F26001_RFP_FurtheringFairHousing_Attachment_G_FHAP_Draft.pdf

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Furthering Fair Housing Activities 2026
Solicitation number
S-12300-00017589
Issued by
Oregon

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Summary

This document is a Fair Housing Action Plan (FHAP) prepared by the State of Oregon, acting through the Oregon Housing & Community Services and Business Oregon divisions, as an attachment to an Intermediate Request for Proposal (RFP) for consultant services to address fair housing goals and strategies for 2026–2030. The document outlines six primary research findings and associated impediments that serve as the foundation for the state's fair housing initiative: the lack of affordable and accessible housing for protected class populations; persistent housing discrimination, particularly against individuals with disabilities; the need for targeted education and outreach on fair housing rights in rural areas; homeownership barriers for people of color; economic opportunity disparities affecting protected classes; and poor conditions of affordable housing in rural communities. The consultant services sought are intended to develop and implement strategies that directly address these impediments through activities such as targeted training programs for governing bodies, collaboration with the Fair Housing Council of Oregon, support for housing rehabilitation initiatives, and programs designed to strengthen economic opportunity for underrepresented populations.

The RFP seeks a consultant to work with state agencies in developing comprehensive solutions to the documented fair housing challenges. Specific action areas include expanding fair housing education and outreach, particularly in rural regions where approximately 50% of complaints originate from areas outside major population centers; supporting the Housing Rehabilitation Program to preserve naturally occurring affordable housing; administering funding programs such as the Rural Opportunity Initiative and Technical Assistance for Underrepresented Businesses; and addressing source of income discrimination, with data showing that nearly 40% of fair housing tests between 2014 and 2022 revealed positive discrimination cases. The state emphasizes that COVID-19 has exacerbated existing housing instability and structural inequities, with one in six renter households falling behind on rent and protected class populations experiencing disproportionate impacts. The consultant engagement is designed to leverage state investments and policy actions to further reduce barriers to fair housing choice across Oregon.

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Fair Housing Action Plan | 2026

State of Oregon

Fair Housing Action Plan

Oregon Housing & Community Services

Business Oregon

2026-30 Fair Housing Impediments The State of Oregon continues to be a national leader in its continued commitment to addressing affordable challenges and impediments to fair housing choice. Several barriers— specifically those that are the result of decades of structural discrimination—are challenging to address. Moreover, the COVID-19 pandemic magnified many of the inequalities already impacting protected class populations and exacerbated them. Several research studies during and following the pandemic found that one in six renter households were behind on rent,1 federal policies providing rent relief did not fully protect all low-income renters from becoming unhoused,2 and populations already most at risk of housing instability were most affected during the pandemic.3 The study noted that, “effectively, COVID-19 accelerated precarity for groups already at risk, partially due to the lifetime consequences of structural racism and socioeconomic disparities.”4

The significant investments and policy action taken by the State to address the barriers identified in the previous FHAP over the last five years have made a substantial impact on reducing barriers to fair housing choice. However, several of the same fair housing impediments remain today.

1 Himmelstein, G. , & Desmond, M. (2021b). Eviction and health: A vicious cycle exacerbated by a pandemic. Health Affairs.

10.1377/hpb20210315.747908 [DOI] [Google Scholar]

2 Versey, H. S. (2021a). The impending eviction cliff: Housing insecurity during COVID‐19. American Journal of Public Health, 111(8), 1423–1427. 10.2105/ajph.2021.306353

3 Berkowitz, R. L. , Gao, X. , Michaels, E. K. , & Mujahid, M. S. (2020). Structurally vulnerable neighborhood environments and racial/ethnic COVID‐19 inequities. Cities & Health, 5(1), S59–S62. 10.1080/23748834.2020.1792069

4 Versey HS, Russell CN. The impact of COVID-19 and housing insecurity on lower-income Black women. J Soc Issues. 2022 Oct 3:10.1111/josi.12555. doi: 10.1111/josi.12555. Epub ahead of print. PMID: 36711011; PMCID: PMC9874908.

https://doi.org/10.1377/hpb20210315.747908 https://scholar.google.com/scholar_lookup?title=Eviction%20and%20health:%20A%20vicious%20cycle%20exacerbated%20by%20a%20pandemic&author=G.%20Himmelstein&author=M.%20Desmond&publication_year=2021b&

Research Finding #1—The lack of affordable and accessible housing impacts protected class populations’ ability to find rental housing that meets their housing needs.

The lack of affordable housing, primarily units affordable to households with income at or below 30% and 50% AMI, continues to be a fair housing impediment, restricting the housing choices of protected class populations, particularly people of color and people living with disabilities. The critical need for more permanent supportive housing and other supportive services identified by stakeholders reaffirmed the challenges that “harder to house populations,” including residents living with serious and persistent mental illness and residents experiencing substance use disorders, experience when looking for housing.

Impediments: Actions Taken: Notes from Business Oregon

Impediment 1-1.

Affordable rental housing, particularly units affordable to households with income less than 30% and 50% AMI, was identified as the greatest housing need statewide.

Black/African American residents and residents living with disabilities are much more likely to experience cost burden and poverty. Over a third of Black/African American homeowners (35%) and nearly six in ten Black/African American renters (57%) experience cost burden compared to just under a quarter of non- Hispanic White homeowners (23%) and under half of renter households (46%). Additionally, over a quarter of Black/African American households (26%) experience severe cost burden—12 percentage points higher than non-Hispanic White households (14%). Moreover, over a quarter of Black/African American residents (27%) experience poverty—more than twice the rate of Oregon residents overall (12%). Additionally, one in five

Impediments: Actions Taken: Notes from Business Oregon residents living with a disability lives in poverty, a slight increase over the last ten years.

Impediment 1-2.

Discrimination on the basis of protected class status persists, particularly among Oregonians living with disabilities and Oregonians utilizing rental assistance and/or other housing subsidies—even with source of income protections at the state level. Stakeholders provided anecdotal evidence of landlords avoiding renting to voucher holders by raising rents just above payments standards and imposing income requirements that do not match risk. Fair housing test conducted by FHCO showed that between 2014 and 2022, nearly 40% of tests for source of income discrimination were positive. Allegations of source of income discrimination are common in both rural and urban areas.

Impediment 1-3.

Residents living with disabilities continue to experience barriers to housing choice with the critical shortage of both affordable and accessible housing. Stakeholders who serve populations living with disabilities overwhelmingly reported there were insufficient numbers of accessible units statewide.

Impediment 1-4.

Impediments: Actions Taken: Notes from Business Oregon

Housing rehabilitation is significantly needed for naturally occurring affordable housing (NOAH), particularly in rural areas of the state. While the proportion of Hispanic households living in substandard housing conditions has decreased since the last AFFH analysis, Hispanic households are still four times more likely to live in substandard housing conditions compared to the overall population (12% for Hispanic households, 3% for the state overall). Moreover, stakeholders shared that there is a common perception among some landlords that housing precarious residents or residents who need a housing subsidy— who are most likely to be protected class populations— are expected to live in units with lower levels of habitability. Stakeholders shared that protected class populations are more likely to “put up” with poor housing conditions due to fear of retaliation and no other housing options.

Through the CDBG-funded Housing Rehabilitation Program, Business Oregon contributes to the preservation of affordable housing while serving as a critical homelessness prevention measure for low- and moderate-income owner-occupied households. Among the program's highest priorities is assisting LMI households in completing home rehabilitation projects that bring their properties into compliance with ADA accessibility standards.

Research Finding #2—Protected classes populations continue to experience housing discrimination.

Direct discrimination remains a barrier to fair housing choice for protected classes in Oregon.

Impediments: Actions Taken: Notes from Business Oregon

Impediment 2-1.

Discrimination against people living with disabilities persists.

Between 2014 and 2022, 1,064 bona fide allegations of discrimination were on the basis of disability—accounting for 40% of all cases investigated by the Fair Housing Council of Oregon (FHCO) over this time period. By complaint type, reasonable accommodation accounted for the greatest number of complaints over this time period. According to the FHCO, allegations of disability discrimination are most common in almost every county regardless of geographic or cultural characteristics.

Impediment 2-2.

Since 2014, the proportion of fair housing inquiries from people of color steadily increased, peaking in 2021—most likely due to the impacts of the COVID-19 pandemic. In 2022, compared to the overall proportion of the population, Black/African American were more than five times as likely to inquire about a fair housing violation compared to their overall proportion of the population.

AIAN and Hispanic populations are also overrepresented in the

Impediments: Actions Taken: Notes from Business Oregon proportion of inquiries, while Asian and non-Hispanic White residents are underrepresented.

Impediment 2-3.

Stakeholders shared that protected class populations, including residents living with disabilities, residents experiencing behavioral health challenges, and residents experiencing substance use challenges, are more likely to experience higher barriers in securing rental housing, including inflated application fees, high credit score requirements, and upfront costs.

Research Finding #3—Targeted education and outreach is needed to increase knowledge of fair housing rights and resources, primarily in rural areas of the state. Changes to federal policy may discourage residents from taking action if they feel they have experienced discrimination.

Impediments: Actions Taken:

Impediment 3-1.

In 2022, the FHCO reported that approximately 50% of complaints received are from areas outside of major population centers, specifically areas where FHCO has made strategic investments to increase education of fair housing rights (e.g., Mid- Willamette Valley, Eastern Oregon and Southern Oregon regions).

Data show that areas outside of those regions were more likely to have lower number of fair housing complaints. Without resources

Business Oregon is furthering this commitment through an active collaboration with the Fair Housing Council of Oregon (FHCO), working jointly to develop and implement targeted training programs for the wide range of governing bodies to invest in these areas, knowledge of fair housing rights, particularly in rural areas, will remain low. Compounding this challenge is the retraction of federal funding received by the FHCO to investigate housing discrimination issues in larger cities throughout Oregon.

operating throughout rural Oregon — ensuring that local leaders are equipped with the knowledge and tools needed to advance fair and equitable housing practices. Impediment 3-2.

Inquiries related to reasonable accommodation made up the greatest proportion of fair housing complaints submitted to FHCO over the last few years. Stakeholders shared that while some landlords intentionally discriminate, most are just unaware of their obligations. Landlords would benefit from increased access to fair housing education and training.

Research Finding #4—While some gains have been made, people of color continue to disproportionately experience homeownership barriers.

While homeownership rates have slightly increased for some households of color over the last ten years (six percentage points increase for Hispanic households, three percentage point increase for Asian households, and two percentage points for AIAN households), homeownership rates still lag far behind that of non-Hispanic White residents. In 2023, Black/African American homeownership was 30 percentage points lower than non-Hispanic White homeownership rates, while Hispanic and AIAN homeownership rates were 20 percentage points lower.

Impediments: Actions Taken: Notes from Business Oregon

Impediment 4-1.

Historical segregation, disinvestment, and past discrimination in lending and disparities contributes to the wealth gap that

Oregon negatively impacts mortgage lending outcomes for BIPOC households.

Impediment 4-2.

Lenders continue to deny Black and African American, Native American, and Latino/Hispanic applicants in Oregon at higher rates than non-Hispanic White applicants. Higher denial rates persist for Black and African American and Hispanic/Latino(a) applicants even after accounting for income. A vast body of research has recently emerged that reveals racial inequity in the lending process to be deeply embedded in the credit scoring process and through consistent undervaluation of property value.

Research Finding #5—Economic opportunity barriers continue to disproportionately impact protected classes in Oregon.

Barriers to economic opportunity continue to disproportionately impact protected class populations, including lack of access to quality learning environments and to services and resources supporting the pursuit of economic opportunity. In 2024, the average monthly wage for non-Hispanic White residents in Oregon was 11% higher than Black/African American residents, 28% more than Hispanic residents, and 30% more than AIAN Oregonians. Moreover, these disparities have increased over the last twenty-five years.

Impediments: Actions Taken: Notes from Business Oregon

Impediment 5-1.

Oregon

Protected class populations, particularly students of color, students living with disabilities, and English Language Learners are more likely to go to schools with higher concentrations of low-income students, have lower proficiency scores and graduation rates, and higher chronic absenteeism rates, all impacting educational attainment and future employment outcomes. With an increase in the number of English Language learners and students with special education needs, students requiring more and specialized services will continue to increase.

Business Oregon administers a range of funding programs designed to strengthen rural economies by fostering entrepreneurship and small business growth. Through initiatives such as the Rural Opportunity Initiative and the Technical Assistance for Underrepresented Businesses program, the agency supports community-driven strategies that elevate the role of entrepreneurship in rural economic development — empowering entrepreneurs to build place-based enterprises that sustain and invigorate local economies.

Impediment 5-2.

The lack of supportive services, including mental health care and substance use disorder treatment, continues to disproportionately the ability of residents of color and residents living with disabilities to attain housing stability and pursue economic opportunity. Stakeholders identified the need for mental health and opioid rehabilitation centers as critical needs in the balance of state.

Research Finding #6—Condition of affordable housing remains generally poor in rural areas.

Stakeholders identified that home rehabilitation needs are very high in rural areas of the state, which has a high inventory of aging homes. The main issue highlighted affecting all households is the lack of available resources to support housing rehabilitation.

Because of the lack of new affordable housing being built in these communities, preservation and rehabilitation of existing housing is critical. Specific to protected class populations:

Observations Fear of landlord retaliation can impact housing choices if condition issues are reported and the experience of discrimination limits other housing choices. For example, one community member shared an example of a tenant living on the coast who has limited English proficiency and was living in a unit that had mold growing in it. They shared that, “the tenant didn’t want to complain about it to the landlord because they didn’t want to be evicted. Tenants in similar situations don’t say anything because they don’t want to be on the streets with no housing. As a result, you just put up with more.”

Landlords maintain properties differently depending on the occupants. One community member noted that in the north coast region, overcrowding is becoming a major challenge. As a result, “landlords get away with not having to keep their units in good condition [because renters have no other housing options].”

State of Oregon
Fair Housing Action Plan
2026-30 Fair Housing Impediments
Research Finding #1—The lack of affordable and accessible housing impacts protected class populations’ ability to find rental housing that meets their housing needs.
Research Finding #2—Protected classes populations continue to experience housing discrimination.
Research Finding #3—Targeted education and outreach is needed to increase knowledge of fair housing rights and resources, primarily in rural areas of the state. Changes to federal policy may discourage residents from taking action if they feel they ha...
Research Finding #4—While some gains have been made, people of color continue to disproportionately experience homeownership barriers.
Research Finding #5—Economic opportunity barriers continue to disproportionately impact protected classes in Oregon.
Research Finding #6—Condition of affordable housing remains generally poor in rural areas.
Observations

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