estate schools and course instructors, as well as the establishment of
standards of practice for the real estate brokerage profession.
25
COORDINATION AND SUPERVISION IN THE RENTAL MARKET
Many agencies oversee the apartment rental process and related practices. This
oversight includes that fair housing laws are understood and followed. The
following organizations have limited oversight within the rental housing market.
New Jersey Apartment Association
The New Jersey Apartment Association is a state chapter of the National
Apartment Association dedicated to serving the interests of New Jersey
apartment owners and managers.
National Association of Residential Property Managers
The National Association of Residential Property Managers (NARPM) is an
association of real estate professionals who are experienced in managing single
family and small residential properties. NARPM promotes the standards of
property management, business ethics, professionalism and fair housing
practices within the residential property management field. NARPM certifies
members in the standards and practices of the residential property management
industry and promotes continuing professional education. NARPM offers
designations to qualified property managers and management firms and these
certifications required educational courses in fair housing practices.
26
FAIR HOUSING ORGANIZATIONS
In addition to the above, there are a number of not-for-profit organizations
concerned with fair housing issues. These organizations provide assistance to
individuals who feel that they may have been the subject of a discriminatory act.
The Fair Share Housing Center (FSHC), founded in 1975, is a public interest
organization devoted the defense of the housing rights of New Jersey’s poor
through enforcement of the “Mount Laurel Doctrine”, which prohibits economic
discrimination through exclusionary zoning and requires all towns to provide their
fair share of the affordable housing needs of their region.
The FSHC mission is to end discriminatory or exclusionary housing patterns and
to provide the opportunity for low income persons to reside in an environment
which offers safe, decent and sanitary housing near employment and educational
opportunities.
Other resources include:
• The Office of Landlord/Tenant Information within the New Jersey
Department of Community Affairs’ Division of Codes and Standards.
• Legal Services of New Jersey, which publishes a handbook for tenants
• HUD Certified Fair Housing Counseling Agencies in New Jersey
27
LENDING DATA AND PUBLIC POLICIES
This section of the AI evaluates lending practices in Union City, using Home
Mortgage Disclosure Act (HMDA) data, information from banking oversight
agencies and complaint data from local, state and federal organizations and
agencies.
At the same time, public policies established at the local level can affect housing
development and therefore may have an impact on the range and location of
housing choices available to residents. Fair housing laws are designed to
encourage an inclusive living environment and active community participation. An
assessment of public policies and practices enacted by the City can help
determine potential impediments to fair housing opportunity. To identify potential
impediments to fair housing choice and affordable housing development, some
housing related documents (eg, zoning ordinance, previous fair housing
assessment prepared for the State) were reviewed.
Complaint Data
An analysis of complaint data indicates that discriminatory behavior exists on a
limited basis, even though specific forms of discrimination are sometimes difficult
to fully document. Housing discrimination primarily affects persons of color, the
disabled and families with children.
Data provided by the U.S. Department of Justice for Title VIII complaints
indicates that between 2004 and 2010, there were 8 such cases in Union City,
with two filed on the basis of race or color, two based on national origin, one on
the basis of disability and 3 based on the sex of the tenant. The were no specific
statistics on fair housing complaints available from a fair housing advocacy group
or monitoring organization.
Although there were very few cases over that six year period of time, there is still
a need for activities by an organization to serve as a means for addressing fair
housing issues. Data on fair housing complaints is difficult to obtain and sketchy
when found. Though there is little data to go by, there may be a need for
agencies to continue to monitor housing providers in the City.
Home Loan Activity
A key aspect of fair housing choice is equal access to financing for the purchase
or improvement of a home. In 1977, the Community Reinvestment Act (CRA)
was enacted to encourage regulated financial institutions to help meet the credit
need of entire communities, including low or moderate income persons and
28
neighborhoods. The Home Mortgage Disclosure Act (HMDA) requires financial
institutions with assets exceeding 10 million dollars to submit detailed information
on the disposition of home loans. HMDA data was evaluated in the AI with
respect to lending patterns, however, the data is only an indicator of potential
problems; the data cannot be used to conclude definite redlining or discrimination
practices. HMDA data lacks the detailed information on loan terms or specific
reasons for denial to make conclusive statements.
As noted above, Union City is dominated by rental units with nearly 80% of the
total number of occupied units in rental tenancy. However, the HMDA reported
limited activity for 2011. The data indicates that of the 138 total conventional loan
applications, 75 or 54% were approved, 28 or 20% were denied and 35 or 26%
were withdrawn. This would appear to indicate positive activity for the
conventional homeowner’s loan market in Union City.
Affordability
Although low income persons are not a protected class under the Fair Housing
Act, as noted earlier, housing costs can serve to restrict fair housing choice. To
combat this situation, it is important that both the public and private sector strive
to build more affordable housing and this is one of the key objectives of both the
City’s Consolidated Plan and its adopted Housing Element and Fair Share Plan.
There are a number of factors which affect the provision of affordable housing
including environmental regulations; labor requirements; the unwillingness of
rental agents to rent to families with children, persons with housing subsidies,
female headed households; neighborhood resistance; and income guidelines that
limit opportunities to moderate income households over those with low incomes.
Public Policies
A wide range of governmental policies affect affordable housing and fair housing
choice. Many of these policies are beyond the control of municipal government,
although municipalities have control over land use and zoning. The most
important impediment is the lack of Federal and State resources for affordable
housing initiatives. The lack of programs and resources to reduce excessive rent
or mortgage burdens to qualified persons is a key factor.
The City of Union City’s Land Use Plan, includes a Housing Element and Fair
Share Plan, and the recently adopted Land Development Ordinance does not
contain any restrictions on the development of affordable housing. Likewise,
housing codes and standards and rent control ordinances ensure the health,
safety and quality of life for City residents while minimizing barriers that might
impede the development of affordable housing.
29
The following are some public policy, zoning and land use issues that were
identified through discussions with planners, developers and other organizations
that might create impediments to fair housing choice.
1.
Market Conditions
The major barrier to affordable housing in Union City is the high cost of
housing created by a demand for housing, both existing and new, which
exceeds the current supply. Union City is starting to be seen as a
desirable place to live and is beginning to see growth in the number of
people who wish to reside in the City. In addition, the cost of site
acquisition is very high and construction costs in northern New Jersey are
among the highest in the nation. These factors make housing construction
in Union City expensive and make affordable housing out of reach of low
income households.
2.
Building Codes
Building regulations are essential to protecting the health and safety of
citizens and the general welfare of the municipality. While these codes
have many positive contributions, they also contribute to increased
construction costs. The New Jersey uniform building code was adopted by
the State in 1977, comes under the authority of the New Jersey
Department of Community Affairs and is administered by local officials
who are licensed and regulated by NJDCA.
3.
Property Taxes
Property taxes generate revenue to support a broad array of public
facilities and services at the local level of government. However, it is also
recognized that property taxes add significantly to the cost of housing and
can therefore impact affordability. The State of New Jersey is known as a
high property tax state with a combined state and local tax burden of
10.2% of income. As property taxes are factored into a household’s month
housing cost, a potential homeowner who can afford a mortgage may not
qualify when property taxes are included.
4.
Permit Delays
Development in New Jersey includes several levels of government and
various agencies in the approval process, either directly or indirectly.
While approvals for new development must always be obtained from the
City Planning Board or Zoning Board of Adjustment, many times approval
30
is also required by the Hudson County Planning Board, utility authorities
and/or soil conservation districts. According to the State’s CHAS, the New
Jersey Builders Association estimates that half of the projects going
through the permit process take more than three years to complete. One
estimate concludes that the cost of delay caused by the lengthy approval
process is one percent per month, which suggests that the residential
construction process can add more than 30% to housing costs.
5.
Land Use Regulations
While zoning regulations typically affect the provision of affordable
housing, the City’s recently enacted Land Development Ordinance does
not contain any such restrictions and provides numerous sites that would
be appropriate for the development of affordable housing. The City has
recently adopted a Redevelopment Plan to provide 101 units of affordable
housing for seniors on the site of the municipally owned 8th Street Parking
Lot.
31
IDENTIFIED IMPEDIMENTS AND RECOMMENDATIONS
This section summarizes the key findings of the Analysis of Impediments and
makes recommendations about actions to eliminate impediments to fair housing
choice in Union City. Housing discrimination continues to occur and it manifests
itself in different ways among different segments of the population. Since it
continues to be a goal of the City to eliminate any existing discrimination and
prevent future impediments to equal housing opportunity, the recommendations
should be considered as a guide to ensure access to fair housing for all current
and future residents.
This 2020 Analysis of Impediments builds upon the previous 2012 Union City
Analysis of Impediments and the AIs included in the Hudson County Consortium
Consolidated Plans and analyzes data and identifies the private and public sector
conditions that foster housing discrimination. Based upon research and limited
interviews with housing advocates, the following is a description of the main
potential impediments that were found to exist in Union City. As noted, more
detailed research and investigation through both the analysis of data and
information gathered from focus groups and fair housing organizations are
necessary to develop a comprehensive picture. Each impediment noted below is
followed by recommendations to address and eliminate that impediment.
1.
Discrimination in the Housing Market
The review of demographic information, discrimination complaint data and
lending data does not clearly indicate the extent of housing discrimination among
persons in the various protected classes. Statistical data can assist in identifying
problems and areas of concern, however, reporting requirements differ, as does
the quality of data that is provided. Further, much of the available data is at least
a year old by the time it is made available. More focused, accurate and current
data is necessary to understand the needs and more sources of first hand
information from focus groups and housing advocacy organizations are needed
to obtain a better understanding of the situation in the marketplace.
In the current economy and given the structure of the housing stock in Union
City, the incidences of discrimination likely focus on rental housing and the focus
of efforts in the immediate future should be on that rental market. In particular,
discrimination among protected classes should be addressed:
• Female-headed households- there are no specific statistics related to this
issue, but female headed households often face discrimination in the
housing market, often due to low incomes and the need to care for
children.
32
• Non-family households- these are numerous throughout Union City and
they may also face discrimination.
• Racial/Ethnic Groups- the City continues to have a large percentage of
foreign born residents, mainly from Spanish speaking countries. While the
City makes a great effort in bilingual outreach, many residents are unlikely
to contact governmental entities when there are issues.
Recommendations
1.
Educate households and housing related organizations by disseminating
Fair Housing Law literature, conducting Fair Housing law seminars and
training and focusing public awareness campaigns about Fair Housing law
in specific neighborhoods and among civic, social, religious and special
interest groups that serve this population.
2.
Provide Fair Housing materials and educational programs in Spanish,
particularly to those neighborhood and organizations impacted.
3.
Conduct training sessions and information campaigns especially among
rental property owners and managers, as well as apartment owner
associations and management companies.
4.
Increase housing choice alternatives for the disabled and families with
children, by continuing the construction of affordable, rental housing.
5.
Convene focus meetings of advocacy groups, community based
organizations, real estate industry professionals, lenders, property owners
and government agency officials to review and assess fair housing issues.
These groups should help to identify discriminatory practices, trends or
changes in these practices as a means to address those issues.
2.
Fair Housing Advocacy and Outreach
At the present time, there is no specific housing advocacy group that focuses on
Union City, nor is there a strong visible fair housing advocacy group in Hudson
County that can assist persons who feel that they have suffered discrimination
and at the same time, provide outreach and education on fair housing issues as
discussed above.
33
Recommendations
1.
Assist in the development of a fair housing organization that will actively
assist City residents with fair housing education and issues.
2.
Expand efforts to inform renters and homebuyers of their rights and what
recourse they have, if they feel that they have been discriminated against.
3.
Conduct training sessions and information campaigns especially among
rental property owners and managers, as well as apartment owner
associations and management companies.
4.
As described above, convene focus sessions of advocacy groups,
community based organizations, real estate professionals, lenders,
property owners and government agency officials to review and assess
fair housing issues.
5.
Update Fair Housing information on a regular basis and adjust strategies
and actions accordingly.
3.
Bias in Lending
This AI did not find significant evidence of discrimination practices. The issue
does not appear to have generated specific complaints, although this data is not
conclusive. Additional, detailed research is necessary to make any definitive
conclusions. However, the City should to the extent possible, ensure that
persons who seek loans for home purchase or improvement are aware of lending
practices and procedures.
Recommendations
1.
Develop programs to foster conventional lending and banking services in
underserved neighborhoods and to specific groups of persons.
2.
Expand financial literacy and credit counseling programs, especially in
minority and lower income neighborhoods.
4.
Limited Supply of Affordable Housing
As discussed above, affordability is one aspect of housing discrimination and it is
difficult to talk about addressing impediments to fair housing, and actions to
34
eliminate discrimination in housing, without also talking about the development of
policies, plans, programs and projects to increase the supply of affordable
housing.
Previous sections of this Analysis, and the Housing Market Analysis contained in
the City’s Consolidated Plan, address the issue of affordability in detail. It is clear
that even moderate income households face challenges to purchase a home in
Union City and low income families face a considerable cost burden for rental
housing. This effort is significantly affected by the reduction in Federal funds
provided to the City for community development projects.
Recommendations
1.
Continue to use all available federal and state funding resources and
programs to address high priority housing needs for the rehabilitation,
preservation and development of affordable units.
2.
Continue to work with community based organizations, affordable housing
developers and housing advocacy groups to increase the supply of larger
and disability accessible housing units.
3.
Continue, and if possible, expand housing rehabilitation programs to
maintain the City’s base of affordable units, both owner occupied and
rental.
5.
Government Policies
This impediment deals with issues relating to the development of land including
housing that is available to a wide range of persons and income levels in
disparate locations. This goal is affected by many factors, some of which, as
noted above, are beyond the abilities of municipalities to change.
Recommendations
1.
Ensure that reasonable accommodation and disabled access issues are
properly addressed in municipal zoning and construction codes. The City’s
Building Department requires all development to provide improvements
that conform to the Americans with Disability Act standards.
2.
Do as much as possible to reduce review and approval process times for
both new construction and home modification applications. The City has a
long-standing process to move projects from building department review
to the appropriate approval agency in a timely manner.
35
3.
Encourage the provision of affordable housing in multi unit projects
wherever feasible. At the present time, the status of the State’s Council on
Affordable Housing and it’s fair share requirements are unclear. However,
the City has an approved Affordable Housing Trust Fund and affordable
housing guidelines to assist in this effort.
1
City of Union City
Community Development Block Grant (CDBG)
Language Assessment
The City of Union City
Community Development Agency’s
Four Factor Analysis
In order to determine the estimated needs of Limited English Proficient (LEP) persons in
the City of Union City, New Jersey the Union City Community Development Agency
conducted the following analysis:
Factor 1 – Number or proportion of LEP persons served or encountered in the
eligible service area
The Union City Community Development Agency obtained information from the U.S.
Census Bureau’s American Factfinder website as recommended by HUD in order to
gather data about the jurisdiction’s overall population, as well as the population of LEP
persons within the jurisdiction and the primary languages spoken. This data indicated
the following:
Total population 5 years and over
61,610
Total LEP population 5 years and over
53,723
Spanish speaking LEP population 5 years and over
52,199
Other language speaking LEP population 5 years and over
1,524
The above data indicates that more than 97% of the jurisdiction’s LEP population is
Spanish speaking and that the Spanish-Speaking LEP population constitutes 84.7% of
Union City’s total population. The only other data available indicates that only 1,524
persons in the LEP population spoke a language other than Spanish.
The staff of the Community Development Agency and the Office of the Mayor is entirely
bi-lingual and is able to provide assistance to the significant amount of residents that
are Spanish speaking. In addition, there are no records of public comment indicating a
lack of availability of LEP assistance over the past five years.
2
Factor 2 – Frequency of contract with the program
Through past experiences, the Union City Community Development Agency and Rent
Control Office determined that on average, there are 25-30 Spanish speaking LEP
persons contacting these offices on a daily basis for information or assistance with
housing related matters. Because of this, the City of Union City is committed to
maintaining bilingual staff serving in both reception and administration of these
particular offices.
The Union City Housing Authority receives roughly 40-50 calls per day from Spanish
speaking LEP persons requesting information or assistance. As with the related City
offices, the Union City Housing Authority also maintains a significant number of bilingual
staff in both reception and administrative positions, and at least one per department.
In reports from all offices, contacts with LEP persons who speak languages other than
Spanish are infrequent.
Factor 3 – Importance of service, information, program or activity
The services provided by the Union City Community Development Agency, the Union
City Offices of Rent Control, and the Union City Housing Authority are important as they
relate to a client’s need for or continued provision of, affordable housing.
Factor 4 - Costs versus resources and benefits
Because the Union City Community Development Agency, the Union City Office of Rent
Control, and the Union City Housing Authority maintain considerable numbers of
Spanish speaking staff, it is cost effective for them to provide Spanish language
translation of all vital documents and many others that while not vital, may be beneficial
to a client.
The Union City Community Development Agency, the Union City Office of Rent Control
and the Union City Housing Authority will utilize any documents provided by HUD in
languages other than English.
The Union City Community Development, the Union City Office of Rent Control and the
Union City Housing Authority will seek to retain the services of a professional
interpretation service to provide oral interpretation in languages other than Spanish as
needed.
3
City of Union City Community
Development Agency & Union City
Public Housing Authority
Language Assistance Plan (LAP)
City of Union City
Community Development Block Grant (CDBG)
Introduction
The Union City Community Development Agency and the Union City Housing Authority
are committed to providing equal opportunity housing in a non-discriminatory manner,
and in complying fully with all Federal, State and local nondiscrimination laws and with
the rules and regulations governing Fair Housing and Equal Opportunity in housing and
employment. This includes complying with Title IV of the Civil Rights Act of 1964 to
ensure meaningful access to programs and activities by Limited English Proficient (LEP)
persons.
The purpose of this Language Assistance Plan (LAP) is to identify how the Union City
Community Development Agency and the Union City Housing Authority will ensure their
methods of administration will not have the effect of subjecting LEP persons to
discrimination because of their national origin, and to ensure LEP persons have full
access the programs and services offered by both entities.
Who is LEP?
For the purposes of this LAP, anyone whose primary language is not English, and has a
limited ability to read, write, speak or understand English may be LEP.
Neither the Union City Community Development Agency nor the Union City Housing
Authority will identify anyone as LEP; the beneficiaries of the services and activities
must identify themselves as LEP (Federal Register Vol. 72, No. 13, January 22, 2007).
4
Identification of Languages Needs Within the Jurisdiction
It was determined through review of the U.S. Census Bureau’s American Fact Finder
for the City of Union City, as recommended by the U.S. Department of Housing and
Urban Development (HUD), that Spanish was the only language to meet the 4 factor
analysis criteria (1 – Number or proportion of LEP persons served or encountered in the
eligible service area; 2 – Frequency of contract with the program; 3 – Importance of
service, information, program or activity; 4 - Costs versus resources and benefits)
requiring translation of vital documents. This was supported by the volume of
encounters with LEP persons, virtually all of whom were Spanish speaking. According
to the 2010 US Census, there are 52,199 Spanish-speaking persons over the age of
five years in Union City. Guidance provided by HUD states that written translations of
vital documents should be provided for each eligible LEP language group constitutes
5% or 1,000, whichever is less, of the population of persons eligible to be serviced or
likely to be affected or encountered. The Union City Community Development Agency
and Union City Housing Authority have determined that because more than 97% of the
total population are Spanish-speakers, the Union City Community Development Agency
and Union City Housing Authority will translate vital documents into Spanish.
The LEP population other than Spanish speaking, is extremely small and therefore did
not meet the threshold to require written translation of vital documents into those
languages. However, The Union City Community Development Agency and the Union
City Housing Authority will provide oral interpretation as needed to LEP persons
requesting such services.
Written Translation
As stated above, the Union City Community Development Agency and the Union City
Housing Authority have determined that because there are more than 1,000 Spanish-
speakers in Union City, the Union City Community Development Agency and the Union
City Housing Authority will translate vital documents into Spanish. As of the date of the
creation of this LAP, Spanish is the only language into which vital documents will be
translated. This is subject to change upon review of the LAP as discussed below.
1. Vital Documents
HUD has defined “vital documents” to be those documents that are critical for
ensuring meaningful access or awareness of rights or services, by beneficiaries
or potential beneficiaries generally and LEP persons specifically. In general, the
Union City Community Development will attempt to translate all letters sent to
program applicants and participants to Spanish. Additionally, this office will
5
publish notices pertinent to the review of critical CPD documents in both Spanish
and English.
The Union City Housing Authority also makes it general practice to translate
letters sent to program applicants and participants to Spanish. Additionally, the
Union City Housing Authority relies upon publications by Nan McKay for Public
Housing and Section 8 (The Family Handbook / El Manual de La Familia) which
are provided to all new tenants and Housing Choice Voucher tenants in either
Spanish or English, whichever is necessary.
Oral interpretation
The Union City Community Development Agency and the Union City Housing Authority
will continue to make every effort to provide oral interpretation for all its clients who have
identified themselves as LEP and request services.
1. Bilingual Staff
The Union City Community Development Agency and the Union City Housing
Authority employ bilingual, Spanish-speaking staff in most positions, including
program management, to ensure there are sufficient personnel available to assist
Spanish-speaking LEP persons when needed. Currently the Union City
Community Development Agency has six full-time Spanish-speaking staff. The
Union City Housing Authority employs twenty six full-time staff, of which all are
Spanish speaking. The Union City Housing Authority employs at least one native
Spanish-speaking bilingual staff members in each organizational department.
As native speakers of the non-English languages detailed above, the Union City
Community Development Agency and Union City Housing Authority bilingual
staff, as well as other City of Union City bilingual employees have not, to date,
been required pass a competency test in the other language in order to be
designated as a bilingual person.
6
2. Interpretation Services
Although there have been no recorded cases by either the Union City Community
Development Agency or Union City Housing Authority in which there has not
been a staff person available who speaks the LEP person’s primary language,
both entities agree that they will seek interpretation through a professional
interpreter service should this situation arise.
In the event that the LEP person’s primary language is not widely spoken and the
Union City Community Development Agency and Union City Housing Authority
are unable to locate a suitable interpreter through a professional interpreter
service, these entities may resort to other methods such as seeking community
volunteers. As a last resort in case where either the Union City Community
Development Agency or Union City Housing Authority is unable to find an
acceptable interpreter within a time frame to effectively assist the client, either
entity may use an online translation website, such as such as Bing Translator or
Babylon.com, in order to communicate via an in-office computer.
3. Informal Interpreters
The Union City Community Development Agency and Union City Housing
Authority will generally discourage the use of family members or other informal
interpreters, but will allow the use of an interpreter of the LEP person’s choosing
(including family members or a professional interpreter at the LEP person’s own
expense) when the LEP person rejects free language assistance services offered
by the Union City Community Development Agency and Union City Housing
Authority. These entities will document the offer and the LEP person’s
subsequent rejection.
Outreach
The Union City Community Development Agency and Union City Housing Authority will
conduct outreach in a method that is inclusive of LEP persons identified through its bi-
annual analysis. All Public Notices and marketing advertisements, such as notification
of the availability of waiting list applications and CDBG planning activities, shall be
published in Spanish as well as English in both the local Spanish- and English-language
media. The Union City Community Development Agency and Union City Housing
Authority may also participate in community-sponsored events and make presentations
through community organizations to target LEP persons and ensure they are aware of
the availability of LEP assistance.
7
For clients of the Union City Housing Authority, reception service is provided in Spanish,
flyers and other communications posted in the lobby are translated into Spanish, and
interviews and programs briefings are available in Spanish. Brochures advertising other
available programs within the organization are also available in Spanish. For clients of
the Union City Community Development Agency, reception service is also available in
Spanish.
For clients who are LEP but are not Spanish-speaking, receptionists of both the Union
City Community Development Agency and the Union City Housing Authority will have a
document created by the US Census Bureau translated into 38 different languages to
use as a tool to identify the client’s primary language. The Union City Community
Development Agency and Union City Housing Authority will also seek translation of a
notice announcing the availability of primary language assistance into as many
languages as possible to be posted in the lobby. Until this is achieved, the Union City
Community Development Agency and the Union City Housing Authority will post the
notice in English.
Staff Training
The Union City Community Development Agency and the Union City Housing Authority
will provide a copy of this LAP to all existing staff, and will also provide training as to its
contents and what is required of them under its policies. This training shall include the
types of services available to clients and how to access them. New employee will
receive this LAP and the same training as part of their orientation.
Monitoring and Updating of This LAP
The Union City Community Development Agency and Union City Housing Authority will
review/revise this LAP on an as needed basis, but no less than every two years to
ensure the populations of the various language groups within the jurisdiction and their
needs are reflected in the provision of primary-language services. At that point the Plan
will be reviewed to determine if the existing LEP services are sufficient to meet the
needs of LEP clients.
Events that will be considered indicators of the need for a review of the LAP and will
also be utilized to identify the need for LEP assistance in other languages include but
not limited to LEP populations within the jurisdiction encountered or affected; frequency
of encounters with LEP population; and continued availability of existing resources and
the addition of new resources.
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