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o Lin its on multi -unit developments, which may it/chicle outright bens on multi -unit developments or indirect limits such as height limits and minimum pcirlanb requirements. O viinimum lot sizes • Occupancy restrictions, which regulate how many persons may occupy o property or the relationship between those persons o inclusionary zoning practices that mandate or incer;tiv'ize the creation of affordable units Requirements for special use permits for all muitif,nrni'y properties or multifamily properties serving individuals with disabilities " The contributing factor identified as Displacement of Residents Due to Economic Pressures is ill conceived Terms larking definition are shorn below in red text Economic pressures are largely driven by market factors that jurisdictions do not influence or contro Being a relatively young county with 94% of the housing stock built after 1978, we believe th potential for residents being d solaced due to economic factors in Douglas County is non-existent 'run exemplifies the uniqueness of each grantee and jurisdiction The description provided lacks clarity, purpose and the potential! resolution HUD expects through implementation of the AFH, inciud•ng the de's;cr ption as a contributing factor implies that it should be addressed The contributing factor r e arci:nn uisp!acement of residents below should be removed from the Tool, and local control restored Displacement of Residents Due to Economic Pressures "The term "displacement" refers her to a r: :dent's tindtesireci departure from a place where an individual hos been living "Eco';o!?c pressures" may Inc:iucie but ori:' not limited to, rising rents, rising property taxes related to hon'ie prices, rehabilitation of existing structures, demolition of subsidized housing, and public and private investments in neighborhoods Such pressures can lead to loss of existing affordable housing in areas experiencing rapid econorn;;,. growtn and 0 resulting /055 of access to Opportunity onsets for lower income families that previously lived there, Where Ciis iocemenr disproport;otiate'l;'a`fects per cons wri' certain protected characteristics, t,'?A, displacement of residents due to economic pressures may exacerbate patterns of residential segregation " in addition to lack of clear definition and intent, benchmarks and metrics have not been identified to guide us in determining if these factors are a fair housing concern for bur corninunity, Douglas County is concerned that the mere identification of these factors subjects all grantees to the judgment of specie! interest groups, as it :','Ill 'be financially Irnpussib e Or any community to address every factor Given that so many factors have been identified for considerat cn, and no clear guidelines were provided to judge them by, it will be extremely difficult to comply with the new AFH requirements