Colorado - Draft Analysis of Impediments To Fair Housing, 2011

DRAFT
DRAFT COLORADO ANALYSIS OF

IMPEDIMENTS TO FAIR HOUSING
Colorado Department of Local Affairs

Reeves Brown, Executive Director
Colorado Department of Human Services

Reggie Bicha, Executive Director
John Hickenlooper, Governor
Colorado Analysis of Impediments to Fair Housing 2011- 2015

1
DRAFT
I. Introduction and Executive Summary ......................................... 4

A. Who Conducted ...................................................................................... 4
B. Participants ............................................................................................ 4
C. Methodology Used................................................................................... 7
Notes on Terminology and Sources ............................................................ 8
D. How Funded........................................................................................... 9
E. Executive Summary and Conclusions ......................................................... 9
Impediments Found ................................................................................. 9
Actions To Address Impediments ............................................................. 11
II. State of Colorado Background Data ......................................... 14
Demographic Data .................................................................................... 14
Racial and Ethnic Composition ................................................................. 14
Language/Cultural Barriers ..................................................................... 24
Persons With Disabilities ......................................................................... 26
Religious Groups ................................................................................... 30
Colorado Households.............................................................................. 34
Income Data ............................................................................................ 36
Median Income ..................................................................................... 36
Income Distribution ............................................................................... 37
Employment Data ..................................................................................... 39
Housing Profile ......................................................................................... 40
Overview.............................................................................................. 40
Rental Mismatch Findings ....................................................................... 42
Rent Burden ......................................................................................... 43
Other Relevant Data.................................................................................. 45
Stakeholder survey results...................................................................... 45
General Public Survey Results ................................................................. 52
III. Colorado’s Current Fair Housing Legal Status........................... 54
Summary of Fair Housing Complaints or Compliance reviews .......................... 54
Fair Housing Complaints by Basis............................................................. 55
Fair Housing Complaints by Issue ............................................................ 57
Reasons for any trends or patterns.............................................................. 59
Other fair housing concerns or problems ...................................................... 59
Homelessness and the Protected Classes .................................................. 59
Segregation and Affordable Housing Site Analysis ...................................... 60
IV. Identification of Impediments to Fair Housing .......................... 61
Public Sector –State Statutes and Regulations .............................................. 61
Building, Occupancy, Health, and Safety statutes ....................................... 61
Approval process for construction of housing ............................................. 61
Community development and housing activities ......................................... 62
Statewide policies that increase segregation or inhibit employment............... 62
Public policies that restrict interdepartmental coordination........................... 63
Statewide actions related to the provision and siting of public transportation and
social services ....................................................................................... 63
Protected-class representation boards, commissions, and committees ........... 63
Private Sector .......................................................................................... 64
State banking and insurance laws and regulations ...................................... 64
State laws and regulations covering the sale of housing .............................. 64

2
DRAFT
State laws and regulations covering housing rentals, trust or lease provisions,
and conversions of apartments to all-adult ................................................ 65
State and local laws that conflict with the accessibility requirements of federal
laws. ................................................................................................... 65
State and local laws or other policies and practices that have the effect of
restricting housing choices for persons with disabilities. .............................. 65
Information on financial assistance for accessibility modification of private
homes ................................................................................................. 66
Lending Policies and Practices.................................................................. 66
C. Public and Private Sector........................................................................ 74
Evidence of segregated housing conditions in non-entitlement areas, and
housing desegregation plans ................................................................... 74
The delivery system for statewide programs providing social services to families
with children and persons with disabilities. ................................................ 74
V. Current Public and Private Fair Housing Programs And Activities .. 75
VI. Conclusions and Recommendations ........................................ 79
Impediments Found ............................................................................... 79
Actions To Address Impediments ............................................................. 83
Other Actions ........................................................................................ 87

3
DRAFT
I. Introduction and Executive Summary

WHAT IS FAIR HOUSING?
Title VIII of the Civil Rights Act of 1968 (Fair Housing Act), as amended in 1988,
“Prohibits discrimination in the sale, rental, and financing of dwellings, and in other
housing-related transactions, based on race, color, national origin, religion, sex,
familial status (including children under the age of 18 living with parents of legal
custodians, pregnant women, and people securing custody of children under the age
of 18), and handicap (disability).”
Colorado’s Fair Housing statutes (C.R.S. 24-34-500 et. seq.) include marital status,
creed and ancestry in addition to the federal definitions of persons protected by Fair
Housing law. It is also illegal to refuse to make reasonable accommodations for
persons with disabilities or to harass or interfere with a person exercising their Fair
Housing rights.
The Civil Rights Act, including the Fair Housing Act, grew out of the civil rights
movement of the 1960s and was particularly directed at relieving the living
conditions that gave rise to the race riots of that era. During the period following
World War II, both public and private sector practices had led to the segregation of
minorities (especially African Americans) into ghettos in inner cities, far away from
the newer housing and job opportunities being created in the suburbs. But the
greater intent of the law was not just to eliminate the practices that created racially-
segregated communities, but to provide equal housing opportunity for all Americans
who experienced discrimination. Later legislation led to the addition of families with
children and people with disabilities as protected classes.
Fair Housing is the process and vehicle for ensuring those protections.
A. Who Conducted
This analysis of impediments was conducted by the Colorado Department of Local
Affairs, Division of Housing (CDOH) and the Colorado Department of Human
Services, Supportive Housing and Homeless Programs (SHHP).
B. Participants
Primary Author: Mary E. Miller, Colorado Department of Local Affairs, Division of
Housing
Contributing Authors:
Susan Niner, Colorado Department of Health and Human Services, Supportive
Housing and Homeless Programs
Lynn Shine, Colorado Department of Local Affairs, Division of Housing
Ryan McMaken, Colorado Department of Local Affairs, Division of Housing
Research Assistance:
Cynthia De Groen, Colorado Department of Local Affairs, State Demographer’s Office
Autumn Gold, Manager of Section 8 Programming

4
DRAFT
Christopher Roe, Colorado Department of Health and Human Services, Supportive
Housing and Homeless Programs
Tony Hernandez, Director, Department of Local Affairs, Division of Local Government
Andy Hill, Sustainability Coordinator, Department of Local Affairs, Division of Local
Government
Survey Participants:
Mark* Colorado Housing and Finance Authority
Randy McCall KeyBank
Charles Kreiman ICF International
Mary Anderies Anderies Consulting
Heidi Aggeler BBC Research & Consulting
Mike Rinner The Genesis Group
Autumn Dever Upper Arkansas Area Council of Governments
Zoe Mick South Eastern Colorado Economic Development
Anne-Marie Mokritsky-Martin Colorado Cross Disability Coalition
Ruth Pederson Colorado Health Network, Inc.
Jenny Wildee Denver Options
Martha Mason Southwest Center for Independence
Kathryn Garcia Developmental Pathways, Inc.
Alison Dawson Disabled Resource Services
Marcella Young Disabled Resource Services
Renee' Walker Foothills Gateway, Inc.
Jennifer Chase Northern Colorado AIDS Project
Vicky Elliot Mountain Valley Developmental Services
Kim Engell Connections Independent Living
Jan Binkley Envision
Marlene Lovato Developmental Disabilities Resource Center
Michael Block Boulder Shelter for the Homeless
Diana Buza The Pinon Project
Cameron Malcolm Colorado Coalition for the Homeless
Les Jones Family HomeStead
Randle Loeb Metro Denver Homeless Initiative
Missy Mish St. Francis Center
Debra MacKillop The Gathering Place
Bobbi Meng Caring Ministries of Morgan County
Sr. Karen Bland Grand Valley Catholic Outreach
Gi Moon Homeward Bound of the Grand Valley
Jodi Hartmann Greeley Transitional House
Mary Yendrek Jeffco Action Center
Carleta Schwartz Southeast Colorado Homeless Shelter
Anita Deshommes Growing Home
Krista Goddard Stepping Stones of Windsor
Rachel Helberg Brush Housing Authority
Judy Scandura Colorado Springs Housing Authority
Andrea Davis Denver Housing Authority
Jo Spotts Housing Authority City of Fort Lupton
Katherine Roby Fountain Housing Authority
Lori Rosendahl Grand Junction Housing Authority
Thomas Teixeira Greeley/Weld Housing Authorities
Jim Sheehan Grand County Housing Authority
J. Anthony Mascarenas La Junta Housing Authority

5
DRAFT
Theresa Folk Metro West Housing Solutions
Bill Lunsford Metro West Housing Solutions
Melanie Gurule Lamar Housing Authority
Dan Burnham Littleton Housing Authority
Kimberly Kamay Littleton Housing Authority
Bonnie Osborn Douglas County Housing Partnership
Moofie A. Miller Housing Authority of the City of Loveland
Carol Kemp Montrose County Housing Authority
Tim Heavers Montrose County Housing Authority
Frank D. Pacheco Pueblo Housing Authority
K Grosscup Garfield County Housing Authority
William Herrboldt Sterling Housing Authority
Cindy Barnett Hull Wray Housing Authority
Janelle Devlin Yuma Housing Authority
None given* City of Arvada
Joseph Garcia Manager, City of Aurora, Community
Development Division
Michelle Allen City of Boulder
Jan Hamilton City and County of Broomfield HHS
Valorie Jordan City of Colorado Springs
Tiffany Colvert El Paso County, CO
ReJean Peeples City and County of Denver
Leona Perkins Eagle County Housing & Development
Bill Wallace Summit County
Jo Ann Sorensen Clear Creek County
Carmen Ramriez City of Longmont-Community & Neighborhood
Resources
Debbie Hughes City of Thornton
Tony K. Watson Barvista Building Systems
Nick Keller Teton Buildings LLC
Tara Lifford VFP, Inc.
Kate Behnken San Luis Valley Mental Health Center
Gillian* Aurora Mental Health
Jean Morrill Mental Health Center Serving Boulder and
Broomfield Counties
Lynne Navin Mental Health Center Serving
Boulder and Broomfield Counties
Jodi Vaimagalo Community Reach Center
Leslie Parker Community Reach Center
Jenni* Axis Health System
Erica Keter Axis Health Systems
Ken Kroneberger Jefferson Center for Mental Health
Katie Hasselgren Arapahoe/Douglas Mental Health Network
Kirstin Schelling Centennial Mental Health Center
Eugene Medina Arapahoe House
Roger Watkins Spanish Peaks Regional Health Center
John Hazlehurst Colorado Springs Business Journal
Rachel Willis San Luis Valley Housing Coalition
Tracy Walters Thistle Communities
Shaylene Kraft Hughes Station LLLC
Diana Telford Partners In Housing
Michelle Mitchell Colorado Housing Assistance Corp.

6
DRAFT
Marvin Kelly Del Norte NDC
Kristin Delcamp Habitat for Humanity of Metro Denver
Getabecha Mekonnen Northeast Denver Housing Center
Joyce Alms-Ransford Rocky Mountain HDC, Inc
Dianna L. Kunz Volunteers of America
Clark Haggard Housing Solutions for the Southwest
Wendie Robinson Neighbor to Neighbor
Monie Stites Tri-County Housing & CDC
Mary Simonson Imagine
Julie Simmons Colorado Housing, Inc.
Jenny Russell Affordable Housing Solutions
Connie Baker Wolfe Rural Community Assistance Corporation
Nancy Burke Colorado Apartment Association
Christopher Stefan Marcus & Millichap
Derek Camunez RE/MAX Avenues
Susan Aldretti Jefferson County Association of Realtors
Linda Love Target Realty Solutions
Marta Loachamin Century 21
Vicki Hall Springfield West
Paulette St. James Colorado Dept of Human Services
Kim* Colorado Dept. of Human Services-
Supportive Housing & Homeless programs
Caitlyn* Colorado Dept. of Human Services-
Karyn Mandler Colorado Dept. of Human Services-
Ryan McMaken Colorado Dept. of Local Affairs,
Division of Housing
*Participant did not supply complete name
C. Methodology Used
The State of Colorado used a combination of primary and secondary sources to
analyze current Fair Housing conditions in the state.
Primary sources included:
• Two surveys made available online, one for those involved in providing
affordable and accessible housing and another for the general public;
• 2008 Home Mortgage Disclosure Act data
• Reports on Fair Housing Complaint Filings from OFHEO and Colorado Civil
Rights Division.
Secondary sources included:

• The United State Census American Community Survey, 2005-2009 5-year
Estimates, 2009 1-year Estimates
• U.S. Census Population Estimates
• Colorado demographic projections from the Colorado Demographer’s office.
• Discriminatory Predatory Lending in Colorado, Colorado Civil Rights Division,
July, 2009
• Housing Mismatch and Rent Burden Information for Rental Housing in
Colorado, Colorado Department of Local Affairs, Division of Housing, April
2010
• State of Working Colorado 2009, Colorado Fiscal Policy Institute

7
DRAFT
• DiversityData.org: Profile summaries by Metropolitan Statistical Area from
http://diversitydata.sph.harvard.edu
• A Step in the Right Direction: 2010 Fair Housing Trends Report, National Fair
Housing Alliance, May 26, 2010
• Housing and Community Grants, GAO Report to Congressional Requestors,
September, 2010.
• The State of Fair Housing, Annual Report on Fair Housing FY 2009, U.S.
Department of Housing and Urban Development, July, 2010
• Between the Lines: A Question and Answer Guide on Legal Issues in
Supportive Housing, Law Offices of Goldfarb & Lipman, Corporation for
Supportive Housing, 2001
• Discrimination in Metropolitan Housing Markets: National Results from Phase I
and Phase II of the Housing Discrimination Study (HDS), Department of
Housing and Urban Development, 2005
• Statistical Report: Fiscal Year 2008, Colorado Dept. of Corrections
• Religious Congregations and Membership in the United States, 2000.
Collected by the Association of Statisticians of American Religious Bodies
(ASARB) and distributed by the Association of Religion Data Archives
(www.theARDA.com).
• What Does It Mean to Have a Disability in Colorado? Six Key Issues, the
Colorado State Independent Living Council, July 2010
Notes on Terminology and Sources

Racial and Ethnic Categories
This report uses the Census Bureau’s categories for race and ethnicity. Under this
system, people are asked to self-identify their race using the following categories:
• White
• Black/African American
• American Indian/Alaskan Native
• Asian
• Native Hawaiian/Other Pacific Islander
• Some other race
• Two or more races
Hispanic/Latino is treated as an Ethnicity rather than a racial category, as people

with Hispanic ancestry can be of any race.
Households and Families are identified by the race and ethnicity of the head of
household only.
To conserve space where necessary, this document will refer to Black/African

Americans as Black and Hispanic/Latino as Hispanic. The standard abbreviation for
American Indian/Alaska Native is AIAN; for Native Hawaiian/Other Pacific Islander is
NHPI; Some Other Race is SOR.
The American Community Survey (ACS) conducted by the U.S. Census Bureau
collects its data by sampling a percentage (1 in 40) of the population on an ongoing
basis rather than everyone. While this provides more current data than the
decennial Census count, the data collected is subject to sampling error. American

8
DRAFT
Community Survey estimates are published with their margins of error (MOE) set at
the 90% confidence level – in other words we can be 90 percent sure that the range
established by the margin of error contains the true value.
Some subgroups of Colorado’s population, such as the numbers for Native

Hawaiians/Other Pacific Islanders, are so small that the margins of error from
sampling one-fortieth of them are very large, rendering the data unreliable.
Data concerning people with disabilities is not readily available. Because the ACS
changed its questions about people with disabilities during the 2005-2009 time
frame, there are no five-year figures available, and the numbers over shorter periods
also have greater margins of error. Specific subjects for which there is no available
census data include income and employment data. Where possible other sources of
data have been used instead.
Data from the 2000 Decennial Census has been used in some circumstances where
more recent data was unavailable during the compilation of this report.
The Census Bureau does not collect information on religious affiliation, although
religion is a protected class. This report has used data from the Association of
Statisticians of American Religious Bodies for the year 2000.
D. How Funded
This analysis was funded from the Colorado Department of Local Affairs 2010 CDBG
allocation using existing staff.
E. Executive Summary and Conclusions

Significant Impediments to Fair Housing exist in Colorado. Housing discrimination
can be hard to prove in the absence of formal testing, but can be inferred from other
sources. It is the reflected in the Impediments listed below.
By analyzing the most recent available U.S. Census and American Community
Survey data, Home Mortgage Disclosure Act data, surveys of the housing and
disability communities and of the general public in Colorado, Analyses of
Impediments (AIs) from Colorado entitlement areas, reports of Fair Housing
complaints, and various other reports and documentation, we can discern social and
economic patterns as well as common concerns.
Division of Housing staff reviewed these source documents, compared the number of
times that issues were raised in surveys and AIs, and the degree to which hard data
supported those concerns to compile the following list of impediments and proposed
actions to address them. The impediments and actions are addressed in more detail
at the end of this document.
Impediments Found
Lack of Fair Housing Education and Coordination
Review of survey responses and Analyses of Impediments from entitlement areas

indicates that many residents and property managers do not have access to
information about Fair Housing rights and responsibilities. Most of the following

9
DRAFT
impediments appear to be related to lack of knowledge, so this appears to be an
underlying problem.
High Housing Costs Combined with Low Income/Wages
Survey responses, entitlement-area Analyses of Impediments, and Colorado Division

of Housing Rental Housing Mismatch report and American Community Survey data
most frequently name the shortage of affordable units for households with low and
very low incomes. The lack of affordable housing has a disparate impact on
Black/African Americans, Hispanics, American Indians, women and people with
disabilities because higher percentages of these protected classes are low income.
However, high housing cost is not, in and of itself, an impediment to Fair Housing. It
is the actions that communities take to limit the types and locations of affordable
housing that can represent impediments to Fair Housing when they cause or
exacerbate existing segregation, whether or not that is the community’s intent.
The shortage and cost of housing specifically suited to people with disabilities is an
additional impediment, as is a shortage of apartments with more than three
bedrooms, which makes it difficult to house large families who need to rent.
Causes of High Housing Costs

• Impact Development Fees
• Other local planning/zoning and building regulations
Impediments Specific to People with Disabilities
This was the largest single source of Fair Housing complaints filed from 2006-2009,
accounting for
• Lack of appropriate, accessible housing that is also affordable.
• Failure of landlords/property managers to provide reasonable
accommodations for tenants with disabilities.
• Communication issues, especially for people with mental disabilities
Community Resistance to Affordable and Special Needs Housing
The “Not in My Back Yard Syndrome” is an impediment to fair housing because it

discourages or may even prevent development of affordable housing that would
provide fair housing choice to protected classes. Twelve of the fourteen communities
whose Analyses of Impediments were reviewed cited this as a major impediment.
Lack of Fair Housing Enforcement
The economic downturn and subsequent reductions in State and Federal revenue
have led to a lack of funding for Fair Housing testing and enforcement. No non-profit
organizations in Colorado have received Fair Housing Initiatives Program (FHIP)
funding since 2007. Comments in our survey noted lack of enforcement and
difficulty in assistance when experiencing discrimination. The Colorado Civil Rights
Division is the lead state agency for Fair Housing enforcement.

10
DRAFT
Predatory Lending and Foreclosures
A study by the Colorado Civil Rights Division found that minorities, especially Blacks
and Latinos, were targeted for subprime mortgage loans and that these groups
consequently have experienced a disproportionate number of foreclosures.
Language and Cultural Issues
Persons who do not speak English well may be vulnerable to discrimination or unfair
acts. Language barriers especially complicate landlord/tenant issues. Colorado’s
population of low-English proficiency Spanish-speakers is 7.3%.
Transportation
Lack of public transit in many areas of the state as well as lack of affordable housing
along existing transit routes impede fair housing choice. Housing patterns, location
of employment opportunities and public transit are not coordinated so as to enable
minorities and low income people to hold a job without having a car. Transportation
is a recurring barrier to service delivery for people with HIV/AIDS outside the Denver
Metro Area, as no public transportation exists and the service areas for HOPWA
sponsor agencies are very large.
Local Government Regulations
Planning and zoning, definitions of “family,” land use plans, development fees,
growth management programs and housing design specifications may increase the
cost of housing and otherwise create impediments to fair housing choice.
Actions To Address Impediments

• Host a Statewide Fair Housing education event

• Develop programs to educate landlords & property managers about Fair
Housing, especially as it affects people with disabilities
• Additional training for CDOH personnel to improve Technical Assistance to
housing providers and services to the public.
• Further development of Fair Housing web page
• Promote fair housing education offered by other organizations
• Provide information about funding available for Fair Housing (NOFAs)
• Provide/coordinate training for Fair Housing with other statewide, federal and
nonprofit housing agencies including CCRD, CHFA, Colorado Department of
Human Services, Supportive Housing and Homeless Programs (SHHP), Fannie
Mae, Freddie Mac, Colorado Coalition for the Homeless (CCH),Colorado AIDS
Project statewide disability organizations and other fair housing leaders.

11
DRAFT
• Ensure that all partners provide webpage links to the Colorado Civil Rights
Division (CCRD) and the U.S. Department of Housing and Urban Development
(HUD), along with information about Fair Housing.
Impact Development Fees

• Work with local governments during the strategic planning process to
encourage infrastructure funding methods that do not increase the price of
producing affordable housing.
• Annually, publish “Affordable Housing: A Guide for Local Officials” as a tool
for local governments in creating affordable housing and reducing regulatory
barriers.
• Prioritize the production of homes that are accessible to people with

disabilities.
• Continue to ensure that our grantees comply with all Fair Housing regulations
concerning reasonable accommodation and reasonable modification.
• Provide education and technical assistance to public housing authorities,
property owners and landlords on Fair Housing for people with disabilities
• Provide training for public housing authorities, property owners and landlords
on communication issues, especially for people with mental disabilities
• Provide incentives to housing developers to exceed Section 504 accessibility
requirements in the production of housing for persons with disabilities.
• Establish a program that can assist landlords in modifying units to meet
accessibility standards in order to increase the supply of accessible units.
• Encourage local housing and disability service agencies to conduct tenant
training programs to increase client knowledge of fair housing rights.
• Continue to promote awareness of the need for affordable housing in

Colorado communities.
• Partner with the Division of Local Government, the Colorado Municipal League
and Colorado Counties Incorporated and Housing Developers to promote
“best planning practices” that involve neighborhoods and the public at the
beginning of the housing development process.
• Enhance public education about the community effects of affordable/special
needs housing through publications, public speaking, involvement in local
comprehensive planning processes
• Provide technical assistance to housing developers on working with neighbors
to allay unfounded fears about the economic and social effects of affordable
and special needs housing.

12
DRAFT
• Request that HUD conduct or fund Fair Housing testing
• Seek out new sources of funding for testing
• Increase access to information and assistance about filing fair housing
complaints
• Develop a list of Department of Local Affairs employees who are bilingual and
competent to act as interpreters and/or translators
• Increase outreach to tenants and landlords
• Analyze needs of Limited English Proficiency persons in Colorado and adopt a
Language Assistance Plan.
• Translation of Fair Housing information into Spanish languages
• Offer training to improve the cultural literacy of those dealing directly with
LEP and/or disabled persons.
• Division of Housing will
Transportation
• Continue to promote Sustainable Communities, which encompass

transportation and economic opportunity as well as affordable housing.
• Encourage the inclusion of public transportation in local government
comprehensive plans, or the placement of affordable housing close to services
in places where public transportation is not economically feasible.
• Encourage development of affordable housing in close proximity to public
transit, especially where it provides access to better employment
opportunities.
• Continue to educate local governments about barriers to affordable and Fair

Housing.
• Ensure that local government applicants have Fair Housing Plans in place and
that they enforce them prior to making housing grants or loans.
• Perform further research into local government planning and zoning policies,
that affect Fair Housing opportunity.

13
DRAFT
II. State of Colorado Background Data

Demographic Data
According to the U.S. Census Bureau 2009 population estimates, Colorado ranks
22nd in the nation for total population, with an estimated 5,024,748 persons. 50.3%
of the population is male, 49.7% is female.
Colorado’s population grew an average annual rate of 1.7% from 2000 to 2005, 2%
from 2005 to 2010 and is expected to grow at an average rate of 1.8% from 2010
to 2020 (Source: Colorado Department of Local Affairs [DOLA] Office of
Demography, 2008).
Racial and Ethnic Composition

The 2005-2009 American Community Survey estimates that Colorado’s population is
83.7% White, 3.9% Black or African American, 2.6% Asian, 1.0% American Indian
or Alaska Native, 0.1% Native Hawaiian or other Pacific Islander, and 8.7% some
other race or more than one race.
955,664 people of any race, 19.7% of Colorado’s population, self-identified as

Hispanic or Latino in ethnicity.
Figure 1, Colorado vs. US Population by Ethncity
Comparison of US and Colorado Populations,

Race and Ethnicity 2009
80.00%
Percent of population
70.00%
60.00% White, Non-Hispanic
50.00%
Hispanic or Latino - all
40.00%
races
30.00%
Black/African American
20.00%
10.00%
0.00%
United States Colorado
Compared to the US as a whole, Colorado’s population is more White and Hispanic,

and contains a much lower percentage of Black/African Americans than the nation.
Denver is the largest city in Colorado with an estimated population of 610,345 in

2009 (U.S. Census Bureau population estimate), and the seven-county metro Denver
area of Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas and Jefferson
Counties has a population of 2,801,318 for the same year.

14
DRAFT
The entire Denver metropolitan area is forecast to grow to 3.3 million by 2020, an
annual average growth rate of 1.6 percent, slightly lower than the growth rate
expected statewide.
Other major cities in Colorado include Aurora, Boulder, Colorado Springs, Fort
Collins, Grand Junction, Greeley, Lakewood and Pueblo.
The Western Slope continues to be the fastest growing region in the state with an
annual growth rate averaging 2.8 percent between 2005 and 2010 compared to the
2.0 percent growth rate statewide.
The North Front Range and Central Mountains are also expected to have above
average growth rates, while the Eastern Plains and San Luis Valley are expected to
continue growing at rates near 1 percent (similar to the Nation).
In 2000, Colorado had an average of 41.5 persons per square mile while the density
of the United States was 79.6 persons per square mile. The Census Bureau
estimates Colorado’s 2010 density at 48.5 persons per square mile compared to 87.4
persons per square mile for the United States.
Minority and Racial Concentrations
The following maps and information are based on the 2000 decennial Census
because the 2010 Census data was not available while this document was being
prepared. We plan to update this section with that information in an annual update
document for 2011.
Data Distortions Created by Correctional Facilities

When looking at the following maps of minority concentrations, be aware that since
members of non-white racial groups are disproportionately represented in prison
populations, they can distort the apparent presence of their groups in non-urban
areas. In contrast to Colorado’s general population, state prison inmates are 46%
White, 31% Hispanic/Latino, and 20% Black/African American in 2008.
Based on the 2000 Decennial Census for Colorado, there were 30, 136 people in
correctional facilities. 13,751 were non-Hispanic White (45.6%), 6,640 were Black
or African American (22%), and 8,316 were Hispanic (27.6%). State Correctional
facilities are located in Crowley, Delta, Fremont, Kit Carson, Lincoln and Logan
counties.
Black/African American
In the 2000 Census, the Black/African American population in Colorado numbered
165,063, or approximately 3.8%. 2005-2009 American Community Survey
estimates put the number at 191,329 (± 2,725), or 3.9%.
In 2005, HUD released a report “Discrimination in Metropolitan Markets Phase I,”
based on 2000-2001 paired testing research by the Urban Institute in various
housing markets nationally, including Denver. The report noted consistent adverse
treatment against Black renters in Denver 19.4% of the time, and against potential
Black homebuyers 19.7% of the time. The most common forms of adverse treatment
were that Blacks were less likely than whites to be told that similar rental units were
available for rent and were less likely to be able to inspect the advertised unit or a

15
DRAFT
similar one. They were also less likely to received follow-up contact from the agent.
The report revealed a significant decrease in discrimination between 1989 and 2000,
but has not been repeated since, so we don’t know whether that reduction has
continued.
Figure 2 Areas of Black/African American Concentration in Colorado, 2000
Most Black/African Americans live in the Denver metropolitan area or in Colorado

Springs. The heavy concentration shown in southwest El Paso County reflects the
presence of military bases in the area. The concentration shown in Fremont county
is due to the presence of a cluster of correctional facilities in Cañon City. Other
concentrations of Black/African Americans in Delta Count, Crowley County, Lincoln
County, Kit Carson County and Logan County also reflect the presence of state
correctional facilities in low-density population areas.
Hispanic Ethnicity
The Hispanic population has a long, rich history in Colorado. In fact, early Spanish
explorations not only mapped and named many Colorado settlements, they also
contributed to our language, religion, custom and culture. The sources of
concentration of Hispanics in Colorado vary by region. In southern Colorado,
especially the San Luis Valley, it is the result of the history of Spanish settlement
prior to the time Colorado became a U.S. Territory. In other areas, Hispanics were
historically recruited as agricultural labor and encouraged to stay. In the past 20
years, there has been a lot of immigration as people primarily from Mexico have
come to find work in Colorado in the construction and tourism industries, among
others.

16
DRAFT
Figure 3, Concentrations of Hispanic Population
Southern Colorado and the San Luis Valley:

Spain claimed the area of Colorado south of the Arkansas River and west of a line
running north from its headwaters in Fremont county to the 41st parallel as Spanish
Territory. While Spanish/Hispanic pioneers attempted to settle in this area, they
were driven back by the Utes, Comanches or Apaches defending their territory.
The land became part of Mexico following the Mexican War of Independence in 1821.
The Mexican government tried to secure the northern border by making large land
grants to some of its citizens in return for promises to settle the area and hold it
against both US citizens and Native Americans.
The Conejos grant covered the area that is now Conejos and Rio Grande counties, as
well as parts of Saguache and Alamosa Counties. The Sangre de Cristo grant
roughly approximated what is now Costilla County. The largest land grant, the Vigil
and St. Vrain, extended from the Sangre de Cristo mountains east, and included
large portions of Huerfano, Las Animas, Pueblo and Otero counties. Smaller land
grants included parts of Archuleta, Saguache, Pueblo and Las Animas counties.
A map created by the Colorado State Archives shows the location of these grants.

17
DRAFT
Figure 4, Mexican Land Grants in Colorado
Key:
Conejos Grant Sangre de Cristo Grant
Luis Baca Grant Tierra Amarilla Grant
Maxwell Grant Vigil and St. Vrain Grant
Nolan Grant
This map coincides closely with concentration of Hispanic population in Southern

Colorado today.
These granted lands, however, were not successfully settled until after the United
States acquired them by war with Mexico in 1848. Under the Treaty of Guadalupe
Hidalgo that ended the war, the U.S. agreed to recognize the property rights of
Mexican settlers, and subsequently built forts to protect the area from the Native
Americans and Hispanic settlers began to come north creating homes, ranches,
farms and new towns like San Luis, which dates to 1852, predating the founding of
Denver and the creation of Colorado as a Territory. Some southern Colorado towns
such as San Luis and Antonito retain much of their rich, Spanish history.
Non-Hispanic settlers converged on these areas after the arrival of the rail roads,
and the earlier residents had to struggle to retain their ownership of the land.
Contrary to the Treaty of Guadalupe Hidalgo, much of the land was stripped away
from the Hispanic settlers because U.S. courts refused to honor the terms of the land
grants.
This history of Hispanic settlement accounts for the high percentage of people with
Hispanic ancestry in southern Colorado, especially in Rio Grande, Alamosa, Conejos,
Costilla, Huerfano and Las Animas counties. Two particular points of census data
(from the 2000 Decennial Census) support this contention.

18
DRAFT
1. The great majority of Hispanics in these counties, especially Conejos and
Costilla, are native born:
Table 1, Native-Born Hispanics in the San Luis Valley
Alamosa County 91.6%
Conejos 95.8%
Costilla 91.5%
Rio Grande 87.6%
Saguache 72.2%
2. Hispanic people in these counties most often self-identify as Spanish,

Spaniard, Spanish-American or “other” rather than identifying with another
Spanish-speaking country.
For example, in Conejos County 23.5% of those who claimed Hispanic identity
in the 2000 Census said they were specifically of Mexican origin while 76.2%
identified as “Other Hispanic. Similarly, in Costilla County, 29% said they
were Mexican in origin, while 70.2% said they were “Other Hispanic.”
These two counties contrast strongly with Colorado’s overall Hispanic
population, where 61.3% of Hispanics claim Mexican ancestry, while only
34.1% say they are “Other Hispanic.”
In sum, the Hispanic concentration in this area does not fit the expected pattern of
segregation due to the majority population forcing members of a minority to live in a
segregated area. In fact, the concentration of Hispanics persists in spite of
discriminatory behavior on the part of the non-Hispanic population.
This part of the state has consistently experienced a high rate of poverty relative to
the rest of Colorado. Many steps have been taken to promote economic
development and reduce poverty in the San Luis Valley. Most recently, Monte Vista,
in Rio Grande County, was selected by former Governor Ritter as a Sustainable Main
Streets Initiative pilot community. As one of four pilot communities in the state for
this initiative, Monte Vista focused on downtown revitalization and restoring historic
properties for re-use, and making the downtown more pedestrian-friendly.
The city received funding to develop a market analysis and leakage study. They
partnered with a nonprofit group to hire a firm to complete a community analysis
(i.e., branding). They are working with CDOT to develop and implement a wayfinding
signage plan. Colorado State University students developed preliminary design
drawings in partnership with community members for two historic building
renovations downtown. A nonprofit professional association worked with key
community stakeholders to perform a pedestrian safety assessment in the downtown
area (free of charge). Also as part of the initiative, CDOT is working with the city to
develop a plan for highway and streetscape improvements in the downtown core
area. The cooperative agreement allows for traffic flow, safety and pedestrian safety,
and by working together, they have not only improved the resulting project but they
have reduced total community costs through planning efficiencies.
These are examples of the types of resources brought to bear to help Monte Vista
address their priority outcomes, which included revitalizing the downtown, improving
pedestrian safety, and improving energy efficiency.
Finally, as part of the initiative, the Department of Local Affairs applied on behalf on
the pilot communities to the HUD Challenge and DOT TIGER II grant programs. The

19
DRAFT
project was awarded joint funding. Monte Vista will receive $94,376 in HUD
Challenge funds, and $47,000 in state funds, to develop construction-ready design
drawings for the renovation of an historic building downtown. The city's plan is to
create affordable housing units upstairs above a retail use on the ground floor. This
strategy helps the city address its goals to provide affordable housing, make the
downtown more pedestrian friendly, preserve historic character, and continue to
develop and redevelop sustainably.
Between January 1, 2000 and December 31, 2010, the CDOH provided nearly $7.8
million in assistance to counties in the valley, including funds for single-family
rehabilitation, down payment assistance, rental housing, Housing Choice vouchers,
assistance for the homeless, and CHDO operating funds to build non-profit capacity
in the area.
Only one loan program, a single-family owner-occupied rehabilitation program
operated by the San Luis Valley Housing Coalition and funded through the City of
Alamosa, reported that 53% of its loans were made to Hispanic borrowers, a number
reasonably consistent with the Hispanic population of the area participating in the
program (Alamosa, Costilla, Conejos, Saguache counties and the town of Monte
Vista). This program continues to provide rehabilitation loans, with new grants
awarded in 2009 and 2010, but no beneficiary information is available at this time.
All counties in the San Luis Valley are included in the Colorado Office of Economic
Development and International Trade’s Enhanced Rural Enterprise Zone Program,
which provides tax credits to businesses “to promote and encourage new job creation
in designated economically lagging rural Enterprise Zone counties.”
Agricultural Immigrants
Other areas of the state have higher proportions of Hispanics in their populations
because they are farming areas where agricultural work has long been performed by
this group.
This is particularly true of Weld and Larimer Counties in the northern part of the
state. In the early part of the 20th century, recruiters went to New Mexico and
Mexico to recruit agricultural workers. According to one source, 45,000 Hispanic
workers came to Colorado as a result. Most went to work in the sugar beet fields of
Weld and Larimer counties migrating south to north and back each year. In the
1920s, employers, especially the Great Western Sugar Company, began building
colonies where Mexican and Spanish-American workers could live year round1. The
company reasoned that it would save costs in the long run by helping to reduce
training costs and retaining the best workers. The colonies were built on the outskirts
of towns in Weld County, resulting in the segregation of the farm workers from the
community at large.
While agricultural immigration dropped off during the 1930’s, recruitment began
again for “braceros” during the 1940s because of the labor shortage created by
World War II.
Many of the agricultural workers who were recruited and housed put down roots in
northern Colorado, and segregation into specific areas is the result of the original
settlements created for them.
1
Weld’s Untold Story,
http://www.greeleytribune.com/apps/pbcs.dll/article?AID=/20010404/WORLDSAPART/112310252&tem
plate=printart, accessed 2/15/2011

20
DRAFT
Recent Immigration
The concentration of Hispanics in Eagle and Lake counties in 2000 is more recent in
origin. These are areas of relatively affordable housing for people who work in the
very high-cost resort areas of Vail/Beaver Creek, Aspen, and throughout Summit
County. While employment by ethnicity data is hard to come by on a county or
census tract level, it is most likely that these are Hispanic immigrants working in jobs
in construction, and resort services such as accommodations, food service, and
retail. The location of their housing is related to housing costs and the overall
shortage of worker housing in the area.
The full extent of Hispanic immigration, both legal and illegal, is difficult to determine
because gathering information is complicated by illegal families’ fear of deportation.
According to the Colorado Fiscal Policy Institute 2004 study entitled The State of
Working Immigrants in Colorado:
“The majority of the immigrant workers surveyed came to Colorado

from Mexico to find work as day laborers, and made an average of
about $15,000 a year, including tips. Most of the workers reported
paying state and federal taxes, yet indicated they did not receive
government benefits. For the most part, the workers did not have
individual or family health care insurance coverage. They paid an
average of $571 a month in housing costs, and an average of $149 a
month in utility costs. Additionally, well over half of the workers
indicated that they send money to their families in their country of
origin, monthly or occasionally.”
Latino immigrant families are often large, close-knit, multi-generational households.
Size and relatedness of household members are issues in some Colorado
jurisdictions. To stem the flow of arrivals, some communities are redefining the
concept of family by limiting the number of people who are allowed to live under one
roof via building codes that limit the number of occupants according to square
footage or by the number of bedrooms. Other communities already have such
policies on the books, but do not rigidly enforce those laws. Nonprofit service
providers express concern that Spanish-speaking legal and illegal immigrants may be
targeted by predatory lenders. A 2006 study published by the Colorado Civil Rights
Commission validated that concern.
In its “Discrimination in Metropolitan Markets Phase I” study HUD found that in the
Denver MSA, Hispanics were subjected to adverse treatment 15.1% of the time, and
potential Hispanic homebuyers 19.2% of the time. While no individual measure of
adverse treatment was statistically significant the rental market, prospective
Hispanic homebuyers were less likely to inspect similar homes to the ones that were
advertised. HUD also studied the Pueblo MSA with regard to discrimination against
Hispanics in the real estate market. They found a 28.4% occurrence of adverse
treatment against renters and a 6.6% occurrence against prospective Hispanic
homebuyers.
MIGRANT AND SEASONAL WORKERS

According to the Colorado Department of Labor, Colorado is federally designated as a
significant Migrant and Seasonal Farm Worker (MSFW) state, and the MSFW
population is predominantly Spanish speaking. Migrant workers in Colorado often
work in rural areas in both agricultural and in service sectors. Migrant farm workers

21
DRAFT
fall into two categories: those who come for a growing season (beginning in May)
and move on at about the end of October, and those who come to work in
agriculture but remain in the state. It is estimated that 30,000 workers travel to
Colorado to participate in agricultural work but do not stay in the state2.
There are six Migrant and Seasonal Farm Workers (MSFW) workforce centers in
Colorado: Brighton, Greeley, Lamar, Monte Vista, Delta and Rocky Ford. 3 These
centers provide employment services to migrant and seasonal farm workers. MSFW
outreach provides a full range of services such as applications, counseling, testing,
job training and placement, and referral to supportive services.
Asians and Native Hawaiians/Pacific Islanders

According to Discrimination in Metropolitan Markets Phase II, Asians and Pacific
Islanders face significant levels of discrimination when they search for housing in
large metropolitan areas nationwide. The study did not, however, perform testing in
Colorado for Asian Americans.
The map below shows the Asian/Pacific Islander population distribution in Colorado
at the time of the 2000 Census.
Figure 5, Concentrations of Asian Population
2
Racial and Ethnic Disparities in Colorado 2005; p. 5 Colorado Department of Public Health and
Environment
3
Colorado Department of Labor and Employment 2007

22
DRAFT
American Indian/Alaska Native

Native Americans comprise 1% of Colorado’s total population. There are two
federally recognized tribes in Colorado: the Southern Ute Tribe that inhabits parts of
Archuleta and La Plata Counties, and the Ute Mountain Ute Tribe located in
Montezuma County, portions of northern New Mexico and southeastern Utah.
Figure 6, Concentrations of Native American Population
Southern Ute Tribal membership (population) was 1,365 at the time of the 2000
Census, with about 75% of the Tribal members residing on the reservation4. The
enrollment for the Ute Mountain Ute Tribe was 1,968 with the majority of the
members living on the reservation in Towaoc, and a smaller community in White
Mesa, Utah.
Many other Native American tribes are represented in Colorado including the Crow,
Cheyenne, Arapahoe, Sioux, Ute, Kiowa, Comanche, Apache, Caddo, Navajo, Hopi,
Nez Pierce, Shoshoni, Shebits, Kaibab, and Paiute. Census 2000 special tabulations
show a total of 79,689 persons of American Indian and Alaska Native ancestry reside
in Colorado. According to “A Guide to Colorado Legal Resources for Native
Americans, “more than 21,300 make their homes in the six county, (Adams,
Arapahoe, Denver, Jefferson, Boulder and Douglas) metropolitan area. A historic
migratory crossroads for numerous American Indian tribes and a former 1950’s
Bureau of Indian Affairs ‘Voluntary Relocation Center,’ Denver is often referred to as
the ‘Hub of Indian Country.’ Unfortunately, the Native American population is one of
the poorest, if not the poorest, in the state.”
According to HUD’s 2003 Study, “Discrimination In Metropolitan Housing Markets
Phase III – Native Americans: “…findings clearly indicate that discrimination is a
4
U.S. Census Bureau, 2005

23
DRAFT
serious problem for American Indians searching for housing in metropolitan rental
markets, and (sic) rigorous paired testing can and should be expanded for both
research and enforcement purposes.“
Although homeownership is touted as one of the most important means of building
personal wealth in America, Native American homeownership lags far behind other
racial and ethnic groups. Only 40.7 % of Native Americans living on reservation or
trust land are homeowners, according to a 2002 study by Rutgers University.
Language/Cultural Barriers
According to the 2005-2009 American Community Survey, 7.3 percent of Colorado
residents speak English “less than very well.” These people could be considered to
have Limited English Proficiency (LEP). LEP persons are more formally defined as
those who do not speak English as their primary language and who have a limited
ability to read, write, speak or understand English. Most of the LEP population,
255,443 (± 5,219) are Spanish-speaking. Non-entitlement counties where more
than five percent of the population have limited English proficiency are shown in the
table below.
Table 2, Counties In Non-Entitlement Areas With 5% or More Low-English Proficiency
Spanish Speakers
County Percent of Population

Eagle 17.2%
Saguache 15.2%
Garfield 12.6%
Phillips 12.4%
Prowers 12.0%
Lake 11.3%
Costilla 11.0%
Morgan 10.4%
Yuma 10.1%
Kit Carson 10.0%
Alamosa 9.0%
Summit 9.0%
Weld 8.1%
Rio Grande 7.5%
Pitkin 7.0%
Montrose 6.1%
Conejos 5.6%
San Miguel 5.4%
Huerfano 5.1%
Rio Blanco 5.0%
In contrast, 25,693 (± 1,452) people with limited English proficiency speak some
other Indo-European language, and 37,417 (± 1,554) speak an Asian or Pacific
Islander language.

24
DRAFT
Improving Access To Services For Persons With Limited English
Proficiency (LEP)
Language for Limited English Proficiency Persons (LEP) can be a barrier to accessing
important benefits or services, understanding and exercising important rights,
complying with applicable responsibilities, or understanding other information
provided about HUD-funded programs. In certain circumstances, failure to ensure
that LEP persons can effectively participate in or benefit from federally assisted
programs and activities may violate the prohibition under Title VI against
discrimination on the basis of national origin. This section of the Analysis of
Impediments incorporates the Notice of Guidance to Federal Assistance Recipients
Regarding Title VI Prohibition Affecting Limited English Proficient Persons, published
December 19, 2003 in the Federal Register.
The Division of Housing and the Division of Supportive Housing and Homeless
Programs (the Agencies) will take affirmative steps to communicate with people who
need services or information in a language other than English.
In order to determine the level of access needed by LEP persons, the Agencies will
balance the following four factors:
(1) the number or proportion of LEP persons eligible to be served or likely to be
encountered by HUD-funded programs;
(2) the frequency with which LEP persons come into contact with the programs; (3)
the nature and importance of the program, activity, or service provided by the
program to people’s lives; and
(4) the resources available to the Departments and costs. Balancing these four
factors will ensure meaningful access by LEP persons to critical services while not
imposing undue burdens on the Departments.
Oral Interpretation
In situations in which health, safety, or access to important benefits and services are
at stake, the Departments will generally offer, or ensure that LEP persons are offered
through other sources, competent interpretation services free of charge.
• The Agencies will analyze the various kinds of contacts they have with the
public to assess language needs and decide what reasonable steps should be
taken. “Reasonable steps” may not be reasonable where the costs imposed
substantially exceed the benefits.
• Where feasible, the Agencies will train and hire bilingual staff to be available
to act as interpreters and translators, will pool resources with other agencies,
and will standardize documents. Where feasible and possible, the Agencies
will encourage the use of qualified community volunteers.
• Where LEP persons desire, they will be permitted to use, at their own
expense, an interpreter of their own choosing, in place of or as a supplement
to the free language services offered by the Agencies. The interpreter may be
a family member or friend.
Written Translation
Translation is the replacement of written text in one language with equivalent
written text in another language.

25
DRAFT
In order to comply with written-translation obligations, the Agencies will take the
following steps:
• Provide written translations of vital documents for each eligible LEP language
group that constitutes 5 percent or 1,000 persons, whichever is less, of the
population of persons eligible to be served or likely to be affected or
encountered. Translation of other documents, if needed, can be provided
orally; or
• If there are fewer than 50 persons in a language group that reaches the 5
percent trigger, the Agencies do not translate vital written materials, but
provide written notice in the that group’s primary language of the right to
receive competent oral interpretation of those written materials, free of cost.
Implementation Plan
After completing the four-factor analysis and deciding what language assistance
services are appropriate, the Agencies shall determine whether it is necessary to
develop a written implementation plan to address the identified needs of the LEP
populations it serves.
• If the Agencies determine that it is not necessary to develop a written
implementation plan, the absence of a written plan does not obviate the
underlying obligation to ensure meaningful access by LEP persons to federally
funded programs and services.
• If it is determined that the Agencies serve very few LEP persons, and the
Agencies have very limited resources, they will not develop a written LEP
plan, but will consider alternative ways to articulate a plan for providing
meaningful access. Entities having significant contact with LEP persons, such
as schools, grassroots and faith-based organizations, community groups, and
groups working with new immigrants will be contacted for input into the
process.
• If the agencies determine it is appropriate to develop a written LEP plan, the
following five steps will be taken: (1) Identifying LEP individuals who need
language assistance; (2) identifying language assistance measures; (3)
training staff; (4) providing notice to LEP persons; and (5) monitoring and
updating the LEP plan.
Persons With Disabilities

The map below shows the distribution of persons with disabilities in Colorado, with
darker areas highlighting larger concentrations of disabled populations. Parts of El
Paso, Las Animas, Conejos, Montrose and Garfield Counties have the highest
concentration of population with disability by Census block.

26
DRAFT
Figure 7, Concentrations of Persons with Disabilities
The 2009 American Community Survey estimates that 638,654 people in Colorado
have a disability, or about 12.7 percent of the population age 5 and over. As many
as 84,545 people, or 1.9 percent of the population age 5 and over, have difficulty
performing self-care activities.
Table 3, Persons with Disabilities by Disability Type

SUBJECT Population # Population
Persons % with a
with a disability
Disability
STATE 5,024,748 638,654 12.7%
POPULATION
Sensory 240,925 4.79%
Mobility 232,907 4.64%
Cognitive 167,266 3.33%
Self-Care 84,545 1.68%
Leaving the 152,065 3.03%
Home
Work 257,504 5.12%
Disability
SOURCE: 2009 American Community Survey

27
DRAFT
Table 4, Distribution of Disabled Persons by Age Group in the 2000 Census

AGE GROUP % OF COLORADANS DISABLED
5 TO 17 Years Old 4%
18 to 64 Years Old 8%
65 Years Old and Older 35%
According to American Community Survey in 2009 there were 46,9761 persons in

Colorado receiving Supplemental Security Income (SSI) and 6,600 on Aid to the
Needy Disabled (AND)2. An analysis of housing data completed in November, 2010
by the Colorado Department of Human Services, Division of Supportive Housing and
Homeless Programs estimates that 44,197 of these SSI and AND recipients are
already housed in affordable units. This analysis finds there are still 9,379 persons
with disabilities who need affordable housing.
Another study, “Priced Out in 2008, Housing Crisis for People with Disabilities” found
that the percentage of Supplemental Security Income (SSI) needed to rent a one-
bedroom housing unit in Colorado in 2008 was 102%3.
Many of the homeless population are also disabled: the August 2006 Statewide
Homeless Count found that approximately one in five homeless survey respondents
reported mental illness (21.2%) and medical conditions (19.5%). Due to the
stigmatizing nature of these questions, it is likely that disabling conditions were
under-reported. Single persons (71%) and households without children (77%) were
most likely to have at least one of five disabling conditions.
Persons Living With HIV/AIDS
Acquired Immune Deficiency Syndrome (AIDS) is caused by the Human

Immunodeficiency Virus (HIV) which attacks the immune system’s ability to fight
infections. According to the Colorado Department of Public Health and Environment,
there were 4,816 persons with living with AIDS and 6,208 living with HIV in Colorado
as of September 30, 2010.
Persons with HIV/AIDS are living longer, healthier lives due to research and
treatment advances. The Colorado AIDS Project and its affiliated agencies across the
state provide a range of housing and supportive services to persons living with
HIV/AIDS. Affordable housing is a crucial element in helping clients and their families
achieve meaningful, productive lives. However the number of housing vouchers does
not meet the needs of the population. In addition, medical and supportive services
are not readily available outside of the Denver metro area and either the client or the
agency often must travel a considerable distance for services to be delivered.
Lingering fear of HIV/AIDS contagion limits the rental housing available to this
population, and requires maintaining the utmost level of confidentiality.
1
The United States Census Bureau, American Community Survey, 2009
2
State of Colorado Joint Budget Committee Briefing, November, 2010
3
Technical Assistance Collaborative, Inc; Consortium for Citizens with Disabilities, Housing Task Force

28
DRAFT
Serious Mental Illness
Based on the 2000 Census, the Colorado Department of Human Services, Division of
Mental Health estimates that as many as 168,878 adults and children in Colorado
may have a serious emotional disability (SED) or serious mental illness (SMI)4
In 2001, the TriWEST Group performed a study for the Colorado Department of
Human Services (CDHS) along with an analysis of mental health systems. They
concluded that 571 additional Section 8 slots were needed 41 HUD Supportive
Housing slots were needed, 49 Single Room Occupancy Modified Rehab slots, 23
homeownership slots and 133 other housing slots were needed. This represents a
total of 817 beds5.
Disabled Senior Citizens
As Colorado’s “baby boom” population ages (those born between the years 1946-
1964), the need for age-appropriate housing and services that allow aging in place
will increase dramatically. Areas with the highest projected increase in the population
in the over-65 age group include areas of the I-70 corridor and central mountains, as
well as Douglas, Elbert La Plata, San Juan and San Miguel Counties. Lincoln and
Prowers counties will experience a slight decrease in the population age 65 years and
older during the period.
Larger numbers of frail elderly will require new strategies to ensure that seniors are
able to age in place. A 2007 study conducted for the Colorado Division of Housing by
Community Strategies Institute estimated that 5,111 senior households are rent
burdened.
Rehabilitation of units is an important strategy to help meet the housing needs of
seniors. While there are many owner-occupied housing rehab programs, there are
few housing rehab programs for senior or disabled clients who rent units in need
improvements that allow aging in place.
According to the Colorado Department of Health and Environment, there are three
types of assisted living residences in Colorado: private pay, alternative care facilities
(assisted living residences that are Medicaid certified) and residential treatment
facilities for persons with severe and persistent mental illness. There are about 518
assisted living residences in Colorado (11/04). Any assisted living residence caring
for 3 or more residents must be licensed. The 2004-2007 State Plan on Aging
forecasts a significant growth of Assisted Living Facilities, but a very limited number
of Assisted Living that will accept Medicaid payments.
The 2007-2011 State Plan on Aging forecasts That the number of seniors 85 years
and older will increase from over 56,000 in 2008 to almost 63,000 in 2011. This
population often has fewer resources and more needs for supportive housing.
4
n. d. “Population in Need of Mental Health Services and Public Agencies Service Use in Colorado”
retrieved on August 29, 2007 from www.cdhs.state.co.us/dmh/de_pin_estimates_of_need.htm
5
An Assessment of Community Mental Health Resources)

29
DRAFT
Developmentally Disabled Individuals
According to Dr. David Braddock, Ph.D., Executive Director of the Coleman Institute
for Cognitive Disabilities at the University of Colorado, in testimony to the Colorado
Senate House Interim Committee on Developmental Disabilities (DD) on July 18,
2007, “An estimated 9,000 families in Colorado aged 60+ care for family members
with DD and over 3,000 persons with ID/DD are on [housing] waiting lists.”
The U.S. Government Accountability Office (GAO) issued a report to Congress
entitled "Public Housing - Distressed Conditions in Developments for the Elderly and
Persons with Disabilities and Strategies Used for Improvement." (GAO-06-163,
12/05) in which they found 64 out of 76 housing projects included in their national
study had fewer than five percent of the units that met the accessibility standards for
persons with mobility disabilities.
David Bolin, Executive Director of Center for People with Disabilities (CPWD), reports
that there are a significant number of persons with developmental disabilities that
want to leave nursing homes who are unable to do so without supportive funding for
housing and services.
Religious Groups
The U.S. Census does not collect information on religious affiliation in the decennial
census, making authoritative information difficult to find. However, the Association
of Statisticians of American Religious Bodies (ASARB) collected data on 149 religious
groups, mostly Christian, with estimates of the number of non-Christian adherents
and makes information for the year 2000 available online at www.theARDA.com.
According to their posted data, there were 753, 398 members of protestant Christian
denomination in Colorado 752, 505 Catholic Christians, and 6,196 Orthodox
Christians. They estimate that 2,604,002 people were not affiliated with any
religion. Their estimated Jewish population for Colorado was 72,000 and the
estimated number of Muslims was 14,855. Seventy-two Buddhist congregations and
7 Hindu congregations are reported, but there is no estimate of the number of their
adherents.
Although very few Fair Housing complaints have been filed on the basis of religion,
the Division of Housing is concerned that this will be a growing problem, especially
with Muslim populations, in the near future.
The number of Muslims in Colorado is being studied, but at this time only estimates
exist.
The following maps from ASARB show the relative density of religious groups by
county in Colorado in 2000. Note that the same color does not represent the same
level of adherence across all maps.
Protestant Christians were most heavily represented in the counties on the eastern
border of the state, while Catholics were most prevalent in the south-central portion.
Muslims are concentrated in the most metropolitan/urban areas. Although there are
clearly areas of concentration of Jewish people, a specific pattern is not apparent.

30
DRAFT
Christian Denominations
Protestant Christians – Evangelical Denominations
Key Number of Adherents per 1000 population

147 to 309 44 to 74
115 to 146 0 to 42
83 to 114
Protestant Christians - Mainline Denominations
Key Number of Adherents per 1000:

89 to 223 36-55
70 to 86 5-36
56 to 69

31
DRAFT
Catholic Population – Rates of Adherence, 2000
Key Number of Adherents per 1000

250 to 853 76 to 112
163 to 242 0 to 60
115 to 161
Figure 8, Rates of Catholic Adherence, 2000
Non-Christian Religions
Jewish Population – Rates of Adherence, 2000

Figure 9, Estimated Rate of Jewish Adherents per 1000 population
Key Values:
13 to 69
2 to 12
0 to 0

32
DRAFT
More recent information on the Jewish population is available in the 2007 Metro
Denver/Boulder Jewish Community Study conducted by Ukeles Associaties, Inc.
According to that study, the Jewish population of the Denver/Boulder area had
increased 33% since the previous study in 1997, totaling 83,900 in the seven-county
study area, and making it the 16th largest Jewish community in the US.
Muslim Population – Rates of Adherence, 2000

Figure 10, Estimated Rate of Muslim Adherents by County as of
Key Number per 1000

1 to 14
0 to 0
Information on the number of Muslims in Colorado’s population consists entirely of
estimates. The total number is estimated to be 14,000 to 15,000.
Religious Congregations and Membership in the United States, 2000. Collected by the Association of
Statisticians of American Religious Bodies (ASARB) and distributed by the Association of Religion Data
Archives (www.theARDA.com).

33
DRAFT
Colorado Households
Colorado’s overall number of households was 1,869,276 according to the 2005-2009
5-year American Community Survey estimate, an increase of 12.7% percent since
2000. Female-headed households increased by 13.9 percent, male-headed
households increased by 22.9 percent and non-family households increased 16.1
percent for the same time period (U.S. Census Bureau, 2006-2008 American Community
Survey [ACS] 3-Year Estimates, Colorado Selected Social Characteristics).
Table 5, Household Characteristics, State of Colorado 2000 and 2008

Number of
Households
%
Household Type 2000 2009 Difference Change
Family Households
Married couple families 858,671 946,419 87,748 10.2%
Female-headed
households 158,979 178,503 19,524 12.3%
Male-headed households 66,811 78,663 11,852 17.7%
Subtotal 1,084,461 1,203,585 119,124 11.0%
Non-family Households 573,777 665,691 91,914 16.0%

Subtotal 573,777 665,691 91,914 16.0%
Total 1,658,238 1,869,276 211,038 12.7%
Source: 2008 American Community Survey, Colorado Selected Social Characteristics
Household Characteristics by Race
Table 6, Household Type by Race or Ethnicity, 2007-2009 American Community

Survey
Number or Percentage of Households

Non-
Hispanic
Household Type White Hispanic Black AIAN Asian
Family Households 1,461,305 276,970 69,403 17,473 42,688
As % of All Households 62.6% 73.9% 59.9% 64.4% 67.0%
Married couple families 51.6% 49.0% 31.9% 37.2% 54.3%
With children under 18 20.8% 29.4% 15.2% 18.9% 30.9%
Female-headed
households 7.6% 16.6% 22.1% 19.7% 8.7%
With children under 18 4.4% 11.8% 15.5% 14.6% 5.3%
Non-family Households 37.4% 26.1% 40.1% 35.6% 33.0%
Note: No data were available for Native Hawaiian/Pacific Islander group.

34
DRAFT
Other Household Facts from 2005-2009 American Community Survey:

• Of the 156,089 single-parent households in Colorado, 72.9 percent were
female-headed
• Grandparents were responsible for grandchildren in 35,392 households
• 623,912 households contained one or more people under 18 years
• 347,649 households held one or more people 65 years or older; 137,529
people over 65 lived alone.
Female-Headed Households
According to the 2005-2009 American Community Survey, there were 127,912

female-headed families with children under 18. The median income for these
families is $32,807, just 41% of the median income for two-parent families
($80,201.) This income puts female-headed families at a disadvantage in finding
affordable housing, since 30% of their monthly median income is $820, whitle the
average statewide rent in as of the 3rd quarter of 2010 was $871.785.
Female-headed households with children make up a significantly greater proportion
of Black, Hispanic and American Indian/Alaska Native households than White or
Asian households. Family income for female-headed households in these groups is
below $30,000 per year. In this income range, Colorado has only half the number of
affordable housing units that are needed.
Table 7, Female-Headed Households by Race and Ethnicity
Race/Ethnicity Percent Median Family Income
of
Families
Black 15.5% $27,258
AIAN 14.6% $23,942
Asian 5.3% $39,619
Hispanic 11.8% $21,782
White, non-Hispanic 4.4% $40,453
2005-2009 American Community Survey, Female-Headed Households with own children under 18
New Household Formation

By 2015, Colorado’s population aged 25 to 34 years old will increase by more than
14 percent over 2010, pushing housing demand higher through the formation of new
households (DOLA, 2008). 2009 estimates show 699,987 persons in this age group,
most of whom will choose a life partner and establish a new residence. This trend will
likely spur a need for starter homes and apartments.
5
Colorado Multi-Family Housing Vacancy and Rental Survey, Third Quarter 2010, conducted by Gordon
E. von Stroh, published by Colorado Division of Housing/Apartment Realty Advisors/
Pierce-Eislen

35
DRAFT
Income Data
Median Income
The 2005-2009 American Community Survey estimates Colorado Median household
income as $56,222. Median income, however, varies greatly by race as well as by
geographic area within the state.
Racial And Ethnic Differences In Median Income
Table 8, 2005-2009 Colorado Median Incomes by Race and Ethnicity

Race or Ethnicity Median Household Median Family Income
Income
All Races/Ethnicities $56,222 $69,591
Alaska Native/American Indian $40,675 $48,685
Asian $60,996 $70,708
Black/African American $33,354 $46,440
Native Hawaiian or Pacific $52,675 $58,102
Islander
Hispanic or Latino $38,166 $40,575
White, not Hispanic $61,771 $78,296
Source: 2005-2009 American Community Survey
As this table shows, African Americans, Hispanics, Native Americans and Native
Hawaiians have median incomes lower than both the overall median and that of
Asians and non-Hispanic Whites. Compared to non-Hispanic whites, Hispanics have
a median household income only 61.8% as high. Black households fare even worse
at 54%. This economic inequality manifests itself in lack of equal housing
opportunity at all levels, from the ability to purchase a single family home to a higher
chance of homelessness.
Gender Differences In Median Income
According to the American Community Survey 2005-2009, the median income for
women aged 16 and over who have wages is 68.8% of the median income for men.
Table 9, 2005-2009 Colorado Median Income by Gender
Subject Total Margin Male Margin Female Margin
of Error of Error of
Error
Population 16 years 2,831,386 ±5,793 1,538,680 ±3,545 1,292,706 ±4,036
and over with
earnings
Median Earnings 30,544 ±144 36,250 ±243 24,953 ±195
(Dollars)
2005-2009 American Community Survey, Income for Population 16 Years and Over with Earnings, by
Gender
Even taking educational attainment into consideration, women consistently have

lower median income than men. In fact, the wage gap gets wider with more
education beyond the high school level.

36
DRAFT
Table 10, Gender Differences in Median Earnings by Educational Level
Subject Total Margin Male Margin Female Margin
of of of Error
Error Error
Population 25 years and 36,201 ±165 42,703 ±268 29,782 ±216
over with earnings
Less than high school 20,276 ±308 23,158 ±448 14,621 ±431
graduate
High school graduate 28,928 ±316 33,923 ±467 23,259 ±422
(includes equivalency)
Some college or 34,169 ±242 41,303 ±342 27,724 ±331
associate's degree
Bachelor's degree 46,261 ±407 57,789 ±850 37,146 ±395
Graduate or professional 59,707 ±743 75,912 ±1,071 47,487 ±660
degree
2005-2009 American Community Survey, Income for Population 25 Years and Over with Earnings, by
Gender
Income Distribution
By Race and Ethnicity
A review of the American Community Survey data for household income by race and
ethnicity indicates a higher percentage of Black and Hispanic households at incomes
below $35,000, while higher percentages of non-Hispanic White households have
incomes greater than $75,000 per year. This disparity results in a lack of housing
opportunity for these two groups because of the inadequate number of homes
affordable for households at the lower income ranges.
Household Income Distribution by Race/Ethnicity
16.0%
14.0%
12.0%
10.0%
8.0%
6.0%
4.0%
2.0%
0.0%
5, -$1 0
e
,0 1 4 9
00 $1 99
or 99
0, -$1 9
5, -$2 9
0, -$2 9
5, -$3 9
0, -$3 9
5, -$4 99
0, -$4 99
0, -$5 9
$1 5,00 74 9
$1 00 9 9 9
$1 00 24 9
$ 1 0 0 ,0 0
$ 2 0 ,9 9
$ 2 0 0 ,9 9
$ 3 0 ,9 9
$ 3 0 0 ,9 9
$ 4 0 0 ,9 9
$ 6 0 0 ,9 9
$ 7 0 ,9 9
00 0- ,99
25 0-$ ,99
or
50 0-$ ,99
$ 4 0 0 9 ,9
$ 5 0 ,9
$2 00- 9,9
00 ,9
Black Households
m
0
,0 9 9
00 4
9
00 4
00 4
9
00 9
0, $1
1
-$
White Households
$1 an
th
0
ss
Hispanic Households
Le
Figure 11
The source for the chart in Figure 1 is 2005-2009 American Community Survey, Tables B19001B,
B19001H, B19001I. The total number of households by race or ethnic group in this set of estimates is
68,737 Black; 271,975 Hispanic; and 1,450,784 non-Hispanic White. There were not enough households
in other racial categories to display meaningful information.

37
DRAFT
Income Distribution By Gender
Table 11, Percentage of Workers at Each Income Level By Gender

Income Range Male Margin Female Margin
of Error of Error
Full-time, year-round
workers with earnings 991,069 ±4,710 654,595 ±3,833
$1 to $9,999 or loss 1.90% ±0.1 2.70% ±0.1

$10,000 to $14,999 4.10% ±0.2 5.40% ±0.2
$15,000 to $24,999 11.30% ±0.3 16.00% ±0.4
$25,000 to $34,999 14.70% ±0.3 20.90% ±0.3
$35,000 to $49,999 20.40% ±0.2 23.70% ±0.4
$50,000 to $64,999 15.10% ±0.2 13.90% ±0.2
$65,000 to $74,999 7.10% ±0.2 5.60% ±0.2
$75,000 to $99,999 11.10% ±0.2 6.40% ±0.2
Source: 2005-2009 American Community Survey
Up to $50,000 in income, the percentage of women at each income range is greater
than the percentage of men; at and above $50,000 the situation is reversed and a
smaller percentage of women than men have earnings at that level. A graph of this
table helps to visualize it.
Percentage of Men and Women at Each Income Range
23.70%
25.00% 20.90% 20.40%
20.00% 16.00% 15.10%
14.70% 13.90%
15.00% 11.30% 11.10% Men
10.00% 7.10%
6.40%
Women
5.40% 5.60%
2.70% 4.10%
5.00% 1.90%
0.00%
9
9
ss
99
99
99
99
99
99
99
lo
4,
4,
4,
9,
4,
4,
9,
or
$1
$2
$3
$4
$6
$7
$9
99
to
to
to
to
to
to
to
,9
0
$9
00
00
00
00
00
00
00
to
0,
5,
5,
5,
0,
5,
5,
$1
$1
$2
$3
$5
$6
$7
$1
The result of this income distribution is that more women than men are limited in
their housing choices because of the lack of housing affordable to people with lower
incomes – 45% of women earn less than the $40,000 level at which the ratio of
affordable rental units to households is less than 1:1. The greater number of women
than men in the lower income ranges also accounts for the fact that female single-
parent families are far more likely to live below the poverty line than families headed
by males.

38
DRAFT
Employment Data
Shown below are unemployment rates from 1996-2010 from the Colorado
Department of Labor and Employment. Unemployment rates surged after 9/11 then
showed a steady recovery until the “Great Recession” of 2008.
Table 12 Labor Force Statistics

Labor Force Statistics for Colorado – Annual Averages 1996-2010
Unemployment
Year Labor Force Employment Unemployment Rate
1996 2,093,184 2,004,741 88,443 4.20
1997 2,150,160 2,080,012 70,148 3.30
1998 2,241,839 2,155,740 86,099 3.85
1999 2,264,105 2,198,147 65,958 2.90
2000 2,364,900 2,300,192 64,798 2.70
2001 2,395,264 2,303,494 91,770 3.80
2002 2,431,203 2,293,229 137,974 5.70
2003 2,463,161 2,311,998 151,163 6.10
2004 2,510,392 2,370,803 139,589 5.60
2005 2,547,895 2,419,241 128,654 5.00
2006 2,653,333 2,537,289 116,044 4.40
2007 2,695,834 2,591,404 104,430 3.90
2008 2,727,616 2,595,252 132,364 4.90
2009 2,701,026 2,492,540 208,486 7.70
Source: Colorado Department of Labor and Employment
Persons who are unemployed may receive services, apply for unemployment benefits
and/or conduct a job search at local workforce center (see map).
Map 8

39
DRAFT
Colorado’s November 2010 overall unemployment rate was 8.6%. However, as the
table below demonstrates, unemployment rates vary by race and ethnicity. Blacks,
Hispanics and Native Americans had rates of unemployment approximately twice as
high as non-Hispanic Whites between 2005 and 2009.
Table 13, Unemployment Rate by Race and Ethnicity 2005-2009

RACE AND Population 16 Margin Of Unemployment Margin of
HISPANIC OR years & older Error (±) rate Error (±)
LATINO ORIGIN
White 3,225,457 4,782 5.6% 0.1
Black or African 138,844 1,518 11.3% 0.8
American
American Indian 36,010 1,454 12.3% 1.5
and Alaska Native
Asian 99,062 991 5.4% 0.6
Native Hawaiian 3,908 439 10.9% 4.6
and Other Pacific
Islander
Hispanic or Latino 643,276 867 8.7% 0.3
origin (any race)
White alone, not 2,817,998 1,434 5.3% 0.1
Hispanic or Latino
Colorado State Demography Office from S2301: Employment Status, Data Set: 2005-2009 American
Community Survey 5-Year Estimates Survey: American Community Survey Geographic Area: Colorado
Housing Profile
Overview
Colorado’s more than 1.8 million households include nearly 600,000 renter
households. While almost 70 percent of Colorado households are owner occupants,
rental housing continues to be an important source of shelter for households at all
income levels in Colorado.
Homeownership and rental rates vary by race and ethnicity in Colorado. As the
tables below indicate, White non-Hispanic households are far more likely to own the
homes they live in than are Hispanics and members of other racial groups.
Table 14, Colorado Homeowner and Renter Households By Race and Ethnicity
Race or Ethnicity Homeowner Renter Total
Households Households Households
Total Population 1,274,736 594,540 1,869,276
Alaska Native/American
Indian 8,017 9,029 17,046
Asian 26,616 15,200 41,816
Black/African American 29,818 38,919 68,737
Native Hawaiian or Pacific 901 746 1,647
Islander
Hispanic or Latino 140,306 131,669 271,975
White, not Hispanic 1,058,660 392,124 1,450,784

40
DRAFT
INSERT : Homeownership Rate Changes over time
Housing costs affordable at the different median income levels:

Alaska Native/American Indian Households can afford a total housing cost of $1,017
per month; Black/African American households can afford only $834/month; Native
Hawaiian/Pacific Islander households $1,317; and Hispanic or Latino households
$954. At the same time, both Asian and Non-Hispanic White households can afford
monthly housing costs greater than $1,500.
Lower incomes mean that the short supply of affordable housing has a greater
impact on these racial and ethnic groups than on Whites and Asians.
Table 15, Colorado Median Incomes by MSA

MSA Median Household Income Median Family Income
Boulder $65,040 $88,082
Colorado Springs $56,576 $68,964
Denver-Aurora $59,932 $74,441
Fort Collins/Loveland $54,755 $73,006
Grand Junction $50,611 $61,200
Greeley $55,795 $64,259
Pueblo $40,805 $50,298
In addition, homeowner households have a median income roughly twice that of
renters. As of January 1, 2009, the Center for Business and Economic Forecasting
found that median owner income in Colorado was $72,905, while the median renter
income was $36,310.
These factors combine to create a situation in which Blacks and Hispanics have less
opportunity to purchase homes, and so comprise a disproportionate share of renters.
Table 16, Percentage of Colorado Homeowner and Renter Households by

Race and Ethnicity
Race or Ethnicity Homeowner Renter Total
Households Households Households
Total Population 68.2% 31.8% 1,869,276
Alaska Native/American
Indian 47% 53% 17,046
Asian 63.7% 36.3% 41,816
Black/African American 43.4% 56.6% 68,737
Native Hawaiian or Pacific 54.7% 45.3% 1,647
Islander
Hispanic or Latino 51.6% 48.4% 271,975
White, not Hispanic 73% 27% 1,450,784
This disparity is at least partly a function of income. As we have see above (Table
2), all racial and ethnic groups have lower median incomes than non-Hispanic
Whites. Consequently, a greater percentage of them fall into the “low-income”
category.

41
DRAFT
Single parent households, disabled households and elderly people on social security
are also more likely to be forced into renting instead of homeownership by virtue of
their lower incomes.
Among low-income households, rental housing is often the only option, and rental
housing continues to be essential to the housing stock for households at the lowest
income levels.
The mismatch tables below provide information on the number of rental units
available in Colorado to households at different income levels. The tables provide
mismatch ratios that show the number of households for each unit available at a
given income level.
The rent burden tables show three levels of rent burden and show the total number
of rent burdened households and the percentage of all rental households that are
rent burdened in 25 counties.
Rental Mismatch Findings

The housing mismatch describes the difference between the number of households at
a certain income level, and the number of units affordable to households at that
level.
The mismatch in Colorado is largest at the lowest income levels. Statewide, there are
1.9 households for every unit affordable to households earning less than $10,000 per
year. There are 2.3 households for every unit affordable to households earning
between $10,000 and $15,000 per year.
Table 17, Colorado Statewide Rental Housing Mismatch Table, 2009
Affordable Number of Number of

monthly households units
payment in $; Number of per unit available per Household
based on renter affordable 100 Household income as
housing households Number of housing at this households income as % of % of state
Income expense as at this income units at this rent income at this state AMI RMI
level in $ 30% of income level or below level or below level income level ($55,276) ($32,611)
10,000 250 83,384 44,401 1.9 53 18% 31%
15,000 375 140,530 60,173 2.3 43 27% 46%
20,000 499 190,877 94,224 2.0 49 36% 61%
25,000 624 247,849 166,774 1.5 67 45% 77%
30,000 750 296,781 254,078 1.2 86 54% 92%
35,000 875 344,543 327,290 1.1 95 63% 107%
40,000 999 388,202 397,146 1.0 102 72% 123%
45,000 1125 427,270 441,666 1.0 103 81% 138%
50,000 1250 458,089 441,666 1.0 96 90% 153%
60,000 1500 508,256 490,670 1.0 97 109% 184%
75,000 1875 561,011 524,670 1.1 94 136% 230%
100,000 2499 604,399 563,836 1.1 93 181% 307%
In general, there is approximately one affordable unit for every household earning
$35,000 or more, an adequate supply.

42
DRAFT
In other words, households that earn approximately 60 percent of area median
income or more will generally be able to find a rental unit that is affordable to that
household. However, for households earning 45 percent of area median income or
less, rental housing is much more difficult to find. For households earning incomes
below 30 percent of area median income, there are generally two households for
every affordable unit.
While only 26.7% of all White, non-Hispanic households have an annual income less
than $35,000, 47.5% of Black Households, 45.9% of Hispanic households and 43.6%
of Native American households fall below this benchmark. This makes it far more
difficult for them to find housing that is affordable at 30% of their household income.
Findings varied from region to region. In the metro Denver area, there were at least
2.4 households for every unit affordable to households making less than $20,000 per
year. But in Pueblo, the only income group with a mismatch ratio above 2.0 was
households making less than $10,000, which showed a mismatch of 2.1.
In the Mesa County/Garfield County region, there were 1.7 households for every unit
affordable to households making less than $10,000, although there were 2.2
households for every affordable unit for households earning between $15,000 and
$20,000.
The areas showing the largest mismatches were El Paso County and the Larimer
County/Weld County area. In both regions, there were at least 2.9 households for
every unit affordable to households making $15,000 or less.
Rent Burden
Rent burdened households are households that pay more than 30 percent of income
on housing. This report shows data on households paying 30 percent, 35 percent,
and 50 percent of income toward housing.
Overall, the counties that showed the largest rent burdens at all levels were Teller,
Eagle, Pueblo, Fremont, Boulder and Larimer Counties. These counties were among
the counties with the highest rent burdens in all three categories.
At the 50 percent rent burden level, Teller County topped the list with 35.5 percent
of renter households paying more than 50 percent toward housing. Eagle County and
Pueblo County both showed a rate of slightly below 31 percent.
At the 35 percent rent burden level, Teller County showed 46.6 percent of renter
households paying 35 percent or more of income toward housing. Fremont County
showed 47 percent while Eagle County and Pueblo County both showed 45 percent.
At the 30 percent rent burden level, Fremont County topped the list with 63.8
percent of renter households paying 30 percent or more of income toward housing,
while Teller, Pueblo and Boulder Counties all showed rent burden rates at 53 percent.
Rent Burdened Households By Race and Ethnicity

Gross rent as a percentage of household income varies by race and ethnicity. The
data below, derived from the 2007-2009 American Community Survey 3-year
Estimates for Colorado indicate that the majority of Black, Hispanic and American
Indian households that rent pay more than 30% of their income for housing.

43
DRAFT
Gross Rent as Percentage of Household Income

by Race
Percent of Racial Group

80
60
<30%
40
>30%
20
0
Black Hispanic AIAN White NH Asian
<30% 40.6 42.5 45.5 52.0 56.3
>30% 59.4 57.5 54.5 48.0 43.7
Race or Ethnicity
Meanwhile, a small majority of Non-Hispanic White and Asian households pay less
than 50% of their incomes for rent.
When looking at homeowners cost burden by race and ethnic group, the pattern is
less pronounced. Small percentages of homeowners overall are cost burdened, but
larger percentages of Black and Hispanic households pay more than 30% of their
income on housing.
Homeownership Cost as a Percentage of Household Income by

Race or Ethnicity
Percent of Racial or Ethnic Group
70
60
50
40
30
20
10
0
Hispanic Black Asian AIAN White NH
Not Cost Burdened 50.7 52.4 58.7 60.9 65.2
<30%
Cost Burdened >30% 49.3 47.6 41.3 39.1 34.8
Race or Ethnicity

44
DRAFT
Other Relevant Data
Stakeholder survey results

A survey designed to identify impediments to fair housing choice in Colorado was
provided to housing providers, advocates and government agencies in November
2010. The purpose of the survey was to gain a more qualitative analysis of the
knowledge, experiences, opinions and feelings of stakeholders and other interested
parties regarding fair housing in Colorado. A total of 119 responses were received.
Sixty percent of respondents noted that there were significant impediments/barriers

to fair housing in Colorado. (See Graph #1.)
Graph #1
Do you believe that significant impediments/barriers to fair housing
exist in Colorado?
40%
Yes
No
60%
Graph #2 details the specific impediments to fair housing choice identified by

respondents. 73% of respondents identified the lack of affordable housing as a
major impediment to fair housing choice in Colorado. In addition, 36% of
respondents identified the lack of accessible housing as a cause. Almost 60% of
respondents noted that unemployment or under-employment was a contributing
factor to fair housing issues. Other significant identified factors included:
• Lack of education about rights and responsibilities in fair housing (35.4% of

respondents)
• Language and cultural issues (31.9% of respondents)
• Racial bias (19.5% of respondents)

45
46
Employment issues- low
wages/unemployment/lack
of job training opportunities
Inadequate enforcement of
What do you believe to be the main cause, or causes, of impediments to
fair housing choice? select all that apply, but please focus on the main
existing laws
Fear and
misunderstanding of those
with disabilities
Racial Bias
Age Discrimination

Local regulations
DRAFT
Graph #2
causes.
Language/cultural issues
Actions of Homeowner
Associations
Lack of education about
fair housing rights and
responsibilities
Lending
practices/foreclosures
Lack of accessible housing
80.0% Lack of affordable housing
70.0%
60.0%
50.0%
40.0%
30.0%
20.0%
10.0%
0.0%
DRAFT
Graph #3 indicates that slightly more than 32% of respondents indicated that they
themselves, or someone whom they know, were restricted from free and equal
access to housing in Colorado.
Graph #3
Are you aware of any situation involving yourself and/or someone you
know that appeared to restrict the free and equal access to residential
housing in Colorado?
32.2%
Yes
No
68.6%
• Graph #4 details the identified barriers to fair housing as reported by the

respondents.
• Disability (56.8% of respondents)
• Race (21.6% of respondents)
• Familial Status (18.9% of respondents)
• National Origin (18.9% of respondents)

47
DRAFT
Graph #4
What basis do you believe that free and equal access to housing was
restricted?
60.0%
50.0%
40.0%
30.0%
20.0%
10.0%
0.0%
Race Color Religion Gender Disability Familial National
Status Origin
The majority of respondents (80.3%) stated that they knew where to go for
assistance with fair housing issues. (See graph #5.)
Graph #5
Are you aware of where to go to get assistance with fair
housing questions or concerns in Colorado?
19.7%
Yes
No
80.3%
Graph #6 indicates that over 60% of respondents feel that there is not enough
outreach and education on fair housing issues in Colorado.

48
DRAFT
Graph #6
Is there sufficient outreach and education regarding affirmatively
furthering fair housing in Colorado?
0.0%
40.5%
Too Little
Right Amount
Too Much
59.5%
The respondents were asked to comment on additional issues that impact fair
housing in Colorado. The largest number of comments concerned the need for
education and outreach for all parties involved in fair housing including housing
providers, advocates and consumers. There were also a significant number of
comments relating to the need for more affordable housing resources for persons
with special needs, enforcement of current housing laws, and advocacy on behalf of
persons in need of fair housing protection. Responses received are listed below.
• These concerns expressed apply to low-income families too, especially single

parent families with the mother as the head of household.
• More needs to be done to expand affordable housing to low-income

individuals. The current poor economy is placing a huge responsibility on
providers of affordable housing due to limited supply and high demand.
• I believe each city/county/municipality is unique. I feel that collaboration and

coordination between state and local governments could help to reduce
barriers. I feel that there should be greater leadership in building inclusive
communities free from discrimination.
• One of the concerns in our area is managers who are notoriously unfair and
invasive of tenants rights.
• An example of breaching Fair Housing: It is not uncommon to see For Rent

ads in our local newspaper that state "No Children, No Pets". This type of
practice is infuriating and it appears no agency has taken initiative to stop it.
• I believe there is not enough information provided to private landlords in
terms of education on temporary modifications (ramps, etc.) allowed by law
for individuals with disabilities.

49
DRAFT
• We need to paint a picture about what a barrier or impediment looks like e.g.
requiring only Latino applications to provide proof or residency or request
from a disabled individual to prove that can live alone or can go up 2 flights
of stairs. There needs to be some sort of Fair Housing education requirement
for rental properties and it should be for all staff that have contact with
applicants & tenants. It is vague as to how a family can determine the size of
unit they need compared to what property mangers/owners determine for the
family.
• Educating the housing people both private and public.
• Many apartments are not wheelchair accessible; do not have roll-in showers.
• I realize that the economics of funding an organization such as the former

Denver CHRB are not available at this point, but perhaps if funding were
available for additional fair housing educational resources for existing housing
organizations, then non-profit organizations could either access those funds
or organizations who can provide advocacy staff to educate the public.
Realtors are also in need of educational opportunities/resources. Perhaps the
local Boards of Realty would be better advocates if these resources were also
available to them.
• Units that are built for accessibility (WC accessible) are often times not rented
to residents who require this type of housing. The required number of units
often times exceed the applicants on our list requiring these units.
• Web resources exist, but because of language or other barriers, they are not
always accessed by the relevant populations.
• Lack of timely payment with Sec 8 subsidies to new landlords and landlords
that have new Sec 8 tenants from DOH - has angered several landlords who
have refused to rent to another sec 8 tenant.
• One of the huge issues I see around Fair Housing law is that there is that
landlords and others get away with violating people's rights because there is
not adequate enforcement of the law. Also, it is very very difficult to find
attorneys that will take disability rights cases.
• Agencies that claim to help individuals with Fair Housing issues need to do
more. When talking with individuals that have faced fair housing
discrimination, they said they were just "blown off" when they faced issues. I
actually have heard it with my own ears.
• Increased awareness and outreach, particularly to outlying communities in

Colorado would be very helpful.
• Become more involved when discrimination is suspected.
• I think it's the landlords who need further education and outreach.

50
DRAFT
• We desperately need housing for people with mental health issues, severe
mental illness, people with dual diagnosis, and felons.
• The only impediment I see as a major issue is the paper process by which we
all have to adhere (including the corporately run apartment communities) and
the lack of education for landlords and corporate companies alike prohibiting
patients from having the best opportunities to find appropriate housing.
• Lack of accessible housing prevents many people equal enjoyment and access
to housing in their community.
• More outreach to landlords that have properties available for rent but that
might be able to make them accessible to help the physically disabled find
affordable and accessible housing.
• Maybe our community is not the right one to ask? I know that there are a
number of issues that can happen in some place as big as Denver that may
never come up out here - 2 very different ways of life! Smaller, farm-type,
communities seem to pull together and help each other better than large
over-populated ones...i think we have that "decent human being" spirit! Its
just the right thing to do - we were all put on this earth for 1 reason - to be
good to and help each other as much as we can! Do onto others as you
would have done onto you - a great phrase that truly exists in our
community!
• Bumping into housing barriers is an issue I've never faced, so I'm not sure
how valid my responses are to your questions. We tend to be more aware of
circumstances and situations that directly affect or have affected us in the
past.
• I manufacture remote living quarters for the oil and gas industry for living
accommodations at locations. Not a builder of houses in cities.
• Colorado in general and Denver in particular - as a major city lacks the

organizational strength, diversity and accessibility for the affected population
to take full advantage of existing laws.
• Tenants often cannot communicate their issues. Landlords can take

advantage of situations for a variety of reasons. Advocacy groups are not
always well informed.
• As I understand it, banks have received federal assistance to help address

foreclosure problems that their customers are facing. However, because
there is mortgage insurance that will make the bank whole, there is no
reason for the bank to work with the family that is losing their home. If my
understanding is correct, the homeowners I know who lost their homes
through foreclosure wonder why they were dragged through the process of
trying to save their homes when the banks had no motivation to make the
program work. It was a useless and frustrating process for them.
• Need more workshops/trainings on fair housing issues in southwest Colorado.

51
DRAFT
• Round tables of people who have been burdened by the lack of affordable
housing.
• There is too much emphasis on reporting and paperwork burdens that are
placed on local governments as a result of over reaching, overlapping, and at
times conflicted Federal regulations that do not assist those who may need
help regarding impediments or barriers to fair housing choice and indeed lead
to a waste of public resources. These misdirected, inefficient and wasteful
regulations should be eliminated or substantially reduced and simplified and
attention placed on having personnel at the Federal level reassigned to
directly working with persons and households one on one as needed as and if
they encounter barriers to fair housing choice aside from the economic
impediments mentioned previously.
• Too many workshops focus on Fair Housing in terms of rental discrimination.

More opportunities to learn in the context of home ownership would be
appreciated.
• On the front range the issue is affordability. Other issues such as race or
disability are minor or non-existent in comparison. We need more money for
transitional housing and special needs populations. We need to continue and
increase the availability of housing tax credits for development of affordable
housing projects.
• There has been a great deal of progress in Colorado in the last 30 years. It
always is an educational issue for not only the protected groups but for the
general public. Any additional outreach and public information on the topic
helps. Clarification of what constitutes rights especially for the disabled
population would help.
• Ask Realtors about their experiences...
General Public Survey Results

The Department of Local Affairs/Division of Housing and the Department of Human
Services/Supportive Housing and Homeless Programs also posted a Fair Housing
Survey for the general public on our web sites. This survey received only 12
responses, and only 9 completed surveys, not enough for statistically valid results.
However, the 12 who started the survey represented 11 different zip codes from
various parts of the state. Two thirds (6) responded that they had not experienced
any housing discrimination, while one third had.
Of those 3, all said they had been discriminated against by a landlord or property
manager, 33.3% by a mortgage lender, and 66.7% by a government staff person.
None reported discrimination by a real estate agent. More than one response was
possible.
One third reported that the discrimination occurred at an apartment complex, and
two thirds reported that it occurred at a public or subsidized housing project.

52
DRAFT
They reported the basis for the discriminatory acts as 33.3% color, 66.76%
disability, and 100% Familial status. More than one response to this question was
possible.
None of those who experienced discrimination reported it. The reasons given were:
66.7%, not sure of rights; 33.3% didn’t know where to report; 33.3% were afraid of
retaliation and 100% didn’t think it would make any difference.
Two submitted the following written comments:
• “I can’t get a home for me and my son, we are homeless and stay either at a
hotel or a friends home , I feel like when I talk to someone about a home
they tell me I cant afford it because I get SSI, I can’t apply for housing with
the local housing here in Colorado Springs because they tell me they are not
taking applications. There is no place for us to live!”
• “Denied housing because I have a child, though the rental manager would not
say in so many words. Denied housing based on credit, mine is not bad but
not great. Denied housing based on income, it costs a fortune for decent
housing. Employers don't pay well enough. Self employment leaves a narrow
profit margin.”

53
DRAFT
III. Colorado’s Current Fair Housing Legal Status

HUD’s Office of Fair Housing and Equal Opportunity (FHEO) and the Colorado Civil
Rights Division (CCRD) are the two agencies that receive complaints regarding
housing discrimination in Colorado. Through a Freedom of Information Act request,
HUD provided Fair Housing Complaint information for the period from October 1,
2004 through September 17, 2010. This report did not include identifying
information about the complainant, making it impossible to determine how many
cases resulted from tests and how many were complaints by individuals.
Summary of Fair Housing Complaints or Compliance

reviews
Data provided by the FHEO showed that 1000 cases had been filed, of which 923 had
been closed. A case may include more than one basis and more than one issue, so
the number of cases, the number of complaints by basis and issue are not equal.
A finding of “No Cause” was made in 699 cases, more than 75% of the total. There
were three cases in which discrimination was found as a result of litigation.
The outcomes of all cases are summarized below:
Disposition of Complaint Number

Case Still Open 77
Dismissed for lack of jurisdiction 4
Unable to locate complainant 2
Complainant failed to cooperate 45
Complaint withdrawn by complainant
10
without resolution
Closed because trial has begun 1
Conciliation/Settlement successful 69
Complaint withdrawn by Complainant
76
after resolution
No Cause Determination 699
FHAP Judicial Consent order 12
Litigation ended – Discrimination Found 3
ALJ Consent Order entered after
2
issuance of charge
Total FHEO Complaints 1000
This table shows that 62 of the cases were closed without resolution, while 162 were
resolved.
The Colorado Civil Rights Division provided summary information for the period
January 1, 2006 through October 23, 2009. This data revealed that the CCRD had
closed 388 cases, finding probable cause in 25 of these cases.
Summary of the basis for FHEO reported complaints shows that 243 complaints were
on the basis of race, 60 on the basis of gender, 23 on the basis of color, 217 on
ethnicity (Hispanic/Non-Hispanic), 585 on the basis of disability, 26 based on
religion, and 83 on familial status. 12 complaints were filed on the basis of
harassment and another 95 for retaliation.

54
DRAFT
Fair Housing Complaints by Basis

Basis is the term the FHEO uses to describe the reason or characteristic that may
cause a person or persons to be the object of discrimination. These include the
“protected classes” – race, color, national origin, sex, religion, disability and familial
status. Basis also includes sexual harassment and retaliation.
Disability was the
basis for 585 2006-2010 Colorado Fair Housing
complaints filed. 408
of those were based Complaints by Basis
7%
on physical disability.
Most complaints cited 1%
Race
failure to make
6% 18% Gender
reasonable
accommodation for 2% 4% Color
physical disabilities. Ethnicity
2%
Other major bases of Disability
complaints were Race Religion
and National Origin. 16%
Familial Status
194 of 243 44%
complainants on the Harassment
basis of Race were Retaliation
Black/African
American, while 193 of 217 complaints based on National Origin came from
Hispanic/Latino complainants. Relatively small numbers of complaints were based
on gender, color, religion or familial status.
Complaints based on race
Of the 243
Breakdown of Fair Housing Complaints complaints of
housing
based on Race discrimination
based on race, the
vast majority of
3% 8% complainants , 194,
9%
were Black/African
White American. No other
Black racial group
AIAN exceeded 10% of
the total.
Asian
80%
Complaints based on Gender
34 complaints about discrimination based on gender were from women, 26 from

men. Another 12 complaints involved sexual harassment.

55
DRAFT
Complaints based on National Origin (Ethnicity)
Colorado Fair Housing Complaints by 217 complaints

Ethnicity were based on
ethnicity. Of
these, 193
complainants
11%
were Hispanic/
Latino.
Hispanic
Not Hisp
89%
Complaints based on Disability
Fair Housing complaints

Fair Housing Complaints based on based on disability were
Disability the largest category of
complaint, a total of 585 or
58.5% of the total. Most
of these, 408, had to do
with physical disabilities.
30% Of the issues that can most
Mental Disabilit readily be identified as
Physical Disability applicable to people with
70% disabilities, 205 of these
complaints contended a
failure to make reasonable
accommodation, while 19
were for failure to make a
reasonable modification. 2 complaints alleged non-compliance with design and
construction requirements for the handicapped; 1 cited failure to provide “accessible
and usable public and common user areas;” and another “failure to provide usable
kitchens and bathrooms.”

56
DRAFT
Fair Housing Complaints by Issue

“Issue” is the term the FHEO uses to describe the action or type of behavior that
constitutes discrimination.
The table below includes only those issues for which there were complaints.
Table 18, Fair Housing Complaints by Issue
Issue Number of
Complaints
Discriminatory Refusal to Sell 9
Discriminatory Refusal to negotiate for sale 1
Discriminatory Refusal to Sell and negotiate for sale 4
Discriminatory Refusal to rent 126
Discriminatory Refusal to negotiate for rental 7
Discriminatory Refusal to rent and negotiate for rental 18
Discriminatory advertising, statements & Notices 56
Discriminatory advertising - Sale 4
Selective use of Advertisements media or content 7
False denial or representation of availability 2
False denial or representation of availability - sale 2
False denial or representation of availability - rent 3
Discriminatory financing (Inc. RE transactions) 16
Discrimination in making of loans 12
Discrimination in terms/conditions for making loans 12
Discrimination in selling residential real property 3
Discrimination in brokering residential real property 2
Discrimination in appraising residential real property 1
Discriminatory Brokerage service 3
Discriminatory terms, conditions, privileges, or services
and facilities 165
and facilities relating to sale 15
and facilities relating to rental 106
Discrimination in services & facilities relating to rental 6
Steering 5
Otherwise deny or make housing available 82
Other discriminatory acts 22
Adverse action against an employee 1
Refusing to provided municipal services or property 1
Discriminatory acts under Section 818 (coercion, etc.) 80
Using ordinances to discriminate in zoning & land use 1
Non-compliance with design and construction
requirements (handicap) 2
Failure to provide accessible and usable public and
common user areas 1
Failure to provide usable kitchens & bathrooms 1
Failure to meet reasonable modification 19
Failure to meet reasonable accommodation 205

57
DRAFT
Failure to meet reasonable accommodation is the most frequently cited form of
discrimination, followed by discriminatory terms, conditions, privileges or services
and facilities (not specified whether rental or sale), and then by refusal to rent.
Table 19, Fair Housing Complaints by County
% of County
Fair Housing Complaints Filed (FHEO)
Total % of
Complai State Differen-
County 2006 2007 2008 2009 Total nts Pop. tial
Adams 10 6 5 8 29 6.87% 8.72% -1.85%
Alamosa 0 1 1 0 2 0.47% 0.31% 0.16%
Arapahoe 17 15 15 12 59 13.98% 11.22% 2.76%
Archuleta 0 1 2 0 3 0.71% 0.26% 0.45%
Boulder 8 7 3 3 21 4.98% 5.94% -0.96%
Broomfield 1 1 1 1 4 0.95% 1.11% -0.16%
Chaffee 0 1 0 0 1 0.24% 0.34% -0.11%
Crowley 0 0 1 0 1 0.24% 0.13% 0.11%
Custer 0 0 0 1 1 0.24% 0.08% 0.16%
Delta 0 0 3 0 3 0.71% 0.63% 0.08%
Denver 29 21 30 11 91 21.56% 12.12% 9.44%
Douglas 7 4 3 1 15 3.55% 5.68% -2.13%
Eagle 1 0 1 2 4 0.95% 1.06% -0.11%
El Paso 10 12 17 12 51 12.09% 12.07% 0.02%
Elbert 0 2 0 0 2 0.47% 0.46% 0.01%
Fremont 4 2 0 1 7 1.66% 0.96% 0.70%
Garfield 1 0 1 0 2 0.47% 1.12% -0.65%
Jefferson 9 9 20 9 47 11.14% 10.80% 0.34%
La Plata 0 2 0 3 5 1.18% 1.02% 0.16%
Lake 0 0 1 1 2 0.47% 0.16% 0.31%
Larimer 5 4 7 4 20 4.74% 5.93% -1.19%
Las Animas 0 2 0 0 2 0.47% 0.32% 0.15%
Logan 0 0 1 0 1 0.24% 0.42% -0.19%
Mesa 2 7 1 1 11 2.61% 2.90% -0.29%
Moffat 3 0 0 0 3 0.71% 0.28% 0.43%
Montrose 0 1 0 2 3 0.71% 0.82% -0.11%
Morgan 1 0 0 0 1 0.24% 0.56% -0.33%
Otero 0 0 0 1 1 0.24% 0.38% -0.14%
Pueblo 2 1 2 3 8 1.90% 3.17% -1.28%
Rio Grande 0 1 0 0 1 0.24% 0.24% 0.00%
Routt 0 1 0 0 1 0.24% 0.47% -0.23%
San Miguel 0 0 1 0 1 0.24% 0.15% 0.08%
Weld 6 12 1 0 19 4.50% 5.06% -0.55%
Total 116 113 117 76 422
Source: Table excerpted from FHEO-Filed-Cases.xls at www.hud.gov on 10/5/2010
This table comes from a different source, but helps to draw a picture of the
geography of Fair Housing complaints. The numbers highlighted in red in the
“Differential” column above indicate counties where the percentage of complaints
exceeds the county’s percentage of state residents by more than 1%. The number

58
DRAFT
of Fair Housing complaints filed in the City and County of Denver is clearly out of
proportion to the percentage of the population that resides there. A variety of
explanations is possible: (1) residents of Denver are more aware of their rights and
therefore more likely to file a complaint; (2) residents of Denver have more access
to Fair Housing advocacy groups (3) discrimination actually occurs more frequently in
Denver than in other parts of the state.
Reasons for any trends or patterns

The major trend that stands out after analyzing the list of complaints filed is the high
number of filings from people with disabilities, especially those having to do with
reasonable accommodation. It is difficult to pin down the reasons for landlords’ or
property managers’ failure to make such accommodations. Given the number of
comments about the need for further education of both landlords and tenants alike,
and the apparent difficulty of finding competent advocacy or support, it is possible
that landlords do not understand what is required of them. It is also possible that
tenants misunderstand their rights.
Other fair housing concerns or problems
Homelessness and the Protected Classes

Minorities, especially Blacks and Hispanics, and persons with disabilities are more
likely to become homeless than white, non-disabled people.
The most recent an statewide homeless count in August 2006 determined that as
many as 16,203 persons were homeless on the night of the count, and nearly two-
thirds (62.1%) of all homeless persons in Colorado were in households with children.
Homeless persons are included in this Fair Housing assessment since minorities are
over-represented in the homeless population, and housing supply for very-low
income populations is an impediment.
Compared to the general population in Colorado 2005, minorities were over-
represented and whites were underrepresented among Colorado’s homeless.
Black/African Americans made up 14% of the homeless population compared to only
4.1% of the general population. Hispanics comprised 24.9% of the homeless
population, but 19.6% of the general population. 5.3% of the homeless were Native
Americans, while that group made up just 1.1% of the general population. Whites
and Asians were under represented among the homeless. The biggest racial and
ethnic disparities in homelessness are for American Indians at 4.8 times their
prevalence in the general population, and Blacks at 3.41.
Disabled people were also more common among the homeless than in the general
population, with 50.9% of the homeless having at least one serious disabling
condition. Roughly one in five had a serious mental illness (21.2%) or a serious
medical condition (19.5%).
While men made up more than half of the homeless population, the number of
female-headed single parent households (1,297) was more than five times as high as
the number of male-headed single parent households (250), and both were much
higher than the number of two-parent homeless families.
Among reasons given for their homelessness, the cost of housing was second only to
loss of employment. For people living close to the margin of self-sufficiency as many

59
DRAFT
people with disabilities, Blacks, American Indians, and female-headed households
are, the cost of housing is a significant factor in keeping any level of housing.
Segregation and Affordable Housing Site Analysis

In light of the Westchester County court decision, the Division of Housing will review
its project underwriting processes to ensure that the siting of projects does not
exacerbate segregation of protected classes. Staff will look closely at the census
tract in which the project lies, especially its minority concentration and poverty rate,
then assess whether the proposed project with increase or decrease segregation in
that census tract and surrounding community.
In addition, Division of Housing has historically placed an emphasis on meeting local
housing needs and in having local community support for projects it funds. The
Westchester decision implies that grantees of Federal funds, such as the State of
Colorado, have a responsibility to confront and even take legal action against local
governments that set up regulatory barriers against affordable housing.

60
DRAFT
IV. Identification of Impediments to Fair Housing

Public Sector –State Statutes and Regulations
Building, Occupancy, Health, and Safety statutes

Division of Housing staff have reviewed state statutes that could affect fair housing
opportunity. Colorado generally relies on local governments to adopt building,
occupancy, health and safety codes. 51 of Colorado’s 64 counties have adopted such
codes and in the 13 that have not, the Division of Housing is responsible for
establishing and enforcing code for hotels, motels and multi-family housing. The
building code that the State enforces under C.R.S. 24-32-705, is the 2006
International Residential Code, which is compatible with HUD Fair Housing
guidelines.
Approval process for construction of housing

The Colorado Division of Housing examined its Public Housing Authority plans, and
its other plans, policies and procedures for compliance with HUD’s requirement to
Affirmatively Further Fair Housing. The Division works proactively to develop and
maintain affordable and accessible units and documents our compliance with Fair
Housing requirements.
In underwriting potential affordable housing projects, the Division of Housing
considers a standard set of factors. Factors that impact Fair Housing include: local
support for a project, access to public transportation and services, and the number
of accessible and visitable units to be created. The review system gives priority to
special needs housing. Before a project goes to contract, the applying agency must
submit a 504 self-certification and a compliance plan, a list of steps to affirmatively
further fair housing, an affirmative fair housing marketing plan and a citizen
participation plan. The evaluation process includes consideration of the applicants
administrative experience with Fair Housing, Section 3 and Minority and Women-
owned Business Enterprises. However, in assessing the externalities of a proposed
project, two factors could negatively serve to impede fair housing: consistency with
local land use plans and social impact. Local land use plans may contain elements
that impede fair housing. A requirement that a project not have “a detrimental
social impact” could easily impede fair housing when the local community considers
increased diversity to be a negative impact. These elements need to be assessed in
a way that requires local land use plans to be fair housing friendly and that
specifically considers increased diversity to be a positive social impact.
Section 504 and Accessibility
Section 504 of the Rehabilitation Act of 1973 prohibits discrimination on the basis of
disability in any program or activity that receives financial assistance from any
Federal agency. Section 504 imposes requirements to ensure that “qualified
individuals with handicaps” have access to programs and activities that receive
Federal funds. With regard to new housing construction (which includes Federal
assistance) it also requires that 5% of the dwelling units, or at least one unit,
whichever is greater, must be accessible top for persons with mobility disabilities and

61
DRAFT
an additional 2% of the dwelling units, or at least one unit, whichever is greater,
must be accessible for persons with hearing or visual disabilities.
(Need Oracle report on Section 504 units produced)
Consumer Directed Attendant Support Program
The Colorado Department of Health Care Policy and Financing (HCPF) has developed
the Consumer Directed Attendant Support (CDAS) program in 2001 to enable people
with disabilities to manage their own attendant services in their own home instead of
a nursing facility. The program serves 500 people at a time. In the CDAS program,
people hire, train, supervise and fire their own attendants. They can set their own
attendant schedules and, to a significant degree, determine what services the
attendants provide.
Community development and housing activities

The Colorado Division of Housing (CDOH) enforces federal civil rights regulations
governing each program through our application underwriting, contract terms,
project performance plan, technical assistance, project close out and monitoring
requirements. The Division of Housing loan/grant application requires that all
applicants certify that they will affirmatively further fair housing and comply with the
Civil Rights Act of 1964 and 1968.
Applicants must also address the requirements for accessible units in their project
application, and a public hearing must be conducted to gather public and private
comments on the proposed project. The meetings must be handicapped accessible
and outreach must be done for non-English speaking residents. Colorado Division of
Housing contracts require compliance with all applicable civil rights laws, including
Section 504, Section 3 and the Age Discrimination Act. Project performance plans
list outreach and affirmative marketing plan requirements. When needed, Division of
Housing staff provide technical assistance to a grantee so that they may comply with
civil rights requirements. Division of Housing asset managers monitor each project
to further ensure civil rights compliance. The Division of Housing Project Close-Out
(PCO) requires the reporting of direct benefit activities in order to track those who
have been served with federal/state funding. The PCO also requires the grantee to
list in writing the actions they have taken to affirmatively further fair housing.
CDOH maintains monitoring records and project close out data showing that it has
reviewed the civil rights performance of each grantee. This documentation is
contained in project files and HUD’s IDIS system.
Statewide policies that increase segregation or inhibit

employment
The State of Colorado, and specifically the Department of Local Affairs, have no
policies that restrict the provision of housing and community development resources
to areas of minority concentration, or policies that inhibit the employment of minority
persons and individuals with disabilities.

62
DRAFT
Public policies that restrict interdepartmental coordination

The State of Colorado, and specifically the Department of Local Affairs have no
policies that restrict interdepartmental coordination between other State/ local
agencies in providing housing and community development resources to areas of
minority concentration or to individuals with disabilities. To the contrary, Colorado
State Government has made efforts to increase coordination of the use of housing
and community development resources to improve services to minorities and
individuals with disabilities.
In 2009-2010, the State of Colorado undertook the Sustainable Main Streets
Initiative, a pilot project which brought together the efforts of state, federal, local,
nonprofit, foundation and private sector resources to help develop better solutions
and outcomes in four communities. The Sustainable Main Streets Initiative leveraged
state and other resources to help communities create solutions, innovate and focus
efforts in a new, collaborative way to help t he towns of Fowler, Monte Vista, and
Rifle and the Five Points neighborhood in Denver become sustainable consistent with
the principles agreed upon by the Departments of Transportation and Housing and
Urban Development and the Environmental Protection Agency, but tailored to meet
the needs of Colorado.
Statewide actions related to the provision and siting of

public transportation and social services
None of Colorado’s statewide planning, financing, or administrative social actions
related to the provision and siting of public transportation and social services inhibit
or concentrate affordable housing opportunities for persons with disabilities.
Protected-class representation boards, commissions, and

committees
The composition of state boards and commissions is determined by the state statute
that creates the commission. Each one is different, but most require balance
between political parties or regions of the state.
Only the State Civil Rights Commission is currently required to include any members
of the protected classes. The statute creating the Civil Rights Commission requires
the inclusion of at least four people who are members of groups of people who have
been or who might be discriminated against because of disability, race, creed, color,
sex, national origin, ancestry, sexual orientation, marital status, religion or age.
The Colorado State statutes creating the State Housing Board, State Medical Services
Board, and State Board of Human Services “encourage” the Governor to appoint at
least one member who is a person with a disability, a family member of a person
with a disability, or a member of an advocacy group for persons with disabilities.
Legislation has been proposed in the current session that would require the Governor
to appoint a least one member of each of these boards who fits that description. This
legislation, if passed, would help to ensure fair access to housing, medical services
and social services by assuring that people affected by the decisions have a voice in
making them.
The Colorado State Banking Board is not required to include a representative of any
of the protected classes. This could result in lack of sensitivity to banking practices
that would impede fair access to housing

63
DRAFT
The Colorado Developmental Disabilities Council includes people with disabilities,
family members of people with disabilities, and representatives of state agencies,
nongovernmental agencies and private nonprofit groups concerned with services for
people with disabilities.
The State Emergency Response Commission is made up of the following statutorily
required members representing:
• the Colorado Department of Public Health and Environment - Hazardous
Materials and Waste Management Division,
• the Department of Local Affairs - Colorado Division of Emergency
Management and the Division of Local Government,
• the Department of Public Safety - Fire Safety Division, and
• the Colorado State Patrol.
These representatives are permanent members of the CEPC. The balance of the
CEPC is made up of representatives appointed by the Governor and serving a two-
year term from the following areas:
• two from affected industries
• two from local governments
• two from the public interest or community groups
• one from the Local Emergency Planning Committee (LEPC) community.
No participation by members of the protected classes is specified, which could result
in the Commission overlooking emergency response elements that would be needed
by low-income minorities or persons with disabilities.
This topic requires additional research to account for all relevant Boards and
Commissions.
Private Sector
State banking and insurance laws and regulations

A review of state banking and insurance laws and regulations revealed none that
should negatively affect fair housing choice within the state. In 2007 the State
legislature passed a law (11-102-106, C.R.S.) to protect consumers by regulating
the marketing of non-traditional mortgage loans. The State Banking Board
promulgated regulations conforming to that law in December, 2007. The intent of
the law was to rein in the predatory lending practices that deeply affected the Black
and Hispanic communities in Colorado.
Analysis of Home Mortgage Disclosure Act (HMDA) information still indicates that
Black and Hispanic mortgage applicants are at a disadvantage in receiving mortgage
loans.
State laws and regulations covering the sale of housing

The Colorado Fair Housing Act specifically prohibits engaging in steering,
blockbusting, deed restrictions and discriminatory housing brokerage services.

64
DRAFT
State laws and regulations covering housing rentals, trust

or lease provisions, and conversions of apartments to all-
adult
During the 2008 legislative session, Colorado adopted a statewide habitability law
that provides minimum life, health and safety standard for rental units in Colorado,
which must be met in order for a unit to be considered habitable. It also provides
remedies for tenants in cases where the unit is not habitable including termination of
the of the rental agreement by the tenant under certain conditions. This law should
improve rental housing throughout the state by establishing a minimum level of
quality, and serve to further fair housing opportunity by creating clear standards and
accountability for both landlords and tenants.
There are no state laws regarding conversions of apartments to all-adult. A review
of statutes regarding housing rentals, trust and lease provisions did not reveal any
elements that would impede fair housing opportunity.
State and local laws that conflict with the accessibility

requirements of federal laws.
Denver and other local governments have banned “pit bulls” and/or other breeds
from their jurisdictions. Recently, the Denver City Council refused to create a
service-dog waiver to their ban. The case is expected to go to court. Breed-specific
bans prevent people with disabilities from keeping both their home and their service
animal, thus creating an impediment to Fair Housing.
Colorado state law permits the medicinal use of marijuana, which is contrary to
federal law. Because of this conflict, people with disabilities who use medical
marijuana for relief of pain or other symptoms lose their access to federally-
subsidized housing
State and local laws or other policies and practices that

have the effect of restricting housing choices for persons
with disabilities.
According to a news story in the Denver Post6, regulations that involve a person’s
qualifications to receive home care, together with a shortage of suitable housing,
result in roughly 3,500 persons with disabilities living in an assisted living facility that
would rather live independently. Long-term care in a facility that provides skilled
nursing is very expensive, while home care in an affordable accessible apartment
costs far less.
Changes have already begun to Colorado’s long term care system since the
December Denver Post article. Per the February 24, 2011 press release from the
Department of Health Care Policy and Financing, the State of Colorado has received
a $22 million Federal “Money Follows the Person” grant from the Centers for
Medicare & Medicaid Services to improve the long-term care system in Colorado.
Colorado’s program is called CO-ACTS.
6
Shortage of Living Spaces for Disabled Outside Nursing Homes is Costing Colorado, The Denver Post,
December 5, 2010

65
DRAFT
“CO-ACTS is a multi-agency effort. We have been working with the Department of
Human Services, the Department of Public Health and Environment, the Department
of Transportation and the Department of Local Affairs to ensure that we have the
appropriate community-based long term care services and supports in place along
with housing and transportation. All of these state agencies are working together to
make certain that we have a strong safety-net for those individuals returning to the
community,” states Tim Cortez, project director.
“CO-ACTS is the solution for giving clients needing long-term care services
independence, choice and dignity,” states Sue Birch, executive director. “In order to
support our clients in receiving the care they need in the setting they deserve, we
will build upon our existing community-based services and, at the same time, save
the state money.”
The Department will target individuals in nursing homes and intensive care facilities
for the developmentally disabled and psychiatric hospitals. We will recruit clients who
have an interest in returning to the community and have the potential, which
includes a strong support network – family, friends, and neighbors –and access to
the appropriate community supports. The Department’s goal is to transition
approximately 500 people or more back to the community over the next five years.
Further research into local codes restricting the location of group homes and facilities
that serve people with disabilities is required and will be performed by the Division of
Housing
Information on financial assistance for accessibility

modification of private homes
Thirty-eight organizations in the State of Colorado offer financial assistance for
accessibility modification of privately owned housing. These organizations and
programs are listed in Appendix ???. This list was created by The HERO Alliance, a
nonprofit organization that provides education, resources, and assistance for people
with disabilities seeking homeownership in Colorado. Information about the
programs is not widely known, although readily available to any one with an internet
connection. Although assistance is available, dissemination of information about the
assistance programs needs improvement.
Lending Policies and Practices

Division of Housing staff reviewed and analyzed Home Mortgage Disclosure Act
(HMDA) data for applications made in Colorado in 2008, the most recent available.
370,468 loan applications were processed in 2008 by institutions that are required to
report through the HMDA system. Of these, 156,446 were for home purchases,
20,652 were for home improvement and 193,370 were for refinancing.
CDOH only analyzed loan applications made for the purchases of a single-family (i.e.
1-4 family) home to be occupied by the owner. There were 129,641 loan
applications meeting this description. In addition, only the race, ethnicity or gender
of the primary applicant were considered in analyzing the information.
Since HMDA data does not include information on any protected class statuses other
than race, ethnicity (national origin), and gender, these are the only categories that
can be tested for evidence of discrimination. In addition, since credit scores are not
reported in the database it is not possible to eliminate that critical factor in
attempting to determine whether fair housing violations are taking place.

66
DRAFT
2008 HMDA Mortgage Data by Race
Mortgage Applications by Race

In 2008, the number of mortgage applications recorded in the HMDA system by race
is shown in the following table:
Table 20, Number of Mortgage Applications by Race
Race Number of Applications
White 96,512
Black/African American 2,914
American Indian/Alaska Native 819
Native Hawaiian/Other Pacific Islander 408
Asian 2,956
Not Provided 11,438
Not Applicable 14,594
The overwhelming majority of loan applications came from white applicants. Because
of this huge discrepancy, other tables will be based on percentages of loans within
each race. Loan applications where the race was indicated as “not applicable” are
those where the loan was purchases by the institution – in other words, the loan was
sold from one lender to another.
The percentage of applications from each group approximates their presence in the
general population, except that Blacks, who comprise about 4% of the population,
appear to have submitted only 2.5% of the mortgage applications from those who
provided their race. The true number of Blacks mortgage applications may be
obscured, however, because they are included in the “not provided” category. This
leaves an open question as to whether Blacks actually apply for home mortgages at
a rate consistent with their numbers, or whether they are discouraged from doing so.
Mortgage Loan Denials

The following table shows the percentage of loan applications denied by the
institution by race and income category.
Table 21, Mortgage Loan Denials by Race and Income
Income Range White Black AIAN NHPI Asian
<= $30K 16% 23% 20% 6% 21%
$31-40K 13% 17% 25% 13% 17%
$41-50K 11% 15% 19% 17% 17%
$51-60K 9% 13% 19% 16% 19%
$61-70K 9% 15% 15% 19% 12%
$71-80K 8% 10% 14% 8% 15%
$81-90K 8% 11% 14% 3% 14%
$91-100K 7% 14% 11% 10% 9%
$101-110K 7% 21% 23% 12% 9%
$111-120K 8% 10% 10% 9% 11%
$121-130K 9% 17% 0% 17% 11%
$131-140K 7% 13% 25% 10% 11%
$141-150K 7% 27% 10% 0% 10%
$151-160K 8% No Apps No Apps 17% 15%

67
DRAFT
$161-170K 7% 14% 17% 33% 2%
$171-180K 9% 13% No Apps No Apps 12%
$181-190K 9% 11% No Apps No Apps 12%
$191-200K 10% No Apps 14% No Apps 17%
$201-210K 12% 11% No Apps No Apps 12%
>$210K 13% 17% 44% 14% No Apps
Overall denial Rates 10% 15% 19% 12% 14%
As can be seen from this table, the overall denial rate for White applicants is lower
than for any other racial group. Native Americans experienced the highest rate of
denials, followed by Blacks, Asians, and Pacific Islanders in that order. For Whites,
there is a higher rate of denials at income levels below $50,000, then the rate levels
off to between 7% and 9%, rising again at income levels over $180,000. If this
patterns exists for the other racial categories it is far less clear, probably because the
number of applications for each group is so much smaller.
Other Actions
Other actions taken on applications do not show very significant differences across
races and the pattern is similar to the “race not provided” category.
Table 22, Actions Taken on Applications, by Race
Not
Action White Black Asian AIAN NHPI
Provided
Loan Originated 57% 49% 53% 47% 52% 52%
Loan Approved but not
6% 5% 7% 7% 6% 7%
accepted
Loan Denied 10% 15% 14% 19% 12% 12%
Application Withdrawn 6% 7% 8% 6% 7% 12%
Closed for
1% 2% 2% 3% 2% 1%
Incompleteness
Purchased by Institution 20% 22% 16% 17% 21% 15%
There were no applications where preapproval was denied, or that were preapproved
but not accepted.
Mortgage Applications by Ethnicity

2008 HMDA data for Colorado were also studied for discrimination against people of
Hispanic/Latino ethnicity. There were 91,829 applications received from primary
borrowers of any race who were not Hispanic, and 12,167 from Hispanic/Latino
applicants of any race. Using this racial/ethnic breakdown, applications from
Hispanic applicants were twice as likely to be denied as those from Non-Hispanic
applicants (18.6% vs. 9%). The ratio remains unchanged if Non-Hispanic applicants
are limited to Whites only.
When reasons for denials are analyzed, the only reason that is much higher for
Hispanics than Non-Hispanics is credit history.

68
DRAFT
Figure 12, Reason for Loan Denials by Ethnicity
Reason for Mortgage Loan Denial by Ethnic Group
25.00%
Percent Denied
20.00%
15.00%
10.00%
5.00%
0.00% Debt to Employment Credit Insufficient Unverifiable Incomplete Mortgage
Collateral Other
Income History History Cash Information Application Insurance
Hispanic or Latino 21.14% 4.55% 21.32% 10.50% 4.50% 8.74% 8.12% 1.06% 17.78%
Non-Hispanic 20.75% 3.78% 15.71% 15.91% 4.28% 7.82% 13.90% 0.94% 16.49%
Reason for Denial
Hispanic or Latino Non-Hispanic

Source: 2008 Home Mortgage Disclosure Act data, Federal Financial Institutions Examination Council and
Colorado Division of Housing
Loan Denials by Ethnicity and Income

The table below displays the percentage of loan applications that are denied to each
ethnic group broken down by household income. The Hispanic loan applicants are
much more likely to be denied a mortgage loan at all levels of income. Note that the
apparent outlier at the income range of $191,000 – 200,000 reflects a very small
number of loan applications, only 2 denials out of 25 applications.
Table 23, Mortgage Loan Denials by Ethnicity and Income

%
% Denied
Income Denied Non-
Range Hispanic Hispanic
<= $30K 23% 14%
$31-40K 20% 11%
$41-50K 19% 10%
$51-60K 18% 9%
$61-70K 16% 8%
$71-80K 14% 8%
$81-90K 13% 8%
$91-100K 14% 7%
$101-110K 14% 7%
$111-120K 15% 8%
$121-130K 23% 8%

69
DRAFT
$131-140K 20% 7%
$141-150K 13% 7%
$151-160K 33% 7%
$161-170K 21% 7%
$171-180K 10% 9%
$181-190K 13% 9%
$191-200K 8% 10%
$201-210K 10% 5%
>$210K 25% 12%
The number of applications at each income level varies by ethnicity in a way that
may affect some of the denial rates shown above. The percentage of applications
from Hispanics is higher than the application rate for Non-Hispanics at income levels
below $80,000 per year; beyond that point there is a higher percentage of Non-
Hispanic applicants at every income level.
Figure 13, Percentage of Applications by Income Level and Ethnicity
Percent of Applications
25.00%
20.00%
15.00%
10.00%
5.00%
0.00%
11 0 K
21 0 K
31 0 K
41 0 K
51 0 K
61 0 K
71 0 K
81 0 K
91 0 K
01 0 K
>$ 0 K
01 0K
0K
$3 30K
$4 40K
$5 50K
$6 60K
$7 70K
$8 80K
1 K
$9 -90
$1 -10
21
$1 -11
$1 -12
$1 -13
$1 -14
$1 -15
$1 -16
$1 -17
$1 -18
$1 -19
$2 -20
1
-2
$
1-
1-
1-
1-
1-
1
<=
Income Range
% of Hisp % of Non-Hisp

70
DRAFT
Actions Taken by Ethnicity

The graph below shows the various actions taken on applications by ethnicity.
Hispanics are more likely than Non-Hispanics to withdraw their applications or have
them denied by the financial institution, resulting in a lower rate of loan origination.
Action Types by Ethnicity
70.00%
Percent of Ethnic Group
60.00%
50.00%
40.00%
30.00%
20.00%
10.00%
0.00%
Incompleteness
Purchased by
Preapproval
Originated
not Accepted
Preapproved
Institution
Withdrawn by
Denied by
Approved by
Financial
Institution
accepted
Applicant
denied
Closed for
but not
Action Type
Hispanic Non-Hispanic
Overall, the data on mortgage applications and their outcomes for Hispanics
suggests that impediments to receiving mortgage loans exist; however, without
credit rating data it is not clear that discrimination is occurring.
High Cost Loans, Race and Ethnicity

In the report published by Colorado’s Civil Rights Division on Predatory Lending, the
consulting firm BBC Research and Consulting analyzed 2006 HMDA data for evidence
that high-cost loans may have been made in a discriminatory manner. Subprime, or
high-cost loans are loans made to borrowers who are considered to be at greater risk
of defaulting on their loan because of past credit problems, lower income, or other
reasons. For the purposes of the study, “subprime” was defined as a loan with an
Annual Percentage Rate of more than 3 percentage points above comparable
Treasuries for first liens, and 5 percentage points for second liens. This is consistent
with the intent of the Federal Reserve in requiring the pricing data.
BBC Consulting analyzed the data geographically, by borrower data, and by lender.
In doing so, they found “hotbeds” of subprime lending activity, found that subprime
lending was associated with borrower race, ethnicity and income level, and that
certain lenders were highly involved in the state’s subprime lending in 2006. The
summary of their findings states:

71
DRAFT
“The HMDA analysis conducted for this study found a strong relationship
between minority presence, English as a Second Language and subprime loan
activity. It found a smaller relationship between subprime lending and income
level.
Geographic analysis
At the county level, subprime lending was most active in eastern and south
central Colorado. At the metro level, Adams, Weld and Pueblo Counties had
subprime loan activity disproportionate to their share of the state’s households.
Counties whose minority population was above the state average had the highest
proportions of subprime loans.
• In Denver, Census Tracts with high minority populations were much more
likely to have high subprime loan activity than Census Tracts with low
minority populations.
• Subprime lending activity in the City in 2006 was very active in the
western and northeastern portions of the City.
• Areas in Denver with relatively high proportions of households that are
“linguistically isolated”—i.e., where no member of the household 14 years
and older speaks English very well—also had high subprime loan activity
in 2006.
• Subprime lending was also stronger in lower-income areas; however, the
relationship between income and subprime lending was less dramatic than
that between race/ethnicity and subprime lending. We believe this is due
to two factors: 1) High income borrowers represent a good portion of
subprime borrowers, and 2) Low income areas have higher proportions of
renters and households who are unlikely to qualify for home purchases.
Borrower analysis. African Americans and persons of Hispanic descent in

Colorado were twice as likely to get subprime loans than whites or Asians in
2006. This disparity persists across income levels, as shown in Exhibit IV-1
below. The Exhibit shows the disparities of subprime origination by income—the
number of times more likely minority borrowers are to receive subprime loans
than non-Hispanic, white borrowers with similar incomes.
Exhibit IV-1. Subprime Origination Disparities by Income

Black-white Hispanic-white
Income disparity disparity
< $25K 1.31 2.03

$25K-$49K 2.15 2.18
$50K-$74K 2.06 2.06
$75K-$99K 2.24 1.88
$100K+ 2.37 2.04
All incomes 2.14 2.12
Source: 2006 HMDA, Federal Financial Institutions Examination Council and

BBC Research & Consulting.

72
DRAFT
Our analysis revealed the following overall disparities in 2006:

• One in 5 white borrowers got a subprime loan.
• One in 2.3 African American borrowers got a subprime loan.
• One in 2.23 Hispanic borrowers got a subprime loan.
• One in 3.5 multi-race borrowers got a subprime loan.
High-income borrowers represent a significant segment of the subprime
market—a surprising finding to us. Borrowers earning more than $100,000
represented about 22 percent of the subprime market compared to 31 percent of
the non-subprime market.
Lender analysis. Option One, Long Beach and Decision One were the
predominantly subprime outfits originating the highest number of subprime loans
in Colorado. Their overall share of the subprime market, however, was only about
1 percent each. This is because there were many, many lenders making subprime
loans to Colorado borrowers in 2006. The top lenders originated just between and
1 and 3 percent of the total subprime volume in the state.
Summary. Our study uncovered large disparities in subprime lending between

minority and white borrowers. In 2006, minority borrowers were more than twice
as likely as white borrowers to get subprime loans. We also found that subprime
loan activity is much higher in areas of the state with high minority populations
and persons who speak English as a Second Language.
Because of data limitations, we are unable to determine the extent to which
minorities and ESL households receive subprime loans because of credit issues.
However, if income is a partial proxy for creditworthiness, our analysis provides
some evidence of potential discrimination in Colorado mortgage lending.
Seventeen percent of white borrowers earning $100,000 and more received
subprime loans in 2006, compared to 39 percent of African Americans and 34
percent of Hispanics at the same income level. Therefore, the disparity in
subprime lending holds across income levels, suggesting that minority
borrowers may be unnecessarily receiving subprime loans compared to white
borrowers, all other things being equal.”
These findings indicate racial and ethnic disparities in lending practices that are likely
impediments to Fair Housing.
Mortgage Lending and Gender

2008 HMDA data were also studied to determine whether there were obstacles to
home ownership based on gender. Of the 129,188 total loans studied, males were
the primary applicant on 76,685 and females on 32,393. 5,528 applicants did not
provide gender information. Loan origination and denial rates were very close for
both sexes. A breakdown of actions taken by gender

73
DRAFT
C. Public and Private Sector
Evidence of segregated housing conditions in non-

entitlement areas, and housing desegregation plans
Analysis of 2000 Census data on segregated housing conditions indicates that there
are areas of the state in which certain racial or ethnic groups are more concentrated,
indicating the presence of segregated housing conditions. See the analyses of areas
of minority concentration beginning on page 15. When Division of Housing is able to
access and analyze 2010 Census data, we will be able to address specific areas more
directly.
The delivery system for statewide programs providing

social services to families with children and persons with
disabilities.
The State of Colorado has a state-supervised, county-administered system for the
delivery of traditional social services, including programs such as public assistance
and child welfare services. This system allows for local control, which enables each
community to design and deliver a social services system tailored to the unique
needs of its community. In addition, this local control allows for the development of
partnerships at the local level between HUD providers, public housing authorities and
local social service agencies. This community-by-community placement makes social
services more accessible to families with children and persons with disabilities.
Services are localized rather than regionalized or located at the state level.

74
DRAFT
V. Current Public and Private Fair Housing

Programs And Activities
Lack of funding due to the economic downturn and resulting reductions in tax
revenue appears to have dampened Fair Housing education and enforcement efforts
in recent years. HUD’s web site showing FHIP grantees indicates that no Colorado
non-profits have received FHIP funding since 2007. When preparing the 2010-2015
Consolidated Plan we asked the Colorado Civil Rights Division if they planned to do
any Fair Housing testing, and were told there was no funding available to do so.
Lack of Fair Housing education and knowledge was noted as a major impediment by
both survey respondents and in entitlement-area Analyses of Impediments. The
Colorado Civil Rights Division provides Fair Housing Training classes in Denver four
times a year at no charge.
The Department of Local Affairs/Division of Housing co-sponsored Fair Housing
training workshops at four locations around the state in August of 2008 featuring a
nationally-recognized expert. The workshops were held in Denver, Grand Junction,
Pueblo and Greeley. The workshops were well attended, but additional efforts to
inform and educate landlords, property managers, PHA and government employees
are badly needed.
RCAC and HUD Region VIII are jointly sponsoring Fair Housing Training in Cheyenne,
Wyoming in April, 2011, a major outreach effort
Other steps that Division of Housing has taken to further Fair Housing since the last
Analysis of Impediments include:
• The appointment of a Fair Housing Coordinator within the Division of Housing.
• Creation of a Fair Housing page on the Division’s web site containing links to
relevant documents, resources and trainings.
• Changes made to our proprietary database to better track Fair Housing
compliance for projects that we fund.
• To help address lack of affordable housing, 23 communities received funding
for Housing Needs Assessments.
• Under the new competitive application system, the matrix gives a project
points depending on the percentage of its units that will be affordable at or
below 30% AMI.
25% or more – 50 points
12-24% - 25 points
6-11% - 15 points
5% or less – 0 points
This evaluation matrix has been in use since Sept. 09
• To help address high land costs, the Division of Housing has discussed land
donations with local governments and has tracked the number and amount of
local government donations of land or contributions to its acquisition. Local
governments have donated land or money toward acquisition in 48 projects
since January, 2005. The total value of their contributions over that period is
$25,522,888.

75
DRAFT
To address lack of affordable housing for people with disabilities the Division of
Housing encourages local housing and disability service agencies to conduct tenant
training programs. Specific efforts:
• DOH sponsored Fair Housing workshops conducted by a national expert, Jeff
Boyd, in 2008. Workshops were held in Denver, Pueblo, Grand Junction and
Greeley. 102 people attended the workshops. The workshops covered The
seven protected classes, how Fair Housing affects property access and use by
all people including those with disabilities, families and immigrants, ways to
help market the property, design leases, contracts and lending, and provide
maintenance and services that proactively promote Fair Housing and how Fair
Housing affects all types of housing.
• DOH has funded two projects that created housing units for people with
HIV/AIDS:
• Juan Diego Apartments, $200,000 21 units (permanent)
• Eaton House in Boulder, $35,000 4 units/8 beds (Transitional)
• The Division of Housing has created a web page devoted to Fair Housing
information. (http:\\colorado.gov\dola\cdh\fairhousing.htm), with links to it
available from the Home page, Landlords, Renters, Local Governments, and
Section 8 pages. It includes links to HUD’s Fair Housing web page, to the
Colorado Civil Rights Division and other sources of Fair Housing information.
• At this time, Dept. of Human Services, Supportive Housing and Homeless

Programs has considerable information on Fair Housing for the disabled,
including links to HUD and to CCRD. The FHA has links to HUD’s Fair Housing
information. None of the other “partners” listed in section (4) II directly
addresses Fair Housing, except that Colorado AIDS Project displays the Fair
Housing logo and states CAP’s compliance with Section 504.
To address language and cultural barriers, Division of Housing has taken the
following actions:
• Fair Housing posters/flyers are available in Spanish on our web site

• ESG agencies are provided with Fair Housing flyers with contact information in
both English and Spanish
• NSP 1 Substantial Amendment and all of its revisions have been made
available in Spanish as well as English on our website.
• The notice of Public Hearing was published in Spanish in newspapers.
• Meeting notices for HPRP and NSP were published in Spanish on our web site;
HPRP meetings were published in the Denver Post in both English and
Spanish.
• The “Puzzle of Homeownership” training on the Division of Housing web site
is available in Spanish.

76
DRAFT
Since 2006, the Department of Local Affairs has made efforts to revitalize known
areas of racial segregation and high poverty. The following table lists housing
projects undertaken and the 2000 minority and income characteristics of the census
tracts where they are located.
Table 24, Division of Housing Project Locations by Census Tract
Project Census Tract Minority Tract to

Number County Number Percentage MSA Income
06-060 ADAMS 78.03 81.68 42.38
06-049 ADAMS 78.03 81.68 42.38
07-039 ADAMS 96.04 36.74 69.33
06-014 ADAMS 92.03 35.91 62.87
09-068 ALAMOSA 9816.00 43.55 84.56
06-038 ARAPAHOE 70.16 42.07 75.49
06-029 BOULDER 133.08 21.44 71.86
08-007 BOULDER 133.05 15.51 93.55
10-012 BOULDER 124.01 9.59 76.43
09-059 BOULDER 133.08 21.44 71.86
09-052 BOULDER 135.04 18.70 93.96
07-060G BOULDER 129.06 13.94 94.70
08-045 BOULDER 137.01 5.29 132.41
06-021 CLEAR CREEK 148.00 7.97 80.12
08-073G CONEJOS 9747.00 50.98 71.38
09-040G CUSTER 9801.00 5.82 92.96
08-040G DELTA 9651.00 24.78 80.18
10-020 DENVER 11.01 88.62 48.55
06-028 DENVER 41.05 69.24 NA
06-073 DENVER 14.03 35.70 68.20
07-005C DENVER 4.02 65.83 56.46
07-027 DENVER 26.02 44.22 60.49
09-041 DENVER 9.04 83.23 58.63
08-051 DENVER 24.03 80.85 33.59
10-015 DENVER 42.02 31.26 120.79
07-038 DENVER 28.02 29.65 60.00
07-064C DENVER 15.00 83.03 55.71
07-029 DENVER 27.03 28.38 48.03
07-009 DENVER 24.03 80.85 33.59
10-042 DENVER 24.03 80.85 33.59
07-054 DENVER 16.00 66.55 49.74
06-063 DENVER 42.01 20.35 147.12
07-001 DOUGLAS 141.16 12.31 196.62
08-015 DOUGLAS 141.16 12.31 196.62
10-027 EL PASO 27.00 33.57 62.46
08-005 EL PASO 29.00 51.01 57.16
07-049 EL PASO 22.00 39.26 51.30

77
DRAFT
Project Census Tract Minority Tract to

Number County Number Percentage MSA Income
06-056 FREMONT 9784.00 12.86 96.44
08-052G GRAND 1.00 10.61 116.54
05-059G GRAND 2.00 5.83 126.15
07-003 JEFFERSON 111.00 24.60 75.85
07-013 JEFFERSON 104.02 20.25 56.37
07-070 JEFFERSON 115.50 35.44 67.34
09-060 JEFFERSON 114.00 44.01 51.92
06-062 LA PLATA 9707.02 11.66 112.74
09-044G LA PLATA 9711.00 29.39 92.27
07-044 LARIMER 4.00 19.75 74.20
07-025 LARIMER 10.07 13.08 142.35
10-014 LARIMER 11.07 13.49 105.45
07-006C LARIMER 11.07 13.49 105.45
06-046 MESA 19.00 10.27 112.45
07-040C MESA 12.00 11.50 125.48
08-048G MONTROSE 9663.00 28.15 71.68
06-075C OTERO 9878.00 33.37 98.52
08-027 PUEBLO 9.02 43.55 114.55
10-026 WELD 11.00 18.03 99.93
Source: Colorado Division of Housing proprietary database.
Of fifty-six projects listed above, fourteen were undertaken in census tracts that
exceeded the MSA’s median income, and twenty-six in tracts with minority
populations below 25%. Twelve of these projects were built in census tracts that are
both low minority and high income.
Eight projects in high-minority census tracts (minority percentage greater than 75%)
were in entitlement areas in Denver and Adams counties. Eight projects carried out
in very low income census tracts (below 50% of MSA median) were also in
entitlement areas. Only six projects were located in census tracts that are both
high-minority and very low income using 75% minority and 50% of MSA income as
the cutoff points.

78
DRAFT
VI. Conclusions and Recommendations

NOTE: The following list of impediments and ways to address them is
preliminary. It has not been reviewed by Department of Local Affairs
or Department of Health and Humans Services staff or management,
and has not been subjected to public comment although based in part
on public input.
Impediments Found
Review of survey responses and entitlement AIs indicates that many residents and
property managers do not have access information about Fair Housing rights and
responsibilities. Housing and service agencies’ staff require Fair Housing training as
well as advocate organizations. Nearly 60% of respondents to our survey of
affordable housing providers and those who serve the disabled said that the amount
of outreach and education about Fair Housing was inadequate and eleven of those
who left comments mentioned lack of education and training. None of those in the
general population who felt they had been discriminated against were sure of their
rights, nor did they know how to file a complaint.
Survey responses, entitlement-area Analyses of Impediments, and Division of

Housing’s Housing Mismatch report and analysis of American Community Survey
data show that the greatest barrier to fair housing in Colorado is the relative
shortage of affordable units for households with low and very low incomes. High
housing costs coupled with low incomes for Blacks, Hispanics, American Indians,
people with disabilities and women put these protected classes at a major
disadvantage in obtaining housing they can afford. Specific shortages of affordable
housing for disabled people and for large families were cited in several examples.
Causes of High Housing Costs

• Land Costs
Land costs continue to be an impediment to the production of an adequate
supply housing that will promote fair housing choice. This is especially true in
resort communities, where there is both great demand for second homes for
the wealthy, and where much of the land is unavailable for development
because it is owned by the Federal government or is not suitable for housing
because of the terrain. Rapidly developing communities in other areas also
have high land costs.
• Impact Development Fees
Many local jurisdictions pay for new growth in the community through the use
of impact development fees. These fees may include water, wastewater,
parks and recreation facilities, fire stations, libraries, and road improvements
among other items. These development charges add an additional layer of
cost to the expense of creating affordable housing units.

79
DRAFT
• Other local planning/zoning and building regulations
Other local regulations can add to the cost of housing development, such as
growth limits, minimum house or lot sizes, expensive design standards,
zoning to exclude multi-family or manufactured housing. Long and complex
permitting processes and fees add to developers’ costs and increase the cost
of the final housing units.
Causes of Low Income

• Unemployment
According to What Does It Mean to Have A Disability in Colorado?, a majority of
Coloradans with disabilities report that their disabilities make working difficult. Only
43.5% of Coloradans with disabilities are employed, compared to 83.8 percent of
those without disabilities.7
Blacks, Native Americans, Native Hawaiians, and Hispanics are also far more likely to
be unemployed than Whites and Asians, as shown in Table 13, Unemployment Rate
by Race and Ethnicity 2005-2009, on page 40.
• Lack of well-paying jobs that do not require high levels of education
Colorado has lost jobs in the extraction industries and construction, especially during
the last economic downturn, but that loss is simply the most recent aspect of a trend
that has been going on since the 1970s. Technology has reduced the number of
people required to perform low-skill work and more jobs have been lost to other
countries because of the low wages paid their. This global competition has also put
downward pressure on wages paid in the U.S. The creation of numerous well-paying
jobs that do not require education beyond high school seems unlikely.
• Lack of educational attainment
Education Attainment data from the American Community Survey 2005-2009
demonstrates that Blacks, Hispanics and Native Americans generally attain lower
levels of education that Non-Hispanic Whites and Asians as shown in the graph on
the next page. Reasons for this phenomenon are beyond the scope of this Analysis,
except to the extent that they may reflect the lack of affordable housing near good
schools.
7
What Does It Mean to Have a Disability in Colorado? Six Key Issues, A Summary Report from the
Colorado State Independent Living Council, July 2010.

80
DRAFT
Figure 14, Educational Attainment by Race and Ethnicity
Educational Attainment by Race and Ethnicity

Percent of Race or Ethnicity
60%
40%
20%
Black/AA
0%
Some Bachelor's AIAN
Less than High school
HS Diploma graduate
college or degree or Asian
Assoc. Higher NHOPI
Black/AA 13% 28% 37% 22% Hispanic
AIAN 20% 31% 33% 16% White NH
Asian 15% 18% 19% 48%
NHOPI 14% 28% 37% 21%
Hispanic 37% 29% 22% 12%
White NH 6% 22% 31% 41%
Level of Educational Attainment
• Affordable housing is located areas too far from sources of good jobs with no
public transportation
This phenomenon and the lack of integration of affordable housing, public
transportation, and places of employment was mentioned in several Analyses of
Impediments.
The lack of affordable housing has a disparate impact on Black/African Americans,

Hispanics, American Indians, women and people with disabilities because higher
percentages of these protected classes are low income. The shortage of housing
specifically suited to people with disabilities is an additional impediment, along with a
shortage of apartments with more than three bedrooms, which makes it difficult to
house large families.
• Lack of appropriate, accessible housing that is also affordable.

Much of Colorado’s housing, especially outside the Denver metropolitan area, was
built prior to the Fair Housing Accessibility Guidelines that went into effect in 1991.
Using data from the American Community Survey 2005-2009, roughly 1, 464,000
units were built prior to 1991. This housing is not accessible without modifications.

81
DRAFT
According to What Does It Mean to Have A Disability in Colorado?, “Newer,
accessible, more expensive units are out of the price range of many Coloradans with
disabilities, and so is the cost of adapting older units for accessibility.” There is a
need for a greater number of accessible units that are also affordable.
Lack of accessible housing was the fourth most-cited impediment to Fair Housing in
our survey of affordable housing providers and those who house the disabled.
• Failure of landlords/property managers to provide reasonable
accommodations for tenants with disabilities.
This was the largest single issue behind Fair Housing complaints filed from 2006-
2009, accounting for 205 of the complaints and the primary complaint lodged on the
basis of disability. In addition, our survey of affordable housing providers and those
who serve the disabled cited disability as the most frequent reason that “free and
equal housing was restricted.”
• Communication about disability issues, especially for people with mental
disabilities.
Communication issues were mentioned in comments, but are also revealed by CDOH
staff experiences in dealing with landlord/tenant issues.
Twelve of the fourteen communities whose Analyses of Impediments were reviewed

cited this as a major impediment, and although it was not directly addressed in
surveys, “Fear and misunderstanding of those with disabilities” was the third most
cited cause of impediments to fair housing choice. The “Not in My Back Yard
Syndrome” is an impediment to fair housing because it discourages or may even
prevent development of affordable housing that would provide fair housing choice to
protected classes. Neighbors often express concern that an influx of low-income or
minority households, or people with disabilities will create cultural and language
conflicts, cause property values to drop and increase crime and vandalism in their
neighborhoods.
The economic downturn and subsequent reductions in State and Federal revenue
have led to a lack of funding for Fair Housing testing. No non-profit organizations in
Colorado have received FHIP funding since 2007. It is difficult if not impossible to
prove pattern and practice discrimination in the absence of testing. Comments in
our survey noted lack of enforcement and difficulty in getting assistance when
experiencing discrimination.
Predatory Lending and Foreclosures
A study by the Colorado Civil Rights Division found that minorities, especially Blacks
and Latinos, were targeted for subprime and even mortgage loans and that these
groups consequently have experienced a disproportionate number of foreclosures.
Please see the summary of this study’s findings on page 71.

82
DRAFT
Persons who do not speak English may be vulnerable to discrimination or unfair acts.
Language barriers especially complicate landlord/tenant issues. The Colorado Civil
Rights Division study excerpted beginning on page 71 concluded that Low-English
Proficiency Spanish speakers were one of the groups targeted by predatory lenders
in 2006.
Transportation
Lack of public transit in many areas of the state as well as lack of affordable housing
along existing transit routes is an impediment to fair housing. Housing patterns,
location of employment opportunities and public transit are not coordinated so as to
enable minorities and low income people to hold a job without having a car.
Transportation is a recurring barrier to service delivery for people with HIV/AIDS
outside the Denver Metro Area, as no public transportation exists and the service
areas for HOPWA sponsor agencies are very large.
Planning and zoning, definitions of “family,” land use plans, development fees,
growth management programs and housing design specifications may increase the
cost of housing and otherwise create impediments to fair housing choice. Zoning in
particular, with its emphasis on separation of incompatible uses, may create
situations that necessitate driving a car in order to get to work. In some areas of the
country, such regulations have been used to deliberately impede Fair Housing access
and desegregation. In most other instances it is not deliberate, but regulations such
has minimum lot sizes, or housing design requirements drive up the cost of housing
with the result of excluding lower-income households from the community.
Actions To Address Impediments

This list of proposed actions may have to be revised or limited depending on funding
availability and whether additional funding can be found.
• Host a statewide Fair Housing education event

• Develop program to educate landlords and property managers about Fair
• Additional training for Division of Housing staff to improve Technical
Assistance to housing providers and services to the public.
• Continual development of the Division of Housing’s Fair Housing web page
• Promote Fair Housing education offered by other organizations through our
listserv, housing blog, web site, and e-mail
• Provide information about funding available for Fair Housing (NOFAs) through
our listserv, housing blog, web site, and e-mail.
Mae, Freddie Mac, Colorado Association of Realtors, Colorado Coalition for the

83
DRAFT
Homeless (CCH),Colorado AIDS Project, statewide disability organizations and
other fair housing leaders.
High Housing Costs Combined with Low Income/Wages:
Address local planning/zoning, building regulations and impact development fees

• Work with local governments during the strategic planning process to
encourage infrastructure funding methods that do no increase the price of
producing affordable housing.
• Annually, publish “Affordable Housing: A Guide for Local Officials” as a tool
for local governments in creating affordable housing and reducing regulatory
barriers.
Impediments specific to people with disabilities
• Provide incentives to housing developers to exceed Section 504 accessibility

requirements in the production of housing for persons with disabilities.
• Establish a program that can assist landlords in modifying units to meet
accessibility standards in order to increase the supply of accessible units.
• Encourage local housing and disability service agencies to conduct tenant
training programs to increase client knowledge of fair housing rights.
• Proposed state legislation, House Bill 1230, would combine the administration
of all Housing choice vouchers under the Department of Local Affairs, Division
of Housing by transferring administration of the vouchers for people with
disabilities from the Department of Human Service. The State believes that
this action would save significant administration cost at the state level,
enabling the Division of Housing to accomplish three important objectives: (1)
pass along administrative funding to local Public Housing Authorities and
allowing them to build their capacity; (2) make funding available to provide
training and technical assistance on Fair Housing issues, particularly those
specific to people with disabilities such as reasonable accommodation,
reasonable modifications, and accessibility; and (3) improve communication
and coordination between public housing authorities and organizations that
serve people with disabilities.
• The Division of Housing will release key documents such as the Consolidated
Plan, Annual Action Plan, Analysis of Impediments to Fair Housing, public
notices in large print versions to make them more accessible.
• Increase efforts to build awareness of the need for affordable housing in

Colorado communities through publications, public speaking, participation in
affordable housing and special needs advocacy groups, educating legislators,
and working with local governments.

84
DRAFT
• Partner with the Division of Local Government, the Colorado Municipal League
and Colorado Counties Incorporated and housing developers to promote “best
planning practices” that involve neighborhoods and the public at the
beginning of the housing development process.
• Enhance public education about the positive community effects of
affordable/special needs housing through publications, public speaking,
participation in affordable housing and special needs advocacy groups, and
involvement in local comprehensive planning processes.
• Provide technical assistance to housing developers on working with neighbors
to allay unfounded fears, educating them about common concerns and best
practices for addressing them.
• Host a statewide Fair Housing education event

• Develop program to educate landlords & property managers about Fair
• Additional training for Division of Housing staff to improve Technical
Assistance to housing providers and services to the public.
• Further development of Fair Housing web page
• Promote fair housing education offered by other organizations through our
listserv, housing blog, web site, and e-mail.
Mae, Freddie Mac, Colorado Coalition for the Homeless (CCH),Colorado AIDS
Project statewide disability organizations and other fair housing leaders.
• Request that HUD conduct or fund Fair Housing testing in Colorado

• Seek out new sources of funding for testing, apply for those for which the
Division of Housing is eligible, and pass along information about funding
availability to organizations that are eligible through our web site, listserv and
blog.
• Increase access to information and assistance about filing Fair Housing
complaints by creating and distributing materials to the public.
• Develop a list of Department of Local Affairs employees who are bilingual and
competent to act as interpreters and/or translators

85
DRAFT
• Increase outreach to tenants and landlords, both through informational
materials person-to-person contact.
• Analyze needs of Limited English Proficiency persons in Colorado and adopt a
formal Language Assistance Plan (currently underway)
• Partner with Colorado Civil Rights Division to provide Fair Housing information
in various languages, especially Spanish.
• Offer training to improve the cultural literacy of those dealing directly with
LEP and/or disabled persons if funding can be found to do so.
• The Division of Housing will release key documents such as the Consolidated
Plan, Annual Action Plan, Analysis of Impediments to Fair Housing, public
notices in Spanish as well as English.
Transportation
• Continue to promote Sustainable Communities, which encompass

transportation and economic opportunity as well as affordable housing.
• Encourage the inclusion of public transportation in local government
comprehensive plans, or the placement of affordable and/or accessible
housing close to services in places where public transportation is not
economically feasible.
• Encourage development of affordable housing in close proximity to public
transit (transit-oriented development), especially where it provides access to
better employment opportunities.
Other Local Government Regulations (not cost related)
• Continue to educate local governments about barriers to affordable and Fair

Housing.
• Ensure that local government applicants have and enforce Fair Housing Plans.
Division of Housing staff will continue to require that local governments have
a Fair Housing Plan in place before any new funding to them goes to contract.
Asset Managers will continue to include Fair Housing compliance in their
monitoring and project close out processes.
• Perform further research into local government planning and zoning policies,
especially those concerning multi-family housing and other rental housing
issues such as definitions of “family” or limits on the number of unrelated
adults per housing units to ensure that they do not impede access to Fair
Housing.
• Further research into which version of the International Building Code local
governments have adopted, and where they are using a code prior to 2003,
provide Colorado's counties and municipalities with the tools and information
needed to implement and benefit from the use of a version of the IBC that is
Fair Housing compliant.

86
DRAFT
Other Actions
The intention of the Division of Housing is to update this Analysis annually as new
data becomes available and in coordination with the Consolidate Plan Annual Action
Plan as funding and other resources permit.

87
DRAFT
VII. Signature Page
Chief Elected Official

88

Colorado - Draft Analysis of Impediments To Fair Housing, 2011

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Colorado - Draft Analysis of Impediments To Fair Housing, 2011

Uploaded by

Copyright:

Available Formats

DRAFT

DRAFT COLORADO ANALYSIS OF

Colorado Department of Local Affairs

Colorado Department of Human Services

John Hickenlooper, Governor

Colorado Analysis of Impediments to Fair Housing 2011- 2015

I. Introduction and Executive Summary ......................................... 4

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Colorado Analysis of Impediments to Fair Housing 2011- 2015

I. Introduction and Executive Summary

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Secondary sources included:

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Notes on Terminology and Sources

Hispanic/Latino is treated as an Ethnicity rather than a racial category, as people

To conserve space where necessary, this document will refer to Black/African

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Some subgroups of Colorado’s population, such as the numbers for Native

E. Executive Summary and Conclusions

Review of survey responses and Analyses of Impediments from entitlement areas

Colorado Analysis of Impediments to Fair Housing 2011- 2015

High Housing Costs Combined with Low Income/Wages

Survey responses, entitlement-area Analyses of Impediments, and Colorado Division

Causes of High Housing Costs

Impediments Specific to People with Disabilities

Community Resistance to Affordable and Special Needs Housing

The “Not in My Back Yard Syndrome” is an impediment to fair housing because it

Lack of Fair Housing Enforcement

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Language and Cultural Issues

Local Government Regulations

Actions To Address Impediments

• Host a Statewide Fair Housing education event

Colorado Analysis of Impediments to Fair Housing 2011- 2015

High Housing Costs Combined with Low Income/Wages

Impact Development Fees

Impediments Specific to People with Disabilities

• Prioritize the production of homes that are accessible to people with

Community Resistance to Affordable and Special Needs Housing

• Continue to promote awareness of the need for affordable housing in

Lack of Fair Housing Enforcement

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Language and Cultural Issues

• Continue to promote Sustainable Communities, which encompass

Local Government Regulations

• Continue to educate local governments about barriers to affordable and Fair

Colorado Analysis of Impediments to Fair Housing 2011- 2015

II. State of Colorado Background Data

Racial and Ethnic Composition

955,664 people of any race, 19.7% of Colorado’s population, self-identified as

Figure 1, Colorado vs. US Population by Ethncity

Comparison of US and Colorado Populations,

Compared to the US as a whole, Colorado’s population is more White and Hispanic,

Denver is the largest city in Colorado with an estimated population of 610,345 in

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Minority and Racial Concentrations

Data Distortions Created by Correctional Facilities

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Figure 2 Areas of Black/African American Concentration in Colorado, 2000

Most Black/African Americans live in the Denver metropolitan area or in Colorado

Colorado Analysis of Impediments to Fair Housing 2011- 2015

Southern Colorado and the San Luis Valley: