HomeMy WebLinkAbout07-15-24 CDB Agenda and Packet MaterialsA. Call to Order - 6:00 pm
B. Disclosures
C. Changes to the Agenda
D. Public Comments
THE COMMUNITY DEVELOPMENT BOARD OF BOZEMAN, MONTANA
CDB AGENDA
Monday, July 15, 2024
General information about the Community Development Board is available in our Laserfiche
repository.
If you are interested in commenting in writing on items on the agenda please send an email to
comments@bozeman.net or by visiting the Public Comment Page prior to 12:00pm on the day of the
meeting.
Public comments will also be accepted in-person and through video conference during the appropriate
agenda items.
As always, the meeting will be streamed through the Commission's video page and available in the
City on cable channel 190.
For more information please contact Chris Saunders, csaunders@bozeman.net
This meeting will be held both in-person and also using an online video conferencing system. You
can join this meeting:
Via Video Conference:
Click the Register link, enter the required information, and click submit.
Click Join Now to enter the meeting.
Via Phone: This is for listening only if you cannot watch the stream, channel 190, or attend in-
person
United States Toll
+1 346 248 7799
Access code: 954 6079 2484
This is the time to comment on any matter falling within the scope of the Community
Development Board. There will also be time in conjunction with each agenda item for public
comment relating to that item but you may only speak once per topic.
Please note, the Community Development Board cannot take action on any item which does not
appear on the agenda. All persons addressing the Community Development Board shall speak in a
civil and courteous manner and members of the audience shall be respectful of others. Please
state your name and place of residence in an audible tone of voice for the record and limit your
comments to three minutes.
General public comments to the Board can be found in their Laserfiche repository folder.
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E. Action Items
E.1 U.S. Department of Housing and Urban Development (HUD) 2024-2028 Consolidated
Housing Plan, 2024 Annual Housing Action Plan, and Fair Housing Equity Plan Public
Hearing(Munfrada)
E.2 NEHMU Zone Text Amendment to Modify the City's Development Code to Allow
Apartments as a Permitted Use with No Restrictions in Area on the Second and Subsequent
Floors, and Basements of Buildings, and to Allow Lobbies on the Ground Floor When
Associated with Residential Uses in the NEHMU District (Northeast Historic Mixed Use
District), Application 24225.(Cramblet)
E.3 South Range Crossing (SRX) II Growth Policy Amendment Application to Revise the Future
Land Use Map from Urban Neighborhood to Community Commercial Mixed Use on
Approximately 7.644 acres in Association with a Zone Map Amendment (Application 24196)
on Property Located on the Northeast Corner of South 19th Avenue and Graf Street,
Application 24195(Rogers)
E.4 The South Range Crossing II Zone Map Amendment Requesting Amendment of the City
Zoning Map to Change the Zoning on the Western Half of an Existing Site From R-1
(Residential Low Density District) and R-2 (Residential Moderate Density District) to REMU
(Residential Emphasis Mixed Use) on the Northwest Corner Containing 9.26 Acres, and B-
2M (Community Business District Mixed) on the Southwest Corner Containing 9.12 Acres.
The Subject Site is Located on the East Side of S 19th Avenue Between Arnold Street and
Graf Street, Application 23127.(Cramblet)
F. FYI/Discussions
F.1 Upcoming Items for the August 5, 2024, Community Development Board
Meeting.(Saunders)
G. Adjournment
Having reviewed and considered the staff report, draft ordinance, public comment, and all information
presented, I hereby adopt the findings presented in the staff report for application 24225 and
recommend approval of the NEHMU Zone Text Amendment.
Having reviewed and considered the staff report, application materials, public comment, and all
information presented, I hereby adopt the findings presented in the staff report for application 24196
and move to recommend approval of the South Range Crossing II Zone Map Amendment, with
contingencies required to complete the application processing.
This board generally meets the first and third Monday of the month from 6:00 pm to 8:00 pm.
City Board meetings are open to all members of the public. If you have a disability that requires
assistance, please contact our Acting ADA Coordinator, Max Ziegler, at 406.582.2439 (TDD
406.582.2301).
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Memorandum
REPORT TO:Community Development Board
FROM:Renata Munfrada, Community Housing Program Coordinator
David Fine, Economic Development Program Manager
Brit Fontenot, Economic Development Department Director
SUBJECT:U.S. Department of Housing and Urban Development (HUD) 2024-2028
Consolidated Housing Plan, 2024 Annual Housing Action Plan, and Fair
Housing Equity Plan Public Hearing
MEETING DATE:July 15, 2024
AGENDA ITEM TYPE:Plan/Report/Study
RECOMMENDATION:I move to recommend adoption of the 2024-2028 Consolidated Housing
Plan, 2024 Annual Housing Action Plan, and Fair Housing Equity Plan as
written via Resolution #5604.
STRATEGIC PLAN:4.5 Housing and Transportation Choices: Vigorously encourage, through a
wide variety of actions, the development of sustainable and lasting housing
options for underserved individuals and families and improve mobility
options that accommodate all travel modes.
BACKGROUND:The Consolidated Housing Plan, Annual Housing Action Plan, and Fair
Housing Equity Plan support the work of the Economic Development
Department in the administration of the Community Development Block
Grant (CDBG) fund. The CDBG Entitlement Program provides annual grants
on a formula basis to entitled cities to develop viable urban communities by
providing decent housing and a suitable living environment, and by
expanding economic opportunities, principally for low- and moderate-
income persons.
Eligibility for participation as an entitlement community is based on
population data provided by the U.S. Census Bureau and metropolitan area
delineations published by the Office of Management and Budget. The U.S.
Department of Housing and Urban Development (HUD) determines the
amount of each entitlement grantee's annual funding allocation by a
statutory dual formula which uses several objective measures of community
needs, including the extent of poverty, population, housing overcrowding,
age of housing and population growth lag in relationship to other
metropolitan areas.
The Consolidated Plan is designed to help local jurisdictions assess
affordable housing needs and market conditions, and to make data-driven,
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place-based investment decisions. The consolidated planning process serves
as the framework for a community-wide dialogue to identify housing and
community development priorities that align and focus funding from the
Community Planning and Development (CPD) formula block grant programs,
including the CDBG programs.
UNRESOLVED ISSUES:None at this time.
ALTERNATIVES:As recommended by the Community Development Board.
FISCAL EFFECTS:None at this time.
Attachments:
2024-2029 Consolidated Housing Plan Memo 07.15.24.pdf
2024-2029 Bozeman Consolidated Plan - DRAFT.pdf
2024-2029 Bozeman Fair Housing Equity Plan - DRAFT.pdf
Resolution 5604 - Adoption of the 2024-2029 Consoidated
Plan.pdf
HUD Categories of Eligible Activities.pdf
Report compiled on: June 18, 2024
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Memorandum
REPORT TO: Community Development Board
FROM: Renata Munfrada, Community Housing Program Coordinator
David Fine, Economic Development Program Manager
Brit Fontenot, Economic Development Department Director
SUBJECT: 2024-2028 Consolidated Housing Plan Public Hearing
MEETING DATE: July 15, 2024
AGENDA ITEM TYPE: Action Item
RECOMMENDATION: I move to recommend adoption of the 2024-2029 Consolidated Housing Plan,
2024 Annual Housing Action Plan, and Fair Housing Equity Plan as written.
Background
The Consolidated Plan, Annual Housing Action Plan, and Fair Housing Equity Plan support the work of the
Economic Development Department in the administration of the Community Development Block Grant
(CDBG) fund. The CDBG Entitlement Program provides annual grants on a formula basis to entitled cities
to develop viable urban communities by providing decent housing and a suitable living environment, and
by expanding economic opportunities, principally for low- and moderate-income persons.
Eligibility for participation as an entitlement community is based on population data provided by the U.S.
Census Bureau and metropolitan area delineations published by the Office of Management and Budget.
The U.S. Department of Housing and Urban Development (HUD) determines the amount of each
entitlement grantee’s annual funding allocation by a statutory dual formula which uses several objective
measures of community needs, including the extent of poverty, population, housing overcrowding, age of
housing and population growth lag in relationship to other metropolitan areas.
On August 24, 2023, the City of Bozeman received notification from HUD’s Region VIII office of Community
Planning and Development that the city has the sufficient population to meet the definition of a
Metropolitan City under the CDBG program and is eligible to become what is known as an “entitlement
jurisdiction” and is therefore eligible to receive CDBG funding directly from HUD, rather than applying for
funding through the State of Montana.
The Consolidated Plan (ConPlan) is designed to help local jurisdictions assess affordable housing needs
and market conditions, and to make data-driven, place-based investment decisions. The Consolidated
Planning process serves as the framework for a community-wide dialogue to identify housing and
community development priorities that align and focus funding from the Community Planning and
Development (CPD) formula block grant programs, including the CDBG program.
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2024-2028 Consolidated Housing Plan
The ConPlan guides policy and investment decisions for housing, economic, economic development, and
community development in Montana. It is designed to meet requirements set by HUD and various housing
and community development acts passed by the U.S. Congress. The ConPlan documents needs such as
affordable housing, homelessness, infrastructure, community facilities, and economic development.
The plan consolidates the planning, application, reporting, and citizen participation components of the
formula programs that receive funding from HUD, with specific emphasis on the Community Development
Block Grant (CDBG) program. The plan includes a five-year comprehensive, strategic plan, known as the
“Consolidated Plan for Housing and Community Development.” This strategic plan assesses needs and
current conditions as well as determines priorities and allocated HUD funding.
To meet the minimum requirements set forth by HUD, the ConPlan must include five main components:
1. A description of the lead agency or entity responsible for overseeing the development of the plan
and a description of the process undertaken to develop the plan
2. A housing and homeless needs assessment
3. A housing market analysis
4. A strategic plan
5. A one-year Action Plan
2024 Annual Housing Action Plan
Under the five-year strategic plan, Annual Action Plans (AAP) further detail how the City will use funds to
carry out the programs with the expected resources available, types of activities offered, distribution of
funds, and other actions. In addition to submitting an AAP, the City will submit a Consolidated Annual
Performance and Evaluation Report (CAPER), which documents accomplishments and progress towards
meeting goals and objectives outlined in the ConPlan and corresponding AAP. Each CAPER is submitted to
HUD within 90 days after the close of the annual plan year.
The AAP serves as the application to HUD for funding of the CDBG program. The AAP describes to HUD
any changes or trends in Bozeman’s housing, homeless residents, special needs populations, and
community and economic development needs. The AAP also summarizes the actions Bozeman will take
to support the strategic goals identified in the ConPlan. Completing the ConPlan and AAP helps grantees
determine what activities and organizations to fund in the coming year.
Fair Housing Equity Plan
In 2023, HUD published in the Federal Register a Notice of Proposed Rulemaking entitled “Affirmatively
Furthering Fair Housing.” The rule implements the Fair Housing Act’s statutory mandates that HUD
ensures that recipients of its funding affirmatively further fair housing (AFFH). The AFFH mandate requires
that program participants proactively take meaningful actions to overcome patterns of segregation,
promote fair housing choice, eliminate disparities in opportunities, and foster inclusive communities free
from discrimination.
Program participants must submit to HUD for review and acceptance an Equity Plan that is developed
following community engagement and contains the fair housing analysis, goals, and strategies. An Equity
Plan will be submitted every five years. Program participants are required to incorporate fair housing goals
from the Equity Plans into subsequent planning documents (e.g., Consolidated Plan and Annual Action
Plan).
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Community Engagement Approach
The Consolidated Planning process serves as the framework for a community-wide dialogue to identify
housing and community development priorities that align and focus funding from the CPD formula block
grant programs. Through the ConPlan, grantee jurisdictions engage the community, both in the process
of developing and reviewing the proposed plan, and as partners and stakeholders in the implementation
of the CDBG program. By consulting and collaborating with other public and private entities, grantees can
align and coordinate community development programs with a range of other plans, programs, and
resources to achieve greater impact.
Residents play an important role in improving the quality of life in their neighborhoods and should have
the opportunity to participate in processes that impact their neighborhoods and community. Community
engagement and public involvement helps inform the development of the ConPlan, which will result in
the setting of fair housing goals to increase fair housing choice and provide equal access to opportunity
for all community members. The City will use the fair housing goals and priorities identified by community
members to inform the investment and other decisions made in the Consolidated Planning process.
The Fair Housing Plan (FHP), with inclusive community participation, will result in the setting of fair
housing goals to increase fair housing choice and provide equal access to opportunity for all community
members. The City of Bozeman will then use the fair housing goals and priorities established to inform
the investments and other decisions made in the Consolidated Planning process.
As part of the community engagement process, the City encouraged participation by low- and moderate-
income residents, particularly those living in areas where federal funds are proposed to be used and those
populations who have historically experienced exclusion, including racial and ethnic minorities, limited
English proficient individuals, and individuals with disabilities.
Headed into the citizen participation process, staff recognized that there was overlap between this project
and the engagement we performed through the Belonging in Bozeman Equity and Inclusion Plan. Both
staff and the City Commission shared concerns about marginalized populations having engagement
fatigue, especially after recently sharing similar and stories about vulnerability in housing needs. To avoid
engagement burnout and ensure the City is still meeting HUD requirements, staff focused on
incorporating feedback from the Belonging in Bozeman Plan and meeting with marginalized populations
and protected classes who showed the most acute and serious housing needs.
During the citizen participation process, the City of Bozeman conducted several Resident Focus Groups
which were in-depth and intentional conversations with low- and moderate-income families, seniors,
residents living with disabilities, unhoused residents, and members of protected classes. These
conversations expanded on themes that were developed during the City’s community outreach efforts
during the development of the Belonging in Bozeman (BiB) plan. One of the goals outlined in the BiB plan
was to deepen engagement with underserved communities.
City staff and consultants also engaged in twelve Stakeholder Interviews with representatives from
housing, community development, social services, and economic development organizations to
understand trends and a wider context of issues from service providers. Emphasis was placed on
organizations serving underrepresented, underserved, special needs and minority populations. These
conversations identified community priority areas and goals.
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In addition, the City conducted a Housing and Community Needs Survey that was open to all residents in
Bozeman and Gallatin County to ensure everyone had an opportunity to give feedback on housing issues,
and to allow for participation from residents and marginalized groups who may not have participated in
the focus groups. The survey closed May 10 and over 950 respondents participated. The survey responses
can be found within the Needs Assessment portion of the ConPlan.
Staff also presented to several City Advisory Boards, including multiple presentations to the Economic
Vitality Board, the Community Development Board and the Inter-Neighborhood Council. Each of these
presentations offered community members with the opportunity to provide public comment and learn
more about the ConPlan, the AAP and the FHP.
The City of Bozeman strives to ensure the provision of fair housing throughout the community. As a
recipient of federal funding, the City must affirmatively further fair housing by taking meaningful actions
to overcome patterns of segregation, promote fair housing choice, eliminate disparities in opportunities,
and foster inclusive communities free from discrimination. Federal and state fair housing laws prohibit
discriminatory practices in any industry-related business or transaction that may affect the ability of
protected class members to secure housing and live in the housing of their choice.
Belonging in Bozeman Housing Goals
Bozeman’s Equity Indicators Project found that access to affordable housing was the top need identified
by survey respondents. The Belonging in Bozeman Equity and Inclusion Plan proposed making equitable
and inclusive housing a reality in Bozeman by focusing strategically on homelessness, displacement, aging
in place and universal building accessibility, increasing community knowledge, and lobbying for local
solutions at the state level, so that Bozeman residents of all ages, abilities, and income levels can feel
confident and secure in call Bozeman home. The top housing goals and recommendations laid out in the
plan are to develop a coordinated strategy to address homelessness in the Bozeman area.
Categories of Eligible Activities
HUD awards grants to entitlement community grantees to carry out a wide range of community
development activities directed toward revitalizing neighborhoods, economic development, and
providing improved community facilities and services. At least 70 percent of CDBG funds must be used for
activities that benefit low- and moderate-income persons.
Entitlement communities develop their own programs and funding priorities. However, grantees must
give maximum feasibility priority to activities which benefit low- and moderate-income persons. A grantee
may also carry out activities which aid in the prevention or elimination of slums or blight. Additionally,
grantees may fund activities when the grantee certifies that the activities meet other community
development needs having a particular urgency because existing conditions pose a serious and immediate
threat to the health or welfare of the community where other financial resources are not available to
meet such needs. CDBG funds may not be used for activities which do not meet at least one of the national
objectives.
CDBG funds may be used for activities which include, but are not limited to:
• Acquisition of real property
• Relocation and demolition
• Rehabilitation or residential and non-residential structures
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• Construction of public facilities and improvements, such as water and sewer facilities, streets,
neighborhoods centers, and the conversion of school buildings for eligible purposes
• Public services, within certain limits
• Activities relating to energy conservation and renewable energy resources
• Provision of assistance to profit-motivated businesses to carry out economic development and
job creation and retention activities
Each activity must meet at least one of the following national objectives for the program: benefit low- and
moderate-income persons, prevention or elimination of slums or blight, or address community
development needs having a particular urgency because existing conditions pose a serious and immediate
threat to the health or welfare of the community for which other funding is not available.
Generally, the following types of activities are ineligible:
• Acquisition, construction, or reconstruction of buildings for the general conduct of government
• Political activities
• Certain income payments
• Construction of new housing (with some exceptions)
HUD has published a Guide to National Objectives and Eligible Activities for Entitlement Communities
which contains Categories of Eligible Activities which outlines each of the permissible ususes of CDBG
funding. HUD also publishes an annual CDBG Activity Expenditure Report for each entitlement jurisdiction.
CDBG Allocation
The CDBG statute identifies poverty, neighborhood blight, deteriorated housing, physical and economic
distress, decline, suitability of one’s living environment, and isolation of income groups, among others, as
important components of community development need. The Community Planning and Development
Formula Program Allocations reflect the level of funding approved for the CDBG program in each
community. These annual formula grants provide critical funding for a wide range of activities to address
their most pressing local needs, providing flexible resources to facilitate the creation of affordable housing
development, support homeowners, provide life-saving assistance to people experiencing homelessness,
create jobs, and improve public facilities, community resilience, and local economies.
Entitlement jurisdictions are metropolitan cities with populations of at least 50,000 residents as
determined by the Office of Management and Budget (OMB). When the City of Bozeman surpassed this
threshold, it became entitled to receive CDBG dollars directly from HUD, rather than applying through the
State of Montana. Bozeman is now eligible to receive an earmarked annual allocation each year.
Entitlement communities develop their own programs and funding priorities.
In 2024, the City of Bozeman is eligible to receive $325,859 in CDBG funding. By comparison, the City of
Missoula will get an allocation of $533,969. The City of Billings will collect $651,536 and the State of
Montana will secure $6,172,506 in funds. The City’s allocation will total nearly $1.6 million over the course
of five years.
HUD uses a dual formula to calculate awards. Formula A has a 50% weight on the number of persons in
poverty, a 25% weight on total population, and a 25% weight on the number of overcrowded households.
Formula B has a 50% weight on the number of housing units built before 1940, a 30% weight on the
number of persons in poverty, and a 20% weight on population growth lag from 1960. This dual formula
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enables CDBG dollars to specifically target communities with the most pressing needs and the least ability
to address those needs with their own resources.
Economic Vitality Board Recommendation
A public hearing before the Economic Vitality Board (EVB) was held on June 5, 2024, to provide the public
an opportunity to comment on the plan development process, community engagement strategy, and to
identify other significant housing and community development needs in the city.
The EVB discussed how far the limited funds would go and what types of projects or activities could be
funded with this CDBG allocation and what the scale and impact of those activities might be. The board
stated that the City’s priorities should match the scale of funding and staffing and other resources
available. The EVB supported staff’s recommendation to prioritize transitional and emergency housing for
the unhoused residents living in this community.
The EVB unanimously agreed that addressing the homelessness is a critical need in the community and
that the City should focus on the most at-risk population. The City should target funding at lower AMI
ranges and activities where there are not currently sufficient funding sources. The EVB discussed how
crucial transitional and emergency housing is and that this is an issue that keeps coming up in community
engagement efforts year over year, and that it is important for the City to listen to the community. The
board stated that hundreds of people transition in and out of the current homeless shelter, and that
funding projects to house and support these individuals can be life-changing and even life-saving.
In addition to supporting transitional and emergency housing as a top funding priority, the EVB
recommended that housing rehabilitation and preservation, as well as universal design for the elderly and
persons living with disabilities should be prioritized in the ConPlan and AAP. The board stated that
maintaining existing affordable housing stock prevents displacement of our residents and workforce.
Adequate workforce housing helps small business attract and retain staff and stay open. This supports
local businesses and stabilizes the economy. Similarly, universal design projects help house the elderly
and persons living with disabilities so they can remain independent in the community.
The EVB voted unanimously to recommend that transitional and emergency housing for the unhoused,
universal design for the elderly and persons with disabilities, and housing rehabilitation and preservation
be prioritized in the ConPlan and AAP. Furthermore, the board recommended that CDBG funding be used
to support the unhoused, particularly with transitional and emergency housing in any capacity that is an
allowable use of CDBG.
Sections of Consolidated Plan for Community Development Board Consideration
The ConPlan is designed to help states and local jurisdictions assess their affordable housing and
community development needs and market conditions, and to make data-driven, place-based
investment decisions. The ConPlan is carried out through the AAP, which provides a concise summary of
the actions, activities, and the specific resources that will be used each year to address the priority
needs and specific goals identified in the Plan. The following items are for the Community Development
Board’s consideration.
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AP-35 Projects
The AAP must provide a concise summary of the eligible programs or activities that will take place
during the program year to address the priority needs and specific objectives identified in the Strategic
Plan. The eligible program activity is called a project.
AP-38 Project Summary
The jurisdiction should include enough detail in the plan for each project so that HUD may determine
that the project is an eligible use of the proposed funding source. Each project must be associated with
one or more priority needs and one or more goals. The jurisdiction must use one or more of the Goal
Outcome Indicators to describe the planned accomplishments and indicate a target date for realizing the
accomplishment.
Conclusion
The ConPlan is a guiding document and a tool the City of Bozeman can use to influence how federal
housing and community development dollars are spent in our community. The ConPlan merges into one
process, and one document, all the planning and applicable requirements of the CDBG program. This long-
term plan must be done at least every five years. It must indicate general priorities for allocating CDBG
monies and must describe the rationale for the fund allocation priorities.
The purpose of tonight’s public hearing is the give the public the opportunity to provide feedback to City
staff about the 2024-2029 Consolidated Plan, 2024 Annual Community Housing Action Plan, and Fair
Housing Equity Plan. In addition, the Community Development Board will be asked to provide Action Plan
priority recommendations as well as CDBG funding priorities to City staff and the City Commission.
Recommended Motion Language
“I move to recommend adoption of the 2024-2029 Consolidated Housing Plan, 2024 Annual Housing
action Plan, and Fair Housing Equity Plan as written.”
Alternative Motion Language
“I move to recommend adoption of the 2024-2029 Consolidated Housing Plan, 2024 Annual Housing
action Plan, and Fair Housing Equity Plan with amendments.”
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PREPARED FOR: ADOPTED
City of Bozeman Economic Development Dept. TBD
121 N. Rouse Avenue, Bozeman, MT 59715
www.bozeman.net/departments/economic-development
(406) 582-2300
DRAFT
Community Development Block
Grant (CDBG) Consolidated Plan
for Fiscal Years 2025-2029
What is the Consolidated Plan?: This document is a requirement of the U.S.
Department of Housing and Urban Development (HUD) as a condition of
receiving a direct allocation of Community Development Block Grant (CDBG)
funds. It provides the vision, goals, and plan specifically for allocating CDBG funds
granted to the City by HUD. These funds must benefit low- and moderate-income
households.
This document is not intended to replace the City’s other housing plans, most
notably the Community Housing Action Plan, which provides a comprehensive
strategy across the housing continuum and prioritizes a broader set of resources.
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Consolidated Plan BOZEMAN 1
OMB Control No: 2506-0117 (exp. 09/30/2021)
Executive Summary
ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b)
1. Introduction
This document – the City of Bozeman’s five-year Consolidated Plan for Fiscal Years 2025-2029
(Consolidated Plan) – provides the vision, goals, and plan for allocating federal housing and community
development funds granted to the City by the U.S. Department of Housing and Urban Development
(HUD). These funds must benefit low- and moderate-income households.
HUD block grant funds covered by this plan include:
• Community Development Block Grant (CDBG): CDBG primarily funds community and economic
development activities. Examples of eligible activities include: building and rehabilitating
community centers and nonprofit facilities, improving public infrastructure such as sidewalks
and lighting and roads, supporting skill development and job acquisition for workers, and
providing direct services to eligible individuals. CDBG funds can be used for some housing
activities including home rehabilitation, accessibility improvements to accommodate persons
living with disabilities, and down payment assistance for homebuying – as well as emergency
and disaster response assistance.
2. Summary of the objectives and outcomes identified in the Plan Needs Assessment
Overview
The greatest housing and community development needs in Bozeman identified through the
development of this Plan include:
• More affordable rental housing options, particularly for local workforce;
• More affordable homeownership opportunities;
• More transitional housing and emergency shelter options;
• More accessible housing and supportive housing;
• Increased access to critical community services, such as mental health services, chemical
dependency services, and affordable and available childcare.
The five-year goals established to address housing and community development needs in Bozeman
include:
• Increase, protect and preserve affordable rental and homeownership housing opportunities by
improving access to a diverse set of affordable housing, including but not limited to, naturally
occurring affordable housing (NOAH), supportive housing for seniors and residents living with
disabilities, and accessible housing.
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Consolidated Plan BOZEMAN 2
OMB Control No: 2506-0117 (exp. 09/30/2021)
• Improve housing stability for individuals and households with critical needs, including persons
experiencing or at-risk of homelessness by providing appropriate housing and service solutions
grounded in Housing First approaches, including but not limited to, emergency shelter,
transitional housing, and other supportive services.
• Improve community services by addressing critical needs and promoting equity through
improved or increased access to community programming, including but not limited to, mental
health services, chemical dependency services, and affordable and available childcare.
• Planning and Administration to support the goals articulated above.
3. Evaluation of past performance
The City of Bozeman received notification that it has sufficient population to meet the definition of a
Metropolitan City under the Community Development Block Grant program and is entitled to an annual
formula allocation of CDBG funds in Federal Fiscal Year 2024 on August 24, 2023. As such, this is the
City’s first Consolidated Plan..
4. Summary of citizen participation process and consultation process
The City of Bozeman’s primary goal for community participation is to facilitate engagement
opportunities that allow for a broad and diverse representation of the community to participate in the
development of the plan. Additionally, the City engaged with housing, economic, and other service
agencies, organizations, and experts to gather current information on the needs and priorities of low- to
moderate-income households in Bozeman. Specifically, the City:
• Presented to the City Commission on April 16, 2024 and July 23, 2024. Presented to the
Economic Vitality Board twice over the course of the plan’s development. Presented to the
Inter-Neighborhood Council on June 13, 2024 and the Community Development Board on July
15, 2024. These meetings are open to the public.
• Consulted with representatives from several agencies and organizations to collect specific
feedback on the needs and priorities of the populations they serve.
• Hosted four focus groups with organizations that serve residents living with disabilities, families
and individuals experiencing homelessness
• Developed a community needs survey in English and Spanish to identify the greatest needs in
the residents’ neighborhoods and how they want the City to prioritize federal funding. The City
worked with several service providers and nonprofit organizations to promote the survey.
• Held a 30-day draft public comment period and two public hearings to provide additional
opportunities for residents to provide input and comment on the draft document.
5. Summary of public comments
(NOTE: This section will be completed after the public comment period has concluded and prior to
submission of the final version to HUD. All public comments received will be published in the final draft
and staff responses will be provided if needed).
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Consolidated Plan BOZEMAN 3
OMB Control No: 2506-0117 (exp. 09/30/2021)
6. Summary of comments or views not accepted and the reasons for not accepting them
(NOTE: This section will be completed after the public comment period has concluded and prior to
submission of the final version to HUD. All public comments received will be published in the final draft
and staff responses will be provided if needed).
7. Summary
(NOTE: This section will be completed after the public comment period has concluded and prior to
submission of the final version to HUD).
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Consolidated Plan BOZEMAN 4
OMB Control No: 2506-0117 (exp. 09/30/2021)
The Process
PR-05 Lead & Responsible Agencies 24 CFR 91.200(b)
1. Describe agency/entity responsible for preparing the Consolidated Plan and those
responsible for administration of each grant program and funding source
The following are the agencies/entities responsible for preparing the Consolidated Plan and those
responsible for administration of each grant program and funding source.
Agency Role Name Department/Agency
Lead Agency BOZEMAN
CDBG Administrator BOZEMAN City of Bozeman Economic
Development Department
Table 1 – Responsible Agencies
Narrative
The City of Bozeman’s Economic Development Department administers the Community Development
Block Grant (CDBG) program for the city of Bozeman, Montana. The City has administered the CDBG
Entitlement Program since 2024.
CDBG funds are awarded to the City from the U.S. Department of Housing and Urban Development
(HUD) annual budget on the Federal Fiscal Year (FFY). The FFY24 runs from October 1, 2023 through
September 30, 2024. Program Years (PY) are adopted by each local jurisdiction and can be different than
the FFY. The City of Bozeman Program Year 2024 runs November 1, 2024 through October 31, 2025.
Consolidated Plan Public Contact Information
For more information about Bozeman’s 2024-2028 Consolidated Plan:
• Go-to: https://engage.bozeman.net/consolidatedplan
• Call: 406-582-2258
• Mail/Visit: City of Bozeman, Economic Development Department, 121 N. Rouse Avenue,
Bozeman, MT, 59715
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PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and
91.315(I)
Introduction
This section summarizes how the City of Bozeman coordinates with housing providers, other relevant
government departments and agencies, including the state Continuum of Care, and reviews how the
City consulted with stakeholders during the development of the Consolidated Plan.
Provide a concise summary of the jurisdiction’s activities to enhance coordination between
public and assisted housing providers and private and governmental health, mental health
and service agencies (91.215(I)).
The City works with the Regional Housing Coalition (a Coalition of housing providers, developers, the
business community, and local government) to inform and shape priorities and strategies to address
housing needs. The Regional Housing Coalition hosts a subcommittee called the Unhoused to Housed
Initiative (a committee with representation from homeless service providers and City and County
officials and personnel) that assesses service gaps and develops regional strategies and priorities to
address homelessness. The City works with the Gallatin Behavioral Health Coalition (a Coalition of
healthcare and service providers and local governments) to identify gaps and implement strategies to
address mental health service needs across the community.
The City of Bozeman and Gallatin County do not have a public housing authority. The Human Resource
Development Council of District IX, Inc. (HRDC) has acted as a public housing authority for the City and
County since 1995. HRDC is a Certified Housing Development Organization, Community Development
Corporation, and Community Action Agency. HRDC develops, preserves, owns, and manages affordable
housing, ranging from multi-family properties with HUD subsidies to Low-Income Housing Tax Credit
developments to single and multi-family community land trust homes. HRDC also provides housing
services ranging from emergency shelter to transitional housing to rental assistance to homebuyer
education and down payment assistance. HRDC also administers the Section 8 Housing Choice Voucher
program as a field agent for the State of Montana.
The City of Bozeman and Gallatin County and HRDC work closely to ensure coordination across public
and private housing and service organizations.
Describe coordination with the Continuum of Care and efforts to address the needs of
homeless persons (particularly chronically homeless individuals and families, families with
children, veterans, and unaccompanied youth) and persons at risk of homelessness
The Montana Continuum of Care Coalition (MTCoC) is responsible for local, regional, and statewide
coordination of housing and services for individuals and families experiencing homelessness. The MTCoC
does not provide direct assistance with housing or support services. They work with local service
providers across Montana to help individuals, families, and youth experiencing homelessness. HRDC acts
as the MTCoC Local Coordinator. Pathways MISI is a not-for-profit partnership that supports the success
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of HRDC’s Continua of Care. Pathways offers planning, data, and consulting services that help HRDC plan
for growth and comply with HUD, HMIS, HIPPA and other applicable regulations.
Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in
determining how to allocate ESG funds, develop performance standards and evaluate
outcomes, and develop funding, policies and procedures for the administration of HMIS
City of Bozeman collaborates with HRDC, which manages our region’s CoC services. The Regional
Housing Coalition hosts a subcommittee called the Unhoused to Housed Initiative (a committee with
representation from homeless service providers and City and County officials and personnel) that
assesses service gaps and develops regional strategies and priorities to address homelessness. HRDC, as
the ESG grantee determines how to allocate ESG funds, develop performance standards, evaluate
outcomes, develop funding, policies, and procedures for the administration of HMIS. The City meets
with HRDC on a monthly basis to discuss issues such as homelessness, transitional housing, rapid
rehousing, permanent supportive housing, navigation services, and first-time homebuyer education. The
City also supports HRDC’s year-round shelter.
2. Describe Agencies, groups, organizations and others who participated in the process
and describe the jurisdictions consultations with housing, social service agencies and other
entities
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Agency/Group/O
rganization
Agency/Group/
Organization
Type
What section of
the Plan was
addressed by
Consultation?
How was the Agency/Group/Organization
consulted and what are the anticipated
outcomes of the consultation or areas for
improved coordination?
CHILD CARE
CONNECTIONS
Services –
Children
Needs Assessment
and Strategic Plan
A representative from Child Care Connections
provided input on needs and outcomes during
a stakeholder meeting on Wednesday, April
17, 2024.
MONTANA
HOUSING
COALITION
Other –
Statewide
housing
coalition
Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from Montana Housing
Coalition provided input on needs and
outcomes during a stakeholder meeting on
Wednesday, April 17, 2024.
GROUNDPRINT Planning
Organization
Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from Groundprint provided
input on needs and outcomes during a
stakeholder meeting on Thursday, April 18,
2024.
REACH, Inc. Services –
Persons with
Disabilities
Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from REACH provided input
on needs and outcomes during a stakeholder
meeting on Thursday, April 18, 2024.
BOZEMAN
CHAMBER OF
COMMERCE
Business Leaders Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from the Bozeman Chamber
of Commerce provided input on needs and
outcomes during a stakeholder meeting on
Friday, April 19, 2024.
BRIDGERCARE Services – Health Needs Assessment
and Strategic Plan
A representative from Bridgercare provided
input on needs and outcomes during a
stakeholder meeting on Friday, April 19, 2024.
HAVEN Services –
Victims of
Domestic
Violence
Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from Haven provided input
on needs and outcomes during a stakeholder
meeting on Tuesday, April 23, 2024.
FAMILY PROMISE
OF GALLATIN
VALLEY
Services –
Housing,
Homeless,
Children
Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from Family Promise of
Gallatin Valley provided input on needs and
outcomes during a stakeholder meeting on
Wednesday, April 24, 2024.
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STATE OF
MONTANA
CONTINUUM OF
CARE COALITION
Other –
Statewide CoC
Needs Assessment
and Strategic Plan
A representative from the Montana CoC
provided input on needs and outcomes during
a stakeholder meeting on Thursday, April 25,
2024.
MSU
INNOVATION
CAMPUS
Services –
Education,
Employment,
Business
Leaders
Market Analysis
and Strategic Plan
A representative from the MSU Innovation
Campus provided input on needs and
outcomes during a stakeholder meeting on
Tuesday, April 30, 2024.
HEADWATERS
HOUSING TRUST
Housing Needs Assessment,
Market Analysis,
and Strategic Plan
Two representatives from Headwaters
Housing Trust provided input on needs and
outcomes during a stakeholder meeting on
Wednesday, May 1, 2024.
THE HRDC Services –
Housing,
Homeless,
Education,
Employment,
and Health
Needs Assessment,
Market Analysis,
and Strategic Plan
A representative from HRDC provided input on
needs and outcomes during a stakeholder
meeting on Wednesday, May 1, 2024
GREATER
GALLATIN UNITED
WAY
Services –
Education,
Children, and
Health
Needs Assessment
and Strategic Plan
A representative from Greater Gallatin United
Way provided input on needs and outcomes
during a stakeholder meeting on Tuesday,
June 11, 2024.
GALLATIN
COUNTY
EMERGENCY
MANAGEMENT
Agency –
Emergency
Management
A representative from Gallatin County
Emergency Management provided input on
needs and outcomes during a stakeholder
meeting on Thursday, June 13, 2024.
Table 2 – Agencies, groups, organizations who participated
Identify any Agency Types not consulted and provide rationale for not consulting
All relevant agencies and groups were invited to participate in the development of the Consolidated
Plan; none were intentionally excluded or not invited to participate.
Other local/regional/state/federal planning efforts considered when preparing the Plan
The plans, studies, and community engagement activities conducted by other city departments and
other partners and organizations were consulted during the development of the Consolidated Plan
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appear in the matrix below (Table 3). Relevant information from those documents appears throughout
this Consolidated Plan.
Name of Plan Lead
Organization
How do the goals of your Strategic Plan overlap with the
goals of each plan?
2023 Belonging in
Bozeman Equity Plan
City of
Bozeman
City’s Diversity, Equity, and Inclusion Plan. The
Consolidated Plan goals were developed in alignment
with the Belonging in Bozeman goals.
2020 Community Housing
Action Plan
City of
Bozeman
The Community Housing Action Plan outlines a
partnership framework to address community housing in
Bozeman over the next five years. The CHAP helped to
inform the development of the Consolidated Plan goals.
2020 Bozeman
Community Plan
City of
Bozeman
The City’s General Plan guiding growth and community
development. The Plan helped to inform the
development of the Consolidated Plan goals.
2023 Economic
Development Strategy
City of
Bozeman
This Strategy provides deliberate direction to guide
actions that will evolve over the next five years to meet
dynamic economic and business conditions. The
Consolidated Plan goals were developed in alignment
with the EDS goals.
2020 Bozeman Climate
Plan
City of
Bozeman
Bozeman’s Climate Plan to reduce the City’s GHG
emissions and create a more resilient and equitable
community. The Climate Plan helped to inform the
development of the Consolidated Plan goals.
2019 City of Bozeman
Vulnerability Assessment
and Resiliency Strategy
City of
Bozeman
This Assessment and Strategy helps the City anticipate
how best to adapt to the risks associated with climate
change. This Strategy helped to inform the development
of the Consolidated Plan goals.
Table 3 – Other local / regional / federal planning efforts
Describe cooperation and coordination with other public entities, including the State and any
adjacent units of general local government, in the implementation of the Consolidated Plan
(91.215(l))
The City of Bozeman intends to coordinate with Gallatin County, the Regional Housing Coalition, and the
Montana Housing Coalition in the implementation of the Consolidated Plan.
While the City of Bozeman is creating its Consolidated Plan, Gallatin County is writing a growth policy
including a housing strategy to create a comprehensive, balanced, and equitable housing strategy that
identifies opportunities for Gallatin County to address growing housing challenges. The purpose of the
strategy is to: understand how the housing market has changed across the County; identify what types
of housing people need compared to what the market is providing; and determine roles for the County
to improve hosing access for employees and residents.
By uniting diverse experts and decision-makers – from government leaders to housing developers,
banks, realtors, employers, and more – the Regional Housing Coalition (RHC) ignites collaboration and
21
Consolidated Plan BOZEMAN 10
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innovation to tackle the region’s pressing challenges of housing attainability and affordability. The RHC
informs community members, coordinates diverse partners, and resources, and catalyzes solutions to
address housing stability and attainability in Gallatin County. Through strategic coordination and
alignment, the coalition ensures that resources are leveraged, and every effort is synchronized towards
a common goal.
The Montana Housing Coalition (MHC) advocates for state housing policy that creates homes that
working families, seniors, veterans, and Montanans with disabilities can afford to rent or buy. Legislative
priorities for the MHC include: support of a State Workforce Housing Tax Credit; reauthorization of the
Coal Trust Multifamily Homes Program; and investment in the Housing Montana Fund.
Narrative (optional):
22
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PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c)
1. Summary of citizen participation process/Efforts made to broaden citizen participation
Summarize citizen participation process and how it impacted goal-setting
Public Meetings
The City’s Economic Vitality Citizen Advisory Board (EVB) works with the City’s Economic Development Department on general economic
development, housing, municipal art, and diversity, equity, and inclusion efforts. For the development of this plan, the City engaged with the
following groups:
• City Commission—April 16, 2024 and July 23, 2024
• Economic Vitality Board—April 18, 2024 and June 5, 2024
• Inter-Neighborhood Council—June 13, 2024
• Community Development Board—July 15, 2024
Housing and Community Needs Survey
The City of Bozeman developed a housing and community needs survey for both residents and stakeholders to identify respondents’ greatest
housing, community development, public service, and economic development needs, as well as provide feedback on how the City should
prioritize its funding. The survey was available online from March 25th to May 10th, 2024, in both English and Spanish. Additionally, the survey
was available in hard copy form in English and Spanish. The survey was promoted through email blasts, social media, stakeholder networks, and
community partners and organizations. More than 950 responses to the survey were received. A complete summary of the survey findings can
be found in the Community Engagement Findings report section in the appendix.
Public Hearings
Two public hearings were held at City Council meetings throughout the development of the plan.
• April 16th, 2024 – City Council was given an overview of the Consolidated Plan planning process and community engagement strategy.
The public was asked to provide feedback on the plan development process, community engagement strategy, and other significant
housing and community development needs in the city. A summary of those comments are below.
23
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Several comments were made during this public hearing, including a significant need for more affordable housing. Supportive housing for
people living with disabilities and tiny home communities were noted as housing types needed in Bozeman. Residents also encouraged this
plan to draw on needs and outcomes from previous community engagement efforts, specifically the Belonging in Bozeman plan. Another
resident advocated for the City to host fair housing workshops or provide educational resources about fair housing for residents.
• July 23rd, 2024 – City Council will be given an overview of the draft Consolidated Plan and asked to consider adoption of the plan. This
public hearing will be held during the 30-day public comment period from July 1 to July 31, 2024, to receive final comments and
feedback on the draft Consolidated Plan.
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Citizen Participation Outreach
Sort
Order
Mode of
Outreach
Target of
Outreach
Summary of
response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
1 Housing
and
Community
Needs
Survey
Low- and
moderate-
income
residents,
other
vulnerable
populations.
953 Bozeman residents and
stakeholders responded to the
survey. The survey was open from
March to May 2024.
Findings from the
housing and
community needs
survey are summarized
in Section II of the
City’s Fair Housing Plan
(Appendix to this plan).
All comments were
accepted.
n/a
2 Public
Hearing
Non-
targeted/broad
community
A public hearing before City
Commission was held on April 16,
2024, to provide the public an
opportunity to comment on the
plan development process,
community engagement strategy,
and to identify other significant
housing and community
development needs in the city.
Comments from this
public hearing are
summarized above in
the PR-15 section.
All comments were
accepted.
n/a
3 Public
Hearing
Non-
targeted/broad
community
A public hearing before the
Economic Vitality Board was held
on June 5, 2024, to provide the
public an opportunity to comment
on the plan development process,
community engagement strategy,
and to identify other significant
housing and community
development needs in the city.
Findings from this
public meeting are
summarized in the
Community
Engagement Appendix.
All comments were
accepted.
n/a
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Sort
Order
Mode of
Outreach
Target of
Outreach
Summary of
response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
4 Public
Meeting
Non-
targeted/broad
community
A public meeting was held before
the Inter Neighborhood Council on
June 13, 2024, to provide the
public an opportunity to comment
on the City’s draft Consolidated
Plan.
Comments will be
summarized in the final
version of the
Consolidated Plan.
TBD n/a
5 Public
Hearing
Non-
targeted/broad
community
A public hearing will be held
before the Community
Development Board on July 15,
2024, to provide the public an
opportunity to comment on the
City’s draft Consolidated Plan.
Comments will be
summarized in the final
version of the
Consolidated Plan.
TBD n/a
6 Public
Hearing
Non-
targeted/broad
community
A public hearing will be held
before the City Commission on July
23, 2024, to provide the public an
opportunity to comment on the
City’s draft Consolidated Plan.
Comments will be
summarized in the final
version of the
Consolidated Plan.
TBD n/a
Table 4 – Citizen Participation Outreach
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Needs Assessment
NA-05 Overview
Needs Assessment Overview
The needs assessment examines a variety of housing, homeless, community development, and non-
homeless special needs through an analysis of the most updated Census data and CHAS data. These data
quantify housing problems, such as overcrowding and cost burden and disproportionate needs, and
measure the magnitude of non-homeless special needs populations, including elderly residents, people
experiencing disabilities, or populations with HIV/AIDS.
Between 2009 and 2020, according to American Community Survey (ACS) data, the City of Bozeman
gained 8,010 people, an increase of 20%. The number of households increased by 23%, meaning that
household formation outpaced population growth. This is due to a significant increase in the number of
people in Bozeman who are living in non-family households (2,695 households) compared to a much
smaller increase in the number of families with children (617). This trend is likely driven by the increase
in student population over the last decade. Average household size has remained largely the same
during this time period (2.11 in 2010, 2.17 in 2020).
Median household income has increased by nearly a third over the same time period and is now
$59,695. Between 2010 and 2020, median income increased across racial and ethnic groups, but not
equally: White, non-Hispanic median household income rose by $18,161; American Indian/Alaska Native
median household income rose by $13,931; Hispanic median household income rose by $10,162; and
Black/African American median household income rose by $9,520.
The primary housing needs in Bozeman, as presented in HUD CHAS housing problems data, include:
• Severe housing cost burden, where households pay more than 50% of their household gross
income on housing, is the most common housing problem for renters and owners with incomes
of less than 50% AMI.
• Affordability. The median income in Bozeman has grown 31% since 2009. This has brought with
it affordability challenges for those who have not seen wages keep pace with housing costs—
particularly households living on fixed incomes or with limited ability to work. The challenges of
rising housing costs disproportionately fall on certain resident groups including people with
disabilities, people experiencing domestic violence, single parents with young children, and
people with mental health challenges.
• Homelessness. The 2024 Point-in-Time (PIT) Count identified 409 individuals experiencing
homelessness in Bozeman in January 2024, which accounted for 20% of all residents
experiencing homelessness in the state of Montana identified during this year’s count.
Comparing these data to 2022 5-year ACS data, Hispanic, American Indian and/or Alaska Native,
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and Black/African American residents are all overrepresented in the unhoused population in
comparison to their proportions in Bozeman’s general population.
• Non-homeless special needs. Residents who are victims of domestic violence, have young
children in their households; and/or have past experiences with drug or alcohol addiction face
the highest barriers to finding stable housing. The greatest needs identified for these
populations were more access to supportive housing situations, such as transitional housing and
permanent supportive housing. Additionally, these populations need access to a wide range of
supportive services, including mental health services, life skills/independent living support,
counseling, care management, and accessible transportation to health care facilities and
employment.
The five most critical housing needs in Bozeman identified in the housing and community needs survey
include:
• Homeownership opportunities (84% of survey respondents, n=796);
• Rental housing for low-income renters (75%, n=711);
• Workforce housing (55%, n=525);
• Emergency shelter (38%, n=364); and
• Housing rehabilitation for low-income renters (36%, n=342).
The five most critical community development needs in Bozeman identified in the housing and
community needs survey include:
• Affordable childcare (65% of survey respondents, n=615);
• Mental health services (52%, n=477);
• Supportive services for vulnerable populations (37%, n=353);
• Climate-resilience planning and implementation (33%, n=316); and
• More public transportation options (29%, n=276).
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NA-10 Housing Needs Assessment - 24 CFR 91.205 (a,b,c)
Summary of Housing Needs
The following data provide an analysis of housing problems in the City of Bozeman, as measured by
HUD’s unique Comprehensive Housing Affordability Strategy (CHAS) data.
There are four housing problems reflected in the CHAS data: 1) housing unit lacks complete kitchen
facilities; 2) housing unit lacks complete plumbing facilities; 3) household is overcrowded; and 4)
household is cost burdened.
A household is said to have a housing problem if they have any 1 or more of these 4 problems.
• Overcrowding— more than 1 person per room.
• Severe overcrowding—more than 1.5 persons per room.
• Cost burden—monthly housing costs (including utilities) exceeding 30% of monthly income.
• Severe cost burden—monthly housing costs (including utilities) exceeding 50% of monthly
income.
Population and household growth. The population of the city of Bozeman grew by 20% between 2009
and 2020, with the addition of 8,010 people. Household growth outpaced population growth, increasing
23% overall. This difference was driven by a significant increase in the number of people living in non-
family households (e.g., students) compared to a much smaller increase in the number of families with
children.
Income growth. Median income increased by nearly a third (31%) between 2009 and 2020 and is now
$59,695.
Households by income and type. An estimated 3,385 Bozeman households have incomes of less than
30% AMI (17% of all households), and another 3,250 households have incomes between 31% and 50%
AMI (16% of all households). In sum, a third of households of the city’s households are very low income.
There are approximately 12x as many small family households as large households, and close to twice as
many senior households with younger children, in the city.
Demographics Base Year: 2009 Most Recent Year: 2020 % Change
Population 40,320 48,330 20%
Households 16,575 20,455 23%
Median Income $45,729.00 $59,695.00 31%
Table 5 - Housing Needs Assessment Demographics
Alternate Data Source Name:
American Community Survey
Data Source Comments:
29
Consolidated Plan BOZEMAN 18
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Number of Households Table
0-30%
HAMFI
>30-50%
HAMFI
>50-80%
HAMFI
>80-100%
HAMFI
>100%
HAMFI
Total Households 3,385 3,250 3,620 2,355 7,850
Small Family Households 495 770 1,015 560 3,955
Large Family Households 10 225 60 25 255
Household contains at least one
person 62-74 years of age 285 275 555 320 1,470
Household contains at least one
person age 75 or older 330 220 185 255 395
Households with one or more
children 6 years old or younger 205 505 359 130 469
Table 6 - Total Households Table
Data
Source:
2016-2020 CHAS
Housing Needs Summary Tables
Of the Housing Problems included in Table 7, severe housing cost burden is the most common housing
problem for renters and owners with incomes of less than 50% AMI.
Severe cost burden is most prevalent among 0-30% AMI renters and owners. For renters with incomes
of 30% AMI and higher, cost burden is a more common problem than severe cost burden. The data
show that owners with incomes less than 30% AMI and greater than 50% AMI are more likely to be cost
burdened, while owners with incomes between 30% and 50% are more likely to experience severe cost
burden. Nearly half of homeowners experiencing cost burden have incomes between 51% and 80% AMI,
highlighting the challenges of keeping up with mortgage payments in a high-cost market. In all, 2,950
renters and 645 owners are severely cost burdened, while 2,350 renters and 1,235 owners are cost
burdened.
Compared to cost burden, a significantly smaller proportion of Bozeman’s population experience other
housing problems. Severe overcrowding, defined as more than 1.5 people per room, affects 100 renters
in Bozeman. Similarly, approximately 100 renters are impacted by substandard housing, defined as
lacking complete plumbing or kitchen facilities.
1. Housing Problems (Households with one of the listed needs)
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Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
NUMBER OF HOUSEHOLDS
Substandard
Housing - Lacking
complete
plumbing or
kitchen facilities 60 20 15 20 115 0 0 0 0 0
Severely
Overcrowded -
With >1.51
people per room
(and complete
kitchen and
plumbing) 10 50 40 0 100 0 0 0 0 0
Overcrowded -
With 1.01-1.5
people per room
(and none of the
above problems) 0 4 0 0 4 0 0 10 0 10
Housing cost
burden greater
than 50% of
income (and
none of the
above problems) 2,095 810 45 0 2,950 270 210 110 55 645
Housing cost
burden greater
than 30% of
income (and
none of the
above problems) 230 1,320 745 55 2,350 310 145 595 185 1,235
Zero/negative
Income (and
none of the
above problems) 120 0 0 0 120 70 0 0 0 70
Table 7 – Housing Problems Table
Data
Source:
2016-2020 CHAS
2. Housing Problems 2 (Households with one or more Severe Housing Problems: Lacks kitchen or
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Consolidated Plan BOZEMAN 20
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complete plumbing, severe overcrowding, severe cost burden)
The data in Table 8 shows that renters with incomes below 30% AMI are more likely than other
household types to be affected by housing problems—81% of renters in this income bracket have
housing problems. Once renters reach incomes of 50% AMI and higher, their likelihood of having
housing problems diminishes.
While homeowners are significantly less likely to experience one or more of the four housing problems
compared to renters, the greatest proportion of homeowners who experience at least one or more
housing problem are owners with income between 0-30% AMI—38% of these households face some
type of housing problem.
Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
NUMBER OF HOUSEHOLDS
Having 1 or more
of four housing
problems 2,165 890 105 20 3,180 270 210 120 55 655
Having none of
four housing
problems 500 1,795 2,220 1,180 5,695 445 360 1,175 1,100 3,080
Household has
negative income,
but none of the
other housing
problems 0 0 0 0 0 0 0 0 0 0
Table 8 – Housing Problems 2
Data
Source:
2016-2020 CHAS
Table 3 shows the number of Bozeman households paying more than 30% of their gross household
income for housing, including those who pay more than 50%, defined as severe cost burden. Of the
household types presented in Table 3, Other households, Large Related households, and Small Related
households have the highest rates of cost burden across income ranges (calculated by dividing the
number of cost burdened households by all households for each household group).
For Other households, 84% of households with 0-30% AMI are cost burdened; 78% of 31-50% AMI
households are cost burdened; and 67% of all households with incomes of less than 80% AMI are cost
burdened. For Large households, 100% of households with 0-30% AMI are cost burdened (10
households in total); 60% of 31-50% AMI are cost burdened; and 56% of all households with incomes
less than 80% AMI are cost burdened. For Small Related households, 58% of households with incomes
between 0-30% and 61% of 31-50% AMI households are cost burdened. Cost burden is lowest for elderly
households.
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Consolidated Plan BOZEMAN 21
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3. Cost Burden > 30%
Renter Owner
0-30%
AMI
>30-50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
NUMBER OF HOUSEHOLDS
Small Related 285 470 85 840 125 40 310 475
Large Related 10 135 20 165 0 85 20 105
Elderly 190 235 69 494 304 109 200 613
Other 1,910 1,365 615 3,890 150 115 190 455
Total need by
income
2,395 2,205 789 5,389 579 349 720 1,648
Table 9 – Cost Burden > 30%
Data
Source:
2016-2020 CHAS
Severe cost burden—defined as housing costs exceeding 50% of gross household income—is highly
prevalent among 31-50% AMI households and much less common among 0-30% and 51-80% AMI
households. All Other households with income between 31-50% AMI are severely cost burdened.
Additionally, 40% of Other households with incomes of 80% AMI or less are severely cost burdened.
Severe cost burden is lowest for Large Related and Small Related households.
4. Cost Burden > 50%
Renter Owner
0-30%
AMI
>30-50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
NUMBER OF HOUSEHOLDS
Small Related 0 0 125 125 110 30 0 140
Large Related 0 0 0 0 0 75 10 85
Elderly 170 110 15 295 50 60 85 195
Other 0 1,755 595 2,350 110 0 0 110
Total need by
income
170 1,865 735 2,770 270 165 95 530
Table 10 – Cost Burden > 50%
Data
Source:
2016-2020 CHAS
Overcrowding impacts significantly fewer households that cost burden—approximately 110 renters and
10 owners. By household type, renters are more likely than owners to be living in overcrowded
conditions, and single-family households experience more overcrowding than unrelated and other non-
family households. Data are not available for the number of households with children living in
overcrowded conditions.
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5. Crowding (More than one person per room)
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
NUMBER OF HOUSEHOLDS
Single family
households 10 49 40 0 99 0 0 10 0 10
Multiple,
unrelated family
households 0 0 0 0 0 0 0 0 0 0
Other, non-family
households 0 10 0 0 10 0 0 0 0 0
Total need by
income
10 59 40 0 109 0 0 10 0 10
Table 11 – Crowding Information – 1/2
Data
Source:
2016-2020 CHAS
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
Households with
Children Present 0 0 0 0 0 0 0 0
Table 12 – Crowding Information – 2/2
Data Source
Comments:
Describe the number and type of single person households in need of housing assistance.
The category of “Other” in the Housing Needs Summary tables above includes single persons
households and households of unrelated individuals. The City of Bozeman does not collect specific data
on the housing needs of single-person households nor is this data provided by HUD. To estimate the
number of single person households in need of housing assistance, data was gathered from the 2022 5-
year American Community Survey (ACS) estimates.
According to ACS estimates, 11,971 “non-family” households lived in Bozeman during 2022. Of those
non-family households, approximately 6,321 (53%) are single-person households and the remaining
households (47%) are unrelated persons living together. Single-person households make up 29% of all
households in the city, while family households (married, unmarried, or single parent with children)
make up 46% of households in the city. The remaining 25% are other non-family households.
34
Consolidated Plan BOZEMAN 23
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Single-person households living below the poverty level can be used to estimate the number of single-
person households who have housing needs, as poverty-level households are severely under-housed.
Applying the respective poverty rates of seniors and adults to those living in single-person households,
returns an estimated 14%, or 872 single person households, with housing needs.
As part of the development of the City’s 2019 Community Housing Needs Assessment, an employer
survey was administered to better understand the extent to which the availability of housing may be
impacting employers and business operations. Comments related to single person households included:
• “It’s hard enough for a single person renting a room to afford to live here. Families that are
making the prevailing wage are having an even harder time.”
• “The service industry is traditionally an entry level employer. This makes it very difficult for a
majority of our staff to earn enough to live in Bozeman. Even our mid and upper-level managers
struggle to find housing, especially those who are single parents. Several staff are working two
and three jobs just to get by.”
• “Affordable housing is especially difficult for single parents [to find]…”
• “It took me 3 months to find a place inexpensive enough for a teacher to purchase. Another 3
months trying to find a single mom (a supervisor at MSU) a place she could manage. Both
purchased in Belgrade but work in Bozeman.”
Cost burden can be a significant challenge for single parents, as a single income is stretched by housing,
childcare, and transportation costs. Stakeholders shared that lack of available and affordable childcare
was a significant challenge for single parents. One stakeholder shared that several single parents they
work with have left the workforce because it’s less expensive to watch their children than find reliable
and affordable childcare, if they can find it. In turn, not having employment and income can have
significant impacts on the housing stability of the household. As a result, single parents may have to
locate far from places of employment, job training, and/or schools to find affordable places to live. It
may also force some single parents to compromise on space to afford housing, which can lead to
overcrowding.
Estimate the number and type of families in need of housing assistance who are disabled or
victims of domestic violence, dating violence, sexual assault and stalking.
Households with disabilities. According to 2022 5-year ACS estimates, an estimated 5,115 residents live
with mental, physical, and/or developmental disabilities in Bozeman. Among these residents, an
estimated 20%, or 1,018, have housing needs based on the share that live below the poverty level.
Stakeholders shared that residents living with disabilities, regardless of age or level of care needed,
would benefit from more affordable and accessible housing available in the community. As such, the
primary recommendation coming out of the Disability Community Liaison Report for the City’s Belonging
in Bozeman Equity and Inclusion Plan was to encourage and promote construction of affordable,
inclusive, barrier-free dwellings that improve equitable access to housing.
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Consolidated Plan BOZEMAN 24
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Disability is closely correlated with aging, and, as such, Bozeman residents over the age of 65 are more
likely than other age groups to report a disability.
Victims of domestic violence, dating violence, sexual assault, and stalking. According to a stakeholder
who works for a local organization serving residents impacted by domestic violence, sexual assault, sex
trafficking, and stalking, between July 2022 and June 2023, 1,232 unique individuals were assisted by the
organization. This stakeholder also noted that while the number of people who have reached out to
their organization over the last few years has continued to increase, they estimated that a larger
proportion of the population than they currently serve are in domestic violence situations.
According to the National Intimate Partner and Sexual Violence Survey, an estimated 3.1% of women a
year and 3% of men in the United States experience domestic violence, sexual violence, and stalking.
Applying this rate to Bozeman, this equates to 780 women and 850 men who would have experienced
intimate partner and sexual violence in 2022. Of these victims, 13.4% of women and 5.3% of men will
need housing assistance at some point according to Center for Disease Control (CDC) estimates – or
approximately 150 survivors who need housing assistance.
According to the 2024 Point-in-Time Count, 40 people experiencing homelessness in Bozeman are adult
survivors of domestic violence, which accounts for approximately 10% of residents experiencing
homelessness. A stakeholder shared that there is an emergency shelter in the community available
specifically for survivors of domestic violence, which offers 40 beds among 30 rooms. Related to housing
assistance, this stakeholder also shared that a direct subsidy/financial resources for rental assistance
would be most helpful for this population.
What are the most common housing problems?
A household is said to have a housing problem if they have any one or more of these four problems:
• Overcrowding – More than 1 person per room.
• Severe overcrowding – More than 1.5 persons per room.
• Cost burden – Monthly housing costs (including utilities) exceeding 30% of monthly income.
• Severe cost burden – Monthly housing costs (including utilities) exceeding 50% of monthly
income.
According to HUD CHAS data, 53% of Bozeman renter households with incomes of 80% AMI and less
spend more than 30% of their income on housing costs and , as such, are cost burdened. Over a quarter
of these households (27%) pay more than 50% of their income on housing costs and are severely cost
burdened. A total of approximately 5,400 low-income households are cost burdened with 2,770 severely
cost burdened. Cost burdened disproportionately impacts renter households: 5,389 low-income renter
households are cost burdened compared to 1,648 low-income owner households.
The discrepancy between wages and housing costs compounds cost burden experienced by households
in Bozeman. According to the 2023 National Low Income Housing Coalition Out of Reach report for
Gallatin County, the necessary hourly wage to afford a two-bedroom fair market rental is $22.38 per
36
Consolidated Plan BOZEMAN 25
OMB Control No: 2506-0117 (exp. 09/30/2021)
hour and the minimum wage for the state of Montana is $9.95. This means that renters earning
minimum wage need to work 90 hours a week (2.25 jobs) in order to afford a two-bedroom fair market
rental.
Are any populations/household types more affected than others by these problems?
According to CHAS data, both Other and large households have the highest rates of cost burden: 67% of
“Other” and 56% of “large related” households under 80% AMI face cost burden. This compares to 27%
of elderly housing facing cost burden.
The proportion of households impacted by cost burden and severe cost burden is highest for households
in lower income brackets. Households with incomes between 0-30% AMI face very high rates of cost
burden: 84% of Other households (1,910 households), 58% of small related households (285
households), and 100% of large households (10 households) with 0-30% AMI income are cost burdened.
Additionally, 78% of Other households (1,365 households), 61% of small related households (470
households), and 60% of large related households (135 households) with income between 31-50% AMI
are cost burdened. Additionally, 100% of Other households (1,755 households) with income between
31-50% AMI experience severe cost burden.
Elderly households are less likely to experience cost burden, even households with income between 0-
30% AMI, because they are more likely to be homeowners compared with other groups.
For all housing problems, renter households with incomes of 0-30% AMI are far more likely than others
to face problems: 81% have at least one housing problem, compared to 33% of 31-50% AMI renters, 5%
of 51-80% AMI renters, and 2% of 81-100% renters. Renters with income between 0-30% AMI are more
likely to have housing problems compared with owners in the same income range. However, a greater
proportion of homeowners with incomes between 31-50% AMI (37%), 51-80% AMI (9%), and 81-100%
AMI (5%) are more likely to experience at least one housing problem compared to renters in the same
income range.
Describe the characteristics and needs of Low-income individuals and families with children
(especially extremely low-income) who are currently housed but are at imminent risk of
either residing in shelters or becoming unsheltered 91.205(c)/91.305(c)). Also discuss the
needs of formerly homeless families and individuals who are receiving rapid re-housing
assistance and are nearing the termination of that assistance
Severe cost burden can be used as a proxy for households with imminent risk of either residing in
shelters or becoming unsheltered. According to HUD CHAS data, 2,770 renters and 530 owners are
severely cost burdened. A portion of these renters are likely students at Montana State University and
may face a lower risk of houselessness because they have family support and/or can rely on college
savings accounts to manage housing costs.
The community survey conducted for this study collected resident input on the populations with the
greatest housing needs and priorities. The responses to this question can be a proxy for which low-
37
Consolidated Plan BOZEMAN 26
OMB Control No: 2506-0117 (exp. 09/30/2021)
income populations are most at risk of becoming homeless. According to the survey, the populations
with the greatest housing needs include:
• Low- to moderate-income populations (78% of survey respondents chose this option);
• Unhoused populations (62%)
• Local workforce (56%)
• Residents experiencing mental health challenges (40%); and
• Residents living with disabilities (36%).
Stakeholders also shared the characteristics and needs of low-income individuals and families with
children who are currently housed but are at imminent risk of residing in shelters or becoming
unsheltered.
One stakeholder that works for an organization serving families experiencing homelessness or at-risk of
homelessness shared that a lot of the families they assist struggle with financing their household
expenses and managing their money. They added that a lot of clients they serve are working in lower-
paying jobs and can’t find any housing that is affordable to them. This client also shared that “a lot of
these families are $400 away from experiencing homelessness.” Monolingual Spanish-speaking
households, as well as Native American households, were mentioned as a subset of unhoused families
with children that disproportionately experience more housing challenges than other populations.
Additionally, single parents, particularly those experiencing domestic violence, also have a greater
likelihood of falling into homelessness. One stakeholder shared that their organization sees a lot of
survivors fall into homelessness because they are not the primary income earners in their home, adding
that “if an abuser ends up getting arrested, then the survivor runs the risk of being evicted for not
paying their bills.” This stakeholder added that the cost of childcare is also a significant barrier in this
population securing safe and affordable housing.
Families with lower levels of education attainment, limited work experience, and without an economic
safety net are vulnerable to housing instability, especially if couples separate. As shown in the MA-45 –
Educational Attainment section (Table 51), the median household income for earners with a high school
degree is $36,437 per year. Affording rent and childcare for young children with low earnings is very
challenging in the current housing market, and doing so with one income is nearly impossible.
The 2024 Point-in-Time Count reported that 195 individuals experiencing homelessness were identified
as living in family households; however, this is likely an undercount of the true number of families
experiencing homelessness. Low-income families and families with children at imminent risk of
homelessness are underrepresented in such statistics because these families are difficult to identify.
They may be living in overcrowded conditions with friends or family, or residing with an abusive family
member/partner to remain housed. Undocumented, refugee, and/or immigrant families may prefer to
remain unidentified and not participate in surveys.
HRDC provides rapid rehousing assistance via a small grant from HUD CoC funding. As such, there is a
limited pool of funding for this type of assistance. Per HRDC:
38
Consolidated Plan BOZEMAN 27
OMB Control No: 2506-0117 (exp. 09/30/2021)
• In 2022, four families received rapid rehousing assistance—three maintained their housing
following the rapid rehousing assistance, while one family received an eviction due to lease
violations.
• In 2023, eight families received rapid rehousing assistance—seven maintained their housing
following the rapid rehousing assistance, while one family received an eviction due to lease
violations.
• In 2024, three families received rapid rehousing assistance so far and all have maintained their
housing following the rapid rehousing assistance.
While the sample size is small, nearly all families in Bozeman who have utilized rapid rehousing
assistance over the last three years have maintained their housing. Stakeholders felt that these rapid
rehousing resources helped to stabilize families’ housing and financial situations and that having more
of these specific resources would help keep more families at-risk of experiencing homelessness housed.
If a jurisdiction provides estimates of the at-risk population(s), it should also include a
description of the operational definition of the at-risk group and the methodology used to
generate the estimates:
The City of Bozeman adheres to HUD’s criteria for defining homelessness to identify those at imminent
risk of homelessness risk of homelessness. This is category two within the homeless definition, which is
an individual or family who will imminently lose their primary nighttime residence, provided that:
• (i) Residence will be lost within 14 days of the date of application for homeless assistance;
• (ii) No subsequent residence has been identified; and
• (iii) The individual or family lacks the resources or support networks needed to obtain other
permanent housing.
Specify particular housing characteristics that have been linked with instability and an
increased risk of homelessness
There are many reasons that individuals and families fall into homelessness. Homelessness is
increasingly related to rapidly rising rental housing costs relative to incomes; very limited and low
production of affordable housing units; conversion of housing stock to vacation and recreational use;
and few resources to serve low-income households – such as long-term rental assistance – relative to
demand. Primary social factors include domestic violence; prior history of eviction or foreclosure; bad
credit history; past justice involvement or chemical dependency; mental illness; and discrimination,
especially for youth identifying as LGBTQIA+.
39
Consolidated Plan BOZEMAN 28
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2)
Introduction
According to HUD, disproportionate need refers to any need for a certain race/ethnicity that is more
than 10 percentage points above the demonstrated need for the total households within the jurisdiction
at a particular income level. The tables and analyses below identify the share of households by
race/ethnicity and income level experiencing one or more of the four housing problems outlined by HUD
guidelines. The four housing problems are:
1. Housing unit lacks complete kitchen facilities
a. A complete kitchen consists of a sink with a faucet, a stove or range, and a refrigerator
2. Housing unit lacks complete plumbing facilities
a. Complete plumbing consists of hot and cold running water, a flush toilet, and a bathtub
or shower
3. More than one person per room (overcrowded)
4. Housing is cost burdened
a. Between 30-50% of income is devoted to housing costs.
In the following tables, income is grouped as follows:
• 0-30% AMI is extremely low income;
• 31-50% AMI is low income;
• 51-80% AMI is moderate income; and
• 81-100% AMI is middle income.
0%-30% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,975 405 0
White 2,635 325 0
Black / African American 10 10 0
Asian 80 0 0
American Indian, Alaska Native 45 0 0
Pacific Islander 0 0 0
Hispanic 115 70 0
0 0 0 0
Table 13 - Disproportionally Greater Need 0 - 30% AMI
Data Source Comments:
*The four housing problems are:
40
Consolidated Plan BOZEMAN 29
OMB Control No: 2506-0117 (exp. 09/30/2021)
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per
room, 4.Cost Burden greater than 30%
30%-50% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,565 690 0
White 2,345 595 0
Black / African American 0 0 0
Asian 20 20 0
American Indian, Alaska Native 30 0 0
Pacific Islander 0 0 0
Hispanic 90 0 0
0 0 0 0
Table 14 - Disproportionally Greater Need 30 - 50% AMI
Data Source Comments:
*The four housing problems are:
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per
room, 4.Cost Burden greater than 30%
50%-80% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 1,565 2,060 0
White 1,445 1,915 0
Black / African American 25 0 0
Asian 0 4 0
American Indian, Alaska Native 35 70 0
Pacific Islander 0 0 0
Hispanic 15 65 0
0 0 0 0
Table 15 - Disproportionally Greater Need 50 - 80% AMI
Data Source Comments:
*The four housing problems are:
41
Consolidated Plan BOZEMAN 30
OMB Control No: 2506-0117 (exp. 09/30/2021)
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per
room, 4.Cost Burden greater than 30%
80%-100% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 315 2,040 0
White 315 1,895 0
Black / African American 0 0 0
Asian 0 75 0
American Indian, Alaska Native 0 4 0
Pacific Islander 0 0 0
Hispanic 0 60 0
0 0 0 0
Table 16 - Disproportionally Greater Need 80 - 100% AMI
Data Source Comments:
*The four housing problems are:
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per
room, 4.Cost Burden greater than 30%
Discussion
This section highlights the disproportionate housing needs of racial and ethnic groups by income
category in Bozeman based on a unique analysis of CHAS data provided by HUD. The narrative draws on
the NA-15 Disproportionately Greater Needs tables. Discussions by income category include racial and
ethnic groups within which data represent 20 or more households.
0-30% AMI. At this income level, 88% of households have one or more of four housing problems. Most
households experience housing problems in each racial and ethnic group except for Black/African
American households, where half of households have housing problems; it should be noted that this
population group is very small (20 households) relative to other population groups. The groups with the
highest share of households with housing problems are Asian (100%) and American Indian, Alaska Native
(100%). These groups have disproportionately high needs compared to non-Hispanic White households.
30-50% AMI. The share of households with housing problems remains high for this income group at
79%, and high shares (80% to 100%) of households in all racial and ethnic groups face housing problems
except for Asian households (50%). Compared to non-Hispanic White households, American Indian,
Alaska Native and Hispanic households have disproportionately high needs.
50-80% AMI. In this income group, 43% of households have housing problems—much lower than the
share of lower income groups with housing problems. The share of Black/African American households
with housing problems is disproportionately high at 100%, while Hispanic households have housing
problems at the lowest rate (19%).
80-100% AMI. This income group has the smallest share of households with housing problems, with
about 13% of households having one or more housing problems. The share of households with housing
42
Consolidated Plan BOZEMAN 31
OMB Control No: 2506-0117 (exp. 09/30/2021)
problems is 14% for non-Hispanic White households and 0% for Asian; American Indian, Alaska Native;
and Hispanic households.
43
Consolidated Plan BOZEMAN 32
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205
(b)(2)
Introduction
This section draws on the HUD definition of severe housing needs and uses HUD-prepared housing
needs data. The tables separate severe housing needs by racial and ethnic group and income. Severe
housing needs are:
• Housing lacks complete kitchen facilities; • Housing lacks complete plumbing facilities; • Household has more than 1.5 persons per room; and • Household cost burden exceeds 50%.
Disproportionate need is revealed when members of a racial or ethnic group experience housing
problems at a greater rate than the category of need as a whole. For example, if 30% of renters in the
city experienced cost burden, but Black households faced the problem at a rate of 50%, then this would
indicate that Black households have a disproportionately greater need.
As specified in 91.205(b)(2), 91.305(b)(2), and 91.405, the Consolidated Plan must include an
assessment for each disproportionately greater need. The tables show need by racial and ethnic group
and the jurisdiction as a whole to compare experiences.
In the following tables, income is grouped as follows:
• 0-30% AMI is extremely low income;
• 31-50% AMI is low income;
• 51-80% AMI is moderate income; and
• 81-100% AMI is middle income.
0%-30% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,435 945 0
White 2,140 820 0
Black / African American 10 10 0
Asian 65 15 0
American Indian, Alaska Native 25 20 0
Pacific Islander 0 0 0
Hispanic 115 70 0
0 0 0 0
Table 17 – Severe Housing Problems 0 - 30% AMI
Data Source Comments:
*The four severe housing problems are:
44
Consolidated Plan BOZEMAN 33
OMB Control No: 2506-0117 (exp. 09/30/2021)
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per
room, 4.Cost Burden over 50%
30%-50% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 1,100 2,155 0
White 995 1,945 0
Black / African American 0 0 0
Asian 20 20 0
American Indian, Alaska Native 0 30 0
Pacific Islander 0 0 0
Hispanic 55 40 0
Other 0 0 0
Table 18 – Severe Housing Problems 30 - 50% AMI
Data Source Comments:
*The four severe housing problems are:
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per
room, 4.Cost Burden over 50%
50%-80% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 225 3,395 0
White 180 3,175 0
Black / African American 0 25 0
Asian 0 4 0
American Indian, Alaska Native 0 105 0
Pacific Islander 0 0 0
Hispanic 0 85 0
Other 0 0 0
Table 19 – Severe Housing Problems 50 - 80% AMI
Data Source Comments:
45
Consolidated Plan BOZEMAN 34
OMB Control No: 2506-0117 (exp. 09/30/2021)
*The four severe housing problems are:
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per
room, 4.Cost Burden over 50%
80%-100% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 75 2,280 0
White 75 2,140 0
Black / African American 0 0 0
Asian 0 75 0
American Indian, Alaska Native 0 4 0
Pacific Islander 0 0 0
Hispanic 0 60 0
Other 0 0 0
Table 20 – Severe Housing Problems 80 - 100% AMI
Data Source Comments:
*The four severe housing problems are:
1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per
room, 4.Cost Burden over 50%
Discussion
This discussion highlights the disproportionately severe housing needs of racial and ethnic groups by
income category. The narrative draws on the NA-20 Severe Housing Problems tables. Discussions by
income group include racial and ethnic groups within which data represent 20 or more households.
0-30% AMI. In this income group, Asian and non-Hispanic White households have the largest shares of
households with severe housing needs, and these are similar to the share of households overall who
face severe needs (72%). Black/African American households have the smallest share of households with
needs (50%); it should be noted that this population group is very small (20 households) relative to other
population groups.
30-50% AMI. This income group has a smaller share of households with needs at 34% of households
overall. Disproportionately large shares of Hispanic and Asian households have severe housing needs at
58% and 50%, respectively. American Indian, Alaskan Native households had the smallest share of
households with severe housing problems at 0%.
50-80% AMI. The share of households with severe needs continues to decline for this income group with
6% of all households facing severe needs. Non-Hispanic White households have the highest shares of
households with severe needs in this income group (5%) and 0% of Asian; American Indian, Alaska
Native; Black/African American; and Hispanic households have severe needs.
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80-100% AMI. At this income level, only 3% of households have severe housing problems. Non-Hispanic
White households have the highest shares of households with severe needs in this income group (3%)
and 0% of Asian; American Indian, Alaska Native; and Hispanic households have severe needs.
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NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2)
Introduction:
This section analyzes data on households experiencing cost burden disproportionately by race and
ethnicity. Housing cost burden exists when a household pays more than 30% of their gross household
income toward housing costs, including utilities. Severe housing cost burden occurs when households
spend more than 50% of their gross household income.
Disproportionate need is revealed when members of a racial or ethnic group experience housing
problems at a greater rate than the category of need as a whole. For example, if 30% of renters in the
city experienced cost burden, but Black households faced the problem at a rate of 50%, then this would
indicate that Black households have a disproportionately greater need.
As specified in 91.205(b)(2), 91.305(b)(2), and 91.405, the Consolidated Plan must include an
assessment for each disproportionately greater need. The tables show need by racial and ethnic group
and the jurisdiction as a whole to compare experiences.
In the following tables, income is grouped as follows:
• 0-30% AMI is extremely low income;
• 31-50% AMI is low income;
• 51-80% AMI is moderate income; and
• 81-100% AMI is middle income.
Housing Cost Burden
Housing Cost Burden <=30% 30-50% >50% No / negative
income (not
computed)
Jurisdiction as a whole 12,730 3,850 3,690 190
White 11,605 3,610 3,300 125
Black / African
American
35 35 0 0
Asian 320 15 85 0
American Indian,
Alaska Native
95 85 25 0
Pacific Islander 0 0 0 0
Hispanic 385 55 170 70
Table 21 – Greater Need: Housing Cost Burdens AMI
Data
Source:
2016-2020 CHAS
Discussion: About one-fifth of total households and non-Hispanic White households are cost burdened.
Black/African American and American Indian, Alaska Native households face disproportionately high
rates of cost burden at 50% and 41% respectively, while cost burden is lowest for Asian households at
under 4%. Another 18% of total households and non-Hispanic White households are severely cost
burdened, and no racial group faces disproportionately high severe cost burden. Hispanic households
have the highest rate of severe cost burden at 28%, while Black/African American households have the
lowest rate of severe cost burden at 0% (though it should be noted that only 20 Black/African American
households were represented in the data).
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NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2)
Are there any Income categories in which a racial or ethnic group has disproportionately
greater need than the needs of that income category as a whole?
Disproportionate housing needs exist when members of a racial or ethnic group experience housing
problems at least 10 percentage points higher than the category of need as a whole. For example, if 30%
of renters in the county experienced cost burden, but Black households faced the problem at a rate of
50%, then this would indicate that Black households have a disproportionately greater need.
If they have needs not identified above, what are those needs?
In Bozeman, the following groups have disproportionately high rates of housing problems: Asian and
American Indian, Alaska Native households earning 0-30% AMI; American Indian, Alaska Native and
Hispanic households earning 30-50% AMI; and Black/African American households earning 50-80% AMI.
Note that 90 or fewer households are in each of these groups.
Asian and Hispanic households earning 30-50% AMI face severe housing problems at disproportionate
rates. Note that fewer than 60 households belong to each of these groups.
Disproportionate need exists for Black/African American and American Indian, Alaska Native households
experiencing cost burden
Are any of those racial or ethnic groups located in specific areas or neighborhoods in your
community?
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Census tracts with more than 1.4% of Native American residents are considered a concentration. There
are 3 such tracts in Bozeman. Census Tract 7.04, bounded by N Ferguson Avenue to the west, W
Babcock Street to the south, Farmer’s Canal to the east, and Durston Road to the north, has the greatest
concentration of AIAN residents in the city (3.9% of the total tract population). Other census tracts with
concentrations of AIAN residents include Census Tract 6 (3%) and Census Tract 7.01 (1.6%).
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African American/Black residents make up a very small proportion of residents in the city. In this case,
concentrations occur when just 0.9% of residents report their race as African American/Black. There are
two Census tracts in Bozeman that have a concentration of African American/Black residents, both of
which cover the Montana State University campus. African American/Black residents represent 2.2%
and 2.5% of residents in Census Tracts 11.01 and 11.02, respectively.
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NA-35 Public Housing – 91.205(b)
Introduction
There is no public housing authority in the city of Bozeman or Gallatin County and as such, no public housing units. In lieu of a public housing
authority, the city of Bozeman, along with other municipalities in Gallatin, Meagher, and Park counties, is served by the Human Resource
Development Council District IX, or HRDC IX. In addition to providing community development, emergency assistance, transportation, food and
nutrition, and several other services, HRDC administers the housing choice voucher program for the area. As of spring 2024, HRDC administers
approximately 400 tenant-based vouchers and approximately 275 project-based vouchers. Additionally, HRDC administers eight Section 811
vouchers. The organization also manages a portfolio of around 400 units, the majority of which are subsidized. HRDC's leadership in housing
development and preservation is an asset in Bozeman, alongside the organization's programs in housing.
As of spring 2024, there are approximately 1,200 applicants on the waitlist for tenant-based vouchers. Additionally, there is approximately an
18-month wait for applicants wanting to rent a subsidized apartment from HRDC.
Totals in Use
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units vouchers in use 0 38 0 675 275 350 50 0 0
Table 22 - Public Housing by Program Type
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
Data Source: PIC (PIH Information Center)
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Characteristics of Residents
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Average Annual Income 0 6,995 0 10,547 0 10,464 11,426 0
Average length of stay 0 3 0 5 0 5 0 0
Average Household size 0 1 0 2 0 2 1 0
# Homeless at admission 0 11 0 19 0 10 9 0
# of Elderly Program Participants
(>62)
# of Disabled Families
# of Families requesting
accessibility features
# of HIV/AIDS program
participants
# of DV victims
Table 23 – Characteristics of Public Housing Residents by Program Type
Data Source: PIC (PIH Information Center)
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Race of Residents
Program Type
Race Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project
-based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
White 84% 84% 84%
Black/African American n/a n/a n/a
Asian 2% 2% 2%
American Indian/Alaska
Native 4% 4% 4%
Pacific Islander 2% 2% 2%
Other 2% 2% 2%
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
Table 24 – Race of Public Housing Residents by Program Type
Data Source: PIC (PIH Information Center)
Ethnicity of Residents
Program Type
Ethnicity Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
Hispanic 6% 6% 6%
Not Hispanic 94% 94% 94%
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
Table 25 – Ethnicity of Public Housing Residents by Program Type
Data Source: PIC (PIH Information Center)
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Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants
on the waiting list for accessible units:
There are no public housing units in the city of Bozeman. Several stakeholders shared that there is a
significant lack of accessible housing units available in Bozeman. One stakeholder shared that many new
housing developments being built in Bozeman are not accessible, adding that for a resident who needs
both an affordable and accessible unit through HRDC, an applicant can wait for up to two years.
Most immediate needs of residents of Public Housing and Housing Choice voucher holders
Given the city’s tight and expensive rental market, residents with vouchers are experiencing extreme
difficulty in both finding landlords willing to accept vouchers and obtaining affordably priced units.
Stakeholders shared that there are approximately 400 tenant-based vouchers and 275 project-based
vouchers available in the Bozeman area.
According to stakeholder interviews, as of March 2024, the estimated time to find a subsidized property
in Bozeman is 18 months. A stakeholder shared that for HRDC’s tenant-based voucher waitlist, the list
has been dwindling because when vouchers are issued to residents and they can’t find a unit within the
allotted time, they are moved to the bottom of the waitlist. This stakeholder added that understandably,
residents express frustration about not finding a unit and getting moved to the bottom of the waitlist so
they choose to not go back on the waitlist.
The housing and community needs survey found that 6% (45 responses) of respondents utilize a Section
8 housing choice voucher. Of those respondents, 57% reported that it is “somewhat difficult” to find a
landlord that accepts a housing choice voucher while 27% reported that it was “very difficult” to find a
landlord to accept it.
The most common reasons cited for why it is “somewhat difficult or very difficult” to utilize the voucher
include the voucher is not enough to cover the rent for the places the respondent wants to live (21
responses) and the respondent can’t find information about landlords that accept Section 8 (17
responses).
Limited voucher funding, which is set by Congress, has not kept up with demand and rental assistance is
in short supply. According to the “Worst Case Housing Needs 2023 Report to Congress” from HUD’s
Office of Policy Development and Research, just one in four eligible households nationwide received
rental assistance.
How do these needs compare to the housing needs of the population at large
Households utilizing housing choice vouchers are in critical need of affordable housing. According to the
2024 Gallatin Valley Housing Report, in 2020, the rental vacancy rate was “two percentage points below
what is considered healthy for a market with adequate supply, underscoring the tightness in Bozeman’s
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rental market.”1 Recent data and housing survey results shows that the “market tightness” is easing,
however, residents who need to utilize housing choice vouchers are more likely to experience challenges
finding affordable and suitable rental housing. Additionally, increasing inflation disproportionately
impacts low-income households’ ability to afford basic needs compared to the population at large.
Discussion
The lack of accessible and affordable housing units disproportionately impacts residents living with
disabilities and low-income households and families. Due to the lack of affordable units available,
residents are finding it more challenging to actually utilize the voucher once they secure one. While data
indicate that rental market vacancies are easing, constrained rental supply and inflation are
disproportionately impacting low-income households from finding affordable housing and affording
basic needs compared to the population at large.
1 https://www.gallatinrealtors.com/gallatin-valley-housing-report/ (page 32)
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NA-40 Homeless Needs Assessment – 91.205(c)
Introduction:
The city of Bozeman, along with other municipalities in Gallatin, Meagher, and Park counties, are served by Human Resource Development
Council District IX, or HRDC IX. Known colloquially as “the HRDC”, the HRDC is the local Continuum of Care and administers the local Coordinated
Entry System. The HRDC is a partner with the statewide Montana Continuum of Care Coalition and Pathways Community Network Institute,
which provides public data related to all of the state’s Coordinated Entry Systems.
Between May 1, 2023, and May 1, 2024, the statewide HMIS found that 458 unique individuals were identified through Bozeman’s local
Coordinated Entry System. The 2024 Point-in-Time (PIT) Count identified 409 individuals experiencing homelessness in Bozeman in January 2024,
which accounted for 20% of all residents experiencing homelessness in the state of Montana identified during this year’s count. Comparing these
data to 2022 5-year ACS data, Hispanic, American Indian and/or Alaska Native, and Black/African American residents are all overrepresented in
the unhoused population in comparison to their proportions in Bozeman’s general population.
If data is not available for the categories "number of persons becoming and exiting homelessness each year," and "number of
days that persons experience homelessness," describe these categories for each homeless population type (including chronically
homeless individuals and families, families with children, veterans and their families, and unaccompanied youth):
According to the Montana Statewide Continuum of Care’s Homeless Management Information System (HMIS) data dashboard, from May 1,
2023, to May 1, 2024, 458 individuals experiencing homelessness were identified through HRDC’s Coordinated Entry System—432 were unique
individuals. During that same time period, 438 individuals exited HRDC’s Coordinated Entry System and 246 individuals have yet to exit the
Coordinated Entry System.
The State’s HMIS dashboard provides data on the median days to find housing by entry/exit destination. The top five fastest destinations of
finding housing by entry/exit destination where clients answered include:
• Staying or living with family, permanent tenure (31 days)
• Rental by client, no ongoing housing subsidy (69.5 days)
• Staying or living with friends, permanent tenure (71 days)
• Place not meant for habitation (e.g., a vehicle, abandoned building, bus station, etc.) (79.5 days)
• Staying or living with family, temporary tenure (e.g., room, apartment, or house) (92.5 days)
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The top five slowest destinations of finding housing by entry/exit destination where clients answered include:
• Emergency shelter, including hotel or motel paid for with emergency shelter voucher, Host Home shelter (421.5 days)
• Jail, prison, or juvenile detention facility (406 days)
• Residential project or halfway house with no homeless criteria (351 days)
• Owned by client, no ongoing housing subsidy (217 days)
• Rental by client, no ongoing housing subsidy (197.5 days)
Demographics. Of the unique individuals entering HRDC’s Coordinated Entry System from May 1, 2023, to May 1, 2024:
• Age:
o 7% were under the age of 18;
o 16% were between the ages of 18-24;
o 22% were between the ages of 25-34;
o 23% were between the ages of 35-44;
o 23% were between the ages of 45-61;
o 6% were over the age of 62; and
o Data was not collected for 4% of individuals.
• Gender:
o 51% identify as a man;
o 43% identify as a woman;
o .01% identified as non-binary;
o .01% identified as transgender; and
o Collectively, .03% preferred not to answer, identified differently from the presented options, identified as questioning, or data
was not collected for the individual.
Chronic homelessness. Over this time period, 49 individuals were identified as experiencing chronic homelessness—44 were unique individuals.
Of those identified, 19 individuals had yet to exit the Coordinated Entry System. For individuals experiencing chronic homelessness, the top
three fastest destinations of finding housing by entry/exit destination where clients answered include:
• Staying or living with friends, permanent tenure (42 days)
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• Rental by client, no ongoing housing subsidy (98 days)
• Long-term care facility or nursing home (113 days)
The top three slowest destinations of finding housing by entry/exit destination where clients answered include:
• Emergency shelter, including hotel or motel paid for with emergency shelter voucher, Host Home shelter (527 days)
• Jail, prison, or juvenile detention facility (396 days)
• Rental by client, with ongoing housing subsidy (223 days)
Below is a summary of Bozeman's 2024 Point-in-Time (PIT) Count. Overall:
• 192 residents were identified experiencing sheltered homelessness in emergency shelter (47% of residents identified during the PIT
Count);
• 104 residents were identified experiencing sheltered homelessness in transitional housing (25%); and
• 113 residents were identified experiencing unsheltered homelessness (28%).
By household type, 217 residents identified during the count were in adult-only households, 195 residents were in family households, and two
residents were in child-only households. By age, there were 31 residents between the ages of 0-4, 59 residents between the ages of 5-12, and 15
residents between the ages of 13 and 17. Of the unaccompanied youth and children identified during Bozeman’s count, 26 were between the
ages of 18 and 24 and two residents were under the age of 18. Of those identified during the Count that were found to be experiencing chronic
homelessness, 70 residents were identified in adult-only households while 11 residents were in households with children.
Other demographic information provided in the 2024 Count include:
• 25 residents identified as Veterans (6%);
• 125 residents identified living with a disabling condition (31%); and
• 40 residents identified as survivors of domestic violence (10%).
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Nature and Extent of Homelessness: (Optional)
Race: Sheltered: Unsheltered (optional)
White 0 0
Black or African American 0 0
Asian 0 0
American Indian or Alaska
Native 0 0
Pacific Islander 0 0
Ethnicity: Sheltered: Unsheltered (optional)
Hispanic 0 0
Not Hispanic 0 0
Data Source
Comments:
Estimate the number and type of families in need of housing assistance for families with
children and the families of veterans.
According to the 2024 Point-in-Time Count, 195 residents experiencing homelessness identified as living
in family households (48% of all residents identified during the Count). Additionally, two residents were
identified as living in child-only households. As noted earlier in the plan, this is likely an undercount of
the true number of families experiencing homelessness. Low-income families and families with children
at imminent risk of homelessness are underrepresented in such statistics because these families are
difficult to identify. They may be living in overcrowded conditions with friends or family, or residing with
an abusive family member/partner to remain housed. Undocumented, refugee, and/or immigrant
families may prefer to remain unidentified and not participate in surveys.
According to CHAS data, there are 7,284 households in Bozeman with income less than 80% AMI with
housing needs. Applying the proportion of the city’s family households with children under 18 (17.1%)
(46% and 54%, respectively) to this subset of households, there are an estimated 1,246 families with
income less than 80% AMI in need of housing assistance.
Additionally, 25 residents identified during the 2024 Point-in-Time Count (6% of all residents
experiencing homelessness) identified as Veterans. Additionally, between May 1, 2023 and May 1, 2024,
26 Veterans were identified in the local Coordinated Entry System.
Describe the Nature and Extent of Homelessness by Racial and Ethnic Group.
The 2024 Point-in-Time Count reported that 274 residents identified during the Count identified as
White (67% of all residents), while 101 residents identified as Other (11%) and 34 residents identified as
Native American (8.3%). Additionally, between May 1, 2023, and May 1, 2024, Bozeman’s local
Coordinated Entry reported the top five categories of race and ethnicity during this time period as:
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• Non-Hispanic White (47% of respondents);
• Hispanic (11% of respondents);
• Hispanic and White (9% of respondents);
• American Indian, Alaska Native, or Indigenous (8%);
• Black, African American, or African (4%); and
• Data was not collected for 14% of individuals.
Additionally, according to HRDC staff, “since 2020, the HRDC has seen the number of Hispanic residents
it serves rise from 5 percent to 16 percent of the total. Use of the emergency warming shelter by Latino
individuals ‘has gone up significantly since the pandemic,’ however, ‘they remain a small percentage of
the overall guests.’”2
Comparing these data to 2022 5-year ACS data, Hispanic, American Indian and/or Alaska Native, and
Black/African American residents are all overrepresented in the city’s unhoused population in
comparison to their proportions in Bozeman’s general population.
Describe the Nature and Extent of Unsheltered and Sheltered Homelessness.
Stakeholders described that the number of residents experiencing homelessness continues to grow,
with 2024 representing the greatest number of people ever identified experiencing homelessness during
the PIT Counts. In 2024, of the 409 residents identified during the Point-in-Time Count:
• 192 were in emergency shelter (47% of all residents identified during the count);
• 113 were unsheltered (28%); and
• 104 were in transitional housing (25%).
It’s important to note that PIT counts typically significantly underestimate the number of people who
are experiencing homelessness, as those living in precarious housing situations (unsafe conditions,
unsafe partners/roommates, about to be evicted, couch surfing, etc.) are not captured in the traditional
counts. From 2023 to 2024, the number of people experiencing homelessness captured by the PIT Count
for the Bozeman/Livingston area increased by 36%, while the number of people experiencing
unsheltered homelessness increased by nearly 50% (57 people in 2023, 113 in 2024).
Currently, HRDC’s Warming Center currently has 105 beds available; however, Homeward Point, a new
emergency shelter opening in 2025, will add an additional 30 beds and five family suites. HRDC has an
additional 42 units of emergency shelter available for families. Haven, an organization serving survivors
of domestic violence, also recently opened an emergency shelter with 30 units and 40 beds.
Additionally, stakeholders expressed a significant need for more transitional housing options. This
stakeholder shared that from a community perspective, “all the shelter providers have identified
transitional housing as the big need.” They noted that collectively, HRDC, Family Promise and Haven
2 https://www.thenation.com/article/society/bozeman-montana-undocumented-labor/
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have approximately 35 units available; however, collectively, they are not enough to meet demand. A
stakeholder shared there is also a significant need for more permanent supportive housing in Bozeman.
According to this stakeholder, there are only 19 PSH units available to the entire community.
Discussion:
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NA-45 Non-Homeless Special Needs Assessment - 91.205 (b,d)
Introduction:
HUD’s term “special needs” means any population that has greater housing challenges and/or unique
housing needs when compared to low-income households in general. The special needs groups for
which Consolidated Plan regulations require estimates of supportive housing needs include:
• Elderly and frail elderly,
• Persons with disabilities (mental, physical, developmental),
• Persons with alcohol or other drug addictions,
• Persons with HIV/AIDS and their families, and
• Public housing residents.
This Consolidated Plan also includes needs estimates for survivors of domestic violence and
undocumented residents.
Describe the characteristics of special needs populations in your community:
Elderly and Frail Elderly. According to 2022 5-year ACS estimates, there are 6,840 residents in Bozeman
over the age of 62. Of these residents, 243, or 4%, have incomes below the poverty level—a proxy for
housing and service needs. Of the city’s senior population, 688 residents live below the poverty level
and have a self-care disability. Of this population, 24 residents are estimated to have housing and
service needs.
Bozeman residents over the age of 65 are two and a half times more likely than the general population
to have a disability.
Persons with Disabilities. The noninstitutionalized population with a disability in Bozeman totals 5,115.
Of these residents, 20% live below the poverty level and have housing and supportive service needs
according to ACS data—putting those with needs at 1,018 residents.
The needs of residents with disabilities vary depending on the disability, and the level of support
required to provide the same opportunity as non-disabled residents to access and enjoy community
assets. By disability:
• There are 2,035 residents with hearing or vision impairments in Bozeman, and 35%, or 705, have
housing and service needs according to HUD CHAS data.
• 1,365 residents have an ambulatory limitation and 44%, or 594, have housing and service needs.
• 1,535 residents have a cognitive limitation and 43%, or 655, have housing and service needs.
• 1,455 residents have a self-care or independent living limitation, and 43%, or 630, have housing
and service needs.
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Persons with Alcohol or other Drug Addiction. An estimated 10,321 Bozeman residents have some form
of alcohol or drug addiction based on national incidence rates applied to the local population. An
estimated 4,991 residents need and are not receiving treatment for their addiction.
Public housing residents. While there are no public housing units available in Bozeman, stakeholders
articulated that the waitlist for tenant-based vouchers in the Bozeman area is approximately 1,200
residents.
Survivors of Domestic Violence. Based on surveys conducted by the CDC, an estimated 1,415 Bozeman
residents are victims or survivors of domestic violence. Of these, 9%, or 130 residents, will have long-
term housing and service needs associated with the experience of violence.
Undocumented residents. It is difficult to estimate the number of undocumented residents living in
Bozeman. An excerpt from a recent article3 shared that:
“It’s nearly impossible to accurately measure the growth of Bozeman’s Spanish-speaking population
since nearly all the new arrivals are undocumented. In Gallatin County, the Latino proportion of the
population jumped from 2.8% to 5% between 2010 and 2020, according to U.S. census data – a nearly
140% increase. Experts say the estimate is conservative and doesn’t include the years since 2021, the
period of Bozeman’s most explosive housing-market growth.”
What are the housing and supportive service needs of these populations and how are these
needs determined?
Elderly and frail elderly residents. Stakeholders shared several housing and service needs of elderly and
frail elderly populations in Bozeman. Stakeholders noted that a subset of senior residents that own their
homes are being displaced due to rising property taxes. Compounding the displacement of seniors is the
lack of affordable housing options, particularly options to downsize from their current living situation.
This stakeholder shared that “seniors are being priced out of their home because there are no
smaller/other alternatives available.” Another stakeholder shared that the community is seeing a large
spike in the number of seniors experiencing homelessness and that anecdotally, they know a lot of
seniors who have moved into a camper/RV and are now living down the street from HRDC’s shelter.
This stakeholder also added that the window of income eligibility for seniors to live in LIHTC
developments is “really narrow.” They shared that HRDC recently developed 96 senior tax credit housing
units but that seniors who make barely over the eligibility threshold (<60% AMI) are ineligible to live in
the units.
The top housing challenges faced by survey respondents over the age of 65 included:
3 https://montanafreepress.org/2024/05/07/bozemans-boom-depends-on-immigrants-but-struggles-to-support-
them/
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• N/A; I don’t face any of these challenges (64% of respondents);
• I need help taking care of myself/my home and can’t find or afford to hire someone (10%); and
• I worry that if I request a repair it will result in a rent increase or eviction (6%).
Service needs articulated by stakeholders for elderly and frail elderly populations included more access
to mental health service and affordable health care options, as well as more availability of paratransit
services and senior-oriented services and community events.
Disability. Stakeholders overwhelmingly identified the significant lack of affordable and accessible
housing available in Bozeman, which disproportionately impacts residents living with physical
disabilities. One stakeholder shared that one of the greatest challenges to providing more accessible
housing are zoning regulations that require mixed-use developments to have housing on the second
floor and commercial space on the ground floor. They added that for people who have mobility
challenges, “the second floor is dangerous. What if there’s a fire? An elevator isn’t going to do anything
for you. A lot more housing would be available for people with accessibility needs if it was made
available on the ground floor.” Stakeholders also articulated a significant need for mental health
services, energy utility assistance, and more affordable health and dental care services.
The top housing challenges faced by survey respondents living with a disability or with someone
experiencing a disability in their household included:
• I worry that if I request a repair it will result in a rent increase or eviction (19% of respondents);
• N/A; I don’t face any of these challenges (18%);
• My house or apartment isn’t big enough for my family members (16%);
• My home/apartment is in bad condition (14%); and
• My landlord refuses to make repairs despite my requests (9%).
Persons with Drug or Alcohol addiction. Stakeholders described a significant need not only for more
affordable housing options, but for more detox and sober living home facilities to be available in
Bozeman. One stakeholder shared that for residents struggling with drug or alcohol addiction
challenges, having a stable and affordable living situation is critical to ensuring people continue to thrive
on their path to recovery. Greater Impact, Inc., a nonprofit organization that serves residents
experiencing drug or alcohol addiction challenges, currently offers the only sober living home options in
the Gallatin Valley, with one home serving men and two homes serving women.4
Stakeholders also articulated a critical need for more substance abuse/chemical dependency services.
They noted that Alcohol and Drug Services of Gallatin County closed in fall 2023 and as a result, there
“has been a spike in the number of overdose-related deaths in the first part of 2024.”
Survivors of domestic violence. One stakeholder shared that for survivors of domestic violence, “there
can be a lot of barriers to finding housing.” They added that each situation is different and some
4 Second women's sober living home in Bozeman to open soon (kbzk.com)
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survivors are more resourced than others, adding that “we’ve seen a lot of survivors who are not the
primary income earners in their home…if the abuser ends up getting arrested, then the survivor runs the
risk of being evicted for not paying their bills.” The stakeholder added that this dynamic also plays into
cooperating with those prosecuting the crimes of their abusers, adding “if they cooperate and the
abuser goes to jail, then they might end up losing their housing. There’s a lot of nuance that survivors
have to navigate.” This stakeholder shared that direct subsidy/financial resources for rental assistance
and other housing costs would be most helpful for survivors of domestic violence. They added that “if
Bozeman is not able to increase its affordable housing stock, direct subsidy will be the most helpful.”
In addition to financial resources, this stakeholder shared that the availability of more mental health
services, particularly services that are trauma-informed, would be incredibly beneficial for this
population. Additionally, several stakeholders identified more available and affordable childcare options
as a significant need for this population.
Undocumented residents. A handful of stakeholders described the significant housing and service
barriers faced by undocumented residents. One stakeholder shared that because these residents don’t
have social security numbers, they can’t “access a lease or other housing programming.” They added
that they also don’t qualify for any federal programs (e.g. WIC, SNAP, housing assistance), so the only
service HRDC can provide is case management. Another stakeholder shared that they only know of one
property management company that will rent housing units to undocumented residents, adding that
one of the families they work with “has been on the waitlist for that property for two years.”
Stakeholders shared that because these residents can’t find housing through traditional means, they are
either forced into housing that is overcrowded and/or in poor condition.
Several stakeholders pointed to Bienvenidos a Gallatin County as the primary organization assisting
immigrant families in Bozeman. A stakeholder shared that most of these families get all their food from
the foodbank and that “it really all comes down to how they can get income.” They expressed concern
about their available employment options, noting that “they don’t receive healthcare benefits, they
might make $10/hour, and they are vulnerable.” They added that “my biggest fear is that these families
are incredibly desperate which makes them vulnerable to exploitation. And most of them have kids.
They are just looking to make a better life.”
Another stakeholder shared that their organization “could use a lot more resources for immigrant
survivors…[we have a] large and growing Spanish speaking population and we need to be able to
provide more information and awareness about their rights.” They advocated for more translation
services to be made available, adding that “we have a pretty good network of interpreters….translators
would be most helpful.”
Discuss the size and characteristics of the population with HIV/AIDS and their families within
the Eligible Metropolitan Statistical Area:
According to AIDSVu, in 2021, 69 of every 100,000 people in Gallatin County are living with HIV. This rate
is lower than surrounding counties, including Jefferson (83/100K), Madison (88/100K), and Park
(91/100K) counties, as well as the state of Montana (77/100K). Based on the state’s incidence rate of
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people living with HIV and AIDS, there are approximately 35 people in the city of Bozeman living with
HIV/AIDS. However, this is likely an undercount.
AIDS Outreach, an organization serving Gallatin County, offers several services to residents living with
HIV, including individual counseling, financial assistance in the form of food, clothing, shelter, and
medical treatment, and direct outreach and support for families and caregivers.
Similar to other special populations, residents living with HIV/AIDS also have significant housing and
supportive service needs. One stakeholder that provides healthcare services shared that a lot of their
patients report difficulty finding and securing stable housing, adding that “our sense is that cost of living
continues to increase and puts a strain on people with lower incomes, with housing being their largest
cost.” This stakeholder added that even with flexible payment options, “fewer people are coming
in…[they’re] delaying care if they feel they don’t have the funds for it.”
Additionally, this stakeholder shared that for residents living with HIV/AIDS, there is “stigma in accessing
care,” which necessitates more healthcare options that are trauma-informed and inclusive. They added
that “we hear from our clients that have gone into a different healthcare setting and felt judged and
stigmatized, which led them not to return to that provider.” They added that “accessing healthcare in a
non-judgmental compassionate space can be difficult to find….[if people don’t find this], they will forego
care altogether.”
If the PJ will establish a preference for a HOME TBRA activity for persons with a specific
category of disabilities (e.g., persons with HIV/AIDS or chronic mental illness), describe their
unmet need for housing and services needed to narrow the gap in benefits and services
received by such persons. (See 24 CFR 92.209(c)(2) (ii))
N/A. The City of Bozeman does not receive HOME funds.
Discussion:
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NA-50 Non-Housing Community Development Needs – 91.215 (f)
Describe the jurisdiction’s need for Public Facilities:
Overall, public facilities that Bozeman survey respondents most wanted to see include:
• Additional and/or higher quality childcare centers (43% of respondents);
• Improvements to parks and recreation centers (28%); and
• A community center and/or improvements to existing community centers (24% of respondents).
Other comments from survey respondents related to public facilities included:
• “ADA improvements [should be] prioritized above all else. The city follow through with the goals
and recommendations in the Equity & Inclusion plan, which would address all of the community
development outcomes listed.”
• “An Adult Day Care Center that offers quality life enrichment to enhance the quality of life for
persons with dementia and disabilities.”
• “Community park/center with outdoor swimming pool.”
• “We need a community center on the NW side of the city.”
• “Improve indoor centers with activities for homeschool families, events or activities indoors
during winter months for kids/youth.”
Several residents and stakeholders articulated a need for more community centers in the city. One
stakeholder shared that “since the COVID-19 pandemic, it’s been difficult for a lot of community
members to find places to meet people. We need more public spaces that help facilitate these
interactions.”
How were these needs determined?
The City of Bozeman conducted a Housing and Community Needs survey for the development of this
plan, as well as a series of resident focus groups and stakeholder interviews throughout the plan
development process to determine the most urgent community needs.
Describe the jurisdiction’s need for Public Improvements:
Overall, public improvements that Bozeman survey respondents most wanted to see include:
• Street and sidewalk improvements (32% of respondents);
• Improvements to parks and recreation centers (28%);
• A community center and/or improvements to existing community centers (24% of respondents)
Other comments from survey respondents related to public improvements included:
• “Street maintenance – potholes, plowing is a long-term problem in this town that is worse than
other comparable towns….”
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• “Bring back benches please! The disabled and elderly really rely on them.”
• “We need better public transit, pedestrian infrastructure, and biking infrastructure.”
• “Multi-modal transport infrastructure and neighborhood-scale amenities.”
• “Separated bike lanes and shared use paths.”
Several stakeholders shared that a lot of the public infrastructure in Bozeman, including sidewalks,
streets, and parks, are not accessible to residents living with disabilities. One stakeholder articulated
that, “accessing things around the city can be difficult. If our organization receives free tickets to a show
downtown for our clientele with mobility challenges, trying to find parking downtown is incredibly
tough…accessibility is a huge issue.” This stakeholder wanted to see more thought go into building
accessible spaces in the city, citing Story Mill Park as a “great example of accessibility being integrated
into the space.”
How were these needs determined?
The City of Bozeman conducted a Housing and Community Needs survey for the development of this
plan, as well as a series of resident focus groups and stakeholder interviews throughout the plan
development process to determine the most urgent community needs.
Describe the jurisdiction’s need for Public Services:
Overall, the public services that Bozeman survey respondents most wanted to see included:
• Increased access to mental health care services (50% of respondents);
• Climate resilience-focused planning and implementation (37%);
• Increased access to addiction treatment services (34%);
• More recreation options for youth and other special populations (23%)
• Increased access to internet/broadband services (12%)
Other comments from survey respondents related to public services included:
• “More effective snow removal.”
• “Increase Streamline bus service (more frequent).”
In addition to the community survey and stakeholder consultations, an April 2024 article5 quoted
HRDC’s food and nutrition outreach coordinator saying “food insecurity is a thing in our community…it’s
something that we are working to address every day. We’ve had some record numbers recently for visits
to the food bank.” Resident and stakeholders also articulated a desire for expanded transportation
options, including more reliable and frequent bus options, more financial services and life skills classes,
5 https://nbcmontana.com/news/local/hrdc-to-host-food-drive-as-donations-slow-need-rises
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more employment services for harder-to-employ residents to secure jobs, and more tenant rights/legal
aid/fair housing resources.
How were these needs determined?
The City of Bozeman conducted a Housing and Community Needs survey for the development of this
plan, as well as a series of resident focus groups and stakeholder interviews throughout the plan
development process to determine the most urgent community needs.
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Housing Market Analysis
MA-05 Overview
Housing Market Analysis Overview:
Affordable housing is very limited for households earning less than 80% of the AMI, especially those with
incomes lower than 30% AMI. According to a gaps analysis conducted to support this Consolidated Plan,
renters making below $50,000 do not have an adequate supply of affordable housing. There are 5,339
renter households in Bozeman with incomes of $50,000 and less. These renters have 4,899 rental units
that are affordable to them, leaving a gap of 440 affordable rentals or rental subsidies to accommodate
their needs. The gap is largest for renters with who live on fixed incomes, and renters with incomes
between $20,000 and $25,000. The City of Bozeman’s 2019 Community Housing Needs Assessment
found that between 5,400 to 6,340 housing units were needed over the next five years to address the
city’s current housing shortfall for residents and the workforce to keep up with job growth. The Plan
identifies that while community housing should serve the full range of incomes, efforts should focusing
on increasing:
• Ownership housing from 80% to 120% AMI, while also incentivizing the production of missing
middle housing up to 150% AMI;
• Additional resident and employee rentals up to 80% AMI; and
• Safety net rentals below 30% AMI.
As outlined in the 2024 Gallatin Valley Housing Report, “economic expansion plays a pivotal role in
fueling housing demand, with job growth serving as a critical component.” As articulated by residents
and stakeholders throughout the development of this Consolidated Plan, as well as other local and
regional economic development plans, the need to provide a range of affordable housing options is a
critical factor in the continued growth of Bozeman’s economy.
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MA-10 Number of Housing Units – 91.210(a)&(b)(2)
Introduction
As of 2020, 40% of the City’s housing stock was made up of single-family detached homes. The second
most common housing type is multifamily properties with 5-19 units. Properties with 2-4 units make up
16% of the city’s housing stock while single-family attached homes make up 15%. Another 9% is units in
multifamily properties with 20 units or more. Mobile homes represent approximately 2% of the city’s
housing stock.
All residential properties by number of units
Property Type Number %
1-unit detached structure 8,880 40%
1-unit, attached structure 3,295 15%
2-4 units 3,425 16%
5-19 units 3,950 18%
20 or more units 2,002 9%
Mobile Home, boat, RV, van, etc. 505 2%
Total 22,057 100%
Table 26 – Residential Properties by Unit Number
Data Source: 2016-2020 ACS
The City of Bozeman has a homeownership rate of 42%. Approximately 7 in 10 homeowners live in
single family detached homes; 85% have homes with 3 or more bedrooms and 14% live in homes with
two bedrooms. Just 1% of homeowners live in homes with fewer than two bedrooms.
Single family detached homes also provide rental opportunities for residents, with 18% of renters living
in single family detached homes. Rental units with three or more apartments make up approximately
60% of units where renters reside. Renters are much more likely than homeowners to live in units with
one bedroom (15%) or no bedrooms (6%). However, most renters live in two- or three-bedroom homes
(79%).
Unit Size by Tenure
Owners Renters
Number % Number %
No bedroom 20 0.2% 679 6%
1 bedroom 114 1% 1,771 15%
2 bedrooms 1,197 14% 5,715 49%
3 or more bedrooms 7,389 85% 3,572 30%
Table 27 – Unit Size by Tenure
Data Source: 2016-2020 ACS
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Describe the number and targeting (income level/type of family served) of units assisted with
federal, state, and local programs.
The City of Bozeman defines community housing as rental or owned homes that are affordable to
households earning within specific income ranges or for special needs households. According to the
City’s 2019 Community Housing Needs Assessment, a total of 138 community ownership units and 947
affordable community rental units have been constructed in Bozeman. Since the City’s Housing Needs
Assessment, an additional 43 affordable community ownership units and 277 affordable community
rental units have been built.
Of the 181 community ownership units:
• 69 units utilize a land trust mechanism to maintain the below market sales prices for 99 years;
• 20 units were built through the Habitat for Humanity program and are targeted at housing
earning under 50% AMI; however, only eight units remain in the program. The other 12 units
were purchased in full by their owners or sold on the open market.
• Eight (8) units were constructed through the Affordable Housing Ordinance and have a cap on
the initial purchase price to ensure affordability to the target income housing. Upon resale,
homes may be sold at market prices, but any cash subsidy used to ensure affordability to the
initial buyer will be recaptured.
• 84 homes were purchased by HRDC and sold to owners earning between 50% to 120% AMI
through a downpayment program. The homes may be resold at market prices and the
downpayment will be recaptured at resale.
Additionally, the table below presents the affordability levels by income of the existing community
ownership units. Of the 181 community ownership units:
• 46 units were targeted to households with incomes up to 50% AMI;
• 80 units were targeted to households with incomes up to 80%;
• 10 units were targeted to households with incomes up to 100%; and
• 45 units were targeted to households with incomes up to 120%.
Of the 1,224 affordable community rental units:
• Affordable rentals are a mix of low-income housing tax credit (LIHTC), project-based section 8,
MT Board of Housing funding, and non-profit owned properties.
• Two properties are voluntarily operated as affordable rentals, meaning they could charge
market rates. One is owned by a non-profit.
• A total of 357 units (29% of the community rental stock) are limited to occupancy by seniors
and/or persons with disabilities.
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Below is a table that describes the number and targeting (income level/type of family served) of units
assisted with federal, state, and local programs in Bozeman since 2018.6
In addition to the inventory listed above, the following affordable rental housing developments have
been built:
• Housing First Village, 42 units of permanent supportive housing for residents with incomes up
to 50% AMI (Built in 2021);
• Arrowleaf, 76 units of affordable rental housing for residents with incomes up to 60% AMI (Built
in 2021);
• Perennial Park, 97 units of affordable rental housing for residents older than 55 with incomes
up to 60% AMI (Built in 2021);
• Timber Ridge, 30 units of affordable rental housing for residents with incomes up to 60% AMI
*Built in 2023); and
• 30 units of emergency shelter/rental housing for survivors of domestic violence.
6 2019 City of Bozeman Community Housing Needs Assessment, page 46
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With the majority of units in LIHTC developments, 58% of the units in the city’s community rental
housing stock are targeted at households with income of at least 60% AMI. Additionally:
• Less than 1% of units are targeted at households with incomes less than 30% AMI;
• 1% of units are targeted at households with incomes less than 40% AMI;
• 23% of units are targeted to households with incomes up to 50% AMI;
• 13% of units are targeted to households with incomes up to 80% AMI;
• And 8% of units do not have income limits.
Additionally, as of January 2024, the City of Bozeman reported that 17 community housing projects are
currently in the pipeline, totaling an additional 1,241 affordable housing units and 3,715 units overall.
Provide an assessment of units expected to be lost from the affordable housing inventory for
any reason, such as expiration of Section 8 contracts.
Pond Row Apartments (22 units) have an affordability expiration period this year; no other LIHTC
development’s affordability period will expire until at least 2031. However, many more properties are or
will be eligible to apply for a “qualified contract” during this period.
Does the availability of housing units meet the needs of the population?
No. The City of Bozeman’s 2019 Community Housing Needs Assessment found that between 5,400 to
6,340 housing units were needed over the next five years to address the city’s current housing shortfall
for residents and the workforce to keep up with job growth. The Plan identifies that while community
housing should serve the full range of incomes, efforts should focus on increasing:
• Ownership housing from 80% to 120% AMI, while also incentivizing the production of missing
middle housing up to 150% AMI;
• Additional resident and employee rentals up to 80% AMI; and
• Safety net rentals below 30% AMI.
Additionally, to support the Housing Market Analysis of this Consolidated Plan, a “gaps analysis” was
conducted, which compares renter household incomes to the distribution of both affordable rental and
homeownership units. That analysis was based on the 2022 American Community Survey (ACS) data and
reflects housing market conditions during 2022.
According to that gaps analysis, renters making below $50,000 do not have an adequate supply of
affordable housing. There are 5,339 renter households in Bozeman with incomes of $50,000 and less.
These renters have 4,899 rental units that are affordable to them, leaving a gap of 440 affordable
rentals or rental subsidies to accommodate their needs. The gap is largest for renters with who live on
fixed incomes, and renters with incomes between $20,000 and $25,000 (a gap of 1,873 affordable rental
units).
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Additionally, the gaps analysis also looked at the availability of homes for sale that were affordable to
residents at different AMI levels. The analysis found that there are no affordable homes for sale to
households that make less than 120% AMI.
Describe the need for specific types of housing:
The City’s Needs Assessment also found that about 60% of the units needed to be priced “below-
market” to meet the full range of community housing needs. This includes a mix of housing unit types to
diversify options for residents, with prices ranging primarily between $160,000 and $400,000 for
ownership and $500 to $1,200 per month for rent. The gaps analysis also reveals a need for deeply
affordable and permanent supportive housing for the city’s extremely low-income renters, as well as a
need for more affordable homeownership opportunities for households making less than 120% AMI.
More income and deed restricted housing is needed to accommodate this group of renters and
potential buyers.
Specific housing types articulated by residents and stakeholders include a need for more transitional
housing options, more accessible and first-floor housing options for residents living with disabilities,
more housing options that allow older residents to downsize, and smaller-scale, affordable
homeownership opportunities.
Discussion
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MA-15 Housing Market Analysis: Cost of Housing - 91.210(a)
Introduction
Between 2010 and 2022, the median market value of homes in Bozeman, as measured by the American
Community Survey (ACS), increased by 104%. The median value was $546,100 as of 2022, requiring an
annual household income of approximately $164,000 and a downpayment of at least $54,600.
Rents have also increased significantly, rising 96% between 2010 and 2022. The annual household
income needed to afford the median rent and utilities is $58,000. In 2022, 47% of Bozeman’s renters
paid $1,500 or more per month for rent. In 2010, just 6% of renters paid $1,500 or more per month for
rent.
Cost of Housing
Base Year: 2010 Most Recent Year:
2022
% Change
Median Home Value $268,100 $546,100 104%
Median Contract Rent $686 $1,343 96%
Table 28 – Cost of Housing
Data Source: 2010 and 2022 5-year ACS estimates
Rent Paid Number %
Less than $500 279 2
$500-999 2,517 21
$1,000-1,499 3,561 30
$1,500-1,999 3,183 27
$2,000 or more 2,400 20
Table 29 - Rent Paid
Data Source: 2018-2022 ACS
Housing Affordability
Number of Units affordable to
Households earning
Renter Owner
30% HAMFI No Data
50% HAMFI
80% HAMFI
100% HAMFI No Data
Table 30 – Housing Affordability
Data Source: 2016-2020 CHAS
The fair market rents listed in Table 36 represent FY2024 fair market rents.
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Monthly Rent
Monthly Rent ($) Efficiency (no
bedroom)
1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom
Fair Market Rent $901 $999 $1,275 $1,797 $2,164
High HOME Rent $901 $999 $1,275 $1,797 $1,998
Low HOME Rent $901 $999 $1,226 $1,417 $1,581
Table 31 – Monthly Rent
Data Source: HUD FMR and HOME Rents
Is there sufficient housing for households at all income levels?
No. According to the City’s 2019 Community Housing Needs Assessment, between 5,405 and 6,340
housing units for residents and employees were estimated to be needed by 2025 –an average of about
770 to 905 housing units per year. According to the Needs Assessment, about 60% of the housing
needed to be priced below-market, approximately 3,210 to 3,765 units (about 460 to 540 per year).
Specifically, this meant ownership housing priced below $350,000 (150% AMI) and rental units priced
below $1,000 per month (60% AMI). The Needs Assessment articulated that to support the local
workforce, 41% of new units should be targeted for ownership and 59% of units should be targeted for
renters.
As highlighted above, the gaps analysis completed for this plan found that renters making below
$50,000 do not have an adequate supply of affordable housing. There are 5,339 renter households in
Bozeman with incomes of $50,000 and less. These renters have 4,899 rental units that are affordable to
them, leaving a gap of 440 affordable rentals or rental subsidies to accommodate their needs. The gap is
largest for renters with who live on fixed incomes, and renters with incomes between $20,000 and
$25,000 (a gap of 1,873 affordable rental units). The analysis found that there are no affordable homes
for sale to households that make less than 120% AMI.
How is affordability of housing likely to change considering changes to home values and/or
rents?
Between 2009 and 2020, Bozeman’s population has increased by 20%. Over roughly the same time
period, median market value of homes has increased by 104% while rents have increased by 96%.
Market home values and rents have continued to increase alongside the population, suggesting that
people with higher incomes are moving to the area and are able to afford the rising cost of housing.
Therefore, the market is incentivized to accommodate the demand of high-income households. For
these high-income households, affordability may not be a concern. However, for existing residents with
lower incomes, finding and maintaining stable, affordable housing may become less likely as housing
costs outpace their income.
How do HOME rents / Fair Market Rent compare to Area Median Rent? How might this
impact your strategy to produce or preserve affordable housing?
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According to 2022 5-year ACS data, median gross rent for efficiency, one-bedroom, two-bedroom, and
three-bedroom units are all higher than the FY24 Fair Market Rents established by HUD, as well as
HOME High Rents for Gallatin County. This suggests that the payment standards established by HUD are
lower than current market rates in Bozeman for rental units. Consequently, this indicates that the City
will need to continue prioritizing the preservation of existing affordable housing and the production of
new affordable units.
These findings align with feedback from both stakeholders and residents that have articulated that for
residents who are able to secure a housing voucher, the payment standards are too low for the voucher
to cover the remainder of rent after a household pays 30% of their income. Additionally, “voucher is not
enough to cover the rent for places I want to live” was the number one answer articulated by survey
respondents who indicated it was somewhat difficult or very difficult to use a voucher in the Bozeman
area.
Discussion
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MA-20 Housing Market Analysis: Condition of Housing – 91.210(a)
Introduction
This section provides data on the condition of housing units within Bozeman, based on American
Community Survey (ACS) data from 2022. Of owner-occupied units, about a quarter, or 2,372 units, have
a reported condition issue. A small share, just 1% or 54 units, have more than one condition issue.
Seventy five percent of owner-occupied units in Bozeman have no condition issues.
Rental units are much more likely to be in poor condition, with 47% or 5,770 units with one condition
issue. Similar to owner-occupied units, just 1% of the rental housing stock in Bozeman, or 129 units,
have more than one condition issue. Just over half of the city’s rental housing stock have no condition
issues.
Condition issues appear to be somewhat correlated with year built. As described above, rental units are
nearly 2.5 times more likely to have a condition issue compared with owner-occupied units. Between
1950 and 1979, twice as many rental units were built as owner-occupied units. Additionally, between
1980 and 1999, for every one owner-occupied unit built, approximately 1.8 rental units were built.
Homes built before 1980 have the greatest risk of lead-based paint hazard, as the federal government
banned lead from paint beginning in 1978. According to the federal Environmental Protection Agency
)EPA), nationally, 24% of homes built between 1960 and 1977 contain lead-based paint, in addition to
69% of homes built between 1940 and 1950, and 87% of homes built before 1940.
Bozeman has a sizable share of homes built before 1980: nearly a third (32%) of owner-occupied homes
and 35% of renter-occupied homes were built before lead-based paint was banned. There were nearly
one and a half times more rental units built during before 1980 than owner-occupied units (3,066
owner-occupied, 4,316 rental units).
Due to the lack of available data, this analysis did not include an inventory of the suitability of units in
need of rehabilitation.
Definitions
Condition of Units
Condition of Units Owner-Occupied Renter-Occupied
Number % Number %
With one selected Condition 2,318 24% 5,770 47%
With two selected Conditions 54 1% 129 1%
With three selected Conditions 0 0% 0 0%
With four selected Conditions 0 0% 0 0%
No selected Conditions 7,269 75% 6,501 52%
Total 9,641 100% 12,400 100%
Table 32 - Condition of Units
Data Source: 2022 5-year ACS
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Year Unit Built
Year Unit Built Owner-Occupied Renter-Occupied
Number % Number %
2000 or later 4,952 51 5,155 41
1980-1999 1,623 17 2,929 24
1950-1979 1,551 16 3,230 26
Before 1950 1,515 16 1,086 9
Total 9,641 100 12,400 100
Table 33 – Year Unit Built
Data Source: 2022 5-year ACS
Risk of Lead-Based Paint Hazard
Risk of Lead-Based Paint Hazard Owner-Occupied Renter-Occupied
Number % Number %
Total Number of Units Built Before 1980. 3,066 32 4,316 35
Housing units built before 1980 with children present
Table 34 – Risk of Lead-Based Paint
Data Source: 2018-2022 ACS (Total Units) 2016-2020 CHAS (Units with Children present)
Vacant Units
Suitable for
Rehabilitation
Not Suitable for
Rehabilitation
Total
Vacant Units n/a n/a n/a
Abandoned Vacant Units n/a n/a n/a
REO Properties n/a n/a n/a
Abandoned REO Properties n/a n/a n/a
Table 35 - Vacant Units
Need for Owner and Rental Rehabilitation
Housing units built over 30 years ago are more likely to need rehabilitation assistance. Given that 32% of
owner-occupied stock and 35% of renter-occupied stock was built before 1980, a sizable portion of
Bozeman’s housing stock likely has moderate rehabilitation needs. In general, low- and moderate-
income households are more likely to be renters and renters are also more likely to experience
substandard housing conditions. In Bozeman, households in Census Tract 6, which is north of W Peach
Street, east of N19th Avenue, and south of W Griffin Drive, have lower median household incomes and
higher poverty rates compared to the city at-large. According to 2022 5-year ACS data, more than half of
the housing stock in this Tract (53.7%) was built before 1980.
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Estimated Number of Housing Units Occupied by Low or Moderate Income Families with LBP
Hazards
According to CHAS data, an estimated 189 households with children aged 6 or younger live in owner-
occupied homes built before 1980, which are more likely to contain lead-based paint hazards. There are
an estimated 209 households with children aged 6 or younger in renter-occupied units with risk of
exposure to lead-based paint hazards. It is common for households with lower incomes to live in older
housing given that new and updated homes are likely more expensive. Low-income renters may be
more likely to reside in substandard housing that contains lead-based paint hazards, as homeowners
often have more income to remodel and more autonomy over the decision to address potential hazards
in the home.
Discussion
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MA-25 Public and Assisted Housing – 91.210(b)
Introduction
There are no public housing units in the city of Bozeman.
Totals Number of Units
Program Type
Certificate Mod-Rehab Public
Housing
Vouchers
Total Project -based Tenant -based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units vouchers
available 0 38 0 675 275 350 50 0 0
# of accessible units
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
Table 36 – Total Number of Units by Program Type
Data Source: PIC (PIH Information Center)
Describe the supply of public housing developments:
n/a.
Describe the number and physical condition of public housing units in the jurisdiction, including those that are participating in an
approved Public Housing Agency Plan:
n/a.
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Public Housing Condition
Public Housing Development Average Inspection Score
n/a n/a
Table 37 - Public Housing Condition
Describe the restoration and revitalization needs of public housing units in the jurisdiction:
n/a.
Describe the public housing agency's strategy for improving the living environment of low-
and moderate-income families residing in public housing:
n/a.
Discussion:
n/a.
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MA-30 Homeless Facilities and Services – 91.210(c)
Introduction
The 2024 PIT Count counted 296 sheltered and 113 unsheltered homeless individuals in the city of Bozeman. A variety of housing facilities and
services are offered to these homeless individuals by organizations within Bozeman, including the City, HRDC, other community-based
organizations, and health service agencies. Housing facilities include emergency shelters, transitional housing, safe havens, and permanent
supportive housing options. Homeless support services offered within the Bozeman area include: prevention and diversion, outreach, case
management, system navigation and housing location assistance, medical services, employment services, substance use disorder services,
mental health care, public assistance benefits and referrals, and domestic violence support.
Facilities and Housing Targeted to Homeless Households
Emergency Shelter Beds Transitional
Housing Beds
Permanent Supportive Housing
Beds
Year Round Beds
(Current & New)
Voucher /
Seasonal /
Overflow Beds
Current & New Current & New Under
Development
Households with Adult(s) and
Child(ren)
Five family suites
(Homeward Point)
40 beds (Haven)
- 15 units (Family
Promise)
- -
Households with Only Adults 105 beds (HRDC
Warming Center)
136 beds (Homeward
Point -opening 2025)
- 10 units (HRDC) 42 units (Housing
First Village)
19 units
(community
wide)
-
Chronically Homeless Households - - - -
Veterans - - - -
Unaccompanied Youth - - - -
Table 38 - Facilities and Housing Targeted to Homeless Households
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Describe mainstream services, such as health, mental health, and employment services to the
extent those services are use to complement services targeted to homeless persons
Medical and Mental Health Care Services available to the Bozeman community include:
• Community Health Partners – CHP provides medical, dental, behavioral health, and
pharmaceutical services. CHP also institutes a sliding scale payment system for services in use,
and referrals to specialists also are on a sliding scale basis.
• Bridgercare – provides excellent, affordable reproductive and sexual healthcare and education
in a safe environment.
• Gallatin County Health Department – Resources provide by the Health Department include
environmental health, immunizations, WIC nutrition services, emergency preparedness, and
preventative cancer screenings, among other services.
• St. Catherine Family Health Care Clinic – Low cost prenatal care and ultrasounds, free
pregnancy testing, STD testing, and IUD removal. Primary care services, natural family planning,
and sports physicals are also available to residents and families.
• Hope House – Hope House provides a Crisis Stabilization Center for anyone experiencing a
mental health crisis who needs a safe place to go. Hope House also provides case management
and short-term stay for clients.
• Gallatin Mental Health Center – GMHC assists individuals and communities with the challenges
of mental health, substance use, and co-occurring disorders in order to achieve the highest
quality of life. GMHC has sliding scale fees.
• Human Development Clinic – HDC provides quality, low-cost counseling services for the Gallatin
Valley, including individual and group counseling, skill development workshops, and therapy for
families, children, adults, and couples.
• Western Montana Mental Health Center – an integrated community-based mental health
center offering a comprehensive range of services to adults living with mental health conditions
in Montana.
• A.W.A.R.E., Inc. – statewide nonprofit organization that offers quality, community-based
support for people with mental health and/or developmental disabilities and families with
children ages 0 to 8.
• MSU Human Development Clinic – staffed by faculty and graduate students of the counseling
program within the Department of Counseling at MSU, services are offered to members of the
community, as well as students and staff at MSU. Low-cost mental health services to adults and
children of Gallatin County are available.
• Providence Mental Health – Providence works toward alleviating the harmful effects of
traumatic experiences for families and individuals.
In addition to the housing services provided for residents experiencing homelessness in the Bozeman
area, HRDC also provides youth employment support, Medicare counseling, at home assistance for older
adults, and care coordination for older adults. The day services also provide support to unhoused
residents to meet their basic hygiene needs.
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Additionally, employment and adult education services available to the Bozeman community include:
• Bozeman Job Service – Bozeman Job Service provides employment listings, job matching and
training, Veteran resources, and counseling. The Job Service also provides computers, phone,
fax, copying, and printing services for employment searches.
• Vocational Rehab – Promotes work and independence for adults with disabilities. Resources
include job training and placement, counseling, and post-employment services.
• Youth Development @ the HRDC – Jobs skills, resources, and job placement for youth (ages 14-
21, up to 24 years old in some cases).
• Career Transitions – Career Transitions uses a variety of tools to promote job readiness,
including training and computer literacy classes, to ensure successful job placement for
individuals.
• LC Staffing – A staffing agency for those seeking temporary or full-time employment.
• Express Employment – A staffing agency for those seeking temporary or full-time employment.
• Adult Learning Center – A service of Bozeman Public Schools, the ALC provides assistance in HI-
SET preparation (formerly the GED) as well as resume skills, job search help, and basic adult
education.
• Beacon Employment Services – Employment assistance for people with mental and physical
disabilities. Assistance includes resume writing assistance, job search and placement, job
coaching, interview skills development, and benefits counseling.
While there are available mental health services available in the Bozeman community, residents and
stakeholders indicated that the demand for these services far outpaces supply. The majority of
stakeholders consulted for this plan indicated that mental health services was one of the most critical
needs in Bozeman. Additionally, 50% of survey respondents (n=477) indicated that more mental health
services were a critical need for the Bozeman community.
List and describe services and facilities that meet the needs of homeless persons, particularly
chronically homeless individuals and families, families with children, veterans and their
families, and unaccompanied youth. If the services and facilities are listed on screen SP-40
Institutional Delivery Structure or screen MA-35 Special Needs Facilities and Services,
describe how these facilities and services specifically address the needs of these populations.
Montana 2-1-1 provides information and connects people to resources for non-emergency needs, via an
easy-to-remember phone number (2-1-1) and a website (montana211.org).
Facilities
• HRDC Warming Center – The Bozeman Warming Center offers emergency shelter to anyone in
need, including families with children, single adults, and couples. The space provides each
individual or group with separate sleeping areas. The Shelter is open nightly from 8 p.m. to 8
a.m. Additionally, the Warming Center also provides Drop-In Services during the day. Warming
Center and Day Center Services include computer access, day storage, housing case
management, housing navigation, job search assistance, peer support and recovery groups,
personal laundry, showers, and sock exchange.
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• HRDC Homeward Point – Expected to open in spring 2025, HRDC @Homeward Point will be
Bozeman’s year-round shelter. The shelter was planned from a trauma-informed point of view
and includes dedicated space for families with a separate entrance. Staff and community
partners will be located onsite, along with a variety of services, to ensure that clients’
experience with homelessness is brief and that they are well supported as they aim for housing
stability.
• Haven – Recently, Haven has relocated to a new emergency shelter facility, which now offers 40
beds in 30 units. This shelter provides a confidential and safe house for victims of sexual and
domestic violence. Staff also helps with crisis intervention, on-going support, education, and
legal advocacy.
• Family Promise – Family Promise’s Shelter Programs provide temporary shelter and highly
individualized, person-centered, trauma-informed case management to move families from
homelessness to housing independence. Family Promise services individuals who are pregnant,
families with children under the age of 18, and families of all compositions.
• VASH program – Veteran Affairs Supportive Housing for homeless veterans, including case
management, counseling, and ongoing rental assistance.
• Supportive Services for Veterans and Families – Volunteers of American Northern Rockies
provides supportive services for veterans and families who are experiencing or at risk of
homelessness.
Additionally:
• There are 25 units of transitional housing available in the community (HRDC manages 10 units;
Family Promise manages 15 units);
• HRDC also manages the Housing First Village, which offers 42 units of permanent supportive
housing. An additional 19 units of PSH are available in the community.
Prevention and Diversion Services
• HRDC – HRDC’s Homeless Prevention program includes case management, housing counseling,
financial coaching, and temporary emergency rental relief for households who meet program
eligibility criteria.
• Family Promise – Through its Prevention and Diversion programs, Family Promise provides
temporary assistance needed to prevent moving into emergency shelter, to maintain or move
into stable housing, including rental payment assistance, landlord mediation, and transportation
and utility support.
• Haven – Haven has a community engagement team and prevention education team that
performs community outreach and awareness building to help people recognize domestic
violence when it’s happening and how to support survivors. Haven also has a partnership with
Bridgercare to administer a Peer Education program, which trains teens to teach their peers
about sexuality and healthy relationships in a medically accurate, developmentally-appropriate,
evidence-based, and culturally-sensitive manner.
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Haven also provides counseling services, a 24-hour support line, emotional support, personal
advocacy services, and safety planning. They also connect clients to other available community
resources.
Supportive and Specialized Services
• HRDC – Other services provided by HRDC include emergency energy and emergency food
assistance. In addition to the Homeless Prevention services and Transitional Housing mentioned
above, HRDC’s Housing First program provides Rapid Rehousing services, Housing
Counseling/Supportive Services, and SSI/SSDI Outreach, Access, and Recovery (SOAR).
Additionally, HRDC’s Market Place offers a no-cost grocery market (Gallatin Valley Food Bank),
monthly grocery program for seniors, a pay-what-you-can restaurant, cooking and nutrition
classes, year-round kid friendly food programs, emergency assistance, financial coaching and
education, support to help clients file their taxes, utility assistance programs, home
weatherization assistance, preschool registration, youth employment support, foster youth
support, transitional housing support for youth, volunteer opportunities, and Medicare
counseling, among others.
• REACH – REACH works to empower adults with a range of physical or developmental disabilities
through employment, residential, and transportation assistance.
• The Help Center – provides a 24-hour crisis hotline, as well as Bozeman’s 211 information line.
• Ability MT – Provides services that promote independence for people with disabilities.
• Rural Dynamics, Inc. – provides financial counseling, debt management, bankruptcy education,
and other financial services.
• Bozeman Public Library – free books, movies, music, computers, and internet access.
• LOVE, Inc. – service for residents of Gallatin County who need clothing, food, budgeting
assistance, car repairs, home repairs, transportation, and family help.
• Salvation Army – assists with clothing, linens, housewares, etc. Veterans and homeless
assistance is also available.
• Family Outreach, Inc. – Provides free services to families and friends of children and adults with
disabilities to help keep families intact. They also offer placement assistance.
• Eagle Mount – Provides quality adaptive recreation and support opportunities for people with
disabilities and young people impacted by cancer and provide support for families of
participants.
• Big Sky Youth Empowerment – Creates transformative community where vulnerable teenagers
experience belonging, purpose, and well-being through group mentorship, adventure, and
connection with the natural world.
• Bozeman Adult Learning Center English for Speakers of Other Languages – ESOL classes are
designed to meet the individual language and cultural understanding needs of non-native
English speakers.
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• Bienvenidos- Connects new Spanish-speaking families with local mentors, volunteers, and
professionals who help families meet their goals through language acquisition, coordination of
services, access to community resources, and advocacy.
• Montana Legal Services – provides non-criminal legal information, advice, and representation to
Montanans to fight scam on seniors, assist veterans, help people escape abusive relationships,
and represent families living in unsafe housing conditions.
• Child Care Connections – assists families in affording child care through scholarships, provides
resources for families regarding child safety, emergency preparedness, and special needs
resources for both families and childcare providers.
• South North Nexus – Manages Migrant Legal Fund which assists migrants and their families in
Montana with legal support to address pressing issues related to their residency in Montana.
• McKinney-Vento – Education for homeless children and youth program through Montana’s
Office of Public Instruction.
• Montana Fair Housing – Promotes non-discrimination in Montana through outreach, education,
dispute resolution and enforcement.
•
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MA-35 Special Needs Facilities and Services – 91.210(d)
Introduction
Special needs populations in Bozeman include the elderly; frail elderly; persons with mental, physical, or
developmental disabilities; persons with HIV/AIDS; and persons with substance abuse disorders. These
populations face unique barriers to stable housing. Some rely on a fixed income, such as Social Security
Disability Income (SSDI) that cannot withstand large increases in housing costs. People with mental,
physical, or developmental disabilities have limited accessible and affordable housing options. For those
relying on housing vouchers, the task of finding an accessible unit can be challenging.
Including the elderly, frail elderly, persons with disabilities (mental, physical, developmental),
persons with alcohol or other drug addictions, persons with HIV/AIDS and their families,
public housing residents and any other categories the jurisdiction may specify, and describe
their supportive housing needs
Special needs populations require unique housing support. An estimated 40% of households with a
disability have a housing need that may require modifications to make a unit more accessible, such as
shower grab bars, ramps, or wide doors. This population may need help with one or more daily activities
requiring assistance of a hired caregiver or family member. If neither option is available due to lack of
family members or for financial reasons, group homes offer vital support for populations with
disabilities.
An estimated 4% of elderly (aged 62 years and older) and 4% of frail elderly (elderly and requiring
assistance with daily living) have housing or service needs; this is based on the share of elderly and frail
elderly living in poverty. These needs are similar to those with disabilities, such as modifications to the
home or care provided by a family member, or at-home caregiver.
There are an estimated 35 people living with HIV/AIDS in Bozeman based on CDC rates of incidence in
Montana at 65.6 infections per 100,000 people. According to the CDC, treatment for HIV requires
intensive, consistent medication to suppress the viral load to keep this population healthy and reduce
the risk of transmission. Housing stability is critical for this population, as homelessness can make
obtaining the necessary medication challenging and risks inconsistent usage. Support to maintain
housing stability could be permanent supportive housing, housing vouchers, emergency rental
assistance, and a medical care team to ensure health is optimized.
Based on the U.S. Department of Health and Human Services National Survey on Drug Use and Health,
there are an estimated 10,321 persons with alcohol or other drug abuse disorders in Bozeman; 48% of
which have a housing or service need. To best support this population, counseling for the individual and
their family may be needed alongside housing assistance. Stable housing is key to recovery, as many
with substance abuse disorders may use to cope with impending or present dangers of homelessness.
Among the greatest community development needs that residents and stakeholders were asked to
consider as critical needs, the top five were: Affordable Childcare, Mental Health Services, Supportive
Services for Vulnerable Residents, Climate Resilience Planning and Implementation, and Public Transit.
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Describe programs for ensuring that persons returning from mental and physical health
institutions receive appropriate supportive housing
As noted earlier in this section, several organizations serve residents experiencing mental health
challenges, including Community Health Partners, Gallatin Mental Health Center, Human Development
Clinic, Western Montana Mental Health Center, and the MSU Human Development Clinic. Organizations
serving the needs of residents living with physical or development disabilities include REACH, Inc., Ability
MT, and Family Outreach.
While programs and services do exist for providing supportive housing options to these populations,
residents and stakeholders described a significant gap in the availability of supportive housing.
Stakeholders described a critical shortage of affordable and accessible housing options for people living
with disabilities. Additionally, mental health services were highlighted as being a significant community
need. Several stakeholders felt that until residents treated their mental health challenges, finding and
remaining in a stable housing situation would be a challenge. Stakeholders also mentioned that the lack
of staff capacity and resources available for organizations to provide services in a housing setting were
significant barriers to supportive housing. A couple of stakeholders cited the cost of living in Bozeman as
a primary reason they are unable to retain their staff.
Specify the activities that the jurisdiction plans to undertake during the next year to address
the housing and supportive services needs identified in accordance with 91.215(e) with
respect to persons who are not homeless but have other special needs. Link to one-year
goals. 91.315(e)
The City of Bozeman strives to ensure that city information and public participation options are inclusive
and accessible. The City has adopted policies in compliance with the Americans with Disabilities Act. The
City will generally, upon request, provide appropriate aids and services leading to effective
communication for qualified persons with disabilities so that people with disabilities can participate
equally in City programs, services, and activities, including, but not limited to, qualified sign language
interpreters, documents in Braille, and other ways of making information and communications
accessible to people who have speech, hearing, or vision impairments.
The City is dedicated to increasing staff resources to serve the elderly, persons with disabilities, and
individuals with other special needs. The City is in the process of hiring a Disability Community Liaison, a
Belonging in Bozeman Coordinator, Community Engagement Coordinator, and ADA Coordinator. The
role of the ADA Coordinator is to ensure ADA compliance and bolster disability inclusivity in accessing
the community. This will allow the City to move away from a reactionary model of addressing ADA
compliance and ensure the City meets all federally mandated requirements in a proactive manner. The
Disability Community liaison will assist the ADA Coordinator on community engagement and outreach to
promote a positive relationship between the disability community and the City, ensure that community
members with disabilities have an avenue to voice their concerns and provide feedback in community
development. The Belonging in Bozeman and Community Engagement Coordinators will work together
to implement the goals and strategies outline in the City Diversity, Equity and Inclusion Plan, which
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includes goals pertaining to residents living with mental, physical, developmental disabilities and other
special needs.
The Neighborhood Services division at the City of Bozeman has a specific focus on the health and safety
impacts related to houseless residents, including those living with disabilities. The Neighborhood
Services program connects vulnerable members of the community to services and resources, including
mental health and substance abuse services, for persons suffering from drug and alcohol addiction and
mental illness.
In partnership with Eagle Mount Bozeman the City of Bozeman’s Parks and Recreation Division are
working together to create inclusive summer camps for our community. Eagle Mount is focused on
celebrating abilities and removing barriers to recreation. Eagle Mount offers a wide range of activities
with adaptive features, such as skiing, horseback riding, swimming, camping, rock climbing, kayaking,
cycling, fishing, and more. These activities foster freedom, joy, strength, focus and confidence. This
collaboration allows for more success in a group setting for children with greater individual special
needs. The summer camps are for all abilities to promote diversity and the beauty of disability.
In addition to the services these various departments provide for people with special needs, the City of
Bozeman has identified the need to promote aging in place and universally accessible residential design.
The City intends to leverage expertise of the disability community to educate design and building
professionals and conduct educational workshops for design, construction, and real estate professionals
on universal design practices and adaptable dwellings within residential developments. If an
environment is accessible, usable, convenient and a pleasure to use, everyone benefits. By considering
the diverse needs and abilities of all throughout the design process, universal design creates digital and
built environments, services and systems that meet peoples’ needs.
For entitlement/consortia grantees: Specify the activities that the jurisdiction plans to
undertake during the next year to address the housing and supportive services needs
identified in accordance with 91.215(e) with respect to persons who are not homeless but
have other special needs. Link to one-year goals. (91.220(2))
Please see above.
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MA-40 Barriers to Affordable Housing – 91.210(e)
Negative Effects of Public Policies on Affordable Housing and Residential Investment
Through the stakeholder consultation process, a handful of barriers were identified impacting the
development of affordable housing in Bozeman.
One stakeholder felt that the housing conversation is not really occurring at the regional level, adding
that “it’s ignored a little bit at the regional level.” They noted that regionally, there is a de facto
moratorium on development because of infrastructure constraints, namely sewer infrastructure. As a
result, “the inability of other places to grow is putting pressure on growth in Bozeman.” This stakeholder
wanted to see more regional cooperation among Bozeman and other local communities to try and
address their housing issues in a collective manner.
Another stakeholder shared that the current zoning code does not allow the development of more
compact homes on smaller lots, adding that to move their development through the process, they
needed approximately 20 variances to the zoning code and had to use the Planned Unit Development
(PUD) tool. Describing the process as “extremely challenging,” they felt there was a disconnect between
the vision of the community and what can actually be built in the city.
Another stakeholder felt that zoning gets blamed a lot as a barrier to affordable housing development,
however, they articulated that “Bozeman’s Unified Development Code (UDC) has tons of flexibility…it’s
just really convoluted.” They noted that the city’s zoning code has been “patched up and moved
around” so much that only a handful of people actually can navigate it and understand it. They felt that
if you can navigate the code, it’s not overly difficult to move developments through the process.
Private covenants can also create barriers, particularly when they duplicate overly large lot sizes,
excessive design costs, etc. Once adopted, covenants are very difficult to change. Montana has very little
state law setting any kind of process guidance or standards for owners associations, fiscal stewardship,
or equal protection making them easy to misuse.
Other stakeholders highlighted the development approval process in the city as a barrier, citing that due
to staff capacity issues and unfamiliarity with the development code, the process to obtain all of the
necessary approvals was not as efficient as it could have been.
Additional barriers identified by stakeholders impacting the development of affordable housing included
the high cost of land and lack of availability of land, high cost of infrastructure, high cost of labor, and
NIMBYism. A couple of stakeholders also mentioned that in addition to these barriers, Bozeman has a
short construction season due to the weather, which compounds the negative impacts of the
aforementioned barriers. One stakeholder also cited high interest rates as another current barrier to
development.
At the state level, stakeholders highlighted the State Legislature’s removal of a jurisdiction’s regulatory
authority to allow for inclusionary zoning. In response, the City is currently implementing an incentive-
based approach to increasing the number of community housing units in Bozeman.
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Stakeholders did acknowledge the City’s effort to update the Unified Development Code, which aimed
to:
• Ensure consistency with the Growth Plan and other adopted policy documents;
• Modernize and improve the organization, usability, and user-friendliness of the code;
• Provide for a wide range of housing types to meet an expanded range of housing needs;
• Improve the built environment and provide new and improved development standards; and
• Ensure compliance with recent state land use legislative changes.
However, the City’s Mayor and Commission paused the update to the UDC in fall 2023 to allow for
additional community engagement activities.
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MA-45 Non-Housing Community Development Assets – 91.215 (f)
Introduction
Economic Development Market Analysis
The City of Bozeman updated its Economic Development Strategy in 2023, which includes the following goals:
Strong Economic Base
• Increase middle and high wage traded sector employment and diversify the economic base.
• Support local sector businesses with a seamless permitting process and awareness about existing small business programs.
• Invest in infrastructure projects identified on the capital improvement plan (CIP) that the business community needs and wants.
Strong Community
• Protect the outdoor environment by guiding efficient industry site development within the city limits.
• Foster an environmentally and economically sustainable community with an active transportation network (transit networks, bicycle
routes, trails, and sidewalks) that employers and employees desire.
• Offset livability costs for citizens with conscious infrastructure and workforce investments that improve access to job opportunities with
the understanding that several other stakeholders are focused specifically on affordable housing.
Additionally, the City’s 2023 Economic and Market Update highlight eight key segments that distinguish the Bozeman economy from other mid-
sized cities and recreation/resort-oriented mountain communities:
• Higher Education – In 2022, Montana State University (MSU) had 16,688 students enrolled and 4,250 faculty and staff. MSU is one of
131 R1 research institutions with “very high research activity” within the Carnegie Classification of Institutions of Higher Education.
• Tourism and Recreation – Bozeman is a “gateway community” for world class recreation including the Bridger Bol and Big Sky ski areas,
pristine rivers and streams, and Yellowstone and Glacier National Parks. Yellowstone International Airport (BZN) is a major tourism (and
business) driver with over 2.2 million passengers in 2022.
• Health Care – Bozeman Health is a regional hub for health care in Southwest Montana, employing over 1,000 people. There are
numerous other clinics and medical offices clustered around the hospital and located throughout Bozeman.
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• Technology – Bozeman is a hub for technology and research and development companies that have both started in or moved to
Montana. Major employers range from companies focusing on software development to photonics R&D and manufacturing.
• Manufacturing – There are numerous manufacturing firms in Greater Bozeman ranging from outdoor companies to optical technology,
materials science, electronics, and aerospace.
• Retail and Hospitality – Bozeman retailers serve at least a 50-mile radius trade area, making it the premier retail, services, and health
care hub in Southwest Montana. Downtown Bozeman is a vibrant main street with independent shops, restaurants, and breweries
serving locals and visitors.
• Creative Arts – The city has many businesses that provide goods and services based on intellectual property and individual creativity.
These businesses include publishing, film, TV, media, design, technology, performing arts, and museums and galleries.
• Montana State University Innovation Campus – The MSUIC hosts the only Secure Compartmental Information Facility (SCIF) in the state
of Montana and facilitates classified research for both government agencies and the private sector.
Business Activity
Business by Sector Number of
Workers
Number of Jobs Share of Workers
%
Share of Jobs
%
Jobs less workers
%
Agriculture, Mining, Oil & Gas Extraction 495 64 1.6% 0.2% -1.4%
Arts, Entertainment, Accommodations 4,586 6,308 14.6% 16.2% 1.6%
Construction 2,493 2,237 7.9% 5.7% -2.2%
Education and Health Care Services 8,231 11,101 26.2% 28.5% 2.3%
Finance, Insurance, and Real Estate 1,590 1,793 5.1% 4.6% -0.5%
Information 194 601 0.6% 1.5% 0.9%
Manufacturing 2,149 1,573 6.8% 4.0% -2.8%
Other Services 1,697 1,665 5.4% 4.3% -1.1%
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Business by Sector Number of
Workers Number of Jobs Share of Workers
% Share of Jobs
% Jobs less workers
%
Professional, Scientific, Management Services 3,867 4,664 12.3% 12.0% -0.3%
Public Administration 545 1,438 1.7% 3.7% 2.0%
Retail Trade 4,326 5,690 13.8% 14.6% 0.8%
Transportation & Warehousing 892 644 2.8% 1.7% -1.1%
Wholesale Trade 368 903 1.2% 2.3% 1.1%
Grand Total 31,433 38,981 100% 100% -
Table 39 - Business Activity
Data Source: 2017-2021 ACS (Workers), 2021 Longitudinal Employer-Household Dynamics (Jobs)
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Labor Force
Total Population in the Civilian Labor Force 33,661
Civilian Employed Population 16 years and
over
32,708
Unemployment Rate 2.8%
Unemployment Rate for Ages 16-24 7.3%
Unemployment Rate for Ages 25-65 1.3%
Table 40 - Labor Force
Data Source: 2018-2022 ACS
Occupations by Sector Number of People
Management, business, science, arts 15,519
Farming, fisheries and forestry occupations 277
Service 6,074
Sales and office 5,673
Construction, extraction, maintenance and
repair
2,144
Production, transportation and material
moving
3,021
Table 41 – Occupations by Sector
Data Source: 2018-2022 ACS
Travel Time
Travel Time Number Percentage
< 30 Minutes 24,602 91%
30-59 Minutes 1,596 6%
60 or More Minutes 756 3%
Total 26,954 100%
Table 42 - Travel Time
Data Source: 2018-2022 ACS
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Education:
Educational Attainment by Employment Status (Population 16 and Older)
Educational Attainment In Labor Force
Civilian Employed Unemployed Not in Labor Force
Less than high school graduate 372 0 199
High school graduate (includes
equivalency)
1,727 54 685
Some college or Associate’s
degree
4,684 88 800
Bachelor’s degree or higher 14,921 138 1,831
Table 43 - Educational Attainment by Employment Status
Data Source: 2018-2022 ACS
Educational Attainment by Age
Age
18–24 yrs 25–34 yrs 35–44 yrs 45–65 yrs 65+ yrs
Less than 9th grade 161 2 22 28 88
9th to 12th grade, no
diploma
191 68 190 261 39
High school graduate,
GED, or alternative
4,049 713 520 1,233 1,177
Some college, no degree 7,477 1,630 1,069 1,330 1,080
Associate’s degree 656 915 280 348 202
Bachelor’s degree 2,318 5,624 2,253 2,999 1,392
Graduate or professional
degree
354 2,467 1,631 1,916 1,756
Table 44 - Educational Attainment by Age
Data Source: 2018-2022 ACS
Educational Attainment – Median Earnings in the Past 12 Months
Educational Attainment Median Earnings in the Past 12 Months
Less than high school graduate $27,455
High school graduate (includes equivalency) $36,437
Some college or Associate’s degree $39,535
Bachelor’s degree $46,677
Graduate or professional degree $63,252
Table 45 – Median Earnings in the Past 12 Months
Data Source: 2018-2022 ACS
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Based on the Business Activity table above, what are the major employment sectors within
your jurisdiction?
In Bozeman, Education and Health Care Services is the largest employment sector, with 26% of all
workers and 29% of all jobs (Table 45). The second largest sector is Retail Trade at 14% of workers and
15% of jobs. Professional, Scientific, and Management Services make up 12% of both workers and jobs in
the city. According to the City’s 2023 Economic Vitality Strategy, the largest industries in the city of
Bozeman and Gallatin County are local and tourism sectors, including retail trade, hotels and
restaurants, construction, and health care. The traded sectors of professional and technical services and
manufacturing are the next largest groups of industries.
Describe the workforce and infrastructure needs of the business community:
According to a SWOT analysis performed for the 2023 Strategy, there were three significant
weaknesses/threats impacting the Bozeman and Gallatin County economies:
• Rapid increase in housing and real estate costs. The implications associated with this factor
include constraining the availability of the labor force, as well as constraining business
expansion or relocation (cost of space).
• Large proportion of jobs in the Bozeman area are in tourism, retail, and food and beverage
industries. The implications associated with this factor include lower wages, less economic
productivity, and a mismatch between wages and housing costs.
• Education and opportunity gap between white and non-white population. The implications
associated with this factor are investing resources into career paths to ensure there is more
diversity in higher paying jobs.
In addition to the factors highlighted above and the lack of affordable housing, stakeholders also shared
that the lack of available and affordable childcare is a significant economic impact. One stakeholder
highlighted a recent workforce impact report that found Gallatin County is only meeting 50% of the
demand for childcare. Several stakeholders highlighted recruitment and retention of childcare workers
as a major problem, with one stakeholder sharing that “[as a city], we don’t retain workforce very well.
Childcare is a very low paying occupation, and with the cost of living in Bozeman as high as it is, the
turnover rate [of childcare staff] is really high.”
Another stakeholder articulated that for a significant number of people who live and work in Bozeman,
“they’re not making enough money to cover the cost of childcare.” This forces households to have one
member leave the workforce so they can care for their child(ren). Quality of childcare is another issue
highlighted by this stakeholder, noting that a lot of households bounce around from one childcare
facility to another due to the lack of quality. They felt that providing more resources to better train
employees can improve retention rates with both employees and families.
One stakeholder shared that, “if parents don’t have reliable childcare, they won’t show up for work.”
They added that they know residents who have had to leave the workforce because they haven’t been
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able to find affordable childcare, noting that “availability [of childcare options] is one thing, but being
able to afford childcare is a greater challenge.”
Describe any major changes that may have an economic impact, such as planned local or
regional public or private sector investments or initiatives that have affected or may affect
job and business growth opportunities during the planning period. Describe any needs for
workforce development, business support or infrastructure these changes may create.
The City’s 2025-2029 Capital Improvement Plan (CIP) articulates the priorities of improving and
maintaining the city’s infrastructure, facilities, parks, and roads over the next five years. The 2025-29 CIP
has $394.6 million in scheduled projects and $513.5 million in unscheduled projects. However,
stakeholders overwhelmingly described more affordable housing and childcare as the primary needs to
continue supporting workforce development and economic growth in Bozeman and the broader region.
As articulated in the City’s CIP Plan, “…the need to address the demand for affordable housing in
Bozeman continues to be a priority. This plan serves as an indication to the City’s commitment to
leverage as many capital projects as possible for the further development of affordable housing in the
community. The City will continue to evaluate and explore opportunities to address this critical
concern.”
How do the skills and education of the current workforce correspond to employment
opportunities in the jurisdiction?
As the largest university in the state of Montana, Montana State University has positioned itself to align
the growing sectors of its economy with the educational opportunities offered at the campus. The
primary investment in this alignment of education and supply workforce is the MSU Innovation Campus,
which is the state’s premier commercial development offering opportunities for partners to invest and
build in a highly creative and entrepreneurial environment. The Campus will establish collaborative
programs between institutions and the private sector with the aim of amplifying research,
commercializing new technologies, and catalyzing Montana’s entrepreneurial ecosystem. Specifically,
the Campus will offer opportunities in the following areas:
• Computer science;
• Biofilm engineering;
• Optical technology;
• Mental health and recovery;
• Space science and engineering; and
• Business and entrepreneurship.
According to the Northern Rocky Mountain Economic Development District (NRMEDD)’s Comprehensive
Economic Development Strategy (CEDS), the labor force participation rate in Gallatin County is higher
than the national average, meaning most of the residents are working and there are not many residents
to attract into the workforce. However, stakeholders were most concerned with the lack of affordable
housing and cost of living in Bozeman, which forces many recent graduates to leave the area for
employment. One stakeholder shared that while MSU is providing the appropriate educational
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opportunities to fill Bozeman’s workforce needs, “some students have to leave and only come back 10
years later when they can afford to live here…that’s not a sustainable strategy.”
Describe any current workforce training initiatives, including those supported by Workforce
Investment Boards, community colleges and other organizations. Describe how these efforts
will support the jurisdiction's Consolidated Plan.
• Gallatin College, Montana State University offers two-year workforce associate degrees and
one-year professional certificates that complement four-year programs at Montana State
University to ensure access to workforce development that promotes a vibrant local economy.
Examples of degrees and certificates offered include HVAC-R, Photonics and Laser Technology,
IT Cybersecurity Information Assurance, and CNC Machining Technology.
• As noted above, the MSU Innovation Center is working to provide space for companies to locate
while offering MSU student opportunities to be involved in real-time research projects and
other efforts. For example, in 2020, the Applied Research Laboratory opened as the first building
on the campus, where scientists work with federal agencies, such as the U.S. Department of
Energy and Department of Defense, on projects related to lasers and photonics, advanced
manufacturing and materials, and cyber security.
Stakeholders described that the MSU Innovation Campus is attracting a lot of attention from domestic
and international companies. As such, these companies are exploring how to contribute in providing
housing opportunities and other amenities, such as childcare, to recruit and retain high-quality
employees.
Does your jurisdiction participate in a Comprehensive Economic Development Strategy
(CEDS)?
Yes.
If so, what economic development initiatives are you undertaking that may be coordinated
with the Consolidated Plan? If not, describe other local/regional plans or initiatives that
impact economic growth.
The goals articulated in the Northern Rocky Mountain Economic Development District (NRMEDD) CEDS
document are:
• Region-Wide Collaboration – foster and catalyze region-wide economic development
collaboration among local and state governments, businesses, educational institutions, federal
government agencies and nonprofits;
• Data-Driven Thoughtful Growth – champion economic vitality, resiliency, recovery, and
thoughtful growth through data-driven initiatives that reflect the region’s character and
resources;
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• Infrastructure Enhancements – encourage and support enhancements to regional infrastructure
to address existing and future economic constraints, including housing needs; and
• Workforce Development and Education – promote workforce expansion and development
opportunities, including education, to support local businesses.
Additionally, the City’s 2023 Economic Vitality Strategy identified the following goals and objectives to
guide economic vitality actions in the city:
Goal 1: Provide Opportunity for Gallatin Valley Residents
• Enhance the small business development ecosystem;
• Provide comprehensive and coordinated skills development starting with childcare through
middle school and higher education; and
• Improve access to career opportunities for local and surrounding rural residents.
Goal 2: Support a Diverse Economy
• Focus on traded sector industries that are emerging and can increase exports;
• Enhance development of the talent pipeline; and
• Elevate a growing creative arts industry cluster.
Goal 3: Build a More Resilient Region
• Increase amount and access to housing for all
• Develop a sustainable city; and
• Foster a cultured-focused on climate change resilience.
The goals articulated above in both the CEDS and City plan align with the goals of the Consolidated Plan,
namely increasing the amount of and access to affordable housing in the city and region and ensuring
that community services, such as childcare and access to education, are available to ensure that all
residents can contribute to and benefit from the local economy.
Discussion
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MA-50 Needs and Market Analysis Discussion
Are there areas where households with multiple housing problems are concentrated?
(include a definition of "concentration")
For the purposes of this plan, a “concentration” is defined a Census Tract with 150 percent (or 1.5 times)
of the city proportion of that group. For example, if 10% of residents are Asian but the Asian population
of a specific Census tract is 15%, that tract would be considered “concentrated.”
Excluding the Census Tracts that overlap the Montana State University campus, Census Tract 6 is the one
tract in Bozeman that contains a majority of households experiencing housing problems. Specifically:
• 59% of households in Census Tract 6 have income less than $50,000 (33% of households in the
city make $50,000);
• The median household income in Census Tract 6 is $44,762; the household median income in
the city of Bozeman is $74,113.
• The poverty rate in Census Tract 6 is 25%; in the city of Bozeman, 14% of the population live in
poverty.
• While not a concentration, Census Tract 6 has a greater proportion of households that
experience cost burdened compared to the city overall (54% of households in Census Tract 6,
51% of households overall).
Are there any areas in the jurisdiction where racial or ethnic minorities or low-income
families are concentrated? (include a definition of "concentration")
The same definition of “concentration” articulated above is used in this subsection. The following
Census Tracts in Bozeman have concentrations of racial/ethnic minorities:
• Concentrations occur when Census tracts are more than 7.2% Hispanic. Three Census in the city
of Bozeman have concentrations of Hispanic residents—one in the northeast quadrant of the
city (Census Tract 6) and two directly north of the Montana State University campus (Census
Tracts 7.03 and 9).
• African American/Black residents make up a very small proportion of residents in the city. In this
case, concentrations occur when just 0.9% of residents report their race as African
American/Black. Two Census tracts in Bozeman have a concentration of African American/Black
residents, both of which cover the Montana State University campus (Census Tracts 11.01 and
11.02).
• Asian residents make up a relatively small proportion of residents overall (2.3%). Census tracts
with 3.5% and more Asian residents are considered concentrated. There are three Census tracts
in the city with a concentration of Asian residents—all located south of Main Street. Census
Tract 11.01, located on the Montana State University campus, has the greatest proportion of
Asian residents in the city (6.9%), followed by Census Tract 10.02 (4.5%) and Census Tract 9
(4.3%), which are directly east and north of campus, respectively.
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• Census tracts with more than 1.4% of Native American residents are considered a
concentration. There are 3 such tracts in Bozeman. Census Tract 7.04, bounded by N Ferguson
Avenue to the west, W Babcock Street to the south, Farmer’s Canal to the east, and Durston
Road to the north, has the greatest concentration of AIAN residents in the city (3.9% of the total
tract population). Other census tracts with concentrations of AIAN residents include Census
Tract 6 (3%) and Census Tract 7.01 (1.6%).
What are the characteristics of the market in these areas/neighborhoods?
The market in these areas offer more affordable options low-income renters. Rental units make up 57%
of all units in the tract; moreover, there are several LIHTC developments and other community housing
options located in Census Tract 6. Additionally, according to 2022 5-year ACS data, more than half of the
housing stock in this tract (53.7%) was built before 1980. It is common for households with lower
incomes to live in older housing given that new and updated homes are likely more expensive.
Similarly, Census Tract 11.01 and 11.02 overlap with the Montana State University campus. As such,
more rental housing opportunities are available in these areas – rental units make up 98% of total units
in Census Tract 11.01, as well as 60% of units in Census Tract 11.02. In Census Tract 11.01, 61% of the
housing was built before 1980 while just over a fifth of the housing units (21%) in Census Tract 11.02
were built before 1980. With students as the primary tenants in these Census Tracts, it would suggest
units are more affordable in these areas compared to the city overall.
Are there any community assets in these areas/neighborhoods?
Census Tract 6 has several community assets located within its boundaries, including Story Mill Park,
Bozeman’s only completely accessible park. In addition to several other parks, Headwaters Academy and
the Bozeman Social Senior Center are located in the tract, along with multiple Streamline bus routes.
The greatest asset in Census Tract 11.01 and 11.02 is Montana State University. These Tracts also have
direct access to Streamline bus routes to the north, along with several parks in Census Tract 11.02.
Are there other strategic opportunities in any of these areas?
Several of the City’s planned/pipeline community housing projects are located in Census Tract 6 and
Census Tract 11.02. Montana State University is the greatest strategic opportunity in not only Census
Tract 11.01 and 11.02, but the entire city. For example, when complete, Montana State University’s
Innovation Campus, the campus will be home to more than 500,000 square feet of technology, biotech,
healthcare, and office space.
The census tracts that overlay commercial corridors like Midtown (North 7th Avenue) offer strategic
opportunities for LMI workers in the expanding hospitality and hotel industries, in the growing variety of
small businesses in the corridors and a growing number of minority-owned businesses. Around MSU the
strategic opportunities are found in the educational opportunities offered by 2yr and 4yr educational
opportunities as well as one-year certificates of training in a variety of disciplines.
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In addition to opportunities in the specific tracts above, the City of Bozeman maintains the following
goals / priorities / strategies to promote equity throughout the City:
• Equitable economic growth that improves economic mobility, builds wealth and provides equal
opportunities for under-represented individuals.
• A sustainable economy with varied industries and business sizes including diverse ownership.
• Resilient infrastructure to endure economic shocks and climate change, which includes areas
such as adequate workforce housing, water supply, renewable energy, and multi-modal
transportation.
• Engage higher education that supports an entrepreneurial ecosystem and talent pipeline to
careers in the Gallatin Valley throughout the student’s education.
• Innovation that captures opportunities in emerging technologies and industries including those
aligned with national interests (e.g., defense, energy, climate)
• Fostering a small business hub through a supportive network that generates opportunity for
wealth building of under-resourced individuals and retains businesses through succession
planning.
• Building affordable housing near existing transportation corridors and concentrating growth in
compact walkable urban centers to avoid sprawl.
• Prioritize development of affordable housing for low- and moderate-income households
ensuring housing development keeps pace with job growth in key census tracts.
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MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income
Households - 91.210(a)(4), 91.310(a)(2)
Describe the need for broadband wiring and connections for households, including low- and
moderate-income households and neighborhoods.
According to 2022 5-year ACS data, 91% of households have access to a desktop or laptop while 93%
have access to a smartphone. Additionally, 67% of households have access to a tablet or other wireless
computer. Approximately 3% of households do not have access to a computer.
Ninety-two percent of households have some type of access to broadband, such as cable, fiber, or DSL.
Just 8% of Bozeman households do not have an internet subscription.
Lower income households in Bozeman are less likely to have internet access than households with
higher income. According to 2022 5-year ACS data, 59% of households making less than $20,000 have a
broadband subscription while 41% of households do not have an internet subscription. Conversely,
100% of households making between $20,000-$74,999 and 98% of households making more than
$75,000 have a broadband subscription.
Yellowstone Fiber is a non-profit fiber provider in Gallatin County. In spring of 2023, Yellowstone Fiber
began construction of an all-fiber optic network, with the aim of providing ultra-high speed internet to
over 22,000 homes in Bozeman by 2025. Due to the growing importance of broadband and internet
connectivity, “local officials and community leaders decided to create their own connectivity solutions in
the absence of state and federal leadership. After declaring broadband “essential infrastructure,” the
City [of Bozeman] worked to develop a GIS map of broadband availability for their over 48,000
residents. Specifically, the City wanted to ensure decision makers knew where every inch of city-owned
conduit and fiber assets were laid. Access to this information helped to ensure that decisions were more
effective and efficient in closing the digital divide for Bozeman residents.”7 These “fiber huts,” which
contain broadband fiber infrastructure, are planned to be situated at parks around the city as the City
builds out the network.
Describe the need for increased competition by having more than one broadband Internet
service provider serve the jurisdiction.
According to the Federal Communications Commission (FCC) database, the city of Bozeman is served
primarily by ten large broadband providers (figure below). In terms of coverage at 25/3 Mbps or greater
speed, Space Exploration Technologies Corporation, Viasat, Inc., and Hughes Network Systems, LLC
serve 100% of units in Bozeman. They are followed by Charter Communications (87% of households
7 https://nextcenturycities.org/mappingmontana/
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served), Lumen Technologies, Inc. (86%), SkyNet Communications (64%), T-Mobile USA, Inc. (62%),
Montana Opticom (52%), BHT Investment Holdings (47%), and LAT Inc. (44%).
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MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3)
Describe the jurisdiction’s increased natural hazard risks associated with climate change.
In 2019, the City of Bozeman developed its Vulnerability Assessment and Resiliency Strategy to help the
city identify and mitigate the consequences of climate change and other hazards, as well as find
solutions to adapt to the risks associated with changing local climate condition and establish local
resilience initiatives. This Assessment analyzed the following natural hazards risks on critical facilities,
critical infrastructure, and community centers:
• Extreme heat, expected to be more frequent and intense;
• Floods, expected to be more severe;
• Drought, expected to be more frequent and intense;
• Mountain snowpack, expected to decline in volume;
• Wildfire, expected to be more extensive, frequent, and intense; and
• Winter storms, expected to be more severe.
In the City of Bozeman’s Climate Plan, several strategies related to “Vibrant and Resilient
Neighborhoods” are articulated, including “reducing the vulnerability of neighborhoods and
infrastructure to natural hazards.” Specific actions related to reducing this vulnerability include planning
for resilience hubs at critical facilities, advancing resiliency in development code and development
review processes, supporting business and residential preparedness outreach, and incorporating
resiliency into infrastructure plans. According to the City’s Climate Plan dashboard, all of these actions
are in progress.
Additionally, Gallatin County Emergency Management has several plans that address natural hazard
risks associated with climate change, include the Gallatin County Emergency Management Plan, Gallatin
Hazard Mitigation and Community Wildfire Protection Plan, and the Gallatin County Sheltering Plan.
While plans are in place to address these issues, stakeholders shared that one of the greatest challenges
to addressing natural hazard risks associated with climate change is coordination among local
governments and other partners. One stakeholder shared that until a major event occurs, it’s difficult to
get all the necessary partners in the same room to discuss roles and responsibilities related to the
impacts of natural hazards.
Residents and stakeholders also acknowledged the impacts that natural hazard risks have and will
continue to have on the city of Bozeman and surrounding areas. Of the most critical community
development needs, a third of all survey respondents (n=316) identified a need for climate-resilience
planning and implementation by the City.
Describe the vulnerability to these risks of housing occupied by low- and moderate-income
households based on an analysis of data, findings, and methods.
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The City’s Vulnerability Assessment found that the buildings most vulnerable to extreme heat are
primarily community centers that serve diverse and vulnerable populations. Facilities serving vulnerable
populations at greater risk of experiencing impacts from natural hazards include:
• Bozeman Senior Center – vulnerable to extreme heat events, smoke hazards, and winter storms
• Story Mill Community Center – vulnerable to extreme heat events, flooding, and smoke hazards
• Bozeman Public Library – extreme heat events, flooding, and smoke hazards
In the state of Montana’s 2021 Climate Change and Human Health in Montana, the report details
populations that are particularly vulnerable to the impacts of climate change. These groups include:
• People with existing chronic conditions
• People threatened by increased heat
• People living in proximity to wildfire and smoke.
• People facing food and water insecurity.
• People who are very young, very old, or pregnant
• People with limited access to healthcare services
• People living poverty
• American Indians
• People lacking adequate health insurance.
• People with mental health issues.
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Strategic Plan
SP-05 Overview
Strategic Plan Overview
Five-year goals are a critical part of the development of the Consolidated Plan. Five-year goals guide
funding priorities and allocations, and, as such, housing and community development goals should
reflect community priorities and align with complementary goals and initiatives.
The City utilized the findings from the Needs Assessment (NA) and Market Analysis (MA) sections, as
well as the findings from the community engagement efforts, which included stakeholder consultations,
resident focus groups, and a housing and community needs survey with over 950 responses, to develop
the goals identified in this Consolidated Plan. These goals were also developed to align and reinforce
other goals, strategies, and recommendations articulated in other existing City plans.
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SP-10 Geographic Priorities – 91.215 (a)(1)
Geographic Area
The City of Bozeman will not allocate funding to specific geographic areas of the city; funding will be
allocated on a citywide basis.
General Allocation Priorities
Describe the basis for allocating investments geographically within the jurisdiction (or within the EMSA
for HOPWA)
n/a.
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SP-25 Priority Needs - 91.215(a)(2)
Priority Needs
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1 Priority Need Name Affordable Rental Housing
Priority Level High
Population Extremely low
Low
Moderate
Geographic Areas Affected Citywide
Associated Goals Goal 1: Increasing and Preserving Housing Options
Description The lack of affordable rental housing was identified as the most
critical need in Bozeman through the data analysis for this plan
and community engagement findings.
Basis for Relative Priority Residents and stakeholders identified the lack of affordable
rental housing as the greatest need in the city of Bozeman. In
the housing and community needs survey administered for this
plan, 75% of respondents (n=711) identified rental housing for
low-income renters as a critical need. Other City-led
community engagement findings and plans, such as Belonging
in Bozeman, Bozeman Community Plan, and the 2023
Economic Vitality Strategy, all identify the need for more
affordable rental housing options.
2 Priority Need Name Affordable Homeownership Opportunities
Priority Level High
Population Extremely low
Low
Moderate
Geographic Areas Affected Citywide
Associated Goals Goal 1: Increasing and Preserving Housing Options
Description The lack of affordable homeownership opportunities was
another critical need identified through the data analysis for
this plan and community engagement findings.
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Basis for Relative Priority Residents and stakeholders identified the lack of affordable
homeownership opportunities as another significant need in
the city of Bozeman. In the housing and community needs
survey administered for this plan, 84% of respondents (n=796)
identified homeownership opportunities as a critical need.
Other City-led community engagement findings and plans also
stress the importance of more affordable homeownership
opportunities in the city.
3 Priority Need Name Accessible Housing
Priority Level High
Population Extremely Low
Low
Persons with Disabilities
Geographic Areas Affected Citywide
Associated Goals Goal 1: Increasing and Preserving Housing Options
Description The lack of accessibility in the city, particularly accessible
housing options, was identified through the community
engagement findings.
Basis for Relative Priority Several stakeholders discussed the lack of overall accessibility
in the city for people living with disabilities. The lack of
accessible housing was identified as a significant barrier for this
population. Additionally, over a third of survey respondents
(36%, n=342) identified residents living with disabilities as one
of the population groups with the greatest challenges finding
and keeping housing.
4 Priority Need Name Emergency Shelter and Transitional Housing
Priority Level High
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Population Extremely Low
Low
Chronic Homelessness Individuals
Persons with Disabilities
Families with Children
Mentally Ill
Chronic Substance Abuse
Victims of Domestic Violence
Unaccompanied Youth
Geographic Areas Affected Citywide
Associated Goals Goal 2: Supporting Vulnerable Populations
Description With a growing unhoused population, a need for more
emergency shelter space and transitional housing options were
identified as significant needs through the data analysis for this
plan and community engagement findings.
Basis for Relative Priority Stakeholders who serve unhoused residents described a
significant need for more emergency shelter and transitional
housing capacity in Bozeman. Over 6 in 10 survey respondents
(n=593) identified unhoused residents as a population group
with the greatest challenges finding and keeping housing.
5 Priority Need Name Community Services
Priority Level High
Population Extremely Low
Low
Chronic Homelessness Individuals
Persons with Disabilities
Families with Children
Mentally Ill
Chronic Substance Abuse
Veterans
Persons with HIV/AIDS
Victims of Domestic Violence
Unaccompanied Youth
Geographic Areas Affected Citywide
Associated Goals Goal 3: Critical Community Services
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Description Several community services were identified as significant needs
through the data analysis and community engagement findings.
Basis for Relative Priority Residents and stakeholders identified several community
services that they would like to see increased access to,
including but not limited to, mental health services, chemical
dependency services, and affordable and available childcare.
Nearly two-thirds of survey respondents (n=615) identified
affordable childcare as the greatest unmet community
development need in Bozeman, while 50% of respondents
(n=477) identified mental health services as a significant need.
Over a third of survey respondents (37%, n=353) wanted to see
more supportive services for vulnerable populations.
Table 46 – Priority Needs Summary
Narrative (Optional)
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SP-30 Influence of Market Conditions – 91.215 (b)
Influence of Market Conditions
The City’s Consolidated Plan goals provide flexibility for the City of Bozeman to implement the most
effective strategies to address housing and other community needs. The City understands and
recognizes that these needs can change with economic and housing market conditions. The table below
succinctly summarizes the City’s anticipated response to market conditions that will influence the use of
its entitlement funds.
Affordable Housing Type Market Characteristics that will influence
the use of funds available for housing type
Tenant Based Rental
Assistance (TBRA)
n/a.
TBRA for Non-Homeless
Special Needs
n/a.
New Unit Production Ongoing gap between need and housing supply.
Rehabilitation Low-income owners and renters living in housing in poor condition and
inability of these households to access credit and make repairs.
Acquisition, including
preservation
Opportunity to acquire properties at prices needed to facilitate
preservation and affordability.
Table 47 – Influence of Market Conditions
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SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2)
Introduction
The Office of Community Planning and Development at the U.S. Department of Housing and Urban Development (HUD) allocates entitlement
funds to the City of Bozeman Economic Development Department, which administers the CDBG program.
Anticipated Resources
Program Source
of
Funds
Uses of Funds Expected Amount Available Year 1 Expected
Amount
Available
Remainder
of ConPlan
$
Narrative Description
Annual
Allocation:
$
Program
Income: $
Prior Year
Resources:
$
Total:
$
CDBG Public
Federal
Housing
Homeless Support
Public Services
Planning and Administration
$325,859 n/a n/a $325,859 $1,303,436 Expected Amount
Available for remainder
of Con Plan is FY2024
allocation times four.
Table 48 - Anticipated Resources
Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how
matching requirements will be satisfied
Federal CDBG funds will be paired with the City’s Community Housing Fund to achieve the goals outlined in the Consolidated Plan. The City
estimates that $1 million will be available in the Community Housing Fund over the next program year. There are no additional resources. There
are no matching requirements.
If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs
identified in the plan.
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Within the city boundaries, publicly owned land suitable for development is incredibly limited. However, the City is actively seeking out and
pursuing partnerships with other government agencies, organizations, and local entities to find and develop land suitable for affordable and
workforce housing.
Discussion
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SP-40 Institutional Delivery Structure – 91.215(k)
Explain the institutional structure through which the jurisdiction will carry out its consolidated plan
including private industry, non-profit organizations, and public institutions.
Responsible Entity Responsible Entity
Type
Role Geographic Area
Served
City of Bozeman Government CDBG Administrator Citywide
The HRDC Non-profit
organization
CoC/Homelessness District-wide
Table 49 - Institutional Delivery Structure
Assess of Strengths and Gaps in the Institutional Delivery System
Stakeholders and residents were highly complimentary of the services provided by HRDC and other
organizations serving low-income and unhoused residents, particularly Family Promise, Haven,
Bridgercare, and Bienvenidos a Gallatin County. In general, stakeholders felt that for the size of the
community and the capacity of these organizations, as one stakeholder articulated, “these organizations
continue to do more with less.”
However, stakeholders did acknowledge that the City and its partners could improve upon their
coordination and efficacy at providing services to the City’s high-need populations. Stakeholders felt
that the lack of affordable and accessible housing available throughout the community was a significant
hindrance in providing services in an efficient and impactful manner.
Another issue highlighted by stakeholders was the lack of transitional housing available in Bozeman. One
stakeholder shared that to ensure that the supportive services received by residents are actually
effective, these residents need to be in safe and secure housing. They added that ideally, transitional
housing available in Bozeman are actual homes, and not converted hotel rooms. Stakeholders
emphasized the importance of a resident/household to feel genuinely safe and secure in their housing
situation to make supportive services as impactful as possible.
The City’s Belonging in Bozeman Equity and Inclusion Plan was adopted in December 2023. One of the
recommendations coming out of its Health & Wellbeing Goals/Recommendations was Increasing
coordination between health agencies to reduce barriers to healthcare services and programs. Strategies
to implement this recommendation as articulated in the Plan include:
• Coordinate across organizations to enable data sharing to better characterize health disparities
and social needs in underserved communities.
• Improve referral and case management processes across health care and social service
providers to connect patients/clients with community resources.
Availability of services targeted to homeless persons and persons with HIV and mainstream
services
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Homelessness Prevention
Services
Available in the
Community
Targeted to
Homeless
Targeted to People
with HIV
Homelessness Prevention Services
Counseling/Advocacy X X X
Legal Assistance X X
Mortgage Assistance X
Rental Assistance X X
Utilities Assistance X X
Street Outreach Services
Law Enforcement X
Mobile Clinics
Other Street Outreach Services X X
Supportive Services
Alcohol & Drug Abuse X X X
Child Care X X
Education X X
Employment and Employment
Training
X X
Healthcare X X X
HIV/AIDS X
Life Skills X
Mental Health Counseling X X X
Transportation X X
Other
Other
Table 50 - Homeless Prevention Services Summary
Describe how the service delivery system including, but not limited to, the services listed
above meet the needs of homeless persons (particularly chronically homeless individuals and
families, families with children, veterans and their families, and unaccompanied youth)
The HRDC provides a range of services to a wide variety of residents, including unhoused residents,
residents experiencing emergency needs, families in need of ongoing housing assistance, and others. At
the end of 2023, HRDC opened Market Place, which opened to ensure that no one in the Bozeman
community goes hungry. The Market Place includes a warehouse for emergency food storage, a grocery
area, a pay-what-you-can restaurant, space for enrichment and educational opportunities, and access to
several homelessness prevention and supportive services. In addition to Market Place, HRDC will open
Homeward Point in 2025, Bozeman’s first and only year-round emergency shelter and resource hub to
integrate services is intended to make homelessness rare, brief, and one-time. Several other
organizations, such as Family Promise, Haven, and the VA, provide a range of housing and/or services to
specific unhoused and low-income populations.
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Describe the strengths and gaps of the service delivery system for special needs population
and persons experiencing homelessness, including, but not limited to, the services listed
above
Montana 2-1-1 website provides a comprehensive list of services that are part of the community-wide
effort to connect people at imminent risk of homelessness with help. Services available in the
community include at-risk/homeless housing-related assistance programs, homeless prevention and
diversion programs, healthcare-focused programs, and other specialized services.
Another common issue highlighted by stakeholders in Bozeman’s existing delivery system was the lack
of mental health services available in the city, with one stakeholder sharing that these services “are non-
existent right now.” Other services lacking in the city’s service delivery system include substance
use/chemical dependency services.
Stakeholders that serve unhoused residents in the Bozeman area described the lack of transitional
housing as one of the most critical housing needs in the city. One stakeholder described that while the
city’s shelter capacity has increased, the supply of transitional housing is lagging significantly behind
demand. They added that a consequence of having limited transitional housing is that for residents who
might be ready to move on from the shelter into transitional housing, they have no options available to
them so they usually end up back on the street. Stakeholders felt that the lack of transitional housing
options, as well as the lack of housing in general, makes the city’s service delivery system less effective.
Provide a summary of the strategy for overcoming gaps in the institutional structure and
service delivery system for carrying out a strategy to address priority needs
The City benefits from a strong network of housing and community development partners. Stakeholders
described the lack of funding as a significant barrier to overcoming the gaps in the community’s service
delivery system. Nonetheless, while several stakeholders acknowledged that an influx of funding would
not fix all of the gaps, they did advocate for more coordination among service providers to ensure that
efficiency and efficacy of services is maximized while duplication of services is reduced.
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SP-45 Goals Summary – 91.215(a)(4)
The following table reflects staff recommendations on funding allocation by goal. Final amount will be determined in collaboration with City
Commission.
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome Indicator
1 Increasing and
Preserving
Housing
Options
2024 2028 Affordable
Housing
Citywide Affordable rental
housing
Affordable
homeownership
opportunities
Accessible housing
$846,355 Rental units constructed:
150 Household Housing Unit
Homeowner Housing Rehabilitated:
5 Household Housing Unit
Housing for Homeless added:
10 Household Housing Unit
2 Supporting
Vulnerable
Populations
2024 2028 Homeless Citywide Emergency shelter
and transitional
housing
$212,687 Homeless Person Overnight Shelter:
75 Persons Assisted
Overnight/Emergency Shelter/Transitional
Housing Beds added:
30 Beds
3 Critical
Community
Services
2024 2028 Public Services Citywide Community
Services
$244,394 Public service activities other than
Low/Moderate Income Housing Benefit:
500 Persons Assisted
4 Planning and
Administration
2024 2028 Planning and
Administration
Citywide Planning and
Administration
$325,859 Other:
0 Other
Table 51 – Goals Summary
Goal Descriptions
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Goal Name Goal Description
Increasing and Preserving Housing
Options
Increase, protect and preserve affordable rental and homeownership housing opportunities by improving access
to a diverse set of affordable housing, including but not limited to, naturally occurring affordable housing (NOAH),
supportive housing for seniors and residents living with disabilities, and accessible housing.
Supporting Vulnerable
Populations
Improve housing stability for individuals and households with critical needs, including persons experiencing or at-
risk of homelessness by providing appropriate housing and service solutions grounded in Housing First
approaches, including but not limited to, emergency shelter, transitional housing, and other supportive services.
Critical Community Services Improve community services by addressing critical needs and promoting equity through improved or increased
access to community programming, including but not limited to, mental health services, chemical dependency
services, and affordable and available childcare.
Planning and Administration Support the implementation of the three goals articulated above.
Estimate the number of extremely low-income, low-income, and moderate-income families to whom the jurisdiction will provide
affordable housing as defined by HOME 91.315(b)(2)
The City of Bozeman estimates that through the implementation of the above goals, will serve roughly 100 extremely low-income, low-income,
and moderate-income families to whom the jurisdiction will provide affordable housing, shelter, and/or services.
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SP-50 Public Housing Accessibility and Involvement – 91.215(c)
Need to Increase the Number of Accessible Units (if Required by a Section 504 Voluntary
Compliance Agreement)
n/a.
Activities to Increase Resident Involvements
n/a.
Is the public housing agency designated as troubled under 24 CFR part 902?
n/a.
Plan to remove the ‘troubled’ designation
n/a.
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SP-55 Barriers to affordable housing – 91.215(h)
Barriers to Affordable Housing
As articulated in the housing market analysis, several barriers to affordable housing development were
identified in Bozeman. Barriers identified by stakeholders included the high cost of infrastructure,
complex and convoluted development code, high cost and lack of availability of land, cost of labor, short
construction season, overly restrictive private covenants, and community pushback. Additionally,
stakeholders highlighted the State’s removal of a jurisdiction’s regulatory authority to allow inclusionary
zoning as another barrier.
Strategy to Remove or Ameliorate the Barriers to Affordable Housing
While some of the barriers highlighted above cannot be addressed by the City of Bozeman, the City has
implemented several efforts to address the lack of affordable housing in the community.
Following the 2019 Community Housing Needs Assessment, the City developed the 2020 Bozeman
Community Housing Action Plan to focus the community housing partnership framework and increase
the ability to meet community housing needs in Bozeman. The City identified 17 strategies to implement
over the next five years:
Funding
• General Funds
• Tax Increment Financing (TIF)
• Taxed dedicated to housing
• Low-Income Housing Tax Credits
Preservation
• Community Land Trust
• Deed Restricted Housing (permanent)
• Co-op Housing (mobile home parks)
Incentive/Regulation
• Removal of Regulatory Barriers
• ADUs
• Fee Waiver/Deferral
Partnership/Land
• Public/Private/Institutional Partnerships
• Land Banking
Program
• Homebuyer Assistance
• Permanent Supportive Housing (PSH)
and Transitional
• Employer Assisted Housing
Several of these strategies have and continue to be implemented. In addition to its existing community
housing inventory of over 1,200 affordable rentals and close to 200 affordable homeownership units, as
of January 2024, there are an additional 1,241 community housing affordable units in the project
pipeline.
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Additionally, while the City’s effort to update the Unified Development Code is currently paused, the
effort will aim to:
• Ensure consistency with the Growth Plan and other adopted policy documents;
• Modernize and improve the organization, usability, and user-friendliness of the code;
• Provide for a wide range of housing types to meet an expanded range of housing needs;
• Improve the built environment and provide new and improved development standards; and
• Ensure compliance with recent state land use legislative changes.
The City of Bozeman leverages a variety of programs, public and private, to fill the large financial gaps in
affordable housing projects due to the escalating costs of land, labor, lumber and lending. The tools
currently at the City’s disposal include the Community Housing Fund, a yearly general fund allocation,
Urban Renewal funds when a project is located within an Urban Renewal District, 4% or 9% Low Income
Housing Tax Credits when available, and when awarded by the State of Montana, and the Gallatin
Housing Impact Fund, a $10M privately raised low-interest revolving loan fund. Occasionally, there is
overlap between the geographically constrained URD and LIHTC boundaries where the City can pair and
sometimes triple the incentive to lower the AMI and increase long term affordability.
The City will also look for opportunities to support and defend local housing solutions at the state
legislature and Identify and pursue local and state revenue streams for the creation of affordable
housing and housing assistance programs, including dedicated mills to affordable housing projects and
preserving the ability to use Tax Increment Financing as a tool for affordable housing
The City of Bozeman will continue to implement the strategies above and will look to leverage other
opportunities and partnerships that help reduce barriers to affordable housing development in the city.
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SP-60 Homelessness Strategy – 91.215(d)
The City of Bozeman adopted its Belonging in Bozeman Equity & Inclusion Plan in December 2023 to
ensure that all residents, visitors, and City employees can thrive regardless of their race, identity, or life
circumstance. The Plan builds upon the City’s 2021 Equity Indicators Report and was put together
through a collective partnership of the entire Bozeman community, including nonprofits, businesses,
community groups, educational institutions, residents, employees, and visitors alike. This section
summarizes the primary contents of that strategy and is organized around actions to address the needs
of residents experiencing homelessness, helping individuals and families experiencing homelessness
make the transition to permanent housing, and prevent homelessness.
Reaching out to homeless persons (especially unsheltered persons) and assessing their
individual needs
The development of the City’s Belonging in Bozeman Equity & Inclusion Plan emphasized removing
participation barriers and fostering diverse pathways for input to ensure that the Plan was grounded in
shared experiences and supported by data and community engagement findings. The Plan
acknowledges that residents with lived experiences should be valued and integrated into goals and
recommendations that address homelessness in the community.
To that end, the first goal of the Equity and Inclusion Plan’s Housing recommendations is Develop a
coordinated strategy to address homelessness in the Bozeman area. This goal’s first strategy is to
“Identify and prioritize Housing First approaches to address housing instability and homelessness.”
According to the National Low Income Housing Coalition (NLIHC), under the Housing First model,
“homeless service providers must design programs that address the unique, individualized needs and
interests of each person who is being served, rather than imposing a one-size-fits-all design that denies
or disqualifies people from receiving the assistance they need.”8
Addressing the emergency and transitional housing needs of homeless persons
Additionally, the City’s Equity and Inclusion Plan first Housing Goal includes a recommendation to
address the emergency and transitional housing needs of Bozeman residents experiencing
homelessness. Specifically, the recommendation states, “Support partner organizations by funding
transitional and emergency housing initiatives and programs.” The City is currently addressing this need
through a competitive grant award process (using City general resources) that funds the work of non-
profits that provide social services not covered by the City. This effort aligns with Goal 2 of this
Consolidated Plan. Additionally, several stakeholders consulted for the development of this plan
identified transitional housing as one of the most critical housing needs for unhoused residents in
Bozeman.
8 National Low Income Housing Coalition, Key Facts about Housing First, February 2023
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Helping homeless persons (especially chronically homeless individuals and families, families
with children, veterans and their families, and unaccompanied youth) make the transition to
permanent housing and independent living, including shortening the period of time that
individuals and families experience homelessness, facilitating access for homeless individuals
and families to affordable housing units, and preventing individuals and families who were
recently homeless from becoming homeless again.
One of the primary goals of the HRDC is to assist unhoused residents access safe and secure housing and
to ensure that being unhoused in Bozeman is rare, brief, and one-time. The organization’s housing
services include providing emergency shelter and transitional housing, assisting residents find affordable
rentals and access assistance, and providing homeownership assistance with education, counseling, and
other resources.
Recently, HRDC opened Market Place, which includes a warehouse for emergency food storage, a
commercial kitchen, a grocery area, a pay-what-you-can restaurant, and space for enrichment activities.
Additionally, the Market Place acts as a “one-stop-shop” hub of services to ensure that residents
experiencing homelessness can meet all of their needs in one place. The Market Place also includes
several housing resources, including:
• Emergency assistance;
• Financial coaching and education;
• Support to file taxes;
• Utility assistance programs;
• Home weatherization assistance;
• Transitional housing support for youth;
• Home rental search and assistance;
• Homeowner assistance; and
• Transitional housing support.
Additionally, in 2025, HRDC is opening Homeward Point, a new year-round shelter to address the needs
of Bozeman’s unhoused community, right next door to the Market Place. The proximity of this shelter
and availability of services will make it easier to help unhoused residents transition to permanent
housing, find affordable housing units, and ensure that once these households find housing, they are
stable and secure in their situation.
Help low-income individuals and families avoid becoming homeless, especially extremely
low-income individuals and families who are likely to become homeless after being
discharged from a publicly funded institution or system of care, or who are receiving
assistance from public and private agencies that address housing, health, social services,
employment, education or youth needs
As highlighted above, HRDC’s Market Place provides a variety of services to all residents in Bozeman
who are either unhoused or are at-risk of experiencing homelessness. In addition to the services
described above, other housing resources and services available to residents likely to become homeless
after being discharged from a publicly funded institution or system of care, as well as residents receiving
assistance from public and private agencies, include:
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• Monthly grocery program for seniors;
• Youth employment support;
• Foster youth support;
• Medicare counseling;
• At home assistance for older adults; and
• Care coordination for older adults.
The City’s Belonging in Bozeman Equity & Inclusion Plan includes other recommendations to ensure that
low-income individuals and families, as well as residents receiving assistance from public and private
agencies, find safe, secure, and affordable housing. One of the recommendations under the City’s goal
of developing a coordinated strategy to address homelessness in the area is “Working with partners to
leverage creative funding mechanisms, incentives, existing assets to increase long-term affordable
housing supply and housing preservation for people earning below 60% AMI.” This recommendation
aims to increase the supply of housing that is available to low-income residents in Bozeman, as well as
residents who are currently in need of housing and other service assistance. Other goals articulated in
the City’s Equity & Inclusion Plan aimed at assisting this population include:
• Promote aging in place and universally accessible residential development;
• Support and defend local housing solutions at the state legislature;
• Support continuing education for health professionals on working with underserved
communities;
• Increase coordination between health agencies to reduce barriers to healthcare services and
programs;
• Increase wrap-around support and resources available to students experiencing homelessness;
• Support and recognize inclusive businesses and employers;
• Support the growing Hispanic + Latino workforce to our economy and community;
• Increase knowledge and use of resources for underserved communities; and
• Prioritize food access for low-income communities.
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SP-65 Lead based paint Hazards – 91.215(i)
Actions to address LBP hazards and increase access to housing without LBP hazards
As discussed in MA-20 Housing Market Analysis: Condition of Housing, there is a correlation between
low- to moderate-income households and lead-based paint (LBP) hazards. As such, the City will plan to
develop policies and procedures to address lead-based paint hazards in housing built before 1978 that
are compliant with regulations regarding the use of Community Development Block Grant (CDBG)
funding during this upcoming program year.
How are the actions listed above related to the extent of lead poisoning and hazards?
Lead-based paint (LBP) was prohibited in residential properties starting in 1978. In Bozeman, 33% of the
housing stock was built before 1980. Assuming an equal distribution of Bozeman’s low- to moderate-
income households, then 50% of the 7,382 housing units built before 1980, or 3,691, would be low or
moderate-income households possibly at risk of LBP hazards. As such, the City’s development of policies
and procedures related to lead-based paint hazards will include guidance on lead-based paint
screenings, mitigation actions, when necessary, and information for homeowners and tenants regarding
the hazards of lead-based paint and actions that will help reduce the likelihood of lead poisoning events.
How are the actions listed above integrated into housing policies and procedures?
The City will ensure that all CDBG contracts entered into between the City and Subrecipients of CDBG
funding will include language that stipulates that Subrecipients must comply with lead-based paint
regulations and policies as established by the City, State of Montana, and other applicable Federal laws
and regulations, including specific policies related to lead-based pain in the CDBG program.
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SP-70 Anti-Poverty Strategy – 91.215(j)
Jurisdiction Goals, Programs and Policies for reducing the number of Poverty-Level Families
How are the Jurisdiction poverty reducing goals, programs, and policies coordinated with this
affordable housing plan
Several of the goals and objectives articulated in the City of Bozeman’s 2023 Economic Development
Strategy address reducing poverty in the community including:
Provide Opportunity for Gallatin Valley Residents
• Enhance the small business development ecosystem;
• Provide comprehensive and coordinated skills development starting with child care through
middle school and higher-ed; and
• Improve access to career opportunities for local and surrounding rural residents.
Support a Diverse Economy
• Enhance development of the talent pipeline.
Build a More Resilient Region
• Increase amount and access of housing for all.
Additionally, the City’s Belonging in Bozeman Equity and Inclusion Plan has several goals related to
addressing poverty in the community, which are also coordinated with the goals articulated in this
Consolidated Plan. The Belonging in Bozeman Plan goals include:
Housing Goals
• Develop a coordinated strategy to address homelessness in the Bozeman area.
• Reduce displacement of residents who work and go to school in Bozeman but cannot afford to
live in Bozeman.
• Promote aging-in-place and universally accessible residential development.
Health & Wellbeing Goals
• Support continuing education for health professionals on working with underserved
communities.
• Increased coordination between health agencies to reduce barriers to healthcare services and
programs.
• Expand meaningful language access in clinical settings and in health promotion programs.
Education
• Expand opportunities for multilingual learners of all ages.
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• Increase recruitment and resources to support higher education for underserved communities.
• Increase wrap-around support and resources available to students experiencing homelessness.
Childcare & Youth
• Reduce barriers to out-of-school opportunities and programs for underserved children.
• Increase capacity of after-school and summer programs.
• Increase subsidy for childcare programs and providers.
• Recruit, develop, and retain quality staff.
Economic Security
• Serve as a model for fostering fair and inclusive work environments.
• Expand access to city contracts and funding for local firms, businesses, and vendors.
• Support the growing Hispanic and Latino workforce to our economy and community.
Community Resiliency
• Increase knowledge and use of resources for underserved communities.
• Alleviate utility cost burden for low-income residents.
• Prioritize food access for low-income communities.
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SP-80 Monitoring – 91.230
Describe the standards and procedures that the jurisdiction will use to monitor activities
carried out in furtherance of the plan and will use to ensure long-term compliance with
requirements of the programs involved, including minority business outreach and the
comprehensive planning requirements
The City of Bozeman is responsible for ensuring that all regulations and requirements governing the
administrative, financial, and programmatic operations of the CBDG program are followed. This includes
ensuring that performance goals are achieved within the scheduled timeframe and budget, as well as
ensuring that the City and/or Subrecipient of the City’s CDBG funding are taking appropriate actions
when performance problems arise. If the City decides to allocate its entitlement funding to
Subrecipients, monitoring of the Subrecipient continues over the course of the project.
Monitoring Plan
Because this is the City’s first Consolidated Plan, a Subrecipient Monitoring Plan has not been created.
However, the City will utilize HUD’s Managing CDBG: A Guidebook for Grantees on Subrecipient
Oversight and will develop a Monitoring Plan over the next program year. Specifically, the City’s
Monitoring Plan will include:
• A statement about the importance of Subrecipient monitoring;
• Regulatory requirements related to Uniform Administrative Requirements, Cost Principles, Audit
Requirements for Federal Awards, and grant administration responsibilities related to the
Community Development Block Grant (CDBG) program;
• The City’s Risk Analysis assessment and process to determine a Subrecipient’s technical
assistance needs, how often Subrecipients should be monitored, and how the City’s monitoring
of Subrecipients will be structured;
• Development of a monitoring strategy, which might include remote review of Subrecipient
documents, pre-monitoring, and formal monitoring visits;
• Establishment of a monitoring schedule;
• Creation of a monitoring checklist and workbook;
• A list of monitoring questions to help determine whether Subrecipients are complying with
federal requirements.
• How to conduct a monitoring; and
• How to notify a Subrecipient about concerns and findings, corrective actions, and sanctions; and
• How to address any findings of noncompliance.
The City will also plan to include a list of monitoring resources to ensure City staff have the knowledge
and information needed to conduct monitoring of Subrecipients in an efficient and thorough manner.
The City will work with its local HUD office to ensure its Monitoring Plan includes all necessary
information and applicable federal regulations and requirements. The City will also ensure that its
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Monitoring Plan includes information related to outreach to minority businesses and organizations, as
well as compliance with comprehensive planning requirements.
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Expected Resources
AP-15 Expected Resources – 91.220(c)(1,2)
Introduction
HUD’s FY24 CPD Formula Program Allocations has the City of Bozeman receiving $325,859 in CDBG funding.
Anticipated Resources
Program Source
of
Funds
Uses of Funds Expected Amount Available Year 1 Expected
Amount
Available
Remainder
of ConPlan
$
Narrative Description
Annual
Allocation:
$
Program
Income: $
Prior Year
Resources:
$
Total:
$
CDBG Public
Federal
Housing
Homeless Support
Public Services
Planning and
Administration
$325,859 n/a n/a $325,859 $1,303,436 Expected Amount
Available for remainder
of Con Plan is FY2024
allocation times four.
Table 52 - Expected Resources – Priority Table
Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how
matching requirements will be satisfied
Federal CDBG funds will be paired with the City’s Community Housing Fund to achieve the goals outlined in the Consolidated Plan. The City
estimates that $1 million will be available in the Community Housing Fund over the next program year. There are no additional resources. There
are no matching requirements.
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If appropriate, describe publicly owned land or property located within the jurisdiction that
may be used to address the needs identified in the plan.
Within city boundaries, publicly owned land suitable for development is incredibly limited. However, the
City is actively seeking out and pursuing partnerships with other government agencies, organizations,
and local entities to find and develop land suitable for affordable and workforce housing.
Discussion
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Annual Goals and Objectives
AP-20 Annual Goals and Objectives
The following table reflects staff recommendations on funding allocation by goal. Final amounts will be determined in collaboration with City
Commission.
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs
Addressed
Funding Goal Outcome Indicator
1 Increasing and
Preserving
Housing
Options
2024 2028 Affordable
Housing
Citywide Affordable
rental housing
Affordable
homeownership
opportunities
Accessible
housing
$0 Other:
0 Other
2 Supporting
Vulnerable
Populations
2024 2028 Homeless Citywide Emergency
shelter and
transitional
housing
$212,687 Homeless Person Overnight Shelter:
75 Persons Assisted
Overnight/Emergency Shelter/Transitional
Housing Beds added:
30 Beds
3 Critical
Community
Services
2024 2028 Public Services Citywide Community
Services
$48,000 Public service activities other than Low/Moderate
Income Housing Benefit:
100 Persons Assisted
4 Planning and
Administration
2024 2028 Planning and
Administration
Citywide Planning and
Administration
$65,172 Other:
0 Other
Table 53 – Goals Summary
Goal Descriptions
The five-year goals established to address housing and community development needs in Bozeman are described in the table below.
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Goal Name Goal Description
Increasing and Preserving Housing Options Increase, protect and preserve affordable rental and homeownership housing
opportunities by improving access to a diverse set of affordable housing,
including but not limited to, naturally occurring affordable housing (NOAH),
supportive housing for seniors and residents living with disabilities, and
accessible housing.
Supporting Vulnerable Populations Improve housing stability for individuals and households with critical needs,
including persons experiencing or at-risk of homelessness by providing
appropriate housing and service solutions grounded in Housing First
approaches, including but not limited to, emergency shelter, transitional
housing, and other supportive services.
Critical Community Services Improve community services by addressing critical needs and promoting equity
through improved or increased access to community programming, including
but not limited to, mental health services, chemical dependency services, and
affordable and available childcare.
Planning and Administration Support the implementation of the three goals articulated above.
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Projects
AP-35 Projects – 91.220(d)
Introduction
Based on the Consolidated Plan goals described above, the table below describes the projects that will
be funded in Program Year (PY) 2024-2025.
Projects
# Project Name
1 Emergency and transitional housing
2 Public services
Table 54 – Project Information
Describe the reasons for allocation priorities and any obstacles to addressing underserved
needs.
These priorities meet an increasing need in the Bozeman community by addressing the most acute
housing needs through the additional of transitional and emergency housing, the cost-effective
preservation of naturally occurring ah and supportive housing for underserved seniors and people with
disabilities.
Housing has been an issue for Bozeman residents for many years; concern has increased as costs have
skyrocketed following the COVID-19 pandemic. This is well-documented across several existing reports.
The 2019 Bozeman Community Housing Needs Assessment revealed that prior to the pandemic, housing
costs were already becoming unmanageable – the percentage of households paying over 30% of their
income for rent plus utilities was 55%.
Bozeman’s 2021 Equity Indicators Project found housing access to affordable housing was the top need
identified by survey takers (69% reported “large need”). The most recent 2023 Gallatin Valley Housing
Report confirms that the post-COVID real estate price surge has been staggering: “the median price of a
newly built single-family home in 2022 was $950,000, nearly double the amount recoded in 2019.”
These priorities take steps to ensure equitable and inclusive housing is a reality in Bozeman by focusing
strategically on homelessness, displacement, aging-in-place and universal building accessibility,
increasing community knowledge, and lobbying for local solutions at the state level, so that Bozeman
residents of all ages, abilities, and income levels can feel confident and secure in calling Bozeman their
home.
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AP-38 Project Summary
Project Summary Information
Project
Name
Target
Area
Goals
Supported
Needs
Addressed
Funding Description Target
Date
Estimate the
number and
type of families
that will benefit
Emergency
and
transitional
housing
City-
wide
Goal 2:
Supporting
Vulnerable
Populations
Priority
Need 4.
Emergency
Shelter and
Transitional
Housing
$212,687 Improve housing stability for individuals
and households with critical needs,
including persons experiencing or at-risk
of homelessness by providing
appropriate housing and service
solutions grounded in Housing First
approaches, including but not limited to,
emergency shelter, transitional housing,
and other supportive services.
2024 75 people
experiencing
and/or at risk of
homelessness
Public
Services
City-
wide
Goal 3:
Critical
Community
Services
Priority
Need 5.
Community
Services
$48,000 Improve community services by
addressing critical needs and promoting
equity through improved or increased
access to community programming,
including but not limited to, mental
health services, chemical dependency
services, and affordable and available
childcare.
2024 100 low- and
moderate-
income
residents
Admin City-
wide
All goals
supported
All priorities
supported
$65,172 Planning and administration of CDBG
funds
2024 n/a
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AP-50 Geographic Distribution – 91.220(f)
Description of the geographic areas of the entitlement (including areas of low-income and
minority concentration) where assistance will be directed
The City of Bozeman will not distribute funds geographically.
Geographic Distribution
Target Area Percentage of Funds
Citywide 100%
Table 55 - Geographic Distribution
Rationale for the priorities for allocating investments geographically
n/a.
Discussion
n/a.
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Affordable Housing
AP-55 Affordable Housing – 91.220(g)
Introduction
One Year Goals for the Number of Households to be Supported
Homeless 75
Non-Homeless 100
Special-Needs
Total 175
Table 56 - One Year Goals for Affordable Housing by Support Requirement
One Year Goals for the Number of Households Supported Through
Rental Assistance
The Production of New Units
Rehab of Existing Units
Acquisition of Existing Units
Total
Table 57 - One Year Goals for Affordable Housing by Support Type
Discussion
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AP-60 Public Housing – 91.220(h)
Introduction
There are no public housing units in the city of Bozeman.
Actions planned during the next year to address the needs to public housing
n/a.
Actions to encourage public housing residents to become more involved in management and
participate in homeownership
n/a.
If the PHA is designated as troubled, describe the manner in which financial assistance will be
provided or other assistance
n/a.
Discussion
n/a.
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AP-65 Homeless and Other Special Needs Activities – 91.220(i)
Introduction
Describe the jurisdictions one-year goals and actions for reducing and ending homelessness
including
As highlighted in the City’s Strategic Plan, the City of Bozeman’s Equity and Inclusion recommends that
the City develop a coordinated strategy to address homelessness in the Bozeman area in partnership
with HRDC and the One Valley Regional Housing Coalition. The Coalition is made up of a government
leaders, housing developers, banks, realtors, and other employers to help inform community members
about housing issues, coordinate diverse partners and resources, and catalyze solutions to address
housing stability and attainability in Gallatin County. The City will look to leverage and maximize its
entitlement funding with other local and state resources to address the housing and services needs of
unhoused Bozeman residents, as articulated in Goal 2 of this Plan.
Reaching out to homeless persons (especially unsheltered persons) and assessing their
individual needs
As highlighted in the City’s Strategic Plan, the first goal of the Equity and Inclusion Plan’s Housing
recommendations is “Develop a coordinated strategy to address homelessness in the Bozeman area.”
This goal’s first strategy is to “Identify and prioritize Housing First approaches to address housing
instability and homelessness.” The City will continue to work collaboratively with its local community
partners to provide funding and other resources to support reaching out to residents experiencing
homelessness to not only help assess their own unique individual needs, but to work toward developing
a strategy to address homelessness in Bozeman that is built upon the lived experience of unhoused
residents in the community.
Addressing the emergency shelter and transitional housing needs of homeless persons
The City’s Equity and Inclusion Plan first Housing Goal includes a recommendation to address the
emergency and transitional housing needs of Bozeman residents experiencing homelessness.
Specifically, the recommendation states, “Support partner organizations by funding transitional and
emergency housing initiatives and programs.” The City is currently addressing this need through a
competitive grant award process (using City general resources) that funds the work of non-profits that
provide social services not covered by the City. This effort aligns with Goal 2 of this Consolidated Plan.
Additionally, several stakeholders consulted for the development of this plan identified transitional
housing as one of the most critical housing needs for unhoused residents in Bozeman.
Helping homeless persons (especially chronically homeless individuals and families, families
with children, veterans and their families, and unaccompanied youth) make the transition to
permanent housing and independent living, including shortening the period of time that
individuals and families experience homelessness, facilitating access for homeless individuals
and families to affordable housing units, and preventing individuals and families who were
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recently homeless from becoming homeless again
One of the primary goals of the HRDC is to assist unhoused residents access safe and secure housing and
to ensure that being unhoused in Bozeman is rare, brief, and one-time. The organization’s housing
services include providing emergency shelter and transitional housing, assisting residents find affordable
rentals and access assistance, and providing homeownership assistance with education, counseling, and
other resources.
Recently, HRDC opened Market Place, which includes a warehouse for emergency food storage, a
commercial kitchen, a grocery area, a pay-what-you-can restaurant, and space for enrichment activities.
Additionally, the Market Place acts as a “one-stop-shop” hub of services to ensure that residents
experiencing homelessness can meet all of their needs in one place. The Market Place also includes
several housing resources, including:
• Emergency assistance;
• Financial coaching and education;
• Support to file taxes;
• Utility assistance programs;
• Home weatherization assistance;
• Transitional housing support for youth;
• Home rental search and assistance;
• Homeowner assistance; and
• Transitional housing support.
Additionally, in 2025, HRDC is opening Homeward Point, a new year-round shelter to address the needs
of Bozeman’s unhoused community, right next door to the Market Place. The proximity of this shelter
and availability of services will make it easier to help unhoused residents transition to permanent
housing, find affordable housing units, and ensure that once these households find housing, they are
stable and secure in their situation.
Helping low-income individuals and families avoid becoming homeless, especially extremely
low-income individuals and families and those who are: being discharged from publicly
funded institutions and systems of care (such as health care facilities, mental health facilities,
foster care and other youth facilities, and corrections programs and institutions); or, receiving
assistance from public or private agencies that address housing, health, social services,
employment, education, or youth needs
As highlighted above, HRDC’s Market Place provides a variety of services to all residents in Bozeman
who are either unhoused or are at-risk of experiencing homelessness. In addition to the services
described above, other housing resources and services available to residents likely to become homeless
after being discharged from a publicly funded institution or system of care, as well as residents receiving
assistance from public and private agencies, include:
• Monthly grocery program for seniors;
• Youth employment support;
• Foster youth support;
• Medicare counseling;
• At home assistance for older adults; and
• Care coordination for older adults.
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The City’s Belonging in Bozeman Equity & Inclusion Plan includes other recommendations to ensure that
low-income individuals and families, as well as residents receiving assistance from public and private
agencies, find safe, secure, and affordable housing. One of the recommendations under the City’s goal
of developing a coordinated strategy to address homelessness in the area is “Working with partners to
leverage creative funding mechanisms, incentives, existing assets to increase long-term affordable
housing supply and housing preservation for people earning below 60% AMI.” This recommendation
aims to increase the supply of housing that is available to low-income residents in Bozeman, as well as
residents who are currently in need of housing and other service assistance. Other goals articulated in
the City’s Equity & Inclusion Plan aimed at assisting this population include:
• Promote aging in place and universally accessible residential development;
• Support and defend local housing solutions at the state legislature;
• Support continuing education for health professionals on working with underserved
communities;
• Increase coordination between health agencies to reduce barriers to healthcare services and
programs;
• Increase wrap-around support and resources available to students experiencing homelessness;
• Support and recognize inclusive businesses and employers;
• Support the growing Hispanic + Latino workforce to our economy and community;
• Increase knowledge and use of resources for underserved communities; and
• Prioritize food access for low-income communities.
Discussion
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AP-75 Barriers to affordable housing – 91.220(j)
Introduction:
As articulated in the housing market analysis, several barriers to affordable housing development were
identified in Bozeman. Barriers identified by stakeholders included the high cost of infrastructure,
complex and convoluted development code, high cost and lack of availability of land, cost of labor, short
construction season, restrictive private covenants, and community pushback. Additionally, stakeholders
highlighted the State’s removal of a jurisdiction’s regulatory authority to allow inclusionary zoning as
another barrier.
Actions it planned to remove or ameliorate the negative effects of public policies that serve
as barriers to affordable housing such as land use controls, tax policies affecting land, zoning
ordinances, building codes, fees and charges, growth limitations, and policies affecting the
return on residential investment
While some of the barriers highlighted above cannot be addressed by the City of Bozeman, the City will
continue implementing the strategies articulated in its 2020 Bozeman Community Housing Action Plan.
Those strategies are listed below.
Funding
• General Funds
• Tax Increment Financing (TIF)
• Taxed dedicated to housing
• Low-Income Housing Tax Credits
Preservation
• Community Land Trust
• Deed Restricted Housing (permanent)
• Co-op Housing (mobile home parks)
Incentive/Regulation
• Removal of Regulatory Barriers
• ADUs
• Fee Waiver/Deferral
Partnership/Land
• Public/Private/Institutional Partnerships
• Land Banking
Program
• Homebuyer Assistance
• Permanent Supportive Housing (PSH)
and Transitional
• Employer Assisted Housing
Several of these strategies have and continue to be implemented. In addition to its existing community
housing inventory of over 1,200 affordable rentals and close to 200 affordable homeownership units, as
of January 2024, there are an additional 1,241 community housing affordable units in the project
pipeline. The City of Bozeman will continue to implement the strategies above and will look to leverage
other opportunities and partnerships that help reduce barriers to affordable housing development in
the city.
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The City of Bozeman leverages a variety of programs, public and private, to fill the large financial gaps in
affordable housing projects due to the escalating costs of land, labor, lumber and lending. The tools
currently at the City’s disposal include the Community Housing Fund, a yearly general fund allocation,
Urban Renewal funds when a project is located within an Urban Renewal District, 4% or 9% Low Income
Housing Tax Credits when available, and when awarded by the State of Montana, and the Gallatin
Housing Impact Fund, a $10M privately raised low-interest revolving loan fund. Occasionally, there is
overlap between the geographically constrained URD and LIHTC boundaries where the City can pair and
sometimes triple the incentive to lower the AMI and increase long term affordability.
The City will also look for opportunities to support and defend local housing solutions at the state
legislature and Identify and pursue local and state revenue streams for the creation of affordable
housing and housing assistance programs, including dedicated mills to affordable housing projects and
preserving the ability to use Tax Increment Financing as a tool for affordable housing
The City of Bozeman will continue to implement the strategies above and will look to leverage other
opportunities and partnerships that help reduce barriers to affordable housing development in the city.
The process to develop this plan was grounded in input from community members and partner
organizations to define needs, gather data, and chart a path forward. Community engagement efforts
on reducing barriers to participation and creating multiple ways for everyone to help establish the vision
for the plan, generate goals, and define the specific recommendations to achieve them.
Discussion:
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AP-85 Other Actions – 91.220(k)
Introduction:
Actions planned to address obstacles to meeting underserved needs
Actions planned to address obstacles to meeting underserved needs are listed in AP-65.
Actions planned to foster and maintain affordable housing
Actions planned to foster and maintain affordable housing are listed in Section AP-75.
Actions planned to reduce lead-based paint hazards
Actions planned to reduce lead-based paint hazards are listed in Section SP-65.
Actions planned to reduce the number of poverty-level families
Actions planned to reduce the number of poverty-level families are listed in Section SP-70.
Actions planned to develop institutional structure
Actions planned to develop institutional structure are listed in Section SP-40.
Actions planned to enhance coordination between public and private housing and social
service agencies
Actions planned to enhance coordination between public and private housing and social services
agencies are listed in Section SP-40.
Discussion:
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Program Specific Requirements
AP-90 Program Specific Requirements – 91.220(l)(1,2,4)
Introduction:
Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year are identified in the
Projects Table. The following identifies program income that is available for use that is included in
projects to be carried out.
1. The total amount of program income that will have been received before
the start of the next program year and that has not yet been reprogrammed
$0
2. The amount of proceeds from section 108 loan guarantees that will be
used during the year to address the priority needs and specific objectives
identified in the grantee's strategic plan
$0
3. The amount of surplus funds from urban renewal settlements $0
4. The amount of any grant funds returned to the line of credit for which the
planned use has not been included in a prior statement or plan.
$0
5. The amount of income from float-funded activities $0
Total Program Income $0
Other CDBG Requirements
1. The amount of urgent need activities
2. The estimated percentage of CDBG funds that will be used for activities that
benefit persons of low and moderate income. Overall Benefit - A
consecutive period of one, two or three years may be used to determine
that a minimum overall benefit of 70% of CDBG funds is used to benefit
persons of low and moderate income. Specify the years covered that
include this Annual Action Plan.
0%
100%
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Appendix - Alternate/Local Data Sources
1 Data Source Name
American Community Survey
List the name of the organization or individual who originated the data set.
United States Census Bureau
Provide a brief summary of the data set.
The United States Census Bureau facilitates an annual survey, the American Community Survey
(ACS), that collects detailed demographic information pertaining to social, economic, and housing
characteristics of the U.S. population.
What was the purpose for developing this data set?
The ACS is an ongoing survey that provides vital information on a yearly basis about the nation
and its people. Information from the survey generates data that help inform how trillions of
dollars in federal funds are distributed each year.
Provide the year (and optionally month, or month and day) for when the data was collected.
2018-2022 5-year estimates
Briefly describe the methodology for the data collection.
The Census Bureau mails letters to inform people living at an address that they have been
selected to participate in the ACS and to provide instructions for completing the survey online.
Households are asked to complete the survey online or to mail the completed paper
questionnaire back to the Census Bureau’s National Processing Center. If the Census Bureau does
not receive a completed survey within a few weeks, it will mail an additional paper survey
questionnaire. Following all mail contacts, a sample is taken from the addresses that have not
responded online, by mail, or for those addresses with post office box mail delivery. These
addresses are visited by Census Bureau field representatives, who will conduct the interview in
person. A sample of people living in group quarters facilities, such as college dormitories, nursing
homes, and prisons, are also interviewed in person to ensure coverage of everyone in the country.
Describe the total population from which the sample was taken.
The Census Bureau selects a random sample of addresses to be included in the ACS. Each address
has about a 1-in-480 chance of being selected in a month, and no address should be selected
more than once every 5 years. The Census Bureau mails questionnaires to approximately 295,000
addresses a month across the United States.
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Describe the demographics of the respondents or characteristics of the unit of measure, and the number
of respondents or units surveyed.
The sample is designed to ensure good geographic coverage and does not target individuals. By
focusing on quality geographic coverage, the ACS can produce a good picture of the community’s
people and housing by surveying a representative sample of the population.
2 Data Source Name
Comprehensive Housing Affordability Strategy (CHAS)
List the name of the organization or individual who originated the data set.
United States Department of Housing and Urban Development (HUD)
Provide a brief summary of the data set.
HUD receives custom tabulations of American Community Survey (ACS) data from the U.S. Census
Bureau, know as CHAS data. These data demonstrate the extent of housing problems and housing
needs, particularly for low income households.
What was the purpose for developing this data set?
The CHAS data are used by local governments to plan how to spend HUD funds, and may also be
used by HUD to distribute grant funds.
Provide the year (and optionally month, or month and day) for when the data was collected.
2016-2020
Briefly describe the methodology for the data collection.
The Census Bureau mails letters to inform people living at an address that they have been
selected to participate in the ACS and to provide instructions for completing the survey online.
Households are asked to complete the survey online or to mail the completed paper
questionnaire back to the Census Bureau’s National Processing Center. If the Census Bureau does
not receive a completed survey within a few weeks, it will mail an additional paper survey
questionnaire. Following all mail contacts, a sample is taken from the addresses that have not
responded online, by mail, or for those addresses with post office box mail delivery. These
addresses are visited by Census Bureau field representatives, who will conduct the interview in
person. A sample of people living in group quarters facilities, such as college dormitories, nursing
homes, and prisons, are also interviewed in person to ensure coverage of everyone in the country.
Describe the total population from which the sample was taken.
The Census Bureau selects a random sample of addresses to be included in the ACS. Each address
has about a 1-in-480 chance of being selected in a month, and no address should be selected
more than once every 5 years. The Census Bureau mails questionnaires to approximately 295,000
addresses a month across the United States.
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Describe the demographics of the respondents or characteristics of the unit of measure, and the number
of respondents or units surveyed.
The primary purpose of the CHAS data is to demonstrate the number of households in need of
housing assistance. This is estimated by the number of households that have certain housing
problems and have income low enough to qualify for HUD’s programs (primarily 30, 50, and 80%
of median income). Data are also available by different types of households, such as the elderly,
disabled, minorities, and other household types.
3 Data Source Name
Point-in-Time (PIT) Count
List the name of the organization or individual who originated the data set.
Montana CoC/HRDC
Provide a brief summary of the data set.
The Point-in-Time (PIT) Count is an annual count of sheltered and unsheltered people
experiencing homelessness on a single night in January.
What was the purpose for developing this data set?
The Point-in-Time (PIT) Count is meant to serve as a snapshot of homelessness in a community.
These data help to establish the dimensions of the problem of homelessness and help
policymakers and program administrators track progress toward the goal of ending homelessness.
Provide the year (and optionally month, or month and day) for when the data was collected.
2024
Briefly describe the methodology for the data collection.
The methodology that CoCs select to conduct their sheltered and unsheltered count is influenced
by the CoCs’ geographic and demographic characteristics, as well as their resources and capacity.
HUD allows CoCs to use multiple approaches to complete their count, including a census
approach, sample, or a combination of census and sampling approaches.
Describe the total population from which the sample was taken.
HUD requires CoCs to collect reliable data on the total number and characteristics of all people
(i.e., sheltered and unsheltered) residing in the CoCs’ geographic area who are homeless on a
single night and report these data to HUD. CoCs often do not have complete data on everyone
who is homeless and so must estimate some data.
Describe the demographics of the respondents or characteristics of the unit of measure, and the number
of respondents or units surveyed.
409 residents were identified during the PIT Count.
4 Data Source Name
National Intimate Partner and Sexual Violence Survey
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OMB Control No: 2506-0117 (exp. 09/30/2021)
List the name of the organization or individual who originated the data set.
Centers for Disease Control and Prevention (CDC), Department of Justice (DOJ), Bureau of Justice
Statistics (BJS), and the National Sexual Violence Resource Center
Provide a brief summary of the data set.
This data is compiled from an ongoing survey that collects the most current and comprehensive
national- and state-level data on intimate partner violence, sexual violence and stalking
victimization in the United States.
What was the purpose for developing this data set?
CDC developed NISVS to collect data on these important public health problems and enhance
violence prevention efforts.
Provide the year (and optionally month, or month and day) for when the data was collected.
2016-2017
Briefly describe the methodology for the data collection.
NISVS is an ongoing national random-digit-dial (RDD) telephone survey of women and men in the
United States that began in 2010.
Describe the total population from which the sample was taken.
NISVS samples noninstitutionalized English- or Spanish-speaking persons 18 years and older and
uses a dual-frame strategy that includes landlines and cell phones. It is conducted in all 50 states
and the District of Columbia.
Describe the demographics of the respondents or characteristics of the unit of measure, and the number
of respondents or units surveyed.
The estimates in this data are based on completed interviews (n=27,571). Information collected in
this survey includes lifetime and 12-moth prevalence of intimate partner violence, sexual violence,
and stalking; who is victimized by these forms of violence; characteristics of the violence; impact
of the violence victimization; and health conditions associated with these forms of victimization.
Demographic data collected includes sex, age, race/ethnicity, education status, marital status, and
household income.
5 Data Source Name
Fair Market Rents (40th Percentile Rents)
List the name of the organization or individual who originated the data set.
HUD Office of Policy Development & Research (PD&R)
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OMB Control No: 2506-0117 (exp. 09/30/2021)
Provide a brief summary of the data set.
Fair Market Rents (FMRs) are estimates of rent plus the cost of utilities, except telephone. FMRs
are used to determine payment standard amounts for the Housing Choice Voucher program,
initial renewal rents for some expiring project-based Section 8 contracts, initial rents for housing
assistance payment (HAP) contracts in the Moderate Rehabilitation Single Room Occupancy
program (Mod Rehab), rent ceilings for rental units in both the HOME Investment Partnerships
program and the Emergency Solutions Grants program, maximum award amounts for Continuum
of Care recipients and the maximum amount of rent a recipient may pay for property leased with
Continuum of Care funds, and flat rents in Public Housing units.
What was the purpose for developing this data set?
As described above, FMRs are used to determine annual payment standards for several different
HUD programs.
Provide the year (and optionally month, or month and day) for when the data was collected.
HUD annually estimates FMRs for Office of Management and Budget (OMB) defined metropolitan
areas, some HUD defined subdivisions of OMB metropolitan areas, and each nonmetropolitan
county.
Briefly describe the methodology for the data collection.
HUD uses a variety of data to develop base-year FMR estimates, including ACS data, locally
collected survey data acquired through Address-Based Mail surveys or Random Digit Dialing (RDD)
telephone survey data, and other statistically valid information presented to HUD during the
public comment and review period. Additionally, base-year recent moved adjusted FMRs are
updated and trended to the midpoint of the program year they are to be effective using
Consumer Price Index (CPI) data for rents and utilities.
Describe the total population from which the sample was taken.
FMR are established for metropolitan areas and nonmetropolitan counties. With several
exceptions, the most current Office of Management and Budget (OMB) metropolitan area
definitions of Metropolitan Statistical Areas (MSAs) are used because of their generally close
correspondence with housing market area definitions. Small Area FMR areas are the U.S. Postal
Service Zip code areas within a designated metropolitan area.
Describe the demographics of the respondents or characteristics of the unit of measure, and the number
of respondents or units surveyed.
Fair Market Rents are estimates of 40th percentile gross rents for quality units within a
metropolitan area or nonmetropolitan county.
6 Data Source Name
HOME Rents
List the name of the organization or individual who originated the data set.
U.S. Department of Housing and Urban Development
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OMB Control No: 2506-0117 (exp. 09/30/2021)
Provide a brief summary of the data set.
HOME-assisted units in a rental housing project must be occupied by households that are eligible
as low-income families. As such, HUD provides maximum HOME rent limits, which are the lesser
of the following: 1) The fair market rent for existing housing for comparable units in the area as
established by HUD under 24 CFR 888.111; or 2) A rent that does not exceed 30 percent of the
adjusted income of a family whose annual income equals 65 percent of the median income for the
areas, as determined by HUD, with adjustments for number of bedrooms in the unit.
What was the purpose for developing this data set?
This data set was developed to ensure that HOME-assisted units in a rental housing project are
occupied by eligible households.
Provide the year (and optionally month, or month and day) for when the data was collected.
2023. HUD updates this dataset annually.
Briefly describe the methodology for the data collection.
HUD uses a variety of data to develop base-year FMR estimates, including ACS data, locally
collected survey data acquired through Address-Based Mail surveys or Random Digit Dialing (RDD)
telephone survey data, and other statistically valid information presented to HUD during the
public comment and review period. Additionally, base-year recent moved adjusted FMRs are
updated and trended to the midpoint of the program year they are to be effective using
Consumer Price Index (CPI) data for rents and utilities. Additionally, HUD develops income limits
based on Median Family Income estimates for each metropolitan area, parts of some
metropolitan areas, and each non-metropolitan county.
Describe the total population from which the sample was taken.
FMRs are established for metropolitan areas and nonmetropolitan counties. With several
exceptions, the most current Office of Management and Budget (OMB) metropolitan area
definitions of Metropolitan Statistical Areas (MSAs) are used because of their generally close
correspondence with housing market area definitions. Small Area FMR areas are the U.S. Postal
Service Zip code areas within a designated metropolitan area. As noted above, HUD develops
income limits based on Median Family Income estimates for each metropolitan area, parts of
some metropolitan areas, and each non-metropolitan county.
Describe the demographics of the respondents or characteristics of the unit of measure, and the number
of respondents or units surveyed.
Fair Market Rents are estimates of 40th percentile gross rents for quality units within a
metropolitan area or nonmetropolitan county. Additionally, HUD’s HOME rent limits account for
average occupancy per unit and are adjusted for income.
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PREPARED FOR: ADOPTED
City of Bozeman Economic Development Dept. TBD
121 N. Rouse Avenue, Bozeman, MT 59715
www.bozeman.net/departments/economic-development
(406) 582-2300
DRAFT
Fair Housing Plan
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CITY OF BOZEMAN
2024-28 FAIR HOUSING PLAN
This document is a requirement of the U.S. Department of Housing and Urban
Development (HUD) as a condition of receiving a direct allocation of Community
Development Block Grant (CDBG) funds. As a recipient of HUD funds, the City is
required, under the Fair Housing Act (Title VIII of the Civil Rights Act of 1968) to
administer federal funds in a way that affirmatively furthers fair housing. This Fair
Housing Plan meets the federal standards for evaluating fair housing challenges
in Bozeman and identifying meaningful actions to promote fair housing choice.
Its contents are guided by federal standards and best practices. It should be
noted that the analysis may evaluate conditions—and identify challenges—that
are outside the City government’s sphere of influence.
This document is not intended to replace the City’s other housing and equity
plans, including Belonging in Bozeman and the Community Housing Action
Plan—rather it draws from those plans and builds on previous analyses in order to
comply with HUD reporting requirements.
161
Table of Contents
ROOT POLICY RESEARCH i
I. Executive Summary
Primary Findings ............................................................................................................... I–1
Impediments and Fair Housing Actions ........................................................................ I–7
II. Community Engagement Summary
Primary Findings .............................................................................................................. II–1
Survey Methodology ....................................................................................................... II–4
Survey Responses ............................................................................................................ II–4
Survey Findings ................................................................................................................ II–7
III. Demographic Patterns
Primary Findings ............................................................................................................. III–1
Growth and Diversity ..................................................................................................... III–5
Income and Poverty .....................................................................................................III–21
IV. Access to Opportunity
Primary Findings ............................................................................................................. III–1
Access to Quality Education .......................................................................................... III–3
Access to Employment .................................................................................................III–14
Transportation Access..................................................................................................III–19
Healthy Communities ...................................................................................................III–21
V. Disproportionate Housing Needs
Primary Findings .............................................................................................................. V–1
Indicators of Disproportionate Needs .......................................................................... V–2
Housing Cost Burden ...................................................................................................... V–2
Homeownership Differences ......................................................................................... V–5
Differences in Housing Challenges ............................................................................... V–8
Access to Credit ................................................................................................................ V–9
Housing Access ............................................................................................................. V–20
Public Housing Authority Policy Review .................................................................... V–23
VI. Fair Housing Environment
Primary Findings and Recommendations ................................................................... VI–1
Legal Framework ............................................................................................................ VI–2
Course of Action .............................................................................................................. VI–3
Housing Discrimination, Complaints, and Legal Cases ............................................. VI–6
Land Use, Public Policies, and Practices ...................................................................... VI–9
Bozeman Fair Housing Activities ............................................................................... VI–17
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I. EXECUTIVE SUMMARY
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION I, PAGE 1
SECTION I.
Executive Summary
This Fair Housing Plan commits the City of Bozeman to advancing equity in housing,
community development programs, and residents’ access to high-opportunity and well-
resourced areas. The plan identifies meaningful actions to promote fair housing choice and
foster inclusive communities that are free from discrimination. The plan does also identify
fair housing barriers that may be market-driven and/or outside the direct sphere of
influence of the City and its partners.
Primary Findings
The analyses of community engagement (Section II), demographics (Section III), access to
opportunity (Section IV), disproportionate housing needs (Section V), and fair housing
environment (Section VI) yield the following primary findings for the city of Bozeman.
Community engagement. This section summarizes challenges, ideas, and
outcomes gathered throughout the community engagement process from a wide variety of
residents and stakeholders; see Section II for details. Primary findings include:
Note to Readers: This document is a requirement of the U.S. Department of
Housing and Urban Development (HUD) as a condition of receiving a direct
allocation of Community Development Block Grant (CDBG) funds. As a recipient
of HUD funds, the City is required, under the Fair Housing Act (Title VIII of the
Civil Rights Act of 1968) to administer federal funds in a way that affirmatively
furthers fair housing. This Fair Housing Plan meets the federal standards for
evaluating fair housing challenges in Bozeman and identifying meaningful
actions to promote fair housing choice. Its contents are guided by federal
standards and best practices. It should be noted that the analysis may evaluate
conditions—and identify challenges—that are outside the City government’s
sphere of influence to address.
This document is not intended to replace the City’s other housing and equity
plans, including Belonging in Bozeman and the Community Housing Action
Plan—rather it draws from those plans and builds on previous analyses in order
to comply with HUD reporting requirements.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION I, PAGE 2
The lack of affordable housing was the number one challenge identified by residents
and stakeholders in Bozeman. Factors identified by residents and stakeholders
contributing to the lack of affordable housing included the high cost and lack of
available land, high development costs, zoning constraints, and community opposition.
Specific housing types needed in Bozeman articulated by residents and stakeholders
include more affordable housing for the local workforce, transitional housing options,
supportive housing for older residents, and accessible housing.
Populations with disproportionate housing needs and service needs identified by
residents and stakeholders include undocumented residents, Indigenous residents,
residents living with disabilities, and low-income households.
Barriers contributing to the challenge of finding and securing housing for these
populations included bad credit, criminal history, burdensome application processes
and fees, citizenship status, and low wages compared to the cost of housing (e.g., lack
of employment options to cover the current cost of living).
Residents and stakeholders articulated several housing and service outcomes they
wanted to see, including more landlords willing to take housing choice vouchers, the
availability of more mental health and addiction/chemical dependency services, and
more available and affordable childcare options.
Housing and Community Needs survey findings. The City of Bozeman
administered a Housing and Community Needs survey from March 2024 to May 2024.
Residents and stakeholders throughout the community were asked to identify resident
groups with the greatest housing challenges, the types of housing and housing activities
most needed in the city, the greatest unmet community development, economic
development, and public service needs, and how they wanted the City to prioritize its
federal resources. A brief summary of the high-level results is provided below.
Low- and moderate-income families, persons/families who are currently unhoused,
residents in the local workforce, residents living with mental illness, and residents
living with disabilities were identified as groups with the greatest housing challenges in
Bozeman.
According to residents and stakeholders, the five most critical housing outcomes for
prioritization are more affordable rental housing for low- to moderate-income
residents, more homeownership opportunities for low- to moderate-income residents,
a better distribution of affordable housing, more downpayment assistance for low-
and moderate-income households, and fewer affordable units converted to market
rate housing.
The five most critical community development outcomes identified by residents and
stakeholders included increased access to mental health care services, additional
and/or higher quality childcare centers, more climate resilience-focused planning and
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION I, PAGE 3
implementation efforts, increased access to addiction treatment services, and street
and sidewalk improvements.
One in five survey respondents (21%) reported being displaced from their housing
situation (e.g., moving out of a home/apartment when they did not want to move) in
Bozeman over the last five years.
Demographic patterns. This section analyzed demographic patterns associated
with residential settlement, housing availability and affordability, and access to
opportunity. Primary findings of this section are detailed below.
Bozeman’s population largely consists of non-Hispanic White residents (87%);
however, over the last twelve years, the city has gradually become more diverse.
The majority of households (54%) in the city are “non-family” households—largely
householders who live alone or share the home with people they are not related to.
This is driven in part by the presence of Montana State University.
The percentage of people living in poverty in Bozeman (14.7%) has declined by over a
quarter since 2010. Poverty varies by race and ethnicity but is significantly high for
African American/Black residents (30%). Hispanic residents, residents who identify as
some other race, and single mothers are more likely to live in poverty relative to the
general population.
American Indian and/or Alaska Native (AIAN) and Asian residents have lower
household median incomes compared to the general population.
One in four residents in Census Tract 6, which is located in the northeast quadrant of
the city, are living in poverty. This tract also has concentrations of residents living with
disabilities, Hispanic residents, and AIAN residents. It is important to note that some
sources of federal funding prioritizes low/moderate income Census tracts which can
have the effect of concentrating federally supported housing serving poverty
populations, in some cases maintain poverty concentrations.
While Bozeman’s Dissimilarity Index score—a measure of the severity of segregation—
show low levels of segregation between residents of color and non-Hispanic White
residents, this is primarily due to the city’s relatively low proportion of households of
color.
Access to opportunity. Analysis in this section points to gaps in access to
opportunity in:
Education. Non-Hispanic White students have substantially higher proficiency rates
than all other student groups by race and income within Bozeman schools. Indigenous
students have lower proficiency rates and high school graduation rates in Bozeman
compared to other students by race and ethnicity. Hispanic students in Bozeman also
have low graduation rates. Respondents living in households of color were much more
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION I, PAGE 4
likely to report dissatisfaction with their child(ren)’s education than non-Hispanic White
respondents in the housing and community needs survey. Note that the City of
Bozeman does not have direct influence on the school district, as the State of Montana
bars municipalities from regulating the school system, programs, and funding.
Employment outcomes. Between 2010 and 2022, the unemployment rate
decreased for non-Hispanic White and Hispanic residents, as well as residents who
identify as two or more races. Conversely, Indigenous workers saw a nine-percentage
point increase in unemployment over the same time period. While approximately four
in ten Bozeman residents have a college degree, nearly half of Indigenous residents
are college educated. Black residents have the lowest proportion of residents with a
college degree in Bozeman. Over a third of survey respondents (35%) identified an
increase in wages as needed to improve their job satisfaction.
Broadband access. While 97% of households with income above $75,000 have
an internet subscription, only 71% of households earning below $20,000 have an
internet subscription. For low-income households, lack of internet access may limit
their ability to access employment opportunities and community resources. Seven
percent of survey respondents indicated that increased access to broadband/internet
was a significant community need in Bozeman.
Access to transportation. According to the housing and community needs
survey, 25% of respondents are unsatisfied with their current transportation options.
Of these respondents, most wanted to see increased frequency, reliability, and
coverage of the district bus system1, as well as expanded connective networks for
alternative transportation options (e.g., biking and walking). Additionally, through
stakeholder conversations and focus groups conducted to support this study, as well
as findings from previous city efforts, several barriers exist for residents living with
disabilities to easily access the transportation system. Inaccessible buses, infrequent
fixed-route service, limited paratransit services, and other current infrastructure (e.g.,
sidewalks, parking spaces) make it challenging for residents to utilize these services
and spaces to their full advantage.
Healthy communities. Survey respondents identified a variety of outcomes
they wanted to see to improve their neighborhoods and health, including street and
sidewalk improvements, parks and recreation facility improvements,
new/improvements to existing community centers, more recreation opportunities,
making it easier to exercise, and better access to healthier foods. Census Tract 11.02,
which covers Montana State University and the southwest area of the city, was
1 Note that the City does not operate or own the bus system. There is a separate transit district which sets routes and
frequency and receives federal transportation funding.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION I, PAGE 5
identified as having limited food access, though there is a full-service grocery store in
the adjacent tract.
Disproportionate housing needs. The data analysis in this section of the Fair
Housing Equity Plan finds the most severe disproportionate housing needs in:
Cost burden and severe cost burden. Half of Black/African American
households experience cost burden, while a fifth of Asian households and a quarter of
Hispanic households experience severe cost burden. These households are much
more likely to experience eviction and homelessness due to inability to keep up with
their rent or mortgage payments.
Homeownership rates. Significant gaps in homeownership exist for
Black/African American households in Bozeman; large gaps also exist for Hispanic
households. According to recent ACS data, there are no Black/African Americans that
own their homes in Bozeman, compared to 45% of non-Hispanic White households.
Additionally, just 26% of Hispanic households own their homes. According to the
housing and community needs survey, Black/African American and American
Indian/Alaska Native survey respondents are much more likely to have trouble keeping
up with their property taxes than city respondents overall.
Displacement. Approximately one in five Bozeman households (21%) report
moving in the last five years against their choice. While the sample sizes were small,
50% of American Indian/Alaska Native and 40% of Black/African American respondents
report experiencing displacement. AIAN respondents were more likely to be displaced
due to their landlord not renewing the lease or losing their job, while Black/African
American respondents were more likely to report being evicted because they were
behind on rent or their home went into foreclosure. Renters, respondents living with a
disability, and low-income renters also experienced displacement at a
disproportionate rate. These households reported rent increases as the primary
reason for displacement.
Access to mortgage loans. Of applicants for mortgage loans in 2022, Hispanic
residents had the highest denial rates (12%), 25% higher than non-Hispanic White
applicants. In Bozeman, nearly half of all loan applications are denied due to debt-to-
income ratio. While too few observations were available for most applicants by race
and ethnicity, Hispanic applicants (5%) were more than twice as likely than non-
Hispanic White applicants (2%) to receive a high-priced loan.
Fair housing environment. This section of the Fair Housing Equity Plan assesses
private and public barriers to housing choice within the context of existing fair housing
laws, regulations, and guidance.
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HUD reported seven fair housing complaints in Bozeman between 2019 and 2023.
Most complaints submitted to HUD during this period affected individuals living with
physical disabilities.
Approximately one in five Bozeman survey respondents (19%) reported experiencing
housing discrimination in the last five years. Populations experiencing housing
discrimination at a disproportionate rate include low-income respondents,
respondents with disabilities, single parents, and students. Nearly half of survey
respondents (46%) reported doing nothing about the discrimination because they
were not sure what to do.
The City of Bozeman has tentatively paused its process for updating its Unified
Development Code (UDC). As such, a list of best practices to ensure land use and
zoning regulations don’t serve as barriers to fair housing choice are detailed later in
the section for the consideration of the City to incorporate its UDC update. The City’s
existing code does already meet many of these best practices, such as:
➢ Include a definition of “disability” or “person with disabilities” that aligns with
Fair Housing Amendments Act (FHAA) and Americans with Disabilities Act
(ADA) in the development code. In defining disability, it is important to
include the broad definition that has been interpreted by the courts to apply
to the Fair Housing Act (FHA), which includes persons in recovery from
substance abuse challenges and persons with HIV/AIDS. See code section
38.700.010.A.
➢ Establish a standard process for reasonable accommodation requests in the
development code. See code section 38.250.100.
➢ Implement residential unit classifications, zone districts, and site design
requirements for alternative housing types (e.g. tiny homes, cottage
housing, courtyard development, micro-homes, and cooperative housing).
➢ Include a statement in the purpose of the zoning ordinance that discusses
fair housing law or include a cross-reference that identifies the adopted
planning documents that discuss and contain policies related to fair
housing. See code section 38.700.010.A.
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Impediments and Fair Housing Actions
Impediments. The fair housing impediments found in this Fair Housing Plan include:
Shortage of affordable and accessible housing units. There is a significant
shortage of affordable and accessible housing units in the city, which disproportionately
impacts low-income households—primarily minorities—and households with individuals
living with a disability.
Disparate access to opportunity. As articulated in Section IV of this report, Indigenous
residents in Bozeman have the lowest English and Math proficiency rates among K-8
students by race and ethnicity, as well as the lowest high school graduation rates and
highest unemployment rate among city residents. Residents and stakeholders also
highlighted transportation challenges in the city, which primarily impact low-income
households, Hispanic/Latino immigrants, and residents living with disabilities.
Barriers to homeownership. Households of color have lower rates of homeownership
compared with non-Hispanic White households in Bozeman. Significant gaps in
homeownership exist for Black/African American while large gaps exist for Hispanic
households in Bozeman. Additionally, Hispanic applicants are more than twice as likely to
receive high-priced loans compared with non-Hispanic White applicants. From a policy
perspective, Hispanic households may be most at risk for high-cost loans (predatory, credit
cards) to help with needed home improvements, and would benefit from publicly-assisted
home improvement grants and low cost loans.
Lack of access to fair housing resources. As detailed in Section VI of this report, the
City does not currently have a Fair Housing page on its website. Nearly half of survey
respondents who reported experiencing housing discrimination (46%) identified a need for
more resources and education for residents related to fair housing and how to respond to
housing discrimination. Over a third of these survey respondents also advocated for local
officials and staff to receive fair housing education and training.
Lack of access to translation and interpretation services. Stakeholders
articulated a need for more translation and interpretation services provided by the City,
specifically Spanish. Many stakeholders noted that the Latino/Hispanic community
continues to grow in Bozeman and to ensure that they are able to access mainstream
services, translation and interpretation services need to be available.
Actions. To address the fair housing impediments identified in this Fair Housing Plan,
the City of Bozeman has aligned its fair housing plan actions with the goals developed for
its Consolidated Plan. Consequently, many of the goals outlined in the City’s Equity and
Inclusion Plan address the impediments identified in this Plan. As such, many of the actions
articulated below are meant to reinforce the actions identified in the Belonging in Bozeman
Plan.
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Increasing and Preserving Housing Options. Increase, protect, and preserve
affordable rental and homeownership housing opportunities by improving access to a
diverse set of affordable housing options, including but not limited to, naturally occurring
affordable housing (NOAH) including mobile home communities, supportive housing for
seniors and residents living with disabilities, and accessible housing.
Current or ongoing actions:
While currently paused, the City is in the process of updating its Unified Development
Code (UDC). The UDC update aims to align its development regulations with the vision
and goals established in Bozeman’s guiding documents, such as the 2020 Community
Plan, the Climate Action Plan, and strategic priorities such as affordable housing.2
Planned or potential actions:
One of the goals outlined in the City’s Belonging in Bozeman Equity and Inclusion Plan
is to “Promote aging in place and universally accessible residential development.” To
achieve this goal, the City will conduct an educational workshop for design,
construction, and real estate professionals on universal design practices and
adaptable dwellings within residential developments. The City may also consider
home-buyer and renter education on universal design practices.
Additionally, the City will explore potential development incentives that could enable
aging in place and universal accessibility beyond the requirements of the building
code.
The City will continue prioritizing investment in innovative housing models, such as
community land trusts and housing cooperatives, to increase access to affordable
homeownership opportunities.
Explore policies that address disparities in access to homeownership opportunities.
Supporting Vulnerable Populations. Improve housing stability for individuals and
households with critical needs, including persons experiencing or at-risk of homelessness
by providing appropriate housing and service solutions grounded in Housing First
approaches, including but not limited to, emergency shelter, transitional housing, and
other supportive services.
Planned or potential actions:
The City is currently working with partners to develop a coordinated strategy to
address homelessness in the Bozeman area. Specifically, the City will:
➢ Identify and prioritize Housing First approaches to address housing
instability and homelessness.
2 Note that 76-25 MCA is driving substantial procedural changes and state-level requirements on additional regulatory
changes.
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➢ Support partner organizations by funding transitional and emergency
housing initiatives and programs.
➢ Work with partners to leverage creative funding mechanisms, incentives,
and existing assets to increase the City’s long-term affordable housing
supply.
Critical Community Services. Improve community services by addressing critical
needs and promoting equity though improved or increased access to community
programming, including but not limited to, mental health services, chemical dependency
services, and affordable and available childcare.
Planned or potential actions:
The City will develop a fair housing page on its website, which will include information
on the Federal Fair Housing Act, the Montana Human Rights Act, fair housing-related
education and training opportunities, and local resources and organizations available
to help residents learn more about fair housing.
One of the goals articulated in the City’s Belonging in Bozeman plan is to “Increase
community knowledge in housing issues.” As such, the City will work with a variety of
partners to host workshops on the Montana Tenant Act and Fair Housing Act for
landlords and tenants, becoming a Housing Choice Voucher landlord, and resident-
owned community models.
Another Belonging in Bozeman goal is “Address language barriers to local government
services and public engagement processes.” Currently, the City is training frontline
staff to utilize on-demand interpretation services. Additionally, the City plans to:
➢ Develop and implement a comprehensive Language Access Plan; and
➢ Will consider providing multilingual learning opportunities for staff to learn
other languages, as well as compensating multilingual staff for providing
translation services.
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II. COMMUNITY ENGAGEMENT
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SECTION II.
Community Engagement Summary
This section reports the findings from the City of Bozeman’s Housing and Community
Needs survey and incorporates feedback from resident focus groups and stakeholder
interviews. The survey asked residents and stakeholders to identify groups in Bozeman
with the greatest housing challenges, the greatest unmet housing, community
development, and economic development needs of the city, and which outcomes should
be prioritized by the City with the federal funding it receives from HUD. The survey also
asks about residents’ experience with discrimination and displacement.
The survey was available online, in a format accessible to screen readers, and promoted
through the City’s communications and social media channels, as well as through partner
networks. The survey was also available in paper format.
The survey was available from March to May 2024, collecting a total of 953 responses.
Primary Findings
The 953 residents who responded to the survey for the Consolidated Plan and
Equity Plan were asked about:
Resident groups with the greatest housing challenges;
Housing, community, and economic development needs;
The types of shelter most needed in the city;
The types of housing that should be prioritized by the city;
Experiences with discrimination and displacement; and
Housing, community and economic development outcomes.
Needs and challenges. Residents and stakeholders were asked a series of questions
related to resident groups with the greatest housing challenges, as well as the greatest
housing, community development, and economic development needs in the city.
Resident groups with the most housing challenges. According to residents, the
groups that face the most challenges finding and keeping housing in Bozeman include:
Low- and moderate-income families;
Persons or families who are currently unhoused;
Members of the local workforce;
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 2
Persons living with mental illness; and
Persons with disabilities.
Stakeholders identified unhoused residents, low- and moderate-income families, members
of the local workforce, and persons with mental illness as the top four resident groups with
the greatest housing challenges in Bozeman.
Residents in focus groups and feedback from stakeholder interviews also highlighted
additional barriers for disabled veterans, undocumented residents who do not qualify for
many assistance programs and face additional language barriers.
Housing types/activities most needed in Bozeman. Residents in Bozeman
identified the following housing types/activities as most needed in the city:
Homeownership opportunities for low-or moderate-income residents;
Rental housing for low-income renters;
Workforce housing;
Emergency shelters; and
Housing rehabilitation for low-income renters.
Stakeholders identified a similar list of housing types and activities most needed in the city,
including:
Homeownership opportunities for low- or moderate-income residents;
Rental housing for low-income renters;
Workforce housing;
Transitional housing; and
Housing rehabilitation for low-income renters.
Greatest unmet community and economic development needs. Residents
articulated the following in their top five greatest unmet community and economic
development needs:
Affordable childcare;
Mental health services;
Supportive services for low-income residents, persons living with disabilities,
LGBTQIA+ residents, and other vulnerable populations;
Climate resilience-focused planning and implementation; and
More focus on local renewable energy.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 3
Stakeholders identified affordable childcare, mental health services, supportive services,
public transit, and additional assistance for nonprofits as their top five community and
economic development needs.
Priorities and outcomes. Both residents and stakeholders were asked what they
perceive as the most desirable outcomes as a result of HUD funding. Those collective
priorities and outcomes are summarized below.
Housing outcomes. Residents and stakeholders identified the same five housing
outcomes that should be prioritized by the City:
More affordable rental housing;
More opportunities for homeownership;
Better distribution of affordable housing;
More downpayment assistance for low- and moderate-income households; and
Fewer affordable units that are converted to market rate housing.
Community development outcomes. Residents and stakeholders identified the
same five community development outcomes that should be prioritized by the City:
Increased access to mental health care services;
Additional and/ or higher quality childcare centers;
Climate resilience-focused planning and implementation;
Increased access to addiction treatment services; and
Street and sidewalk improvements.
Economic development outcomes. Residents and stakeholders identified the same
three economic development outcomes that should be prioritized by the City:
Job training programs or job training centers;
More opportunities for start-up businesses, businesses looking to expand, or
businesses looking to relocate; and
Revitalization of neighborhood businesses.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 4
Explanation of terms. Terms used throughout this section include:
“Respondent” means a person who responded to the survey and provided input on
housing and community development needs and allocation priorities;
“Stakeholder” is a person who works with an organization or agency that provides
housing, community development, and/or services to Bozeman residents;
“Resident” means someone living in the city of Bozeman;
“Disability” indicates that the respondent or a member in the respondent’s household
has some type of disability, which can include physical, mental, intellectual, and/or
developmental;
“Large households” means a respondent who lives in a household that has five or
more people;
“Section 8” is shorthand for the Housing Choice Voucher program which provides
rental assistance to low-income renters living in privately provided housing.
Survey Methodology
The survey was available to both residents and individuals working at organizations or
agencies that operate in the housing, community development, and/or service space and
provide services to Bozeman residents. Participation was voluntary. The purpose of the
survey is to collect information on the housing and community development challenges
and solutions to address those challenges in Bozeman. The data supplement the
quantitative analysis in both the Consolidated Plan and Equity Plan.
Sampling note. Survey respondents do not represent a random sample of residents
living in Bozeman. A true random sample is a sample in which each individual has an equal
chance of being selected for the survey. The self-selected nature of the survey prevents the
collection of a true random sample. Important themes and insight are gained from the
survey as it allows for a deeper understanding of resident needs as well as the differences
of the sample from the larger population. However, due to the small sample size of some
resident respondent groups by demographic and economic characteristics, results should
be interpreted with caution.
Survey Responses
Respondent profile. A total of 953 people responded to the survey—736 Bozeman
residents and 217 stakeholders who serve Bozeman residents. The demographic and
economic characteristics of resident respondents are illustrated in Figure II-1.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 5
Figure II-1.
Survey
Respondent
Profile
Note:
N=953; Numbers do not
aggregate either due to
multiple responses or
that respondents chose
not to provide a response
to all demographic and
socioeconomic questions.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and Community
Survey.
Respondent Type
Residents 736
Stakeholders 217
Tenure
Owner 453
Renter 330
Mobile Home/ Other 15
Unhoused 44
Race/Ethnicity
African American/Black 10
American Indian/Alaska Native 13
Asian 2
Hispanic or Latino 18
Non-Hispanic White 542
Gender Identity
Female 371
Male 254
Non-Binary 8
Income
Less than $25,000 62
$25,000-$49,999 121
$50,000-$99,999 208
$100,000-$149,999 113
Above $150,000 109
Employment Status
Employed full-time 425
Employed part-time 64
Unemployed/looking for work 9
Retired 100
Student 44
Selected Household Characteristics
Children under 18 181
Disability 159
Large Households 48
Single Parents 59
Seniors (Older than 65)154
Total
Responses
178
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 6
Stakeholder respondent profile. Survey respondents who identified as
stakeholders represented a variety of organizations and industries (Figure II-2).1:
Figure II-2.
Survey
Respondent
Profile,
Stakeholders
Note:
N=217; Numbers do not
aggregate either due to
multiple responses.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and Community
Survey.
1 Respondents were allowed to choose all industries/organizations that applied to their position.
Respondent Type
Services for Unhoused 50
Affordable Housing Advocate 47
Other 39
Affordable Housing Developer 35
Supportive Services for Residents 31
Affordable Housing Provision 30
Fair Housing 28
Business Owner 24
Government 24
Land Use 23
Owner of Rental Property 21
Regional Planning 21
Home Sales 21
Homeownership Counseling 19
Landlord Tenant Services 17
Property Management 16
Transit Planning 15
K-12 or Education 14
Food Provision 14
Civil Rights 12
Disability Advocate 12
Economic Development 12
Market Rate Housing Developer 12
Services for Businesses 10
Transit Provider 9
Rural Development 8
Criminal Justice 5
Legal Aid 5
Public Housing Authority 3
Residential Appraisals 3
Environmental Justice 1
Insurance 1Lending0
Total
Responses
179
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 7
Survey Findings
Housing challenges. Both residents and stakeholders were asked to identify which
resident groups in Bozeman face the greatest challenges finding and keeping housing.
Survey respondents were instructed to select up to five groups.
Resident groups with the greatest housing challenges. Residents and
stakeholders considered the following groups in Bozeman:
Adults with criminal records
Adults with histories of
eviction/foreclosure
Black, Indigenous, and People of
Color (BIPOC)
Low- or moderate-income families
Persons and/or families who are
currently unhoused
Persons identifying as LGBTQIA+
Persons with a mental illness
Persons living with disabilities
Persons with HIV/AIDS
Persons with intersectional identities
(more than one of the options
provided)
Persons with substance
abuse/chemical addictions
Senior/elderly persons
Veterans who are currently
unhoused
Youth transitioning from foster care
Youth who are currently unhoused
Other
Resident respondents. Low- to moderate-income families (70%) were identified by
residents as the groups with the greatest housing needs in Bozeman (Figure II-3). Residents
also identified persons/families who are currently unhoused (53%), members of the local
workforce (50%), persons with mental illness (34%), and persons with disabilities (31%) as
groups experiencing the greatest housing challenges. Ten percent of resident respondents
chose “Other”; a sample of those responses are below:
“Everyone is having trouble finding housing.”
“Those who grew up here and those who work in more basic services like food and retail.”
“Anyone single and under 40 that doesn’t have inter-generational support.”
“Workers 18-28 trying to start out in Bozeman.”
180
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 8
Figure II-3.
Which
groups in
Bozeman
face the
greatest
challenges
finding and
keeping
housing?
Residents
Note:
N= 736
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Survey.
Stakeholder respondents. Stakeholders identified persons/families who are currently
unhoused (59%), low- and moderate-income families (59%), members of the local
workforce (42%), persons with mental illness (41%), and persons with a disability (35%) as
groups facing challenges finding and keeping housing in Bozeman (Figure II-4).
Stakeholders also identified unhoused youth (29%) as facing these challenges. Twelve
percent of stakeholders chose “Other”; a sample of those responses are below.
“Migrant and Spanish speaking populations.”
“People with limited and poor rental or credit history.”
“Women with children who are victims of domestic violence.”
70%
53%
50%
34%
31%
25%
23%
23%
17%
16%
16%
14%
13%
10%
8%
6%
2%
Low and Moderate Income Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
Unhoused Youth
Seniors
Veterans
Substance Abuse
Intersectional Group
Foreclosure History
Criminal Records
Trans Youth
Other
BIPOC
LGBTQ+
Persons with HIV
181
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 9
Figure II-4.
Which
groups in
Bozeman
face the
greatest
challenges
finding and
keeping
housing?
Stakeholders
Note:
N= 217.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Survey.
59%
59%
42%
41%
35%
29%
21%
20%
19%
19%
19%
18%
13%
12%
12%
7%
3%
Unhoused Residents
Low and Moderate Income Families
Local Workforce
People with Mental Illness
People with Disabilities
Unhoused Youth
Seniors
Foreclosure History
Veterans
Criminal Records
Intersectional Group
Substance Abuse
Trans Youth
BIPOC
Other
LGBTQ+
Persons with HIV
182
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 10
Respondents by demographic and economic characteristics. Figures II-5 through II-
10 present the top five groups identified by resident respondents as having the greatest
challenges finding and keeping housing in Bozeman, sorted by several demographic and
economic characteristics.
By tenure, renter respondents were more likely to identify low- to moderate-income families,
unhoused residents as the groups with the greatest housing challenges while owners were
most likely to identify people with mental illness. Those who identified as unhoused were
more likely to identify the local workforce.
Figure II-5.
Top Groups
by Tenure
Note:
n = 953.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and Community
Needs Survey.
Non-Hispanic White, Hispanic/Latino, and Asian resident respondents were more likely to
identify low- to moderate-income families as the group with the greatest housing challenges,
while a greater proportion of African American/Black resident respondents identified
persons with disabilities as having the greatest housing challenges (Figure II-6). American
Indian/Alaska Native respondents were more likely to identify persons/families who are
currently unhoused as experiencing the greatest housing challenges in Bozeman.
70%
48%
55%
18%
20%
67%
55%
50%
37%
27%
53%
53%
33%
27%
53%
73%
56%
48%
34%
38%
LMI Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
Unhoused
Owner
Mobile Home/
Other
Renter
183
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 11
Figure II-6.
Top Groups
by Race and
Ethnicity
Note:
N= 953.
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
The proportion of responses by gender identity were relatively uniform among the top five
groups facing housing challenges (Figure II-7). However, while respondents who identify as
non-binary were more likely to identify persons with disabilities as having greater housing
challenges than male and female respondents, they were less likely to identify the local
workforce as experiencing challenges. Men were least likely to select unhoused residents
and people with mental illness as facing housing challenges.
31%
54%
23%
69%
23%
30%
50%
30%
20%
30%
75%
60%
52%
36%
33%
67%
56%
44%
33%
33%
LMI Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
American Indian
Black
NH White
Hispanic
184
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 12
Figure II-7.
Top Groups
by Gender
Identity
Note:
N= 953.
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Responses by income level are relatively similar across categories. However, those with
lower incomes identified those with low- to moderate-incomes as facing more housing
challenges compared to those with higher incomes. Those with higher incomes were more
likely to identify unhoused residents, people with mental illness, and the local workforce as
facing the greatest housing challenges. and persons/families who are currently unhoused
(Figure II-8).
69%
48%
50%
34%
27%
75%
63%
50%
50%
75%
75%
64%
53%
37%
34%
LMI Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
Man
Nonbinary
Woman
x
185
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 13
Figure II-8.
Top Groups
by
Household
Income
Note: n = 953
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
As shown in Figure II-9, resident respondents by employment status are relatively uniform
for low- to moderate-income families. However, respondents identifying as unemployed
were the most likely to identify people with mental illness.
76%
55%
45%
27%
40%
73%
60%
53%
32%
37%
73%
54%
50%
35%
29%
72%
60%
55%
42%
32%
71%
61%
53%
39%
27%
LMI Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
Less than $25,000
$25,000-$49,999
$50,000-$99,999
$100,000-$149,999
Above $150,000
x
186
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 14
Figure II-9.
Top Groups
by
Employment
Status
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Figure II-10 presents respondents by other household types. Respondents with children
under 18 were less likely than single parents to select low-to moderate-income households,
unhoused residents, the local workforce, people with mental illness, and people with
disabilities. Large households and respondents over age 65 were most likely to select low-
to moderate-income families. Respondents over age 65 were most likely to select people
with disabilities out of all household types.
73%
58%
52%
36%
32%
76%
59%
54%
43%
33%
71%
0%
43%
71%
29%
71%
53%
55%
37%
26%
73%
59%
52%
25%
43%
LMI Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
Employed full-time
Employed part-time
Unemployed/looking for work
Retired
Student
x
187
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 15
Figure II-10.
Top Groups
by Other
Household
Types
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Additional community perspectives. Resident focus groups were held
throughout Bozeman to enhance data points and hear from groups that are generally
harder to connect with in surveys or community meetings. Stakeholders involved in service
provision and development were also consulted. Residents and stakeholders highlighted
the additional groups as facing additional challenges to finding and keeping housing:
Veterans. One resident shared that it is particularly difficult for disabled Veterans to find
housing in Bozeman. They shared that they called around “quite a bit” for housing, as well
as the local VA for help, but still encountered challenges.
Undocumented residents. One resident shared they believed the population with the
greatest challenges right now are undocumented residents. They don’t qualify for any
programs (e.g., WIC, SNAP, housing assistance). The only service that HRDC, a community
action agency, can provide is a case manager. There is only one property group that will
rent to undocumented families. The resident noted that one undocumented family
currently living at Wheat Suites, a transitional housing facility, has been on the waitlist for
that property for over two years. HRDC does not have fluent Spanish speakers on staff
making day-to-day interactions challenging when working with undocumented people in
need of assistance.
31%
25%
27%
18%
13%
40%
32%
30%
19%
23%
56%
40%
40%
25%
23%
51%
39%
36%
34%
19%
69%
49%
49%
35%
31%
LMI Families
Unhoused Residents
Local Workforce
People with Mental Illness
People with Disabilities
Children under 18
Disability
Large Households
Single Parents
Seniors (+65)
x
188
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 16
Housing activities. Residents and stakeholders were asked to identify the five most
critical housing types or housing activities needed in Bozeman. Survey respondents were
instructed to select up to five housing types/activities. Residents and stakeholders were
asked to consider:
Emergency shelters for persons who
are currently unhoused
Homeownership opportunities for
low- or moderate-income residents
Housing for people or households
experiencing or have experienced
domestic violence
Housing for the city’s workforce
Housing hazard mitigation
Housing rehabilitation for low-
income homeowners
Housing rehabilitation for low-
income renters
Not sure
Rental housing for low-income
renters
Transitional housing
Other
Resident respondents. Homeownership opportunities for low- to- moderate-income
residents (84%) were identified by residents as the housing activity/type most needed in
Bozeman (Figure II-11). Residents also identified rental housing for low-income renters
(75%), workforce housing (55%), emergency shelters (38%), and housing rehabilitation for
low- to moderate-income residents (36%) as greatly needed housing types/activities in the
city. Sixteen percent of residents chose “Other”; a sample of those responses are below.
“Affordable housing for young families.”
“Affordable housing for people who work for Bozeman-based companies.”
“City workers can’t afford to buy a home in the city they work for.”
“Age restricted affordable mobile home parks or tiny home communities.”
“Housing for firefighters, teachers, and nurses.”
189
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 17
Figure II-11.
Which
housing
types/
activities are
most needed
in Bozeman?
Residents
Note:
N=736.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Survey.
Stakeholder respondents. Stakeholder respondents identified homeownership
opportunities for residents with low- to moderate-income (65%), followed by rental housing
for low- to moderate-income renters (61%), workforce housing (45%), transitional housing
(35%), and housing rehabilitation for low- to moderate-income renters (33%) as the housing
types/activities most needed in the city. Fifteen percent of stakeholders chose “Other”; a
sample of those responses are below.
“I believe those most challenged are those earning a middle income as there are no state or
federal subsidies for these incomes, and they cannot afford market-rate homes.”
“We could also use support for lower-middle class. As a support staff I make just barely over
60% AMI and thus don’t qualify [for assistance] and now pay 50% of my net income just
towards housing. I also need housing so I can keep supporting these folks.”
“Service industry and other low skill workers will begin to dwindle if workforce housing
does not become available.”
190
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 18
Figure II-12.
Which
housing
types/
activities are
most needed
in Bozeman?
Stakeholders
Note:
N=217.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Respondents by demographic and economic characteristics. Figures II-13 through
II-18 present the top five housing activities/types identified by resident respondents as
most needed in Bozeman, sorted by several demographic and economic characteristics.
By tenure, those who lived in mobile homes or other housing types were most likely to
select homeownership opportunities for low- to -moderate income residents followed by
renters. Of all needed housing activities, unhoused residents identified rental housing for
low- to moderate-income rentals the most often.
191
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 19
Figure II-13.
Top
Housing
Types/
Activities
by Tenure
Note:
N = 953.
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
Hispanic/Latino, Non-Hispanic White, and Black respondents were more likely to identify
homeownership opportunities for low- to moderate-income residents and workforce
housing as most needed in Bozeman compared with other racial and ethnic groups.
American Indian and Hispanic respondents were more likely to identify emergency shelter
for unhoused residents as the greatest housing type/activity needed.
64%
68%
43%
34%
34%
68%
59%
52%
32%
26%
87%
53%
27%
27%
40%
80%
79%
48%
38%
40%
Homeownership Opportunities
Rental Housing for LMI Renters
Workforce Housing
Emergency Shelters
Housing Rehab for LMI Renters
Unhoused
Owner
Mobile home/
other
Renter
Homeownership opportunities
for LMI residents
192
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 20
Figure II-14.
Top
Housing
Types/
Activities by
Race and
Ethnicity
Note:
N = 953
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
Overall, the variability of responses by gender identity is relatively minimal (Figure II-15).
Non-binary respondents were more likely to identify homeownership opportunities for
low- to moderate-income residents and emergency shelter types/activities that are most
needed compared with male and female respondents. Male and female respondents were
more likely to identify workforce housing as a top need.
46%
46%
38%
54%
46%
60%
20%
20%
20%
20%
79%
35%
53%
38%
35%
78%
33%
72%
61%
33%
Homeownership Opportunities
Rental Housing for LMI Renters
Workforce Housing
Emergency Shelters
Housing Rehab for LMI Renters
American Indian
Black
NH White
Hispanic
Homeownership opportunities
for LMI residents
193
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 21
Figure II-15.
Top
Housing
Types/
Activities
by Gender
Identity
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
Figure II-16 presents respondents’ greatest housing types and activities by income. Over
three-quarters of each income group identified homeownership opportunities for low- to
moderate-income residents as a greatly needed housing type or activity in Bozeman.
Residents with income less than $25,000 were more likely to identify rental housing and
housing rehabilitation for low- to moderate-income renters, while those with income above
$100,000 were more likely to select workforce housing.
74%
70%
51%
30%
70%
100%
75%
25%
50%
75%
79%
73%
55%
43%
73%
Homeownership Opportunities
Rental Housing for LMI Renters
Workforce Housing
Emergency Shelters
Housing Rehab for LMI Renters
Man
Nonbinary
Woman
Homeownership opportunities for
LMI residents
194
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 22
Figure II-16.
Top
Housing
Types/
Activities
by Income
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
Similarly, respondents by employment status all identified homeownership opportunities
for low- to moderate-income residents and rental housing for low-income renters as the
greatest housing types/activities needed in Bozeman (Figure II-17). Those unemployed and
looking for work were most likely to select workforce housing and students were most
likely to select homeownership opportunities, rental housing for low- to moderate-income
residents, emergency shelters, and housing rehabilitation for low- to moderate income
renters.
81%
85%
47%
34%
50%
74%
77%
50%
38%
40%
79%
71%
48%
38%
33%
81%
73%
63%
40%
38%
77%
66%
56%
40%
19%
Homeownership Opportunities
Rental Housing for LMI Renters
Workforce Housing
Emergency Shelters
Housing Rehab for LMI Renters
Less than $25,000
$25,000-$49,999
$50,000-$99,999
$100,000-$149,999
Above $150,000
Homeownership opportunities
for LMI residents
195
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 23
Figure II-17.
Top Housing
Types/
Activities by
Employment
Status
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Figure II-18 presents that over half of respondents who identified as single parents want to
see more homeownership opportunities and rental housing for low- to-moderate-income
residents in Bozeman, while seniors accounted for the greatest proportion of respondents
advocating for all housing types.
80%
72%
52%
39%
34%
80%
76%
57%
37%
33%
71%
57%
71%
29%
29%
70%
68%
63%
37%
29%
84%
82%
32%
43%
48%
Homeownership Opportunities
Rental Housing for LMI Renters
Workforce Housing
Emergency Shelters
Housing Rehab for LMI Renters
Employed full-time
Employed part-time
Unemployed/looking for work
Retired
Student
Homeownership opportunities for
LMI residents
196
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 24
Figure II-18.
Top Housing
Types/
Activities by
Other
Household
Types
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Additional community perspectives. In one-on-one interviews, stakeholders
also identified workforce housing as a key issue not just in Bozeman, but in the entire
county. One stakeholder described that affordable manufactured homes could be part of
the solution. They shared that Cameron Crossing, a manufactured home community of 380
homes, is opening soon. The developer received a low interest loan fund from First Bank
for the development. The community is made up of seven different prototypes and tenants
of the home don’t own the land. These homes are selling for $210,000-$275,000 and
approximately $875/month. While these homes are relatively affordable, this stakeholder
shared that “traditional financing is hard to get.” This stakeholder shared that this type of
development makes land costs “less impactful” because of how many units you can get on
the ground. They added that the community “is trying so many different things” to get
permanent housing built.
Unhoused residents. Survey respondents were asked if they currently are or have
recently been unhoused while living in Bozeman. Five percent of respondents (n = 44)
reported that they are currently or have been unhoused.
Unhoused respondents by demographic and economic characteristics. Figure II-
19 presents the percentage of resident respondents sorted by demographic and economic
characteristics that responded they are currently or have been unhoused in Bozeman.
34%
25%
26%
20%
12%
45%
46%
30%
23%
26%
58%
42%
31%
17%
15%
53%
56%
32%
17%
19%
69%
64%
55%
40%
35%
Homeownership Opportunities
Rental Housing for LMI Renters
Workforce Housing
Emergency Shelters
Housing Rehab for LMI Renters
Children under 18
Disability
Large Households
Single Parents
Seniors (+65)
Homeownership opportunities for
LMI residents
197
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 25
While sample sizes are extremely small, residents that identify as non-Hispanic White made
up a higher proportion of unhoused people relative to residents of color.
By gender identity, female respondents made up a higher proportion of homeless
individuals compared to male and non-binary respondents. Residents with incomes
between $50,000 and $99,999 and those who worked full-time made up the highest
proportion of unhoused individuals within the categories in the following figure. A quarter
(25%) of the unhoused population has a disability and one in five (20%) unhoused people
have children under 18.
Figure II-19.
Percent of
Unhoused
Residents
by
Respondent
Type
Note:
n = 44. Numbers do
not aggregate either
due to multiple
responses or that
respondents chose
not to provide a
response to all
demographic and
socioeconomic
questions.
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Survey.
Additional community perspectives. A resident focus group was held at a
transitional housing facility and stakeholders working within the homeless prevention and
Race/Ethnicity
African American/Black 2%1
American Indian/Alaska Native 0%0
Asian 0%0
Hispanic or Latino 5%2
Non-Hispanic White 55%24
Gender Identity
Female 34%15
Male 27%12
Non-Binary 0%0
Income
Less than $25,000 9%4
$25,000-$49,999 20%9
$50,000-$99,999 25%11
$100,000-$149,999 5%2
Above $150,000 2%1
Employment Status
Employed full-time 41%18
Employed part-time 9%4
Unemployed/looking for work 2%1
Retired 0%0
Student 9%4
Selected Household Characteristics
Children under 18 20%9
Disability 25%11
Large Households 9%4
Single Parents 11%5
Seniors (Older than 65)16%716%
Percent
unhoused n
198
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 26
intervention space shared their thoughts regarding existing transitional housing. A
stakeholder described that “the goal is to transition people into permanent housing. The
first few months, we want them to focus on getting settled (e.g., signing up for benefits
programs, getting a car, finding a job, etc.). Once they have a job and have income, we can
help them with budgeting.” A resident described that they have weekly appointments with
their case managers where they get help with budgeting, applying for housing and
employment, and mental health services.
One stakeholder expressed a need for more case managers and social workers who speak
Spanish to help unhoused Hispanic community members. They noted that “We get people,
but when jobs open up that offer more money, they understandably leave. If we could
offer more money for these positions, that would be great.”
Another stakeholder shared that while they are usually able to find housing for their
families, there is a need for more transitional housing with supportive services. This
stakeholder emphasized the importance of continuing to provide supportive services to
families as they begin to look for housing on their own. They also noted that transitional
housing should be true homes instead of hotels that usually lack kitchen amenities.
Community and Economic Development Needs. Survey respondents were
asked to identify the greatest unmet community and economic development needs in
Bozeman. Respondents were presented the following options:
Accessibility (ADA) improvements to
public buildings;
Accessibility (ADA) improvements to
community amenities (e.g., parks);
Developed parks/playgrounds;
Affordable childcare;
Environmental hazard mitigation;
Job training programs;
Access to internet/broadband;
Neighborhood cleanups;
Food pantries;
Mental health services;
Access to reliable public
transportation;
Senior center/senior services;
Community centers;
Sidewalks, streetlights, and similar
neighborhood improvements;
Help for businesses—for example,
business plan development,
accounting and management, social
media strategy, etc.;
Help for non-profits—for example,
identifying loan/grant opportunities,
capacity building;
Youth activities;
Support services for low-income
residents, persons living with
disabilities, LGBTQIA+ persons;
Local renewable energy generation;
and
Climate resilience-focused planning
and implementation.
199
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 27
Resident respondents. Affordable childcare was the greatest unmet community
development need identified by resident respondents (57%) (Figure II-20). Residents also
identified mental health services for low-income residents (43%), support services (35%),
and climate resilience-focused planning and implementation (33%), as well as local
renewable energy (33%).
Figure II-20.
What are the
greatest
unmet
community
and
economic
development
needs in
Bozeman?
Residents
Note:
N= 736.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Stakeholder respondents. Similar to residents, stakeholders identified affordable
childcare (57%), mental health services (51%), support services for vulnerable populations
(29%), and public transit (29%) as the four greatest unmet community and economic
development needs in Bozeman (Figure II-21). Stakeholders also identified help for
nonprofits (25%) as a significant need in the city.
57%
43%
35%
33%
26%
25%
18%
15%
13%
13%
12%
12%
12%
11%
11%
11%
11%
9%
7%
6%
5%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Local Renewable Energy
Public Transit
Neighborhood Improvements
Community Centers
Activities for youth
Help for Nonprofits
Other
ADA Accessible Public Buildings
Senior Center
Neighborhood Cleanups
Food Pantries
Developed Parks
Job Training
Environmental Hazard
ADA Accessible Community Amenities
Internet
Business Help
200
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 28
Figure II-21.
What are the
greatest
unmet
community
and
economic
development
needs in
Bozeman?
Stakeholders
Note:
N= 217.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Of the respondents who selected “Other”; a sample of those responses are below.
“More bike paths and bike lanes.”
“Reliable paratransit service that meets legal requirements for comparable service to fixed
route.”
“More indoor activities for people to do.”
Respondents identified the following quadrants in Bozeman where these needs are most
prominent:2
Northwest (39%, n=375)
Northeast (39%, n=374)
Southeast (25%, n=235)
Southwest (22%, n=209)
2 Respondents were instructed to “select all that apply” to identify neighborhoods with the most prominent needs.
57%
51%
29%
29%
25%
20%
16%
14%
14%
13%
12%
12%
12%
11%
11%
9%
9%
8%
7%
6%
Affordable Childcare
Mental Health Services
Support Services
Public Transit
Help for Nonprofits
Climate Resiliance
ADA Accessible Community Amenities
Local Renewable Energy
Activities for youth
Community Centers
ADA Accessible Public Buildings
Job Training
Other
Senior Center
Neighborhood Improvements
Developed Parks
Business Help
Food Pantries
Environmental Hazard
Internet
201
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 29
Respondents by demographic and economic characteristics. Figures II-22 through
II-27 present the five greatest unmet community and economic development needs
identified by respondents, sorted by demographic and economic characteristics.
By tenure, those in mobile homes and renters were most likely to select affordable
childcare, mental health services, and public transit as top community needs. Unhoused
people and owners were more likely to select climate resilience.
Figure II-22.
Top
Community
Needs by
Tenure
Note:
N = 953.
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Hispanic residents were more likely to identify mental health services, support services,
and climate resilience, while White respondents were most likely to select affordable
childcare and public transit.
52%
48%
27%
36%
25%
61%
47%
30%
31%
25%
67%
53%
40%
27%
53%
55%
42%
44%
35%
28%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Public Transit
Unhoused
Owner
Mobile home/ other
Renter
202
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 30
Figure II-23.
Top
Community
Needs by
Race and
Ethnicity
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
Figure II-24 presents the top five unmet community and economic development needs
identified by respondents and sorted by gender identity. While female respondents were
more likely to identify affordable childcare and mental health services as a significant
unmet need, non-binary respondents were more likely to identify support services for
vulnerable populations and climate resilience-focused planning and implementation as
unmet needs compared to male and female respondents.
46%
15%
23%
0%
23%
60%
20%
0%
20%
10%
66%
50%
43%
38%
32%
50%
83%
56%
50%
22%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Public Transit
American Indian
Black
NH White
Hispanic
203
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 31
Figure II-24.
Top
Community
Needs by
Gender
Identity
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
By income status, respondents making more than $150,000 were more likely to identify
mental health services and affordable childcare as unmet community needs in Bozeman
compared with lower income residents (Figure II-25). Conversely, respondents making less
than $25,000 were more likely to identify support services for vulnerable populations and
climate resilience as unmet community needs compared with higher income residents.
56%
41%
31%
30%
30%
63%
50%
88%
63%
13%
69%
54%
44%
39%
29%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Public Transit
Man
Nonbinary
Woman
204
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 32
Figure II-25.
Top
Community
Needs by
Income
Note: N = 953.
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
By employment status, respondents who are unemployed/looking for work were more
likely to identify affordable childcare and public transit as unmet community needs in
Bozeman compared with other respondents (Figure II-26). Residents that are retired were
more likely to identify mental health services as an unmet community need, while students
were more likely to identify support services, climate resilience, and public transit as unmet
community needs.
53%
37%
50%
44%
26%
60%
45%
40%
28%
31%
64%
50%
38%
35%
24%
71%
50%
42%
36%
37%
64%
52%
40%
37%
35%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Public Transit
Less than $25,000
$25,000 to $49,999
$50,000 to $99,999
$100,000 to $149,999
$150,000 or more
205
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 33
Figure II-26.
Top
Community
Needs by
Employment
Status
Note: n = 953
Source:
Root Policy Research
from the 2024
Bozeman Housing and
Community Needs
Survey.
Figure II-27 presents the five greatest unmet community and economic development needs
identified by respondents, sorted by other household types. Senior households were most
likely to select affordable childcare, public transit, and mental health services while those
with disabilities were most likely to select support services and public transit.
64%
48%
40%
34%
33%
59%
41%
50%
35%
35%
71%
57%
29%
14%
43%
66%
61%
32%
36%
20%
57%
43%
57%
48%
34%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Public Transit
Employed Full-Time
Employed Part-Time
Unemployed
Retired
Student
206
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 34
Figure II-27.
Top
Community
Development
Needs by
Other
Household
Type
Note: n = 953
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Additional community perspectives. Stakeholders and residents who
participated in focus groups and interviews frequently identified affordable childcare,
mental health services, and public transit as community development needs.
Stakeholders viewed the lack of affordable housing and childcare as intertwined and as key
barriers to community development. The cost of living is so high that those who work in
childcare cannot afford to work or maintain a business and thus take their labor and
expertise elsewhere. Existing programs have income restrictions that do not reach the
entire need of the city, one stakeholder said. Another added that there are no local or state
subsidies to help with childcare costs, stretching the limits of local fundraising and
scholarships available to parents.
Residents utilized split shifts, family members, and attempting to work from home to
maintain childcare and some desired non-traditional hour childcare for people who work
swing shifts. Stakeholders have also observed that many people have left the workforce
entirely to take care of their children. This leads to problems in retaining a workforce in
Bozeman, they added.
Many stakeholders highlighted a lack of mental health support in Bozeman, especially
credential support. Residents also felt there was a critical need for more drug addiction
35%
23%
14%
15%
12%
33%
30%
33%
23%
20%
44%
27%
21%
21%
15%
36%
29%
24%
19%
14%
60%
51%
31%
25%
21%
Affordable Childcare
Mental Health Services
Support Services
Climate Resiliance
Public Transit
Children
Disability
Large households
Single parents
Over 65
207
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 35
services. They reported that wait lists were long for treatment and supportive housing. One
reported that they were happy to see that the city has a crisis response team to assist
people experiencing mental health episodes or drug-related issues, but would like to see
more services available brought directly to people most likely to experience addiction.
Residents wanted to see the transportation system in Bozeman expand outside of city
boundaries. Currently, residents shared that where they’re currently living sits just outside
of the city and there is no way to get to and from their homes via public transportation.
Several residents shared that rideshare options are expensive. One resident shared that
they have walked from Walmart to the campus before, which is 8 miles roundtrip. The cost
of housing also ate into the budget of residents who could not access public transit, thus
making it difficult to get to work and earn money to pay for housing.
Discrimination. Survey respondents were asked if they or anyone they know has been
discriminated against when looking for housing in Bozeman, as well as when the most
recent instance of housing discrimination occurred and what they or the people they know
did about the discrimination. Respondents were also asked to describe the reason(s) that
they or the person(s) they know felt like they were discriminated against.
Resident respondents. Of the 736 resident respondents, 103 (14%) residents reported
that they or someone they know have experienced discrimination when looking for
housing in Bozeman. Of those that said they had been discriminated against, 48% reported
that the discrimination occurred 2 to 5 years ago, 38% reported that it occurred in the past
year, and 15% responded that the discrimination occurred more than five years ago. Two
percent of respondents who reported experiencing housing discrimination in Bozeman did
not remember when it occurred (Figure II-28).
By race and ethnicity, Hispanic and American Indian/Alaska Native resident respondents
were more likely to experience or know someone who has experienced housing
discrimination in Bozeman compared to other racial and ethnic groups. Black and
American Indian respondents were the most likely to report discrimination in the past year.
By gender identity, half of non-binary respondents and 20% of female respondents
reported experiencing or knowing someone who has experienced housing discrimination.
Sixty-seven percent of non-binary people experienced discrimination within the past year.
Resident respondents with lower incomes were more likely to report experiences of
housing discrimination compared with higher income residents. By employment status,
students and residents who are unemployed/looking for work were more likely to report
experiences with housing discrimination, while people living with disabilities and single
parents were more likely to report housing discrimination compared with other household
types.
208
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 36
Below are a sample of responses from residents about why they felt like they/the person(s)
they know were discriminated against:
“I had a pet.”
“Age and income.”
“Because I am in college.”
“Family size.”
“Friends have felt discriminated against because of their age, race, employment.’”
“[Friend] felt discriminated against because he is black and his application was declined
despite his excellent credit and rental history.”
“I am low income, have a disability, children, am queer, and BIPOC.”
“Mental health issues.”
“Nothing direct but trying to be open and honest about having an emotional support
animal we have be suddenly denied housing after being verbally assured that we were
accepted.”
“Didn’t speak English.”
“Adult had a felony on his record from when he was 19 year old for marijuana. The adult
was 24 and sober for years from marijuana and was still declined due to the conviction.”
“The lease was not renewed once they got a Section 8 voucher.”
“Race and income.”
Additionally, nearly half of respondents (46%) who experienced housing discrimination in
Bozeman did not do anything about it because they did not know what to do. Thirty-nine
percent of residents reported moving or finding another place to live while 15% of
respondents did not do anything about the discrimination because they were afraid of
being evicted or harassed (Figure II-29).
209
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 37
Figure II-28.
Percent of Residents Experiencing Discrimination and Most Recent Occurrence
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
n
Respondent Type
Resident 16%103 38%48%11%2%99
Stakeholder 34%46 41%46%10%2%41
Tenure
Owner 9%37 33%45%15%6%33
Renter 28%79 43%51%6%0%77
Mobile Home / Other 23%3 67%0%33%0%3
Unhoused 24%8 38%38%13%13%8
Race/Ethnicity
African American 20%2 50%50%0%0%2
American Indian/Alaska Native 42%5 60%40%0%0%5
Asian 50%1 0%100%0%0%1
Hispanic 24%4 25%75%0%0%4
Non-Hispanic White 18%97 39%49%9%2%97
Gender Identity
Female 20%73 38%55%4%3%74
Male 13%34 41%41%18%0%34
Non-Binary 50%4 67%33%0%0%3
Income
Less than $25,000 39%24 52%32%16%0%25
$25,000-$49,999 26%31 47%43%10%0%30
$50,000-$99,999 17%36 37%54%6%3%35
$100,000-$149,999 12%14 7%79%7%7%14
Above $150,000 9%10 40%50%10%0%10
Employment Status
Employed full-time 18%73 38%58%8%1%73
Employed part-time 17%8 38%38%25%0%8
Unemployed/looking for work 57%4 50%50%0%0%4
Retired 9%9 57%0%29%14%7
Student 27%12 69%31%0%0%13
Household Characteristics
Children under 18 10%9 33%67%0%0%9
Large Households 14%5 80%20%0%0%5
Single Parent 31%13 31%62%8%0%13
Disability 36%34 38%53%9%0%34
Older Adults (age 65+)16%24 27%36%23%14%22
n
Overall
percent has
been or
knows
someone who
has faced
discrimination
Most recent instance of housing discrimination
In the past
year
2 to 5 years
ago
More than 5
years ago
Don't
remember
210
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 38
When sorted by demographic and economic household characteristics, generally, the
majority of respondents did nothing about the discrimination because they were unsure of
what to do, were afraid of being evicted, or moved and found another place to live.
211
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 39
Figure II-29
Percent of Residents Experiencing Discrimination and Response to Discrimination
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
n
Respondent Type
Resident 16%103 48%16%41%8%8%3%4%5%5%7%
Stakeholder 34%46 41%13%35%13%13%9%0%2%4%11%
Tenure
Owner 9%37 38%5%41%5%3%8%3%3%0%5%
Renter 28%79 53%19%41%8%9%3%3%5%6%10%
Mobile Home / Other 23%3 33%0%67%0%0%0%0%0%0%0%
Unhoused 24%8 25%38%38%25%0%13%13%13%13%0%
Race/Ethnicity
African American 20%2 50%0%0%0%0%0%0%0%0%50%
American Indian/Alaska Native 42%5 60%0%20%40%40%0%0%0%0%0%
Asian 50%1 0%0%0%100%0%0%0%0%0%0%
Hispanic 24%4 25%25%50%0%0%0%0%0%0%0%
Non-Hispanic White 18%97 47%16%45%8%7%6%4%6%5%9%
Gender Identity
Female 20%73 52%15%38%4%7%4%1%5%3%8%
Male 13%34 38%21%44%18%12%3%6%6%3%6%
Non-Binary 50%4 25%0%50%25%0%0%0%0%25%25%
Income
Less than $25,000 39%24 63%29%42%13%17%4%4%8%8%8%
$25,000-$49,999 26%31 35%26%45%10%10%3%0%6%3%0%
$50,000-$99,999 17%36 53%8%31%11%8%3%3%3%3%14%
$100,000-$149,999 12%14 57%7%36%7%0%7%0%7%0%14%
Above $150,000 9%10 20%0%60%0%0%20%10%0%0%10%
Employment Status
Employed full-time 18%73 48%11%45%5%8%5%1%5%4%8%
Employed part-time 17%8 63%13%25%25%25%13%13%13%0%13%
Unemployed/looking for work 57%4 25%0%25%50%25%0%0%0%0%0%
Retired 9%9 33%0%22%0%0%0%22%0%0%0%
Student 27%12 67%42%50%25%0%0%0%0%8%17%
Household Characteristics
Children under 18 10%9 44%11%56%0%0%11%0%0%0%0%
Large Households 14%5 40%40%40%0%0%0%0%0%0%0%
Single Parent 31%13 62%54%23%15%8%8%0%8%0%8%
Disability 36%34 41%21%38%9%12%12%0%3%3%12%
Older Adults (age 65+)16%24 38%4%29%17%17%0%13%4%0%0%
Overall
percent has
been or
knows
someone who
has faced
discrimination
Nothing—I
wasn't sure
what to do
Filed a
complaint
What respondent did about the discrimination
Nothing—I
was afraid of
being evicted
Moved/
found
another
place to live
Called/
emailed
housing
authority
Called/
emailed local
fair housing
organization
Called/
emailed
Montana Fair
Housing
Called/
emailed City
office or
human
rights
department
Called/
emailed a
lawyer, Legal
Aid, and/or
ACLU Other
212
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 40
Displacement. Survey respondents were asked if they have had to move out of a
home/apartment in Bozeman when they did not want to move over the last five years.
Respondents were also asked to describe the reason(s) that they had to move.
Resident respondents. Of the 736 resident respondents, 137 (21%) residents reported
that they had to move out of a home/apartment in Bozeman when they did not want to
move. Of those that said they had to move in the past five years when they didn’t want to,
the most common reasons articulated by residents included rent increases (50%), the
landlord was selling the home/apartment (29%), landlord rented to someone else (21%),
and personal/relationship reasons (18%) (Figures II-30 and II-31).
With the exception of non-Hispanic White residents, all other racial and ethnic groups were
more likely to report experiencing displacement in Bozeman compared with resident
respondents overall. Although a small sample size, 38% of non-binary respondents
reported being displaced while 19% of female and 21% of male respondents reported
being displaced from their housing.
Respondents making less than $50,000 were more likely to report being displaced
compared with higher income residents. Students and resident respondents who are
unemployed/looking for work, as well as single parent households and those with
disabilities, were all more likely to report being displaced compared with their counterparts
in their respective comparison groups. In general, the number one reason that most
respondents across all groups reported being displaced was due to rent increases.
Twelve percent of resident respondents reported “other” when asked about why they were
displaced. Below are a sample of responses.
“My apartment turned into a VRBO.”
“New landlord wanted to remodel and rent to someone else for more money.”
“Rent increased from $1,700 to $2,400. Was told I had to pay increase or leave after lease
ended.
“Sewage came up my drains (the building’s main line to the City was backed up) and they
never fixed it.”
213
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 41
Figure II-30
Percent of Residents Reporting Displacement and Reasons they Had to Move
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
n
Respondent Type
Resident 21%137 4%5%9%18%21%18%29%9%8%
Stakeholder 22%30 0%17%10%13%27%27%30%10%20%
Tenure
Owner 6%25 12%16%8%24%20%20%20%12%12%
Renter 38%110 1%3%10%16%22%19%32%6%8%
Mobile Home/ Other 23%3 0%0%0%0%0%0%33%33%33%
Unhoused 32%11 9%18%0%18%36%18%36%27%9%
Race/Ethnicity
African American 40%4 50%25%0%0%0%25%0%25%25%
American Indian/Alaska Native 50%6 17%0%17%33%33%67%0%50%17%
Asian 100%2 0%0%50%50%0%100%0%0%0%
Hispanic 22%4 0%0%0%0%0%0%25%0%25%
Non-Hispanic White 20%109 1%5%8%17%22%17%28%6%8%
Gender Identity
Female 19%72 1%3%7%19%17%21%26%11%10%
Male 21%54 6%7%13%15%22%19%30%7%9%
Non-Binary 38%3 0%33%0%0%33%33%0%0%0%
Income
Less than $25,000 31%19 11%5%5%21%26%21%26%11%5%
$25,000-$49,999 34%41 2%10%10%15%24%20%29%17%10%
$50,000-$99,999 25%53 4%0%11%13%15%19%28%6%8%
$100,000-$149,999 14%16 0%13%6%25%19%19%25%0%19%
Above $150,000 4%4 0%0%0%0%0%0%25%0%0%
Employment Status
Employed full-time 24%97 2%5%10%14%19%18%32%6%9%
Employed part-time 17%8 0%0%13%63%13%38%13%13%13%
Unemployed/looking for work 43%3 0%0%33%0%0%67%0%33%0%
Retired 4%4 25%0%0%0%25%0%25%0%0%
Student 32%14 0%0%0%7%14%7%29%0%7%
Household Characteristics
Children under 18 8%7 0%14%0%29%29%43%43%14%14%
Large Households 11%4 0%0%25%25%0%0%50%0%25%
Single Parent 29%12 0%8%25%8%17%25%42%17%0%
Disability 35%33 6%9%9%12%30%9%12%0%6%
Older Adults (age 65+)12%18 17%11%6%22%17%44%17%39%22%
Career
move/job
change
Overall
percent of
those who had
to move out of
home when
they did not
want to move
Evicted
because I
was behind
on rent
Reason the respondent had to move
Evicted
because of
apartment
rules
Evicted for
no reason
Landlord
wanted to
move back
in/ move in
with family
Landlord
wanted to
rent to
someone
else
Landlord
refused to
renew my
lease
Landlord
was selling
the
apartment
Lost job/
hours
reduced
214
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 42
Figure II-31
Percent of Residents Reporting Displacement and Reasons they Had to Move, continued
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
n
Respondent Type
Resident 21%137 50%8%18%2%10%4%15%3%1%12%
Stakeholder 22%30 53%7%13%0%3%3%20%3%0%10%
Tenure
Owner 6%25 55%18%9%0%0%9%18%0%0%27%
Renter 38%110 32%12%12%0%8%8%8%4%4%16%
Mobile Home/ Other 23%3 33%0%33%0%33%0%33%33%0%0%
Unhoused 32%11 55%6%20%3%11%2%17%2%0%9%
Race/Ethnicity
African American 40%4 0%25%25%0%0%0%0%0%25%25%
American Indian/Alaska Native 50%6 17%33%0%0%0%17%0%0%0%0%
Asian 100%2 0%0%0%0%0%0%0%0%0%0%
Hispanic 22%4 75%0%0%0%25%0%0%0%0%0%
Non-Hispanic White 20%109 54%7%20%3%11%3%17%4%0%12%
Gender Identity
Female 19%72 50%10%19%1%11%6%18%3%0%13%
Male 21%54 52%6%15%4%11%4%9%4%2%6%
Non-Binary 38%3 33%0%33%0%0%0%33%0%0%0%
Income
Less than $25,000 31%19 32%11%21%0%32%5%16%5%5%11%
$25,000-$49,999 34%41 56%10%27%2%10%7%20%0%0%15%
$50,000-$99,999 25%53 57%9%13%4%6%4%15%8%0%11%
$100,000-$149,999 14%16 31%0%6%0%6%0%6%0%0%6%
Above $150,000 4%4 75%0%25%0%0%0%50%0%0%25%
Employment Status
Employed full-time 24%97 56%8%18%1%11%2%13%4%0%11%
Employed part-time 17%8 38%13%13%0%0%0%0%0%0%13%
Unemployed/looking for work 43%3 0%33%0%0%0%33%33%0%0%0%
Retired 4%4 50%0%0%0%0%0%25%25%0%25%
Student 32%14 50%7%29%14%14%0%50%0%0%14%
Household Characteristics
Children under 18 8%7 29%0%0%0%14%0%0%0%0%0%
Large Households 11%4 75%0%25%0%0%0%50%0%0%0%
Single Parent 29%12 33%17%25%8%17%17%17%17%0%17%
Disability 35%33 52%6%18%6%12%0%18%0%3%12%
Older Adults (age 65+)12%18 28%28%6%0%0%17%6%6%0%6%
Other
Circumstances
related to a
substance use
disorder
Reasons that respondent had to move
Overall
percent of
those who had
to move out of
home when
they did not
want to move
Rent
increased
more than I
could pay
Utilities
were too
expensive/
shut off
Personal/
relationship
reasons
Health/
medical
reasons
Housing was
unsafe (e.g.,
domestic
assault,
harassment)
Natural
disaster/
flooding/ fire
Poor
condition of
property
(e.g., mold,
bugs, etc.)
Property
taxes/ other
costs of
owning a
home
215
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 43
Additional community perspectives. Residents expressed the need for
additional assistance for security deposits, first and last month’s rent, and application fees.
This assistance would help those displaced secure housing more quickly and prevent
homelessness. Other residents voiced a desire to see more legal aid and tenants’ rights
resources available. One resident felt that “there needs to be a louder voice at the table
representing our interests…I’m a functioning member of this community and I deserve to
be heard.”
Stakeholders also suggested more financial literacy classes to help families manage their
expenses and better prepare for cost increases. Some noted that there should be more
support available for people who were evicted due to hoarding or issues with neighbors to
present themselves as desirable tenants.
Fair housing. Respondents who identified as stakeholders were asked to whom or
where they refer clients who are interested in filing a fair housing complaint. Additionally,
stakeholders were asked which types of fair housing activities are most needed in
Bozeman. Stakeholders were provided the following options:
Don’t know
Internet search
Scan social media posts
Local fair housing organization
State fair housing organization
HUD
Other
Figure II-32 illustrates that internet search (31%), don’t know (26%), and other (23%) were
the most common referral options provided by stakeholders when asked to help file a fair
housing complaint. For stakeholders that indicated “Other”, below are a sample of
responses.
“Joined Bozeman Tenant’s United.”
“The rental agencies are very careful to not leave a paper trail and we are worried about
retribution in the future of being turned down due to a complaint. There are a limited
number of rental agencies.”
“I was encouraged to not take action against the discriminatory landlord because she was
my friend's landlord, and she was afraid she'd be retaliated against or evicted.”
216
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 44
Figure II-32.
Fair Housing
Complaint
Referral
Options,
Stakeholder
Note:
N=149.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Stakeholders were asked to rank the seriousness of fair housing issues in Bozeman on a
scale from 1 (not a fair housing issue) to 10 (a very serious fair housing issue). Figures II-33
to II-37 group the outcomes by average rating. Lack of diverse housing types and price
points in the city was the top issue, followed by lack of affordable rental housing near
public transit, lack of affordable rental housing near employment centers, loss of low-cost
or market rate affordable housing due to revitalization, commercialization, urban renewal,
or rapid economic growth, and lack of affordable rental housing by proficient schools.
Figure II-33.
Average Rating of Seriousness by Fair Housing Issue, Stakeholders
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Assessment.
31%
26%
23%
21%
17%
15%
8%
Internet search
Don't know
Other
Local fair housing organization
HUD
State fair housing organization
Scan social media posts
6.91
6.84
6.63
6.35
6.31
5.93
5.75
Lack of affordable rental housing near public
transportation
Lack of affordable rental housing near employment
centers
Lack of affordable rental housing by proficient schools
Lack of accessible housing for people living with
disabilities in the community
Concentration of rental units accepting Housing Choice
Vouchers in certain parts of the community
Concentration of people living with disabilities in parts of
the community
Segregation of residents of certain protected classes in
parts of the community
Lack of affordable rental housing
near public transportation
Lack of affordable rental housing
near employment centers
Lack of accessible housing for people living with
disabilities in the community
Concentration of rental units accepting Housing
Choice Vouchers in certain parts of the community
Concentration of people living with disabilities in
parts of the community
Segregation of residents of certain protected classes
in parts of the community
217
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 45
Figure II-34.
Average Rating of Seriousness by Fair Housing Issue, Stakeholders cont.
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Assessment.
Figure II-35.
Average Rating of Seriousness by Fair Housing Issue, Stakeholders cont.
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Assessment.
7
6.71
6.43
6.42
6.36
6.3
6.25
6.07
Lack of diverse housing types and price points in the city
Loss of low-cost or market rate affordable housing due to
revitalization, commercialization, urban renewal, or…
Poor condition of affordable housing
Lack of affordable, integrated housing for individuals who
need supportive services
Lack of larger housing units for families
Lack of housing available for persons with disabilities
transitioning out of institutions and nursing homes
Limited housing options for refugees/ immigrants
Loss of manufactured housing (mobile home) communities
to redevelopment
Loss of low-cost or market rate affordable housing due
to revitalization, commercialization, urban renewal, or
rapid economic growth
Lack of affordable,integrated housing for individuals
who need supportive services
Lack of housing available for persons with disabilities
transitioning out of institutions and nursing homes
Loss of manufactured housing (mobile home)
communities to redevelopment
6.38
6.27
5.8
5.76
5.55
5.5
Community opposition or resistance to development by
neighbors
Lack of funding or assistance for housing accessibility
modifications
Discrimination against certain groups regardless of their
protected class status
Marketing to certain neighborhoods based on a person's
protected class
Lack of mobility counseling programs to assist families
moving from high poverty to low poverty areas
Lack of housing providers that allow service animals or
assistance/ emotional support animals
Community opposition or resistance to development by
neighbors
Lack of funding or assistance for housing accessibility
modifications
Discrimination against certain groups regardless of
their protected class status
Marketing to certain neighborhoods based on a
person's protected class
Lack of mobility counseling programs to assist families
moving from high poverty to low poverty areas
Lack of housing providers that allow service animals or
assistance/ emotional support animals
218
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 46
Figure II-36.
Average Rating of Seriousness by Fair Housing Issue, Stakeholders cont.
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Assessment.
Figure II-37.
Average Rating of Seriousness by Fair Housing Issue, Stakeholders
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Assessment.
6.23
5.84
5.84
5.51
Lack of resources for fair housing agencies and
organizations
Lack of awareness of local, state, or federal fair housing
laws
Lack of practical, effective remedies for fair housing
violations
Complexity/ difficulty with filing fair housing complaints
Lack of practical, effective remedies for fair
housing violations
Complexity/ difficulty with filing fair
housing complaints
Lack of resources for fair housing agencies
and organizations
Lack of awareness of local, state, or federal
fair housing laws
6.32
6.25
6.2
5.84
5.73
5.73
5.71
5.49
Lack of environmentally sustainable development
Lack of regional coordination
Insufficient availability of public transportation
Disparities in public investment
Lack of accessibility in public areas, including streets and
sidewalks
Disparities in provision of municipal services or amenities
Inadequate public transit reliability (e.g., timeliness)
Laws or policies that limit adequate availability of public
transportation
Lack of accessibility in public areas, including streets
and sidewalks
Laws or policies that limit adequate availability of
public transportation
219
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 47
Stakeholders identified resident education (46%), education/ training for local officials and
staff (36%), and assistance filing fair housing complaints (27%) as the three most needed
fair housing activities in Bozeman (Figure II-38). One stakeholder who responded “Other”
articulated that no amount of education could fix housing costs that surpass wages and
that the lack of affordable housing supply is the root of discrimination.
Figure II-38.
Fair
Housing
Activities
Most
Needed in
Bozeman,
Stakeholder
Note:
N=149.
Source:
Root Policy Research
from the 2024
Bozeman Housing
and Community
Needs Survey.
Additional community perspectives. In a resident focus group, participants
shared their experiences with discrimination within the housing market in Bozeman. One
resident felt that “Only a certain demographic fits most landlords’ preference for a tenant.”
Most participants felt that minorities and people with disabilities were looked down upon
by landlords and that they do not want to rent to this demographic.
Another resident shared that “Bozeman is looking for specific kinds of people. There’s a
sense that Bozeman wants people who work in the service industry to not live in
Bozeman.” Other residents shared that places like Livingston, Three Forks, and Townsend
are cheaper options but during the winter months, it would be extremely difficult and
unsafe to travel to Bozeman for work. One resident shared that the pass between
Bozeman and Livingston is really dangerous and that a few people have lost their lives this
past year.
One resident shared that their Hispanic friends who’ve looked for housing in Bozeman
have experienced discrimination. They shared that “they are usually told their references
don’t check out, even though they meet or exceed all of the renter requirements. But it’s
hard to prove [the discrimination].” This resident reiterated that landlords are “looking for a
specific type of demographic.”
Speaking about housing barriers, residents felt that “rental paperwork and applications”
can be overwhelming, particularly for immigrant households. One resident shared that
46%
36%
27%
14%
5%
0%
Resident education
Education/trainings for local officials
and staff
Assistance filing fair housing complaints
Testing
Other
Landlord/property manager education
Education/trainings for local officials
and staff
220
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 48
immigrant families are “out of luck” when trying to get a place, because landlords require
rental history, references, and credit information.
One resident shared that Spanish-speaking families have experienced discrimination while
looking for housing in Bozeman. This resident shared that “when 15 people apply for a unit
and the family doesn’t get the unit, they don’t have to ask why.”
Housing outcomes. Both residents and stakeholders were asked to select the five
housing outcomes they would like to see prioritized as a result of the HUD housing and
community development funding that the City of Bozeman will receive over the next five
years. Residents and stakeholders were asked to consider the following housing outcomes:
Accessible housing for persons with
disabilities
Better distribution of affordable
housing
Downpayment assistance for low-
and moderate-income households
Energy efficiency improvements to
housing units
Fewer affordable units converted to
market rate housing
Funding to support community land
trusts
Housing options for seniors to
downsize
Increased shelter capacity to support
people who are currently unhoused
Land acquisition funding to help
build affordable housing
More affordable rental housing
(specify type, rent, and target
populations below)
More housing options paired with
supportive services
More opportunities for
homeownership (specify home
prices and product type below)
More resources for residents to
avoid displacement
More resources for residents to
resolve housing
discrimination/better awareness of
fair housing rights
More Section 8 or rental subsidies
Owner occupied housing in better
condition
Rental housing in better condition
Seniors/persons with disabilities able
to live independently
Other
Resident respondents. More affordable rental housing (53%) was identified by residents
as the housing outcome that should be the greatest priority for the City of Bozeman (Figure
II-39). Residents also identified more opportunities for homeownership (47%), better
distribution of affordable housing (42%), downpayment assistance for low-and moderate-
income households (26%), and fewer affordable units converted to market rate housing
(23%) as housing outcomes that should be prioritized.
221
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 49
Figure II-39.
What
housing
outcomes
would you
most like to
see as a
result of HUD
funding?
Residents
Note:
N=736.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Stakeholder respondents. Stakeholder respondents ranked more affordable housing
(33%), more opportunities for homeownership (30%), better distribution of affordable
housing (22%), land acquisition funding for affordable housing (18%), and increased shelter
capacity (17%) as the top five housing outcomes they would like to see in Bozeman.
53%
47%
42%
26%
23%
22%
21%
20%
19%
15%
15%
14%
12%
11%
10%
9%
8%
7%
5%
More affordable rental housing
More opportunities for homeownership
Better distribution of affordable housing
Downpayment assistance for LMI households
Fewer affordable units converted to market rate housing
Increased shelter capacity
Other
Energy efficiency improvements to housing units
Land acquisition funding for affordable housing
Rental housing in better condition
More resources for residents to avoid displacement
Funding to support community land trusts
More housing options for seniors to downsize
More housing options paired with supportive services
More Section 8 or rental subsidies
Accessible housing for persons with disabilities
Seniors/persons with disabilities able to live independently
Owner occupied housing in better condition
More resources for discrimination and fair housing
222
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 50
Figure II-40.
What
housing
outcomes
would you
most like to
see as a
result of HUD
funding?
Stakeholders
Note:
N=217.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Answers of respondents who selected “other” are below:
“Affordable housing for Bozeman’s workforce.”
“Current definition of "affordable" here is inconsistent with wages of low and middle income
families in the area.”
“Affordable rent for young people who are working and would be able to save for future
home ownership.”
“Benefits for homeowners providing quality housing at below market rate.”
“Fewer property taxes.”
“More affordable single occupant apartments.”
“Support for residents that can’t qualify for income restricted units but can’t afford market
rate rent/home prices.”
Resident respondents by demographic and economic characteristics. Figures II-
41 through A-44 present the top five housing outcomes for each resident respondent
33%
30%
22%
18%
17%
15%
15%
14%
14%
13%
12%
11%
11%
10%
9%
8%
8%
5%
5%
More affordable rental housing
More opportunities for homeownership
Better distribution of affordable housing
Land acquisition funding for affordable housing
Increased shelter capacity
More Section 8 or rental subsidies
Down payment assistance for LMI households
Accessible housing for persons with disabilities
Fewer affordable units converted to market rate housing
More housing options for seniors to downsize
Other
Energy efficiency improvements to housing units
Funding to support community land trusts
More housing options paired with supportive services
More resources for residents to avoid displacement
Seniors/persons with disabilities able to live independently
Rental housing in better condition
Owner occupied housing in better condition
More resources for housing discrimination and fair housing
223
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 51
group by race and ethnicity, gender identity, household income, employment status, and
other selected household types.
Across tenure, more affordable rental housing was desired. This was followed by more
opportunities for homeownership for low- to- moderate-income residents, with the
exception of mobile home/ other residents who ranked rental housing in better condition
second.
Figure II-41.
Top Five Housing Outcomes by Tenure
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
American Indian and Hispanic groups identified more affordable rental housing as a
housing outcome that should be most prioritized by the City of Bozeman. Black resident
respondents were more likely to identify accessible housing for persons with disabilities
more Section 8 or rental subsidies as a housing outcome, while non-Hispanic White
respondents prioritized shelter capacity and fewer conversions of affordable units to
market rate housing.
More affordable rental housing More affordable rental housing
More opportunities for homeownership for LMI
residents
More opportunities for homeownership for LMI
residents
Better distribution of affordable housing Better distribution of affordable housing
Energy efficiency improvements to housing
units
More down payment assistance for LMI
households
Fewer converstions of affordable units to
market rate housing
Fewer converstions of affordable units to
market rate housing
More affordable rental housing More affordable rental housing
Rental housing in better condition More opportunities for homeownership for LMI
residents
Energy efficiency improvements to housing
units Better distribution of affordable housing
More opportunities for homeownership for LMI
residents Rental housing in better condition
Better distribution of affordable housing Land acquisition funding to help build
affordable housing
MOBILE HOME/ OTHER UNHOUSED
OWNER RENTER
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
224
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 52
Figure II-42.
Top Five Housing Outcomes by Race and Ethnicity
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Male and non-binary resident respondents articulated the same items within their top five
housing outcomes (Figure II-43). Women were more likely to include increased shelter
capacity.
More affordable rental housing Accessible housing for persons with disabilities
Better distribution of affordable housing More affordable rental housing
Accessible housing for persons with disabilities Better distribution of affordable housing
More opportunities for homeownership for LMI
residents
Energy efficiency improvements to housing
units
Increased shelter capacity More Section 8 or rental subsidies
Increased shelter capacity More affordable rental housing
Fewer converstions of affordable units to
market rate housing Better distribution of affordable housing
More opportunities for homeownership for LMI
residents
More opportunities for homeownership for LMI
residents
Funding to support community land trusts Increased shelter capacity
More housing options with supportive services Fewer converstions of affordable units to
market rate housing
AMERICAN INDIAN BLACK
NON-HISPANIC WHITE HISPANIC
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
225
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 53
Figure II-43.
Top Five Housing Outcomes by Gender Identity
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
By income status, resident respondents generally had similar articulated housing outcomes
(Figure II-44). Residents with income greater than $100,000 to $150,000 identified more
homeownership opportunities for low-to-moderate income families as an outcome they
want the City to prioritize, while residents of all other income brackets identified more
affordable housing.
More affordable rental housing More affordable rental housing
More opportunities for homeownership for LMI
residents
More opportunities for homeownership for LMI
residents
Better distribution of affordable housing Better distribution of affordable housing
Energy efficiency improvements to housing
units
More resources for residents to avoid
displacement
More down payment assistance for LMI
households
Energy efficiency improvements to housing
units
More affordable rental housing
More opportunities for homeownership for LMI
residents
Better distribution of affordable housing
More down payment assistance for LMI
households
Increased shelter capacity
MEN NON-BINARY
WOMEN
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
226
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 54
Figure II-44.
Top Five Housing Outcomes by Income
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Figure II-45 presents the top five housing outcomes by employment status for resident
respondents. Residents who were unemployed or looking for work identified more
opportunities for homeownership for low-to-moderate income households and were more
likely to select more Section 8 or rental subsidies. Students were more likely to select rental
housing in better condition.
More affordable rental housing More affordable rental housing
Better distribution of affordable housing Better distribution of affordable housing
Rental housing in better condition More opportunities for homeownership for LMI
residents
Energy efficiency improvements to housing
units
Fewer converstions of affordable units to
market rate housing
More opportunities for homeownership for LMI
residents
More down payment assistance for LMI
households
More affordable rental housing More opportunities for homeownership for LMI
residents
More opportunities for homeownership for LMI
residents More affordable rental housing
Better distribution of affordable housing Better distribution of affordable housing
More down payment assistance for LMI
households
Land acquisition funding to help build
affordable housing
Fewer converstions of affordable units to
market rate housing
More down payment assistance for LMI
households
More affordable rental housing
More opportunities for homeownership for LMI
residents
Better distribution of affordable housing
More down payment assistance for LMI
households
Increased shelter capacity
LESS THAN $25,000 $25,000 TO $49,999
$50,000 TO $99,999 $100,000 TO $149,999
$150,000 OR MORE
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
227
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 55
Figure II-45.
Top Five Housing Outcomes by Employment Status
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Aside from households with children under 18 and large households, the primary housing
outcome identified by all other housing types was more affordable rental housing (Figure
II-46). Households with children under 18 and large households identified more
homeownership opportunities for low- to moderate-income households as a priority.
More affordable rental housing More affordable rental housing
More opportunities for homeownership for LMI
residents Better distribution of affordable housing
Better distribution of affordable housing More opportunities for homeownership for LMI
residents
More down payment assistance for LMI
households
More down payment assistance for LMI
households
Increased shelter capacity Increased shelter capacity
More opportunities for homeownership for LMI
residents More affordable rental housing
Better distribution of affordable housing More opportunities for homeownership for LMI
residents
More Section 8 or rental subsidies Better distribution of affordable housing
More affordable rental housing More housing options for seniors to downsize
Increased shelter capacity Land acquisition funding to help build
affordable housing
More affordable rental housing
Better distribution of affordable housing
More opportunities for homeownership for LMI
residents
Rental housing in better condition
Fewer affordable units converted to market
rate housing
EMPLOYED FULL-TIME EMPLOYED PART-TIME
UNEMPLOYED/ LOOKING FOR WORK RETIRED
STUDENTS
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
228
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 56
Figure II-46.
Top Five Housing Outcomes by Other Household Types
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Additional community perspectives. Stakeholders and residents shared their
perspectives about the process of securing affordable housing and building affordable
housing. One resident shared that they’ve experienced being “bumped up and down the
waiting list [for subsidized housing]. We slipped through the cracks when a new staff
member took over. I was never mailed a package for my voucher and my status still says
pending.” They shared that it was stressful not knowing if they were going to get a voucher,
because they were simultaneously running out of emergency rental assistance. They
added, “why am I not being seen?”
More opportunities for homeownership for LMI
residents More affordable rental housing
More affordable rental housing More opportunities for homeownership for LMI
residents
Better distribution of affordable housing Better distribution of affordable housing
Energy efficiency improvements to housing
units
Fewer affordable units converted to market
rate
More down payment assistance for LMI
households
More down payment assistance for LMI
households
More opportunities for homeownership for LMI
residents More affordable rental housing
Better distribution of affordable housing More opportunities for homeownership for LMI
residents
More Section 8 or rental subsidies Better distribution of affordable housing
More affordable rental housing More down payment assistance for LMI
households
Increased shelter capacity Land acquisition funding to help build
affordable housing
More affordable rental housing
More opportunities for homeownership for LMI
residents
Better distribution of affordable housing
Fewer affordable units converted to market
rate
Increased shelter capacity
CHILDREN UNDER 18 DISABILITY
LARGE HOUSEHOLDS SINGLE PARENTS
SENIORS
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
229
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 57
When it comes to the development of affordable housing, a stakeholder involved in
development shared that it was difficult to build “truly affordable housing” because land is
so expensive. They added that “unless you have a willing partner who can donate the land,”
it’s not going to make financial sense to develop.
They felt that the biggest outside pressure currently facing Bozeman are “the costs to
build.” They added that, “it takes two years to get your permits, there are higher impact
fees, you have to find your workforce, who then needs to find housing, childcare, and
transportation…if you can overcome these things, you’ll be successful.”
Community Development Outcomes. Both residents and stakeholders were
asked to select the five community development outcomes they would like to see
prioritized as a result of the HUD housing and community development funding that the
City of Bozeman will receive over the next five years. Residents and stakeholders were
asked to consider the following housing outcomes:
A community center and/or
improvements to existing community
centers (specify neighborhood
below)
A senior center and/or
improvements to existing senior
centers (specify neighborhood
below)
Additional and/or higher quality
childcare centers
Climate resilience-focused planning
and implementation
Improvements to parks and
recreation centers
Increased access to addiction
treatment services
Increased access to
internet/broadband services
Increased access to mental health
care services
More nonprofit/services space
and/or improvements to
nonprofit/services space
More recreation opportunities for
youth and other special populations
Street and sidewalk improvements
Other
Resident respondents. More recreational opportunities for youth (46%), increased
access to mental health care services (38%), and improvements to or new senior centers
(38%) were identified by residents as top three community development outcomes that
should be the greatest priority for the City of Bozeman (Figure II-47).
230
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 58
Figure II-47.
What
community
development
outcomes
would you
most like to
see as a
result of HUD
funding?
Residents
Note:
N=736.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
Stakeholder respondents. Stakeholder respondents also identified more recreational
opportunities for youth (36%) and increased access to mental health care services (34%) as
top community development outcomes they want prioritized by the City of Bozeman
(Figure II-48).
46%
38%
38%
32%
31%
28%
23%
20%
17%
14%
13%
12%
More recreational opportunities for youth
Increased access to mental health care services
Improvements to or new senior centers
Improvements to or new community center
Other
Street and sidewalk improvements
Additional and/or higher quality childcare centers
Improvements to parks and recreation centers
Increased access to internet/broadband services
Climate resilience-focused planning and implementation
Increased access to addiction treatment services
Improvements to or additional nonprofit/services space
231
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 59
Figure II-48.
What
community
development
outcomes
would you
most like to
see as a
result of HUD
funding?
Stakeholders
Note:
N=217.
Source:
Root Policy Research
from the 2024 Bozeman
Housing and
Community Needs
Survey.
The open-ended responses for those who selected “other” are below:
“An adult care center that offers quality life enrichment to enhance the quality of life for
persons with dementia and disabilities.”
“ADA improvements prioritized above all else.”
“More benches for the elderly and disabled to sit on in public areas.”
“Better public transit, pedestrian infrastructure, and biking infrastructure.”
“New field house/ indoor swim center.”
“Community services in Spanish.”
Resident respondents by demographic and economic characteristics. Figures II-
49 through A-51 present the top five community development outcomes for each
respondent group by race and ethnicity, gender identity, household income, employment
status, and other selected household types.
By tenure, renters and unhoused residents identified more recreational opportunities for
youth and other special populations while owners and those who live in mobile homes or
other housing types identified increased access to mental health care services.
36%
34%
24%
18%
18%
17%
17%
14%
14%
10%
10%
7%
More recreation opportunities for youth
Increased access to mental health care services
Other
Improvements to or new community center
Improvements to or new senior centers
Climate resilience-focused planning and implementation
Improvements to parks and recreation centers
Additional and/or higher quality childcare centers
Street and sidewalk improvements
Increased access to internet/broadband services
Increased access to addiction treatment services
Improvements to or additional nonprofit/services space
232
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 60
Figure II-49.
Top Five Community Development Outcomes by Tenure
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey..
White and Hispanic respondents identified more recreational activities for youth and other
special populations as their number one priority, while American Indian respondents
selected additional and/ or higher quality childcare most frequently. Black respondents
selected increased access to mental health care most frequently.
Increased access to mental health care services More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations
New senior center or improvements to existing
senior center
New senior center or improvements to existing
senior center
New community centers or improvements to
existing community centers
Street and sidewalk improvements Other
New community centers or improvements to
existing community centers Increased access to mental health care services
Increased access to mental health care services More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations
New community centers or improvements to
existing community centers
New community centers or improvements to
existing community centers Other
Other New senior center or improvements to existing
senior center
New senior center or improvements to existing
senior center Increased access to mental health care services
OWNER RENTER
MOBILE HOME/ OTHER UNHOUSED
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
233
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 61
Figure II-50.
Top Five Community Development Outcomes by Race and Ethnicity
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
By gender identity, men and women both selected more recreational activities for youth
and other special populations and had a similar top five. Non-binary respondents
prioritized a new senior center or improvements to existing senior centers followed by
street and sidewalk improvements.
Additional and/or higher quality childcare Increased access to mental health care services
New community centers or improvements to
existing community centers Additional and/or higher quality childcare
Other New community centers or improvements to
existing community centers
Climate resilience-focused planning and
implementation
Climate resilience-focused planning and
implementation
Improvements to parks and recreation centers Improvements to parks and recreation centers
More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations
Increased access to mental health care services New senior center or improvements to existing
senior center
New senior center or improvements to existing
senior center Increased access to mental health care services
New community centers or improvements to
existing community centers Other
Other Improvements to parks and recreation centers
AMERICAN INDIAN BLACK
NON-HISPANIC WHITE HISPANIC
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
234
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 62
Figure II-51.
Top Five Community Development Outcomes by Gender Identity
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Those with incomes less than $50,000 prioritized new senior centers or improvements to
senior centers, more recreational opportunities for youth and special populations, and
increased mental health services. Those with incomes between $50,000 and $100,000
identified increased access to mental health services, additional childcare, and climate
resilience-focused planning. Those with incomes above $100,000 identified more
recreational opportunities for youth and special populations, increased access to mental
health care services, and a new senior center or improvements to existing senior centers.
More recreational opportunities for youth and
other special populations
New senior center or improvements to existing
senior center
Increased access to mental health care services Street and sidewalk improvements
New community centers or improvements to
existing community centers
More recreational opportunities for youth and
other special populations
New senior center or improvements to existing
senior center
Climate resilience-focused planning and
implementation
Street and sidewalk improvements New community centers or improvements to
existing community centers
More recreational opportunities for youth and
other special populations
Increased access to mental health care services
New senior center or improvements to existing
senior center
Other
New community centers or improvements to
existing community centers
MEN NON-BINARY
WOMEN
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
235
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 63
Figure II-52.
Top Five Community Development Outcomes by Income
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Resident respondents who are employed full-time and part-time, as well as retired
respondents and students, all identified the same top five community development
outcomes (Figure II-53). Resident respondents who are unemployed/looking for work
identified more nonprofit/services space and/or improvements to nonprofit/services space
as a primary community development outcome. Students identified new community
centers or improvements to existing community centers as their top priority.
New senior center or improvements to existing
senior center
More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations Increased access to mental health care services
New community centers or improvements to
existing community centers Other
Street and sidewalk improvements New community centers or improvements to
existing community centers
Increased access to mental health care services New senior center or improvements to existing
senior center
Increased access to mental health care services Increased access to mental health care services
Additional and/or higher quality childcare More recreational opportunities for youth and
other special populations
Climate resilience-focused planning and
implementation
New senior center or improvements to existing
senior center
Increased access to addiction treatment
services Additional and/or higher quality childcare
Street and sidewalk improvements Improvements to parks and recreation centers
More recreational opportunities for youth and
other special populations
Increased access to mental health care services
New senior center or improvements to existing
senior center
Street and sidewalk improvements
New community centers or improvements to
existing community centers
LESS THAN $25,000 $25,000 TO $49,999
$50,000 TO $99,999 $100,000 TO $149,999
$150,000 OR MORE
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
236
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 64
Figure II-53.
Top Five Community Development Outcomes by Employment Status
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Households with children under 18 and seniors prioritized mental health services, while
those with disabilities prioritized more recreational opportunities for youth and other
special populations. Large households and single parents both selected improvements to
parks and recreation centers as their top community development priority.
More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations
Increased access to mental health care services Increased access to mental health care services
New senior center or improvements to existing
senior center
New senior center or improvements to existing
senior center
Other Additional and/or higher quality childcare
New community centers or improvements to
existing community centers
New community centers or improvements to
existing community centers
More nonprofit/ service space More recreational opportunities for youth and
other special populations
Increased access to mental health care services Increased access to mental health care services
Additional and/or higher quality childcare New senior center or improvements to existing
senior center
Increased access to addiction treatment
services Other
New community centers or improvements to
existing community centers
New community centers or improvements to
existing community centers
New community centers or improvements to
existing community centers
More recreational opportunities for youth and
other special populations
New senior center or improvements to existing
senior center
Street and sidewalk improvements
Other
EMPLOYED FULL-TIME EMPLOYED PART-TIME
UNEMPLOYED/ LOOKING FOR WORK RETIRED
STUDENTS
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
237
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 65
Figure II-54.
Top Five Community Development Outcomes by Other Household Type
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Additional community perspectives. Stakeholders shared in interviews that
there needed to be increased staff capacity to provide prevention and diversion services
for people experiencing mental health issues. They would like to see more options for
group therapy to bring together community members.
Economic Development Outcomes. Both residents and stakeholders were
asked to select the two economic development outcomes they would like to see prioritized
as a result of the HUD housing and community development funding that the City of
Increased access to mental health care services More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations
New senior center or improvements to existing
senior center
New senior center or improvements to existing
senior center Increased access to mental health care services
New community centers or improvements to
existing community centers Other
Street and sidewalk improvements New community centers or improvements to
existing community centers
Improvements to parks and recreation centers Improvements to parks and recreation centers
More recreational opportunities for youth and
other special populations
More recreational opportunities for youth and
other special populations
Increased access to mental health care services Other
New community centers or improvements to
existing community centers Street and sidewalk improvements
Street and sidewalk improvements Increased access to mental health care services
Increased access to mental health care services
Additional and/or higher quality childcare
Climate resilience-focused planning and
implementation
Increased access to addiction treatment
services
Street and sidewalk improvements
CHILDREN UNDER 18 DISABILITY
LARGE HOUSEHOLDS SINGLE PARENTS
SENIORS
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
1
2
3
4
5
238
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 66
Bozeman will receive over the next five years. Residents and stakeholders were asked to
consider the following economic development outcomes:
Job training programs or job training
centers
More opportunities for start-up
businesses, businesses looking to
expand, or businesses looking to
relocate
Revitalization of neighborhood
businesses/commercial areas
(specify neighborhood below)
Other
Resident respondents. Of the 736 resident responses, 35% of respondents identified a
need for more job training programs or job training centers, revitalization of neighborhood
businesses/commercial areas and more opportunities for start-up and existing businesses.
Nineteen percent of residents chose “Other”; a sample of those responses are below.
Stakeholder respondents. Of the 217 stakeholder responses, 26% identified a need for
more job training programs or job training centers, followed by revitalization of
neighborhood businesses/commercial areas (24%) and more opportunities for start-up and
existing businesses (22%).
Nineteen percent of residents and fourteen percent of stakeholders chose “Other”; a
sample of those responses are below.
“7th is getting better but still has a long way to go, same with 19th and Huffine. The large
commercial arteries just aren't great places to go, and create barriers for active
transportation.”
“Affordable housing for bottom 25% household income to support the future growth!”
“Economic development has surpassed the infrastructure of the city. Focus more on city
planning.”
“Job opportunities for highly educated (e.g. tech, biomedical, etc) “
“Keeping the small businesses that we have. Many have been priced out of downtown and
moved elsewhere or closed. Bringing businesses that people congregate at to all
neighborhoods like bakeries, coffeeshops, bookstores, library branches (NW&SW are
missing this the most).”
“Simplify the project development approval process.”
Resident respondents by demographic and economic characteristics. Figures II-
55 through II-61 present the top three community development outcomes for each
resident respondent group by tenure, race and ethnicity, gender identity, household
income, employment status, and other selected household types.
By tenure, owners and mobile home residents prioritized job training programs while
renters prioritized revitalization of neighborhood businesses or commercial areas.
239
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 67
Respondents who were unhoused prioritized more opportunities for start-up businesses or
for businesses looking to expand or relocate.
Figure II-55.
Top Three Economic Development Outcomes by Tenure
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Black and Hispanic respondents identified job training programs or job training centers as
their top economic development outcome, while American Indian respondents identified
more opportunities for start-up businesses or businesses looking to expand or relocate.
White respondents identified revitalization of neighborhood businesses or commercial
areas as their top economic outcome.
Figure II-56.
Top Three Economic Development Outcomes by Race and Ethnicity
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Job training programs or job training centers Revitalization of neighborhood businesses/
commercial areas
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
More opportunities for start-up businesses,
businesses looking to expand or relocate
More opportunities for start-up businesses,
businesses looking to expand or relocate
Job training programs or job training centers More opportunities for start-up businesses,
businesses looking to expand or relocate
More opportunities for start-up businesses,
businesses looking to expand or relocate
Revitalization of neighborhood businesses/
commercial areas
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
OWNER RENTER
MOBILE HOME/ OTHER UNHOUSED
1
2
3
1
2
3
1
2
3
1
2
3
More opportunities for start-up businesses,
businesses looking to expand or relocate Job training programs or job training centers
Job training programs or job training centers More opportunities for start-up businesses,
businesses looking to expand or relocate
Revitalization of neighborhood businesses/
commercial areas
Revitalization of neighborhood businesses/
commercial areas
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
Job training programs or job training centers Revitalization of neighborhood businesses/
commercial areas
More opportunities for start-up businesses,
businesses looking to expand or relocate
More opportunities for start-up businesses,
businesses looking to expand or relocate
AMERICAN INDIAN BLACK
NON-HISPANIC WHITE HISPANIC
1
2
3
1
2
3
1
2
3
1
2
3
240
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 68
Women and non-binary respondents had the same top three economic development
outcomes, with job training programs or job training centers as the top identified outcome
(Figure II-57). Men identified more opportunities for start-up businesses or businesses
looking to expand/ relocate.
Figure II-58.
Top Three Economic Development Outcomes by Gender Identity
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Those with income less than $25,000 and those with income above $100,000 prioritized
revitalization of neighborhood businesses/ commercial areas while those with income
$25,000 to $100,000 prioritized job training programs or job training centers.
More opportunities for start-up businesses,
businesses looking to expand or relocate Job training programs or job training centers
Revitalization of neighborhood businesses/
commercial areas
Revitalization of neighborhood businesses/
commercial areas
Job training programs or job training centers More recreational opportunities for youth and
other special populations
Job training programs or job training centers
Revitalization of neighborhood businesses/
commercial areas
More recreational opportunities for youth and
other special populations
MEN NON-BINARY
WOMEN
1
2
3
1
2
3
1
2
3
241
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 69
Figure II-59.
Top Three Economic Development Outcomes by Income
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Respondents who work part time, retired, or students identified job training programs as
their top economic outcome while those who work full time or were unemployed identified
revitalization of neighborhood businesses/ commercial areas as their top economic
outcome.
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
More opportunities for start-up businesses,
businesses looking to expand or relocate
More opportunities for start-up businesses,
businesses looking to expand or relocate
Job training programs or job training centers Revitalization of neighborhood businesses/
commercial areas
Job training programs or job training centers Revitalization of neighborhood businesses/
commercial areas
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
More opportunities for start-up businesses,
businesses looking to expand or relocate
More opportunities for start-up businesses,
businesses looking to expand or relocate
Revitalization of neighborhood businesses/
commercial areas
More opportunities for start-up businesses,
businesses looking to expand or relocate
Other
LESS THAN $25,000 $25,000 TO $49,999
$50,000 TO $99,999 $100,000 TO $149,999
$150,000 OR MORE
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
242
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 70
Figure II-60.
Top Three Economic Development Outcomes by Employment Status
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
Households with children and households with disabilities prioritized the revitalization of
neighborhood businesses/ commercial areas while all other groups identified job training
programs or job training centers as their top economic development outcome (Figure II-
61).
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
More opportunities for start-up businesses,
businesses looking to expand or relocate
Revitalization of neighborhood businesses/
commercial areas
Job training programs or job training centers More opportunities for start-up businesses,
businesses looking to expand or relocate
Revitalization of neighborhood businesses/
commercial areas Job training programs or job training centers
Job training programs or job training centers More opportunities for start-up businesses,
businesses looking to expand or relocate
More opportunities for start-up businesses,
businesses looking to expand or relocate
Revitalization of neighborhood businesses/
commercial areas
Job training programs or job training centers
Revitalization of neighborhood businesses/
commercial areas
More opportunities for start-up businesses,
businesses looking to expand or relocate
EMPLOYED FULL-TIME EMPLOYED PART-TIME
UNEMPLOYED/ LOOKING FOR WORK RETIRED
STUDENTS
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
243
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION II, PAGE 71
Figure II-61.
Top Three Economic Development Outcomes by Household Type
Source: Root Policy Research from the 2024 Bozeman Housing and Community Needs Survey.
244
III. DEMOGRAPHIC PATTERNS
245
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 1
SECTION III.
Demographic Patterns
This section examines demographic patterns that are associated with residential
settlement, housing availability and affordability, and access to opportunity.
Primary Findings
Bozeman’s population largely consists of non-Hispanic White residents (87%);
however, over the last twelve years, the city has gradually become more diverse.
The majority of households (54%) in the city are “non-family” households—largely
householders who live alone or share the home with people they are not related to.
This is primarily due to the presence of Montana State University.
The percentage of people living in poverty in Bozeman (14.7%) has declined by over a
quarter since 2010. Poverty varies by race and ethnicity but is significantly high for
African American/Black residents (30%). Hispanic residents, residents who identify as
some other race, and single mothers are more likely to live in poverty relative to the
general population.
American Indian and/or Alaska Native (AIAN) and Asian residents have lower
household median incomes compared to the general population.
One in four residents in Census Tract 6, which is located in the northeast quadrant of
the city, are living in poverty. This tract also has concentrations of residents living with
disabilities, Hispanic residents, and AIAN residents.
While Bozeman’s Dissimilarity Index score—a measure of the severity of segregation—
show low levels of segregation between residents of color and non-Hispanic White
residents, this is primarily due to the city’s relatively low proportion of households of
color.
246
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 2
Figure III-0.
2020 Census Tracts and Bozeman City Boundaries Reference Map
Source: 2020 Decennial Census and Root Policy Research.
247
CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 3
Historical Context
The original inhabitants of the area now known as present-day Bozeman include the Séliš
(Bitterroot Salish), Qlispé (Pend d’Oreille), Ktunaxa (Kootenai), Pikuni (Blackfeet), Tsistsis’tas
(Northern Cheyenne), Apsáalooke (Crow), Anishinaabe (Chippewa), Nehiyawak (Cree),
Metis, Nakoda (Assiniboine), A’aninin (Gros Ventre), Dakota, Lakota, and other indigenous
people and nations.1 The first permanent non-Indigenous settlements in the area were
established in the 1860s through the dispossession of Indigenous lands, as settlers
“ascribed their own understandings onto the land…[which] served to sever the
relationships that Indigenous people had with their Relatives, profoundly altering the
landscape and its inhabitants.”2
Due to the fertile soil and geographic proximity to mining camps, Bozeman“…became one
of the earliest and most successful agricultural communities in the Rocky Mountain West.”3
The arrival of the railroad to Bozeman in the late 19th century helped mitigate “the
economic disadvantages of [Bozeman’s] geographic isolation from eastern population
centers”4 and helped stabilize the city’s population and economic outlook. In 1893, the
College of Agriculture and Mechanic Arts (presently known as Montana State University)
was established and continued to build upon the city’s “advantageous position as a
regional supply center,”5 and its economic advantages through the agricultural industry.
Following World War II, Montana State College “remained the largest local employer and
continued to ensure the economic vitality of the community.”6 The construction of the
interstate highway north and east of the city, in addition to burgeoning air travel, helped
spur Bozeman’s recreational tourism industry. These factors, along with development
pressure brought about by significant population growth in both the city and county over
the last few decades, have shifted the area’s primary economic drivers away from
agriculture and local agribusiness and towards recreational tourism and real estate
development. Presently, high-tech business has been a key factor in Bozeman’s growing
economy, along with “the construction industry and businesses that support that industry,
such as building supplies, banking and financial services, and landscaping materials
suppliers and installers.”7
1 Belonging in Bozeman—Equity & Inclusion Plan, Historical Narrative, page 1
2 Ibid
3 City of Bozeman Community Plan 2020, Appendices, page C-2
4 Ibid
5 Ibid
6 Ibid
7 Ibid
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Factors contributing to settlement patterns of residents of color. In the early
and mid-20th century, several policies and practices promoted racial and ethnic segregation
of BIPOC8 residents within neighborhoods, justified by many as a way to ensure
neighborhood stability. While substantial evidence of discriminatory real estate practices
exists throughout the country, limited documentation is available related to the
implementation of these practices in Bozeman. However, the lack of documentation does
not imply that factors did not impact the settlement patterns of BIPOC households in
Bozeman.
As detailed in the Belonging in Bozeman Plan Historical Narrative, several other factors were
influential in the settlement of residents of color in the city. At the beginning of the 20th
century, Montana was one of the most ethnically diverse states in the country; however,
today, it is now among the least diverse in the country.
The narrative details that “while [the Bozeman] region did not experience the large-scale,
overt racial violence characteristics of the post-Civil War South, violence, in its broadest
sense, was used in a myriad of other ways. Legislative measures, extralegal exclusion,
racism, and deliberate erasure have inflicted enduring historical trauma on marginalized
communities.”9 For example, the Montana State Legislature passed an anti-miscegenation
at the beginning of the 20th century, making interracial marriage illegal. This law remained
in effect until 1953, however, it reflected a “…shift from a society in Montana that offered a
future for a Black community into one that did not.”10 Actions like those described above
have had significant impacts on residents of color in Bozeman. As such, “decades of formal
and informal exclusionary practices have created a sense of invisibility among Bozeman’s
minority residents.”11
Additionally, “Bozeman operated as a small and economically integrated town, a reflection
of its modest size. However, as the 20th century approached, a noticeable economic
disparity emerged between the neighborhoods situated to the north and south of Main
Street. The southern and southwestern areas of the city experienced increasing investment
and enhancement, attracting residents of affluence who crossed the dividing line.
Consequently, northern Bozeman evolved into a working-class neighborhood.”12 Presently,
these patterns still exist. Excluding the census tracts that include and are directly adjacent
to Montana State University, tracts directly north of Main Street generally have a greater
8 BIPOC is an acronym for Black, Indigenous, and People of Color.
9 Belonging in Bozeman—Equity & Inclusion Plan, Historical Narrative, page 5
10 Ibid
11 Belonging in Bozeman—Equity & Inclusion Plan, Historical Narrative, page 6
12 Ibid
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proportion of residents of color, higher rates of poverty, and lower household median
income.
Growth and Diversity
Since 2010, the city of Bozeman has seen significant growth—adding over 16,000 residents
in the past twelve years while increasing its population by nearly half (44%). Driven by the
city’s growth, Gallatin County has also experienced a substantial increase in population,
adding just over 30,000 residents and growing by a third over the same time period.
Additionally, the state of Montana has experienced considerable population growth since
2010, albeit at a significantly lower rate than both the city and county. Stakeholders
attributed the significant growth in both Bozeman and Gallatin County to access to
recreation, relative affordability of the area compared to other high-priced areas, and an
expanding economic base, driven by Montana State University and the technology and
health care sectors.
Figure III-1.
Population
Change, 2010-2022
Source:
2010 Census and 2022 ACS 5-year
estimates, Root Policy Research.
Familial status. The majority of households in Bozeman are non-family households13
(54%), primarily due to the presence of Montana State University. Approximately one in
seven households (14%) in the city are married with children while nearly a quarter of
households (23%) are married without children. Three percent of Bozeman households are
single mothers. Conversely, families account for the majority of households in Gallatin
County and the state of Montana (56% and 61%, respectively). Married households without
children make up approximately three in ten households (29%) in Gallatin County and
nearly a third of households (32%) in the state.
13 A non-family household is a household where the householder lives alone or with people who are not related to
them, such as roommates, unrelated people living together, and single people living alone.
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Figure III-2.
Household Type by Jurisdiction, 2022
Source: 2022 ACS 5-year estimates, Root Policy Research.
Geographic concentrations. For the purposes of this section, a geographic
concentration of a demographic group is defined as a Census tract with 150 percent (or 1.5
times) of the city proportion of that group. For example, if 10% of residents in the city
overall are Hispanic but the Hispanic population of a specific Census tract is 15%, that tract
would be considered “concentrated.”
Disability. More than 5,000 individuals in Bozeman live with at least one disability—
equivalent to 10% of the total population. Disabilities are most prevalent among older
populations. As shown in Figure III-3, one in four residents between 65 and 74 years old
have a disability and more than half of individuals 75 years and older have a disability.
Figure III-3.
Disability by Age Group,
Bozeman, 2022
Source:
2022 ACS 5-year estimates, Root Policy
Research
Cognitive, ambulatory, and independent living disabilities are the most prevalent in
Bozeman (Figure III-4). In Bozeman, residents under the age of 18 are most likely to
experience cognitive difficulties while older adults are more likely to suffer from
ambulatory and hearing difficulties.
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Figure III-4.
Disability by Type,
Bozeman, 2022
Source:
2022 ACS 5-year estimates, Root Policy
Research
Figure III-5 shows the percentage of residents with a disability by Census tract in Bozeman.
Census tracts with more than 15% of residents living with a disability are considered to be
concentrated, using the definition of 1.5 times the overall proportion.
The map suggests that, overall, residents with living with disabilities are more likely to live
in the northeast quadrant of the city (east of 19th Street and north of Main Street). While
Census Tract 5.04, which is represented by the Bridger CreekLands Association of
Neighbors and includes Glen Lake Rotary Park and Bridger Creek Golf Course, has
approximately 15% of its residents living with a disability, nearly a quarter of residents
(23.5%) in Census Tract 6 live with a disability.
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Figure III-5.
Percent of Residents with at Least one Disability by Census Tract,
Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of residents with a disability (9.6%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
Race and ethnicity. Figure III-6 shows the race and ethnicity of residents in
Bozeman. The city has experienced a slow increase in its racial and ethnic diversity as it has
grown: As of 2022, non-Hispanic White residents accounted for 87% of Bozeman’s
population, compared with 92% in 2010. The largest single racial or ethnic group in the city
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are Hispanic residents, which comprise approximately 5% of the population. From 2010 to
2022, the Hispanic population increased by approximately 1,500 individuals, more than
doubling the size of this population in the city over that time period. Residents who identify
as “Other” account for 4% of Bozeman’s population. Over the last twelve years, this group
has increased by approximately 1,700 residents—a nearly three-and-a-half-fold increase
since 2010. Collectively, Hispanic residents and residents who identify as “Some Other
Race” or “Two or More Races” accounted for approximately 20% of the population growth
in Bozeman (nearly 80% of the population growth of residents of color) between 2010 and
2022.
Additionally, while both Asian (2%) and African American/Black (<1%) residents make up
small proportions of Bozeman’s population, they have experienced relatively significant
growth since 2010 (77% and 103% increases in population, respectively). American
Indian/Alaska Native residents, who account for approximately 1% of Bozeman’s
population, have seen a population increase of approximately 25% since 2010. However,
the AIAN population in Bozeman has decreased since 2015 by about 20%.
Figure III-6.
Distribution of Race and Ethnicity, Bozeman
Note: “NH” refers to non-Hispanic; “Other” includes residents who identify as “Some Other Race” or “Two or More Races”
Source: 2010 Census, 2015 and 2022 ACS 5-year Estimates, Root Policy Research.
Geographic concentration of residents of color. Figure III-7 shows the
percent of non-White and Hispanic—collectively “residents of color”—residents by Census
tract. Census tracts with more than 20% of residents of color are considered a
concentration. The one Census tract in Bozeman that meets the definition of geographic
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concentration overlaps with the Montana State University campus, which explains the
greater proportion of residents of color relative to the total tract population.
Figure III-7.
Percent Residents of Color by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of non-White and Hispanic residents (13.1%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
Figure III-8 shows the percent of Hispanic residents by Census tract in Bozeman.
Concentrations occur when Census tracts are more than 7.2% Hispanic. Three Census in
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the city of Bozeman have concentrations of Hispanic residents—one in the northeast
quadrant of the city (Census Tract 6) and two directly north of the Montana State University
campus (Census Tracts 7.03 and 9).
Figure III-8.
Percent Hispanic Residents by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of Hispanic residents (4.8%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
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Figure III-9 shows the percent of African American/Black residents by Census tract in
Bozeman. As mentioned earlier, African American/Black residents make up a very small
proportion of residents in the city. In this case, concentrations occur when just 0.9% of
residents report their race as African American/Black. There are two Census tracts in
Bozeman that have a concentration of African American/Black residents, both of which
cover the Montana State University campus. African American/Black residents represent
2.2% and 2.5% of residents in Census Tracts 11.01 and 11.02, respectively. According to
2022 5-year ACS data, 265 African American/Black residents live in these two Census tracts,
accounting for over three quarters of all African American/Black residents in Bozeman.
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Figure III-9.
Percent Black Residents by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of Black residents (0.6%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
Figure III-10 shows the percent of Asian residents in Bozeman. Similar to other non-White
Hispanic populations, Asian residents make up a relatively small proportion of residents
overall (2.3%). Census tracts with 3.5% and more Asian residents are considered
concentrated. There are three Census tracts in the city with a concentration of Asian
residents—all located south of Main Street. Census Tract 11.01, located on the Montana
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 14
State University campus, has the greatest proportion of Asian residents in the city (6.9%),
followed by Census Tract 10.02 (4.5%) and Census Tract 9 (4.3%), which are directly east
and north of campus, respectively.
Figure III-10.
Percent Asian Residents by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of Asian residents (2.3%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
Figure III-11 shows the percent of American Indian/Alaska Native residents by Census tract
in Bozeman. Census tracts with more than 1.4% of Native American residents are
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considered a concentration. There are 3 such tracts in Bozeman. Census Tract 7.04,
bounded by N Ferguson Avenue to the west, W Babcock Street to the south, Farmer’s Canal
to the east, and Durston Road to the north, has the greatest concentration of AIAN
residents in the city (3.9% of the total tract population). Other census tracts with
concentrations of AIAN residents include Census Tract 6 (3%) and Census Tract 7.01 (1.6%).
Figure III-11.
Percent Native American Residents by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of Native American residents (0.9%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
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Figure III-12 shows the percentage of residents who identify as Some Other Race or Two or
More Races combined (“Other Race”) by Census tract in Bozeman. Census tracts that have
at least 6.8% of Other Race residents are considered concentrated. Just one tract—Census
Tract 5.04 (7.3%)—meets this threshold.
Figure III-12.
Percent Other Race Residents by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of residents who identify as Some Other Race or Two or
More Races combined (0.9%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
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National origin and limited English proficiency (LEP). Nearly 5% of
Bozeman residents—about 2,500—were born outside of the United States. Of these, 47%
are naturalized citizens. Nearly half of foreign-born residents in the city were born in Asia
(46%), followed by Europe (27%) and Latin America (15%). The country of origin accounting
for the most foreign born residents is China, accounting for over 300 residents. This is
followed by Canada (149) and Mexico (131).
Figure III-13 shows the percentage of foreign-born residents by Census tract.
Concentrations occur in Census tracts with more than 6.9% foreign-born residents. Census
Tract 11.01 (9.2%) and Census Tract 9 (7.6%), both of which are located on or directly
adjacent to the Montana State University campus, are the only tracts with concentrations
of foreign-born residents in the city.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 18
Figure III-13.
Percent Foreign Born Residents by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of foreign-born residents (4.6%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
As shown in Figure II-14, 5% of Bozeman’s population over the age of five speaks a
language other than English at home. Overall, just 1% of the population is limited English
proficiency, or LEP, persons—i.e., they speak English less than “very well” according to the
Census LEP—with Asian and Pacific Island languages representing the most common
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 19
languages among LEP residents. Spanish is the second most common language among
Bozeman’s LEP population.
Figure III-14.
Percent of Residents by Language and Proficiency, 2022
Note: Population numbers refer to the population 5 years and over.
Source: 2022 ACS 5-year estimates.
Figure III-15 shows the percentage of LEP residents by Census tract in the city. While there
are no concentrations of LEP populations in Bozeman, LEP residents are more likely to live
near Montana State University (Census Tract 11.01) or in the northeast quadrant of the city
(Census Tract 5.04).
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION III, PAGE 20
Figure III-15.
Percent Limited English Proficiency (LEP) Residents by Census Tract,
Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of LEP residents (1.9%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
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Income and Poverty
In Bozeman, the median household income has increased by 76% between 2010 and 2022
(Figure III-16). Gallatin County and the state also experienced significant increases in
median household income over the same time period (66% and 51%, respectively).
Although the city of Bozeman is the economic driver in Gallatin County, the median
household income still lags behind the county by over $9,000. This is likely due to the
presence of the large college student population in Bozeman.
Figure III-16.
Median Household
Income, 2010 and 2022
Source:
2010 and 2022 ACS 5-year estimates.
In 2022, the proportion of Bozeman residents living below the poverty level was 14.7%, a
decrease of approximately 5 percentage points from 2012 (Figure III-17). The city of
Bozeman has had a higher poverty rate over the last ten years compared to both Gallatin
County and the state of Montana; however, the city’s poverty rate has decreased at nearly
double the rate of Gallatin County and more than double the rate of the state over the
same time period.
Figure III-17.
Poverty Rates and
Change, 2012 and 2022
Source:
2012 and 2022 ACS 5-year estimates.
Figure III-18 shows the percentage of residents living in poverty by Census tract in
Bozeman. There are four Census tracts in Bozeman considered to have a concentration of
poverty, which is more than 22.1% of tract residents living in poverty. While the Census
tracts that overlap and are adjacent to Montana State University suggest concentrations of
poverty, it is likely that students, even though most are not employed, are being financially
supported through other means (e.g., parents). However, one in four residents in Census
Tract 6, which is located in the northeast quadrant of the city, are living in poverty.
Bozeman 19.9%14.7%-5.2%
Gallatin County 13.3%10.6%-2.7%
State of Montana 14.8%12.4%-2.4%
2012 2022
Percent
Change
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Figure III-18.
Individual Poverty Rate by Census Tract, Bozeman, 2022
Note: Breaks represent 50%, 100%, and 150% of the citywide proportion of individual residents living in poverty (14.7%)
Source: 2022 ACS 5-year estimates and Root Policy Research.
Census tracts with median household incomes greater than the citywide median are
primarily located along the western, northern, and southern boundaries of the city (Figure
III-19). Census Tract 11.01 ($42,435), Census Tract 6 ($44,762), and Census Tract 9 ($53,183)
have the lowest median household income in Bozeman.
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Aside from the Census tracts that overlap with Montana State University, which would be
expected to have lower household incomes due to the large student population, Census
Tract 6 is the only tract in Bozeman with a median household income that is 75% less of the
city’s median household income. Moreover, nearly 60% of the residents in this tract have
income less than $50,000 compared to just 33% citywide.
Figure III-19.
Median Household Income by Census Tract, Bozeman, 2022
Note: Median household income for the city of Bozeman is $74,113.
Source: 2022 ACS 5-year estimates and Root Policy Research.
Figure III-20 presents the poverty rate and median household income by race and ethnicity.
Asian and American Indian/Alaska Native residents have lower median income than the city
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overall, while residents who identify as some other race and Hispanic have the highest
household median income. Three in ten Black/African American residents experience
poverty in Bozeman, which is double the rate of poverty experienced by non-Hispanic
White residents.
Of note, even with one of the lower median household income amounts among racial and
ethnic groups, the data show a low poverty rate for American Indian/Alaska Native
residents, which is unexpected. While 2021 and 2022 five-year ACS estimates show a
significantly low poverty rate (2% and 3%, respectively) for AIAN residents, poverty rates
between 2018 and 2020 fall between 20-30%, which is more expected based on household
income. This significant difference might be due to pandemic-related or other government
assistance received by these households during COVID-19; however, more information is
needed to explain the discrepancy.
Figure III-20.
Individual Poverty Rate and
Household Median Income by
Race and Ethnicity, Bozeman,
2022
Source:
2022 ACS 5-year estimates.
Figure III-21 below shows the poverty rate for additional demographic groups.
Demographic groups with a poverty rate that is higher than the individual poverty rate
(15%) are highlighted with red. Black/African American residents, Hispanic residents,
residents who identify as some other race, and single mothers have the highest rates of
poverty in Bozeman. Married households, married households with children, AIAN
residents, and families have the lowest rates of poverty.
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Figure III-21.
Poverty Rate by Familial
Status, Disability Status,
and Race/Ethnicity,
Bozeman, 2022
Source:
2022 ACS 5-year estimates, Root Policy
Research
In every community, there are residents who, for a variety of reasons (debilitating diseases,
and elderly residents living with people who are elderly with ailments) cannot generate
household income through employment, are not capable of being gainfully employed.
These residents generally require long-term public assistance. Income assistance—in the
form of Old Age Pension (OAP), Aid to Needy Disabled (AND), Supplemental Security
Income (SSI), Social Security Disability Income (SSDI), Veterans Affairs (VA) benefits,
Medicare or Medicaid, food stamps, and a “preference” for existing public housing and
Section 8 vouchers—are the most realistic strategies for maintaining household income
and limiting the effects of extreme poverty in these situations.
Additionally, different circumstances leading to poverty demand different approaches.
Situational poverty, usually due to job loss, significant illness, or other life-changing events,
can usually be addressed through temporary safety nets (e.g., rent or mortgage assistance,
shelter, childcare subsidies) and access to programs to help a household regain self-
sufficiency.
Generational poverty, usually defined as poverty lasting two generations or longer, is more
difficult to address. Families experiencing generational poverty require broader and long-
term, sustainable supportive services.
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Racial and ethnic segregation. This section briefly touches on racial and ethnic
segregation in Bozeman. A common measure of segregation used is the dissimilarity index
(DI).
The DI measures the degree to which two distinct groups are evenly distributed across a
geographic area, usually a county. DI values range from 0 to 100—where 0 is perfect
integration and 100 is complete segregation.
A “score” between 0 and 39 indicates low segregation, values between 40 and 54 indicate
moderate segregation, and values between 55 and 100 indicate high levels of segregation.
The DI represents the percentage of a group’s population that would have to move for
each area in the county/city to have the same percentage of that group as the county/city
overall.
Using 2022 5-year ACS data, the city of Bozeman’s DI score for residents of color is 23—
indicating a low level of segregation. However, the DI can give too low or too high
segregation scores to communities with very low numbers of residents of color due to high
measurement error, which is the case for the city.
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs). HUD
has developed a framework to examine economic opportunity at the neighborhood level,
with a focus on racial and ethnic minorities. That focus is related to the history of racial and
ethnic segregation, which, as discussed in the beginning of this section, often limited
economic opportunity.
“Racially or ethnically concentrated areas of poverty,” also known as R/ECAPs, are
neighborhoods in which there are both racial concentrations and high poverty rates.
HUD’s definition of an R/ECAP is:
A Census tract that has a non-white population of 50 percent or more (majority-
minority), or for non-urban areas (those outside of “core based statistical areas”), 20
percent, and
A Census tract where the poverty rate is at least either 40 percent or three times the
average tract poverty rate for the metropolitan area, whichever is lower.
As noted above, due to the city’s large non-Hispanic White population, there are no
“majority-minority” Census tracts in Bozeman and as a result, there are no Census Tracts
designated as R/ECAPs in the city. However, Census Tract 6, located in the northeast
quadrant of the city, has a concentration of residents living with disabilities, as well as
Hispanic and Indigenous residents. This tract also has one of the lowest median household
incomes ($44,762) and the highest rates of poverty in the city (23.5%).
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IV. ACCESS TO OPPORTUNITY
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SECTION IV.
Access to Opportunity
This section examines Access to Opportunity in education, employment, and
transportation—the opportunity areas identified by stakeholders and residents as being
the most challenging in the city of Bozeman. The analysis focuses on disparities in access to
opportunity for persons living in poverty and protected classes. This section draws from
independent research conducted to support the Fair Housing Plan and findings from the
community engagement process.
Primary Findings
Analysis in this section points to gaps in access to opportunity in:
Education. Non-Hispanic White students have substantially higher proficiency rates
than all other student groups by race and income within Bozeman schools. Indigenous
students have lower proficiency rates and high school graduation rates in Bozeman
compared to other students by race and ethnicity. Hispanic students in Bozeman also
have low graduation rates. Respondents living in households of color were much more
likely to report dissatisfaction with their child(ren)’s education than non-Hispanic White
respondents in the housing and community needs survey.
Employment outcomes. Between 2010 and 2022, the unemployment rate
decreased for non-Hispanic White and Hispanic residents, as well as residents who
identify as two or more races. Conversely, Indigenous workers saw a nine-percentage
point increase in unemployment over the same time period. While approximately four
in ten Bozeman residents have a college degree, nearly half of Indigenous residents
are college educated. Black residents have the lowest proportion of residents with a
college degree in Bozeman. Over a third of survey respondents (35%) identified an
increase in wages as needed to improve their job satisfaction.
Broadband access. While 97% of households with income above $75,000 have
an internet subscription, only 71% of households earning below $20,000 have an
internet subscription. For low-income households, lack of internet access may limit
their ability to access employment opportunities and community resources. Seven
percent of survey respondents indicated that increased access to broadband/internet
was a significant community need in Bozeman.
Access to transportation. According to the housing and community needs
survey, 25% of respondents are unsatisfied with their current transportation options.
Of these respondents, most wanted to see increased frequency, reliability, and
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coverage of the city’s bus system, as well as expanded connective networks for
alternative transportation options (e.g., biking and walking). Additionally, through
stakeholder conversations and focus groups conducted to support this study, as well
as findings from previous city efforts, several barriers exist for residents living with
disabilities to easily access the transportation system. Inaccessible buses, infrequent
fixed-route service, limited paratransit services, and other current city infrastructure
(e.g., sidewalks, parking spaces) make it challenging for residents to utilize these
services and spaces to their full advantage.
Healthy communities. Survey respondents identified a variety of outcomes
they wanted to see to improve their neighborhoods and health, including street and
sidewalk improvements, parks and recreation facility improvements,
new/improvements to existing community centers, more recreation opportunities,
making it easier to exercise, and better access to healthier foods. Census Tract 11.02,
which covers Montana State University and the southwest area of the city, was
identified as having limited food access.
Figure IV-1 shows the median household income by Census Tract in the city of Bozeman.
Census tracts with median household incomes greater than the citywide median are
primarily located along the western, northern, and southern boundaries of the city (Figure
III-19). Census Tract 11.01 ($42,435), Census Tract 6 ($44,762), and Census Tract 9 ($53,183)
have the lowest median household income in Bozeman. Aside from the Census tracts that
overlap with Montana State University, which would be expected to have lower household
incomes due to the large student population, Census Tract 6 is the only tract in Bozeman
with a median household income that is 75% less of the city’s median household income.
Moreover, nearly 60% of the residents in this tract have income less than $50,000
compared to just 33% citywide.
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Figure IV-1.
Median Household Income by Census Tract, City of Bozeman, 2022.
Note: Median household income for the city of Bozeman is $74,113.
Source: 2022 ACS 5-year estimates and Root Policy Research.
Access to Quality Education
Publicly supported education and training are key building blocks for a well-functioning
economy. Research published by the Education Law Center shows that education not only
results in billions of dollars of social and economic benefits but an educated population
leads to gainful employment, stable families, and productive residents who are less likely to
commit crimes, place a high demand on the public health care system, and enroll in
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welfare assistance programs.1 Public schools have also played an important part in closing
the gap between wealthy and poor students on academic outcomes typically defined by
standardized tests, which helps reduce income inequality.2 Additionally, well-resourced and
highly performing neighborhood schools are integral to community development and can
provide a catalyst for improved neighborhood environments.3
Disparities in access to K-12 schools. School District 7 provides K-12 public
education within Bozeman and surrounding areas. Within the city of Bozeman, there are
eight elementary schools, two middle schools and two high schools. Figure IV-2 shows total
enrollment and distribution by race and ethnicity, income, and housing status for the 12
schools in Bozeman. The schools with the largest share of Indigenous students are Irving
Elementary and Sacajawea Middle School, while the greatest proportion of Hispanic/Latino
students attend Hyalite Elementary, Irving Elementary, and Whittier Elementary. Schools
with the highest number of economically disadvantaged students (defined by free and
reduced lunch eligibility) are Irving and Whittier elementary schools—both accounting for
nearly half of their respective student populations. Sacajawea Middle School (25%) and
Gallatin High School (19%) have the highest percentage of economically disadvantaged
students of the upper schools.
All of the schools identified in the previous paragraph are located in Census tracts with
median household incomes that are below the city median, with the exception of Whittier
Elementary School. However, Whittier is directly adjacent to the southern boundary of
Census Tract 6, which has one of the lowest median household incomes in the city.
Children eligible for free and reduced lunch (FRL) are an economic indicator of risk that is
used by educational departments to identify at-risk youth and target educational reform
programs as academic achievement gaps are often greatest between students from
different income brackets. Similar to the federal poverty threshold, the FRL threshold is
fixed and does not vary by state or jurisdiction. Currently, children are eligible to receive
free lunches if their families earn less than 130% of the federal poverty threshold, and
reduced lunch prices if earning between 130 and 185% of the poverty threshold.4 This
1 Dana Mitra, ‘Pennsylvania’s Best Investment: The Social and Economic Benefits of Public Education,’ Education Law
Center (June 2008), https://www.elc-pa.org/wp-content/uploads/2011/06/BestInvestment_Full_Report_6.27.11.pdf.
2 Alexander, K., Public Education and the Public Good. 1997, Social Forces. 76(1): p. 1-30.
3 Moore, Sandra M. and Susan K. Glassman. ‘The Neighborhood and Its School in Community Revitalization: Tools for
Developers of Mixed-Income Housing Communities’. Housing and Urban Development. 2007.
4 govinfo.gov/content/pkg/FR-2019-03-20/pdf/2019-05183.pdf
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 5
translates into income levels of roughly $39,000 or less for free lunch eligibility, and
$39,000 to $54,000 for reduced lunch eligibility, both for a family of four.5
One significant barrier to closing the academic gaps between students by race and income
is school composition (high versus low poverty, racially segregated), which is a reflection of
neighborhood composition and school financing. Schools with high concentrations of
economically disadvantaged students and/or with high concentrations of one racial group
impact students negatively across student groups.6 High poverty schools typically have
fewer resources to spread across greater student needs and therefore struggle to progress
students to proficiency. Symptoms of resource-challenged schools include significant
achievement gaps between groups by race and income, high student-to-teacher ratios, and
high student-to-counselor ratios, which have been shown to impact chronic absenteeism—
often a result of housing and home instability.7
5 Paul Tough, in his book “How Children Succeed,” argues that FRL is a weak measure of children in need because of the
wide eligibility income range, an argument that could be applied to many definitions of low income and socioeconomic
status. Children living in families earning $10,000, for example, likely have much greater needs and potentially higher
risks of academic failure than those living in households at the higher end of the threshold ($44,000). These higher risk
factors, according to Tough, include no adult in the household who is consistently employed, mental health, substance
abuse in the household, and potential child abuse and neglect.
Tough further argues that children living in high poverty households also have psychological challenges, many related
to poor parenting, that make the learning environment very challenging. The experience of stress and trauma as a child
can lead to poor executive functioning, difficulty handling stressful situations, poor concentration, difficulty following
directions, and social impairment. These children, therefore, require different interventions and reforms than those at
the “middle class” end of the FRL spectrum.
6 Wells, A. S., Fox, L., & Cordova-Cobo, D. How racially diverse schools and classrooms can benefit all students. The
Education Digest, 82(1), 17. 2016
7 Parzych, Jennifer L., Ph.D., Peg Donohue, Ph.D., Amy Gaesser, Ph.D., and Ming Ming Chiu, Ph.D. ‘Measuring the
Impact of School Counselor Ratios on Student Outcomes”. American Association of School Counselors. February 2019
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 6
Figure IV-2.
Total Enrollment by School District and Race/Ethnicity, Economic Status, 2023-2024.
Note: K-12 Enrollment.
Source: ESSA School Report Card, Montana Office of Public Instruction
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 7
Educational gaps. Providing access to high quality schools—as well as programming
within schools to prepare students for moderate- and high-paying jobs—are key aspects of
improving education outcomes of low-income children.
Figures IV-3 and IV-4 show the percentage of students in School District 7’s K-8 District by
race and income who met or exceeded Montana’s Smarter Balanced Assessment score
expectations for English and math compared to students in Billings, Missoula, and
statewide. Specifically:
Non-Hispanic White students in Bozeman have the highest level of English and Math
proficiency among other students in Bozeman, as well as other peer districts and the
state of Montana.
Indigenous students across all geographies have low proficiency rates.
Hispanic students in Bozeman have similar English proficiency rates as Hispanic
students in Missoula and a slightly higher rate compared with Hispanic students
statewide. Math proficiency rates are similar across all geographies.
Similarly, economically disadvantaged and SPED students have similar English
proficiency rates as economically disadvantaged and SPED students in Missoula and
higher rates than other peer communities; math proficiency rates in Bozeman for
these student groups are higher than peer communities, too.
Figure IV-3.
Proficiency Rates for English by Race and Ethnicity, Elementary Districts in
Montana, 2022-2023
Note: “FRL” means students who are eligible for free and reduced lunch and “SPED” means special education.
Source: Montana Office of Public Education and Root Policy Research.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 8
Figure IV-4.
Proficiency Rates for Math by Race and Ethnicity, Elementary Districts in
Montana, 2022-2023
Note: Insufficient population of Indigenous students in Bozeman to provide Math proficiency rate. “FRL” means students who are
eligible for free and reduced lunch.
Source: Montana Office of Public Education and Root Policy Research.
A measure of school proficiency that captures student base knowledge and progress over
time are growth rates. The Montana Office of Public Education provides data on
elementary and middle school students progressing towards proficiency for both reading
and math (Figure IV-5). Capturing progress towards proficiency is particularly important in
schools with a higher proportion of students who are economically disadvantaged or who
have additional learning needs, such as English Language Learners and Special Education.
In particular, Morning Star K-5 and Longfellow K-5 stand out with very high progress
towards proficiency rates in English and math. Additionally, Emily Dickinson K-5 has a high
progress toward proficiency rate for English while Hawthorne K-5 has a high progress
toward proficiency rate for Math. Hyalite K-5 and Whittier K-5 have the lowest progress
toward proficiency rates for both reading and math.
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Figure IV-5.
K-8 Students
Showing
Progress
Towards
Proficiency in
Reading and
Math, 2022-2023.
Source:
Montana Office of Public
Instruction.
Figure IV-6 shows the collective four-year high school graduation rate for both Bozeman
High and Gallatin High, as well as the Missoula High School District, Billings High School
District, Great Falls High School District and the state of Montana, disaggregated by race,
ethnicity, housing, economic, English language learner, and special education status.
Among peer districts, high school students in Bozeman had the greatest proportion of high
school graduates during the 2022-23 academic school year (90%).
However, disparities in graduation rates are apparent across race and ethnicity in Bozeman
high schools. Indigenous students (60%) and Hispanic/Latino students (64%) have the
lowest graduation rates while Asian students (100%) and non-Hispanic White students
(92%) have the highest graduation rates. This also holds true when compared to other high
schools across the state – non-Hispanic White students in Bozeman have the highest
graduate rates among their non-Hispanic White counterparts in other high schools while
Indigenous and Hispanic/Latino students in Bozeman have the lowest graduation rates
among their respective counterparts throughout the state.
Among other student populations, 76% of SPED students in Bozeman graduated during the
2022-23 academic school year – the highest among peer comparison high schools in the
state. Conversely, second-language learners (57%), economically disadvantaged (67%), and
precariously housed (60%) students in Bozeman had the lowest graduation rates among
their respective counterparts in other high schools across the state.
Additional staff and resources are greatly needed to improve school proficiency and
graduation rates for second-language learners and economically disadvantaged students
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in Bozeman. A recent article8 from The Nation articulated that “the [Bozeman] public-
school system...is scrambling to support the influx of multilingual children. The number of
students who receive additional English-language instruction in Bozeman’s public schools
has doubled in just a few years to around 350, and there are at least as many recently
arrived Latino students who are not enrolled in those programs.”
8 https://www.thenation.com/article/society/bozeman-montana-undocumented-labor/
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Figure IV-6.
High School Graduation Rates by School, School District, Race/Ethnicity and Student Subgroups, 2022-2023
Note: Four-year graduation rates, An asterisk ( * ) indicates this number has been suppressed for student privacy and security reasons.
Source: Montana Office of Public Education.
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The Montana Office of Public Education also provides data on college preparedness for
recent graduates and the percentage of graduates enrolled in any Montana public college
within 3 months of graduating. Figure IV-7 compares the collective rate across the two
Bozeman high schools, along with rates for the Missoula High School District, Billings High
School District, Great Falls High School District, and the state of Montana for peer
comparison purposes. While the high schools in Bozeman have the highest rate of
students prepared for college, only about a third of graduates are likely to actually attend
college within 3 months of graduation, which is similar to other high school districts across
the state.
Figure IV-7.
College Ready and Enrollment, 2022.
Note: The Bozeman High School District consists of both Bozeman High School and Gallatin High School.
Source: Montana Office of Public Instruction.
The housing and community needs survey asked respondents to share what they felt they
needed to improve their child(ren)’s education. While over 40% of respondents indicated
they did not have children, the next greatest proportion of respondents reported they were
satisfied with their children’s education (11%). The greatest proportion of respondents
reported the following improvements they wanted to see:
Other (9%);
Stop bullying/crime/drug use at school (8%);
Have better teachers at their school (6%);
Make school more challenging (6%); and
Have more activities after school (6%).
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The most common response for “Other” provided by respondents was to increase teacher
salaries. A sample of other responses is provided below.
“We need accessible and affordable Pre-K childcare.”
“After school programs that are affordable for parents that work late.”
“More support for the PEAKS program.”
“Way more support for school faculty – better pay, more faculty, lighter workloads ,
and more mental health support.”
Additionally, findings by demographic characteristics and other household types found:
Homeowners (19%) are much more likely to be satisfied with their child(ren)’s
education compared to precariously housed residents (7%) and renters (6%).
Precariously housed respondents (11%) were also twice as likely to report wanting to
make it easier to choose a different school than owners (5%) and renters (4%).
By race/ethnicity, non-Hispanic White respondents (15%) were more likely to be
satisfied with their children’s education that other respondents by race/ethnicity.
While the sample size is small for Hispanic (n=18), American Indian/Alaska Native
(n=13) and African American/Black respondents (n=10), these respondents reported
they were not satisfied with their children’s education (11% of Hispanic residents, 0%
for both AIAN and African American/Black respondents, respectively).
Respondents making more than $150,000 or more (28%) were nearly six times as likely
to report being satisfied with their children’s education compared with respondents
making less than $25,000 (5%).
Just under a quarter of respondents living in large households (23%) are satisfied with
their children’s education, followed by single parents (17%) and households with
children (15%). Households with a member living with a disability were the least likely
to report satisfaction with their children’s education (6%).
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Access to Employment
Figure IV-8 shows growth of jobs by industry in Gallatin Bozeman from 2012 to 2022.
Industries with the most significant gains are construction, financial services, professional
and business services, and manufacturing. The largest industries are education and health
services, driven primarily by Montana State University. Construction gains are notable—
according to ACS data, approximately 6,600 housing units have been built in Bozeman over
this time period. This accounts for approximately 28% of Bozeman’s total housing stock.
The construction sector is likely to keep on this current trajectory. As of May 2024, not
including new market rate housing, the city has 387 community housing units under
construction, approved plans for 607 community housing units, and 1,612 community
housing units in the pipeline.
Bozeman and Gallatin County have one of the strongest economies in the state of
Montana, driven by its tourism and high-tech industries. According to Policom,9 an
independent economics research firm, Bozeman has had the strongest economy of
micropolitan areas in the country for the last five years. As of April 2024, Gallatin County’s
unemployment rate sits at 2%.
Figure IV-8.
Number of
Employees by
Sector, Gallatin
County, 2012-2022
Note:
The number of employees listed
reflect private jobs, with the
exception of Public Administration
and Education and Health Services.
For Education and Health Services,
aggregation includes federal, local,
and private employees. State
employees are not included
because data from 2012 does not
meet BLS disclosure standards.
However, there are 4,124
employees in state government in
the Education and Health services
sector, for a total of 14,033
employees in this sector in 2022.
Source:
Bureau of Labor Statistics.
9 https://policom.com/rankings-micropolitan-areas/
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Figure IV-9 shows the average annual pay by sector and percent change since 2012.
Information, financial services, and leisure and hospitality sectors experienced significant
wage growth in Gallatin County. Wage growth in leisure and hospitality is critical given that
the industry has very low wages and is often seasonal.
Figure IV-9.
Average Annual Pay
by Sector, Gallatin
County 2012-2022
Note:
Annual pay listed in the table
reflects earnings from private jobs
only, unless otherwise noted.
Source:
Bureau of Labor Statistics.
Despite the growth in employment and wages, data on educational attainment suggest
that White workers—who have the highest rates of college graduation—are more likely to
benefit from economic growth while Indigenous, Hispanic/Latino, and Black workers will
suffer more from economic declines (Figure IV-10). However, Indigenous workers in
Bozeman are more than three times as likely to have a college degree compared to
Indigenous residents at the state level while Hispanic/Latino workers are nearly twice as
likely. Black workers with a college degree have similar rates at both the city and state level.
Figure IV-10.
Share of Population with a College Degree, by Race, Ethnicity and
Jurisdiction, 2022
Note: Share of population 25 years and over.
Source: 2022 ACS 5-year estimates.
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Academic gaps translate to employment and wage gaps. The Montana Office of Public
Instruction oversees adult learner programs statewide that receive federal grant funding
under the Adult Education and Family Literacy Act (AEFLA), Title II of the Workforce
Innovation and Opportunity Act (WIOA for alternative high school diploma or GED and
workforce development).10 These programs are free to qualifying individuals and include
English language learning and citizenship examination preparation allowing residents to
improve career outcomes through postsecondary diploma recovery and job training.
Figure IV-11 shows the unemployment rate by race and ethnicity in Bozeman between
2012 and 2022. Over this time period, the unemployment rate decreased for non-Hispanic
White and Hispanic residents, as well as residents who identify as two or more races.
However, the unemployment rate for Indigenous residents increased by nine percentage
points.
Figure IV-11.
Unemployment rate
by Race and
Ethnicity, City of
Bozeman, 2012 and
2022.
Note:
The unemployment rate for
Black/African American residents is
not included due to a high margin of
error.
Source:
2012 and 2022 ACS 5-year
estimates.
Commuting. Figure IV-12 below shows the distribution of Bozeman’s workforce by
commuting status. The workforce is comprised of all workers who live and/or work in the
city of Bozeman. Nearly half of Bozeman’s workforce is comprised of in-commuters (45%),
while nearly a quarter of workers live in Bozeman but commute outside of the city (23%).
10 https://opi.mt.gov/Families-Students/Student-Resources/Veterans-Adult-Education
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 17
Figure IV-12.
Workforce
Commuting
Patterns 2022,
Bozeman.
Note:
Workforce is comprised of all
workers who live and/or work in
Bozeman.
Source:
Longitudinal Employer-Household
Dynamics (LEHD).
Survey respondents were asked to identify what they needed to improve their current job
situation. While 30% of respondents indicated they were satisfied with their current job:
35% of respondents reported a need for increased wages;
9% of respondents reported a need for improved public transportation to get to and
from their job; and
8% of respondents reported a need for more access to consistent childcare.
Other needs and comments articulated by survey respondents included:
“Cost of living that aligns with pay.”
“College graduate working FT for health department, barely enough to live (with 3
roommates).”
“Employers cannot keep up with the high cost of living and are cutting good jobs.”
“I love my job. i just need it to pay me a livable wage.”
“This shouldn’t be a two-income town in order to survive.”
Additionally, findings by demographic characteristics and other household types found:
Renters (57%) were more than twice as likely than homeowners (24%) to select
“increase wages” as what was needed to improve their current job situation. Forty-one
percent of precariously housed residents also selected “increase wages.”
By race and ethnicity, 69% of American Indian/Alaska Native respondents and 67% of
Hispanic respondents identified “increase wages” as what was needed to improve their
current job situation. Non-Hispanic White respondents were most likely to be satisfied
their job situation.
Approximately 4 in 10 American Indian/Alaska Native survey respondents identified
“Case manager/coach to help me find the right the job” as what was needed to
improve their current job situation.
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Respondents with income less than $25,000 (63%) and respondents with income
between $25,000 and $50,000 (55%) were more likely to identify “increased wages” as
needed to improve their job situation. Conversely, respondents with income greater
than $150,000 (59%) were more likely than other respondents to be satisfied with their
job situation.
Unemployed respondents (29%) were more than twice as likely than respondents
employed full-time (14%) to identify “access to consistent childcare” as what was
needed to improve their job situation.
Respondents living with a disability (38%), respondents living in a large household
(33%), and single parents (29%) were more likely to identify “increased wages” as
needed to improve their job situation.
Broadband access. Access to broadband has increasingly become a necessity versus
a luxury. However, according to the Federal Communications Commission (FCC), in 2017,
34 million Americans still lacked broadband Internet access (defined as a minimum of a 25
Mbps connection). In particular, remote or rural areas have lower rates of stable and fast
internet access, which is critical for individual connectivity to jobs and education but also
for community economic development. Figure IV-13 shows that ownership of a device
(desktop/laptop, smartphone, tablet) is higher in Bozeman and Gallatin County compared
to the state.
Although subscription rates are high, and areas like Bozeman and Gallatin County have
more reliable internet access, connectivity speed remains an issue for a large number of
households in Montana. Montana ranked 49th in Ookla’s speedtest, only ahead of Wyoming
and Alaska. In 2023, Montana received $628 million from the federal Broadband Equity and
Access Deployment (BEAD) program and invested $309 million of COVID relief funds in 62
broadband infrastructure projects throughout the state. An estimated 18% of Montana
residents are either unserved or underserved, mostly in rural communities.11
In Bozeman, 8% of residents do not have access to the internet. Residents making less than
$20,000 are most likely to not have access to the internet, with only 71% of these
households holding internet subscriptions. Conversely, 97% of residents making over
$75,000 have access to the internet. In the housing and community needs survey, 7% of
respondents identified increased access to internet/broadband as a significant community
need.
11 https://connectmt.mt.gov/IIJA/2023.06.04_BEAD-Five-Year-Action-Plan_vSHARE.pdf
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Figure IV-13.
Device Accessibility
and Broadband
Subscription, 2022.
Source:
American Community Survey 2022
5-year estimates.
Transportation Access
The housing and community needs survey asked Bozeman residents and stakeholders
about which type of transportation they take most often, as well as if they are satisfied with
their current transportation options.
Nearly 70% of survey respondents indicated that they primarily drive their personal
vehicles, followed by walking (37%) and using a bicycle or scooter (27%). Only 7% of
respondents reported that they take public transit or use the bus system. Additionally,
three quarters of respondents were either “mostly satisfied” or “entirely satisfied” with their
current transportation options. Twenty percent of respondents were “somewhat
unsatisfied” and 5% were “not at all satisfied.”
For respondents who were somewhat unsatisfied or not at all satisfied with their current
transportation options, the most common responses to address their concerns included
better bicycle lanes and routes, better public transportation options, and better overall
walkability in the city. A sample of responses are provided below:
“A good bike trail system that accommodates all ages and skill levels. It also needs to
be safe. We also need better bike education for both riders and non-riders.”
“Add more regular bus stops and diversify bus routes.”
“Better bike lanes on the NW end of town. Too many hot streets in the summer…more
trees are needed. More trails to keep bikes in safer spaces and off roadways.”
“Clear sidewalks better during the winter to make walking/biking more possible.”
“More varied Streamline hours.”
“Strengthen traffic management efforts.”
Additionally, transportation needs and challenges were also identified during stakeholder
consultations and focus groups with residents for the development of this Plan. In general,
residents wanted to see the transportation system in Bozeman expand outside of city
boundaries. Some residents shared that they currently live just outside the city and cannot
get to and from their homes via public transportation. Several residents shared that
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rideshare options are really expensive. One resident shared that they have walked from
Walmart to their current living situation, which is 8 miles roundtrip.
Residents living with disabilities indicated that it is difficult to use the paratransit services
available in Bozeman, noting that demand far outweighs the capacity of the system. One
resident noted that because they are unable to take the fixed route bus system that serves
Bozeman, they rely on solely on paratransit to get around. They noted that for someone
who relies on paratransit and is trying to look for employment, they’re not going to be
successful because the service is too unreliable (in terms of timing and availability).
Other residents expressed a desire to see more reliable public transportation service in
Bozeman. One resident noted that they routinely borrow a car from a friend to pick up
their children from childcare; if they had to rely on the bus and are late picking up their
children, “they charge you and I don’t have any extra money to spend in that way.” Another
resident said, “I wish the buses went more places…right now, it’s not even worth waiting for
the bus.”
Another resident expressed a desire to see emergency transportation options available for
low-income communities. They noted that as a new parent, “I’m terrified about something
happening to my child and feeling like I can’t call 911 because of how much it will cost.”
One resident shared that they like that Streamline has provided more bus stops around
town. He also noted that he likes the pink line, which goes between Belgrade and
Bozeman. He added “if we had [a bus line] going between Bozeman and Livingston, that
would be great.”
Other transportation-related challenges were gathered during the community engagement
process for the City of Bozeman’s Belonging in Bozeman Equity & Inclusion Plan. Some of
those challenges are detailed below.
One Community Liaison articulated that they heard several stories from Hispanic and
Latino immigrants who have experienced difficulties meeting their transportation and
community safety needs in Bozeman.
Several barriers to transportation access currently exist for residents living with
disabilities. A sample of the feedback gathered is highlighted below.
➢ “Bus stops are not set up for wheelchair accessibility.”
➢ Fixed-route drivers need more training on how to support people with
disabilities, especially for wheelchair users.
➢ There are seasonal barriers impacting access to transportation for residents
with disabilities, with one resident sharing that “the number one issue with
transit is snow removal.”
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➢ “Paratransit issues are a barrier to community access for a number of
qualified riders.”
➢ Improve enforcement of accessible parking spaces and improve standards
for accessible parking requirements.
Healthy Communities
Indicators of a healthy neighborhood include the relative quality of public infrastructure,
community, parks and recreation facilities, convenient access to grocery stores and
healthcare facilities, and access to healthy food. Below is a summary of feedback related to
these indicators.
Neighborhood improvements. When asked to identify what is needed to
improve their neighborhoods, a quarter of respondents were satisfied with the current
state of their neighborhood. However:
16% of survey respondents wanted to see the construction of new sidewalks and/or
improvement of current sidewalks in their neighborhood;
13% of survey respondents wanted better street lighting in their neighborhood;
An additional 13% of survey respondents wanted more stores to meet their needs
(e.g., grocer, pharmacy);
11% of survey respondents wanted to see reduced crime in their neighborhood;
9% of survey respondents wanted to see empty buildings and/or lots cleaned up in
their neighborhoods; and
7% of survey respondents wanted to see parks and outdoor spaces in their
neighborhood made more accessible for residents living with disabilities.
Other specific neighborhood improvements identified by survey respondents included:
“Add crosswalk lights at busy crossings.”
“Clean up street and construction debris.”
“Designated bike lanes, bike paths that link to services.”
“Have a greater diversity of businesses within walking distance of all
neighborhoods.”
Additionally, findings by demographic characteristics and other household types found:
Homeowners (33%) were more three times as likely than precariously housed
respondents (11%) and one-and-a-half times more likely than renters (22%) to be
satisfied with their current neighborhood.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 22
Renters (21%) were approximately twice as likely to identify better street lighting in
their neighborhood compared with homeowners (11%). Renters (24%) were also more
than one-and-a-half times likely to identify new or improved sidewalks as needed in
their neighborhood compared to homeowners (14%)
Approximately a third of both non-Hispanic White and Hispanic survey respondents
were satisfied with their current neighborhood. American Indian/Alaska Native and
Black respondents were more likely to be dissatisfied.
Nearly half of respondents with income greater than $150,000 reported that they were
satisfied with their neighborhood, compared to 15% of respondents with income less
than $25,000. Respondents with income less than $25,000 were more likely to identify
better sidewalk infrastructure and lighting, clean up of empty lots/buildings, and
making parks and outdoor spaces more accessible for residents living with disabilities
than other respondents by income group.
Retired respondents and respondents with full-time employment were much more
likely to be satisfied with their neighborhood. Unemployed respondents were much
more likely than other respondents to identify crime reduction (57%) and better street
lighting (43%) as needed to improve their neighborhood.
One in five respondents living with a disability wanted to see improved sidewalk
infrastructure in their neighborhoods. Additionally, single parents were more than
twice as likely to identify cleaning up empty buildings/lots as a needed neighborhood
improvement than all other respondent types.
Public infrastructure and facilities. The housing and community needs survey
found that 32% of survey respondents wanted the City to prioritize street and sidewalk
improvements. Additionally,
28% of respondents wanted to see the City prioritize improvements to parks and
recreation centers;
24% of respondents wanted to see the City prioritize a new community center or make
improvements to existing community centers;
23% of respondents wanted to see the City prioritize more recreation opportunities for
youth and other special populations; and
16% of respondents wanted to see the City prioritize a new senior center or make
improvements to existing senior centers.
Other public infrastructure and facility needs articulated by survey respondents included:
“ADA improvements should be prioritized above all else. The City should follow
through with the goals and recommendations in the Equity and Inclusion plan, which
would address all of the community development outcomes listed.”
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION IV, PAGE 23
Several respondents advocated for improvements to be made to community centers
or new community centers to be built in the northwest and northeast quadrants of the
city.
“A pool that we can access all year long – a real community center.”
Residents also expressed a need for public facilities, such as dog parks, to be more
accessible. One resident shared that many of the newer parks in Bozeman are accessible
but most of the older parks are not. Another residents shared that most playgrounds in
Bozeman are not ADA compliant.
Health and well-being. When asked to identify what is needed to improve their
health, approximately 4 in 10 survey respondents were satisfied with the current state of
their health. However:
16% of survey respondents wanted it to be easier to exercise;
14% of survey respondents wanted better access to healthier foods;
7% of survey respondents wanted it to be easier to access health clinics; and
An additional 7% of survey respondents wanted more playgrounds to be made
available for children.
Other health and well-being needs articulated by survey respondents included:
“Actual repercussions for landlords who fail to make their buildings livable.”
“An outdoor/public access gym would do so well in Bozeman!”
“Currently have mold growing in unit and have been unable to address it.”
“Easier access to more affordable health insurance. I have no health insurance
because I cannot afford it.”
“I can still drive so access to health care is available. But it won’t last. Public
transportation that runs regularly would help. Right now it takes all day to get to the
west side and back.”
“More mixed-use neighborhoods to increase walkability to resources.”
Additionally, findings by demographic characteristics and other household types found:
More than half of homeowner respondents (54%) were satisfied with their health.
Owners are more than one-and-a-half times more likely to be satisfied with their
health than renters (33%) and almost three times as likely to be satisfied with their
health compared to precariously housed respondents (20%).
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Both renters (24%) and precariously housed (27%) respondents were at least three
times as likely to identify better access to healthier food as needed to improve their
health compared to homeowner respondents (8%).
Non-Hispanic White respondents (54%) were nearly seven times more likely to be
satisfied with their health compared to American Indian/Alaska Native respondents
(8%) and more than five times as likely compared with Black/African American
respondents. Half of Hispanic respondents were satisfied with their health.
Black/African American and American Indian/Alaska Native respondents were more
likely to identify making it easier to access health clinics than other respondents.
Approximately seven in ten respondents with income greater than $150,000 were
satisfied with their health—the highest among respondents by income. Conversely,
respondents with income less than $25,000 had the lowest proportion of respondents
satisfied with their health (29%).
Retired (72%) respondents and respondents working full time (50%) were most likely
to be satisfied with their health among respondents by employment status. Just 14%
of unemployed residents were satisfied with their health.
Respondents over the age of 65 (59%) were most likely to be satisfied with their health
among respondents by different household type. Respondents living with disabilities
were the least likely—approximately one in five respondents (19%) living with a
disability were satisfied.
While half of Hispanic respondents indicated they were satisfied with their health, which
was among the highest proportion of Bozeman residents by race and ethnicity, the City
could improve its outreach to these populations to ensure that they are aware of services
available to them and can easily connect to them. One of the Community Liaisons for the
Belonging in Bozeman Equity & Inclusion Plan articulated that:
“Community engagement is an important approach to have a collaborative effort between
organizations, in designing the effective way to deliver services and information to the
community. Due to the complexity of issues in communication, the traditional approaches
have been ineffective and non-inclusive, especially to Spanish-speaking residents in
Bozeman; but the best starting is to have an established and permanent plan which is
going to keep everyone connected.”
As such, the Belonging in Bozeman Plan identified two recommendations to ensure that
traditionally underserved populations have access to health and wellbeing services and
programs:
Partner with organizations to reach underserved communities through mobile/pop-up
health clinics and health education and promotion programs; and
Support additional resources to improve referral processes and help patients/clients
connect with community resources.
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Food provision and insecurity. The United States Department of Agriculture
(USDA) provides several metrics to evaluate food access in their Food Access Research
Atlas (2019). The USDA states, “low access to healthy food is defined as being far from a
supermarket, supercenter, or large grocery store ("supermarket" for short). A census tract
is considered to have low access if a significant number or share of individuals in the tract
is far from a supermarket.”
According to the Atlas, there is one Census tract in Bozeman—Census Tract 11.02—where
a significant share of residents are more than one mile away from the nearest
supermarket. This Census tract includes Montana State University, and is bounded by
Huffine Lane to the north, Cottonwood Road to the west, and Patterson Road to the south.
In Montana, 10% of households experience low or very low food security, which is lower
than the national average.12 Counties with greater Indigenous populations have much
higher rates of food insecurity at roughly 33%. Indigenous households living on
reservations in particular with lower access to jobs and the dismantling of traditional
indigenous food systems have the highest percentage of food insecure residents with 43%
insecurity.13
The USDA estimates that in 2020, 79% of eligible residents in the state of Montana
participated in the SNAP program.14 Children and seniors are particularly vulnerable to
food insecurity. According to Feeding America data from 2022, Gallatin County had a food
insecurity rate of 9%, or an estimated 10,750 residents who are considered food insecure.
Of these households, 38% of food insecure households are not income eligible for SNAP
benefits, creating a significant gap in food access for food-insecure households.
One of the goals coming out of the City’s Belonging in Bozeman Equity and Inclusion Plan is
to prioritize food access for low-income communities. Specifically, the City will look to work
with partners to improve access to healthy local food and nutrition programs through the
sharing and celebration of cultural and indigenous foods.
12 https://www.ers.usda.gov/webdocs/publications/90023/err-256.pdf?v=0
13 Policy Basics: Supplemental Nutrition Assistance Program (SNAP) | Montana Budget & Policy Center
14 Reaching Those in Need: Estimates of State SNAP Participation Rates in 2020, United States Department of
Agriculture, August 2023.
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V. DISPROPORTIONATE HOUSING
NEEDS
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SECTION V.
Disproportionate Housing Needs
The primary purpose of a disproportionate housing needs analysis is to determine how
access to the housing market and housing choice differ for members of protected
classes. Disproportionate needs analyses can also identify where gaps in housing
markets exist for all residents and facilitate goal-setting and strategic housing planning.
To that end, this section:
1) Analyzes rental housing needs and gaps in attaining homeownership, by
jurisdiction and compared to the county and state overall;
2) Identifies where needs differ by protected class;
3) Assesses how these differences affect housing choice. This includes geographic
choice as well as differences in public and private housing options.
Primary Findings
The data analysis in this section finds the most severe disproportionate needs in:
Cost burden and severe cost burden. Half of Black/African American
households experience cost burden, while a fifth of Asian households and a quarter
of Hispanic households experience severe cost burden. These households are much
more likely to experience eviction and homelessness due to inability to keep up with
their rent or mortgage payments.
Homeownership rates. Significant gaps in homeownership exist for
Black/African American households in Bozeman; large gaps also exist for Hispanic
households. According to recent ACS data, there are no Black/African Americans
that own their homes in Bozeman, compared to 45% of non-Hispanic White
households. Additionally, just 26% of Hispanic households own their homes.
According to the housing and community needs survey, Black/African American and
American Indian/Alaska Native survey respondents are much more likely to have
trouble keeping up with their property taxes than city respondents overall.
Displacement. Approximately one in five Bozeman households (21%) report
moving in the last five years against their choice. While the sample sizes were small,
50% of American Indian/Alaska Native and 40% of Black/African American
respondents report experiencing displacement. AIAN respondents were more likely
to be displaced due to their landlord not renewing the lease or losing their job,
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while Black/African American respondents were more likely to report being evicted
because they were behind on rent or their home went into foreclosure. Renters,
respondents living with a disability, and low-income renters also experienced
displacement at a disproportionate rate. These households reported rent increases
as the primary reason for displacement.
Access to mortgage loans. Of applicants for mortgage loans in 2022,
Hispanic residents had the highest denial rates (12%), 25% higher than non-Hispanic
White applicants. In Bozeman, nearly half of all loan applications are denied due to
debt-to-income ratio. While too few observations were available for most applicants
by race and ethnicity, Hispanic applicants (5%) were more than twice as likely than
non-Hispanic White applicants (2%) to receive a high-priced loan.
Indicators of Disproportionate Needs
There is no formal definition or mechanism to measure housing needs, much less
disproportionate needs. In housing market studies, housing needs are typically
measured by:
Cost burden—when a household pays more than 30 percent of their income in
housing costs including basic utilities and property taxes; and Severe cost burden—
when a household pays more than 50 percent of their income in housing costs. This
is also an indicator of eviction or foreclosure, and homelessness;
Homeownership rates and access to mortgage loans; and
The cost of housing (rents, purchase prices).
Our focus on disproportionate needs furthers that analysis by:
Identifying the differences in the above housing needs indicators for residents of
various protected classes;
Examining additional factors that affect choice and further economic opportunity,
which is largely informed by the housing and community needs survey;
Analyzing whom the private market serves, if the market is addressing housing
needs of protected classes differently needs, and if discrimination is at play—again,
informed by the resident survey.
Housing Cost Burden
Figure V-1 shows the percent of Bozeman households that are cost burdened (paying
between 31 and 50% of their income toward housing) and households that are severely
cost burdened (paying more than 50% of their income toward housing) by race and
ethnicity. Citywide, 19% of households are cost burdened and 18% of households are
severely cost burdened.
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African American households are disproportionately impacted by cost burden in
Bozeman, with half of all African American households experiencing cost burden. While
just 8% of Hispanic households experience cost burden, a quarter of all Hispanic
households are severely cost burdened. Similarly, while only 4% of Asian households are
cost burdened, one in five Asian households are severely cost burdened. Meanwhile,
only 19% of non-Hispanic White households are cost burdened, and 18% are severely
cost burdened.
Figure V-1.
Cost Burden by
Race and Ethnicity,
Bozeman
Source:
2016-2020 HUD CHAS dataset. Refer
to the Data Documentation for
details
(www.hudexchange.info/resource/4
848/affh-data-documentation).
Rising housing costs and stagnant wages contribute to cost burden. Over four in ten
survey respondents (44%) reported that they currently experience a housing challenge.
Survey respondents identified cost burden as a significant housing challenge; a sample
of responses related to cost burden are provided below.
“After being a renter for nearly 10 years, I can no longer pay rent because it is too
high. I work for a local business and provide essential community care.”
After paying rent, I don’t have much left for anything else like food or medical,
let alone clothes or a vehicle.”
“[I’m] BARELY making enough to continue to live here....”
“Cost of living here is through the roof…I have definitely had to make the hard
choice of ‘do I pay rent on time or do I put gas in my car/buy groceries/pay the
power bill?’”
“I can pay for my low-income housing but can never afford rent anywhere else
in Bozeman. I work full-time and am making more than I ever have. To me, 55K
is a lot of money but it's only enough to stay where I am. I want to take care of a
home, to grow my own food - why is this not there for me?”
“My housing costs are more than 60% of my income.”
“My rent will be more than I can afford on SS and SSDI combined.”
“I work two jobs to afford housing.”
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Overall, 8% of Bozeman survey respondents struggle to pay their utility costs, 5%
struggle to pay their rent or mortgage, and 3% have bad credit or a history of
eviction/foreclosure and cannot find a place to rent.
Unemployed (43%), Black/African American (30%), American Indian/Alaska Native
respondents (23%), as well as respondents with income less than $25,000 and students
(16% each, respectively) are more likely than the average Bozeman respondent to
struggle to pay housing costs (including utilities).
Residents and stakeholders also shared several experiences and challenges with cost
burden in Bozeman. One resident shared that “prices are insane in Bozeman and
housing costs are really high.” Another resident shared that it’s “hard to save for first and
last month’s rent and security deposit, on top of having to make three times the amount
of rent. Just to move in, you’re looking at having to fork over $8,000.”
One resident shared that they were looking at an apartment that was $2,220 per month
and the landlord required the tenant make three times the amount of rent. They said
that “even as a double income household, how can you make that?” Another resident
shared that “some people who only receive disability income can’t even make their rent.”
They wanted to see SSDI adjusted for cost of living.
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Homeownership Differences
For the majority of households in the U.S., owning a home is the single most important
factor in wealth-building. Homeownership is also thought to have broader public
benefits, which has justified decades of public subsidization. For nearly 100 years, the
federal government has subsidized ownership through the mortgage interest tax
deduction and the secondary mortgage market.1
Yet these incentives for ownership have been in place far longer than the existence of
fair lending and fair housing protections, meaning that the benefits of federal subsidies
for ownership have not been equally realized by all protected classes. This explains
some of the reason for ownership disparities today, in addition to the now-illegal
practices of redlining, steering, blockbusting, unfair lending, and discriminatory pricing.2
Figure V-2 below shows homeownership rates by race and ethnicity for the city of
Bozeman, Gallatin County, and the state of Montana. Overall, Bozeman has lower
homeownership rates than both Gallatin County and the state of Montana, likely driven
by the presence of Montana State University and the relatively large student population.
Non-Hispanic White households have the highest rate of homeownership in the city
(45%) followed by Asian households and households that identify as two or more races
(34% each, respectively).
According to 2022 5-year ACS data, there are no Black/African American households
that own their home in Bozeman. Out of approximately 160 households, nearly 70%
of Black/African American households in Gallatin County own their home while just
over one quarter of Black/African American households statewide own their homes.
Just over a third of Asian households—who typically have similar or better measures
of housing access as non-Hispanic White households—own their homes in
Bozeman. Homeownership rates are higher in both the county (40%) and state
(56%).
1 Despite the many public and private interventions to expand ownership, the overall U.S. rate has been stubbornly
stagnant. In 2015, 63.7 percent of households were owners, compared to 63.9 in 1990. Contrary to what many U.S.
residents believe, the U.S. does not lead developed countries in homeownership. Instead, the U.S.’ rate of ownership
is similar to that of the United Kingdom (63.5%) and lower than Canada’s (67.0%).
2 “Steering” refers to the practice of showing home- and apartment-seekers homes only in neighborhoods with
residents of similar races and ethnicities; it is now illegal for real estate agents to engage in steering. “Blockbusting,”
which is also illegal, refers to the practice of real estate agents and builders convincing homeowners to sell their
homes below market because of the fear that minorities could be moving into the neighborhood, and then reselling
those homes to minorities at inflated prices. “Discriminatory pricing” means intentionally charging certain protected
classes more for housing than others and is often a product of steering, blockbusting, subprime lending, and other
illegal practices.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 6
Approximately a quarter of Hispanic households own their homes in Bozeman.
Homeownership rates are higher for Hispanic households in Gallatin County (38%)
and the state of Montana (49%).
Additionally, 13% of survey respondents reported not being able to keep up with their
property taxes. By household type, American Indian/Alaska Native (31%), Black/African
American (30%) and unemployed (29%) respondents were most likely to have trouble
keeping up with their property taxes, as well as respondents over the age of 65 (25%).
A sample of responses related to homeownership costs are provided below.
“I can [currently] keep up with property taxes but worried that they just keep going
up and I'll soon be retiring.”
“Can't keep up with homeowners’ insurance increases.”
“I am severely cost burdened in my mortgage payments.”
“I wonder if my property taxes will become unaffordable in the future.”
“The issue for me is that I have been very financially responsible and am still
feeling the risk of having to leave the area due to lack of affordability….”
Residents and stakeholders also shared several experiences and challenges with
homeownership in Bozeman.
One stakeholder shared that they have lived in Bozeman for six years, noting that “when
I first got here, it was pretty easy to find a place to live. I thought I would work on my
credit a bit and then be able to buy a house.” They described that since they’ve been
here, prices have continued to skyrocket and then it got even worse with COVID. After
COVID, they said “I’m never, ever, ever going to be able to buy in Bozeman.”
Another resident shared that they have lived in Bozeman since the late 1990s and live in
a single-family home. They shared that the only way they could have bought their house
in 2009 was due to three things: the generosity of a close friend; Obama’s tax credit; and
the death of a grandparent…”I couldn’t have purchased a home without these three
things.”
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 7
Figure V-2.
Homeownership Rate by Race and Ethnicity, 2022
Source: 2022 ACS 5-year estimates and Root Policy Research
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Differences in Housing Challenges
According to the housing and community needs survey conducted for this plan, overall,
58% of Bozeman households face housing challenges. While sample sizes are small,
proportions are much higher for Black/African American (90%) and American
Indian/Alaska Native (85%) respondents. Additionally, households with a member living
with a disability (81%), single parent households (75%), households with children (71%),
and households earning lower than $25,000 (68%) all face housing challenges
disproportionately compared to the overall Bozeman survey respondent.
The following housing challenges emerged as particularly acute for certain
subpopulations but were not prevalent among Bozeman households overall.
I have bad credit/history of evictions/foreclosure and cannot find a place
to rent. Precariously housed respondents were nearly four times as likely to
identify this challenge compared to Bozeman survey respondents overall.
Black/African American, Hispanic, and American Indian/Alaska Native respondents,
respondents whose household includes a member with a disability, respondents
with household income between $25,000 and $50,000, and single parents.
I have Section 8 and am worried my landlord will stop accepting Section
8. Black/African American, American Indian/Alaska Native, and Hispanic
respondents, respondents with household income below $50,000, unemployed
respondents, single parents, and respondents over the age of 65 reported this
concern disproportionately.
My home/apartment is in bad condition. Black/African American and Hispanic
respondents, respondents making less than $50,000, students, and respondents
living in large households reported this issue disproportionately.
Differences in displacement experience. In the last five years, according to
the housing and community needs survey, one in five (21%) Bozeman households
experienced displacement—that is, they had to move out of a home in Bozeman when
they did not want to move. Those households with the highest displacement rates
include:
American Indian and/or Alaska Native. While the sample size is small, 50% of
AIAN respondents experienced displacement from a residence in Bozeman in the
past five years. American Indian/Alaska Native respondents identified being
displaced due to the landlord not renewing their lease (67%) and lost job/hours
reduced (50%).
Black/African American. While the sample size is also small for Black/African
American residents, 40% of Black/African American respondents experienced
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 9
displacement from a residence in Bozeman in the past five years. These
respondents identified “evicted because I was behind on rent” and “my home went
into foreclosure” as the common reasons for their displacement (50% each).
Renters. Nearly four in 10 renters (38%) report recent displacement. More than
half of renters (55%) identified “rent increased more than I could pay” as the
primary reason for being displaced.
Respondents living with a disability. More than a third (35%) of respondents
living with a disability have experienced displacement in the last five years. The “rent
increased more than I could pay” (52%) and “the landlord wanted to rent to
someone else” (30%) were the primary reasons for displacement.
Low-income households. Low-income households were more likely to
experience displacement than higher income households—31% of households with
income less than $25,000 and 34% of households with income between $25,000
and $50,000 were displaced in the last five years. For these respondents, “rent
increased more than I could pay” was the primary reason for their displacement
(32% for respondents with income less than $25,000, 56% for respondents between
$25,000 and $50,000). Additionally, 32% of respondents with income less than
$25,000 cited “housing was unsafe” as a reason for displacement.
Access to Credit
Several factors contribute to the differences in homeownership by race and ethnicity
observed above, including disparities in access to lending. Home Mortgage Disclosure
Act (HMDA) data can shed light on the role of access to credit in homeownership
differences by race and ethnicity. HMDA data is collected by the Federal Financial
Institutions Examination Council (FFIEC) which provides data used in the analysis of
mortgage lending practices.
HMDA data include variables such as race, Census tract, loan type, and loan purpose.
And, while these variables can be used to explain many of the reasons for any lending
disparities (e.g., poor credit history), they do not contain all of the factors that are
evaluated by lending institutions when they decide to make a loan to an applicant.
This section uses the analysis of HMDA data to examine disparities in lending and loan
denials across different racial and ethnic groups and income categories, to determine if
loans are being apportioned more favorably to some racial and ethnic groups as
opposed to others.
Loan applications in Bozeman. During 2022, there were 1,759 loan
applications made for residential properties in the city of Bozeman. Of these loans, 93%
were for conventional loans, 5% were for Veterans Affairs (VA) guaranteed loans, and 2%
were Federal Housing Administration (FHA) insured loans. Just one applicant applied for
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 10
a USDA Rural Development guaranteed loan. Figure V-3 reveals the distribution of loans
by loan type.
Figure V-3.
Loan Applications
by Loan Type,
Bozeman, 2022
Note:
Includes only first lien loans. Does
not include loans for multifamily
properties or non-owner occupants.
n = 1,759
Source:
HMDA Raw Data 2022 and Root
Policy Research.
Figure V-4 shows loan types. Over half (54%) of all loan applications were for home
purchases while a quarter (25%) were cash-out refinancing loans. Approximately 1 in 7
applicants applied for a refinancing loan (14%). A very small portion (2%) were home
improvement loans (although cash-out refinancing may have also been intended for
home improvements).
Figure V-4.
Loan Applications
by Loan Purpose,
Bozeman, 2022
Note:
Includes only first lien loans. Does
not include loans for multifamily
properties or non-owner occupants.
n = 1,759
Source:
HMDA Raw Data 2022 and Root
Policy Research
Of the loan applications in Bozeman in 2022, approximately two thirds (66%) resulted in
the loan being originated; 19% were withdrawn by the applicant; and 10% were denied.
Additionally, 4% of applications had files that were closed for incompleteness and 2%
were approved but not accepted by the applicant.
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Figure V-5.
Loan Action Taken,
Bozeman, 2022
Note:
Includes only first lien loans. Does
not include loans for multifamily
properties or non-owner occupants.
n = 1,759
Source:
HMDA Raw Data 2022 and Root
Policy Research.
Loan outcomes by race/ethnicity. Figure V-6 presents detailed outcomes of the
loan applications, focusing on the difference in outcomes among racial and ethnic
groups.
Although non-Hispanic White applicants applied for loans at a rate 42 times greater than
Hispanic applicants, loan originations were lowest among Hispanic applicants. With an
origination rate of 61%, Hispanic applicants’ loans were originated at six percentage
points less than for non-Hispanic White applicants (67%) and 12 percentage points less
than for Asian applicants (73%).
Moreover, applications submitted by Hispanic would-be-borrowers resulted in a denial
12% of the time—20% higher than for applicants overall and 25% higher than non-
Hispanic White applicants. While Hispanic applicants were 33% less likely to withdraw
their application compared to non-Hispanic White applicants, they were almost four
times as likely to have their file closed for incompleteness. Nearly a quarter (23%) of
Asian applicants withdrew their applications in 2022.
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Figure V-6.
Outcome of Mortgage Loan Application by Race/Ethnicity, Bozeman, 2022
Note: Applicants who identified as having one race and either identified their ethnicity as “not Hispanic or Latino” or had “ethnicity not available” were assigned racial groups based on the one
race identified, while any applicant who identified their ethnicity as “Hispanic or Latino” and had identified as any other racial category were assigned “Hispanic.” Estimates are not
presented for Black/African American or American Indian/Alaska Native groups due to insufficient data (n<20). Note that sample sizes are small for Asian and Hispanic groups. Includes
only first lien loans. Does not include loans for multifamily properties or non-owner occupants. n=1,759.
Source: HMDA Raw Data 2022 and Root Policy Research
Most often, loan applications are denied due to credit worthiness, particularly low credit scores or high debt-to-income ratios. As
revealed in Figure V-7, debt-to-income ratios and credit history were among the most common reasons provided for loan denial.
Combined, they make up close to two thirds of all reasons provided for loan denials in Bozeman.
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Figure V-7.
Reason for Denial,
Bozeman, 2022
Note:
Percent calculated from total
reasons given including multiple
reasons for one applicant. Includes
only first lien loans. Does not
include loans for multifamily
properties or non-owner occupants.
n=168.
Source:
HMDA Raw Data 2022 and Root
Policy Research
Figure V-8 presents denial rates based on loan purpose for all Bozeman applicants in 2022.
Nearly a quarter of loan denials (23%) were for home improvement loans, while just over a
fifth of denials were classified as “other purpose.” Additionally, refinance loans accounted
for 16% of loan denials, while 14% of loan denials are for cash-out refinancing and 10% are
for home purchases.
Non-Hispanic White applicants made up 90% of all loan denials in Bozeman in 2022. As
such, the distribution of denials by loan purpose of non-Hispanic White applicants is
essentially unchanged from the distribution of all loan denials. Denials by loan purpose are
not shown for other applicants by race and/or ethnicity due to too few observations.
Figure V-8.
Denials by Loan
Purpose, Bozeman,
2022
Note:
Denial rates are calculated out of
the total of originated loans, denied
loans, and loans approved but not
accepted. Includes only first lien
loans. Does not include loans for
multifamily properties or non-
owner occupants. n=1,353.
Source:
HMDA Raw Data 2022 and Root
Policy Research
Figure V-9 shows the geographic distribution of mortgage loan denial rates in Bozeman by
Census tract. Census tracts with the highest proportion of mortgage loan denial rates
within city boundaries are Census Tract 8 (30%) and Census Tract 6 (27%); however, the
number of loan originations for these two Census tracts (16 and 18, respectively) are
relatively low compared to other Census tracts in Bozeman (average number of loan
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 14
origination by Census tract is 72). The next highest denial rate for other Census tracts in
Bozeman is 16%.
Figure V-9.
Mortgage Loan Denial Rates by Census Tract, Bozeman, 2022
Note: Census tracts with fewer than 20 total applications were excluded. Includes only first lien loans. Does not include loans for
multifamily properties or non-owner occupants. Denial rates are calculated out of the total of originated loans, denied loans,
and loans approved but not accepted. n=1,353.
Source: HMDA Raw Data 2022 and Root Policy Research.
Beginning in 2004, HMDA data contained the interest rates on higher-priced mortgage
loans. This allows examinations of disparities in high-cost, including subprime, loans
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among different racial and ethnic groups. It is important to remember that subprime loans
are not always predatory or suggest fair lending issues, and that the numerous factors that
can make a loan “predatory” are not adequately represented in available data. Therefore,
actual predatory practices cannot be identified through HMDA data analysis. However, the
data analysis can be used to identify where additional scrutiny is warranted, and how
public education and outreach efforts should be targeted. For the purpose of this section
we define “high priced” as a loan with an ARP of more than one and half (1.5%) percentage
points above comparable treasuries.
Overall, just 2% of Bozeman applicants received high-priced loans in 2022 (Figure V-10).
When broken down by income, 3% of applicants making less than 80% AMI received high-
priced loans, while just 2% of applicants making between 81-120% AMI and more than
120% AMI each received high-priced loans, respectively.
Two percent of White applicants received high-priced loans across all income levels. For all
income categories, White applicants had the same proportion of applicants that received
high-priced loans as city applicants overall. Aside from Hispanic/Latino applicants (5%
received high-priced loans, there are too few observations to report for other applicants by
race and ethnicity.
Figure V-10.
High Priced Loans by Race/Ethnicity and Income, Bozeman, 2022
Note: "High priced" is defined as a loan with an APR of more than one and a half (1.5) percentage points above comparable
treasuries. Percentage is calculated from total originated loans. Includes only first lien loans. Does not include loans for
multifamily properties or non-owner occupants. Income limits corresponding to the income breaks in the table are 2022 2-
person AMI limits for Bozeman as follows: 80% AMI = $63,680; 100% AMI = $79,600; 120% AMI = $95,520. Race categories
include non-Hispanic and ethnicity not provided while the Hispanic category includes Hispanic or Latino of any race.
Estimates are not presented for Asian, Black/African American, American Indian/Alaska Native, and Other groups due to
insufficient data. Estimates are not provided for income groups by race with fewer than 20 originated loans in 2022. Note
that sample size is small for Hispanic residents.
Source: HMDA Raw Data 2022 and Root Policy Research.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 16
Figure V-11 shows the geographic distribution of the proportion of high-priced loans by
Census tract. Just one Census tract has a greater proportion of high-priced loans relative to
the city overall—Census Tract 5.05 (5%). This tract is located on the western end of the city.
Census Tract 5.02 (3%) also has a greater proportion of high-priced loans relative to the
city; however, this tract is located almost entirely outside of city boundaries.
Figure V-11.
Percent High-Priced Loans by Census Tract, Bozeman, 2022
Note: Does not include loans for multifamily properties or non-owner occupants. “High priced” is defined as a loan with an ARP of
more than one and half (1.5%) percentage points above comparable treasuries. Percentage calculated from total originated
loans.
Source: HDMA Raw Data 2018 and Root Policy Research.
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Alternative financial products. Households who are rejected from traditional or even
higher-cost lending products—or who are unaware of or distrust traditional lenders—use
alternative financial products, many of which carry very high interest rates and inhibit
financial stability and wealth-building.
A cornerstone of the Federal Deposit Insurance Corporation’s (FDIC) economic inclusion
(https://www.economicinclusion.gov/whatis/) project is a study of what the FDIC has
identified as unbanked and underbanked households. “Unbanked” households are those in
which no one in the household has a checking or savings account “Underbanked”
households are those who have an account in an insured institution but also use services
that are likely to charge high or very high rates. These services include checking cashing
institutions, payday loans, “tax refund anticipation” loans, rent-to-own services, pawn shop
loans, and/or auto title loans.
The FDIC studies the prevalence of unbanked and underbanked households every two
years. The latest, 2021, survey found that:
1) 4.5% of U.S. households are “unbanked,” which is the lowest rate since the study
began in 2009. The unbanked rate fell by 0.9 percentage points between 2009 and
2021, which corresponds with an increase of approximately 1.2 million banked
households.
2) Approximately 14% of U.S. households are “underbanked.” This rate has fallen by
4.7 percentage points since 2017.
3) The State of Montana has an unbanked rate of 3%, which has been gradually
declining since 2013.
Figure V-12 shows the state’s trend in the percentage of unbanked and underbanked
households since 2009.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 18
Figure V-12.
Unbanked and
Underbanked Households,
State of Montana, 2009 -
2021
Source:
Multiyear FDIC National Survey of Unbanked and
Underbanked Households.
Unfortunately, the FDIC survey data are not available by household characteristic at the city
level. However, household characteristics are available at the state level and are found in
Figure V-13, which shows that:
Just shy of 3% of White households are unbanked in the state. Data were not available
for Hispanic households or any other racial or ethnic group.
Households with a high school diploma are nearly 12 times as likely to be unbanked
compared to college-educated households.
Households making between $15,000 and $30,000 are almost twice as likely as all
households to be unbanked, while households making less than $15,000 are over four
times as likely to be unbanked.
Households with a person living with a disability are almost six times as likely to be
unbanked compared to other same age households without a disability (25 to 64 years
old).
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 19
Figure V-13.
Unbanked Households, State of Montana by Household Characteristics,
2021
Source: 2021 FDIC National Survey of Unbanked and Underbanked Households.
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 20
Housing Access
A growing body of recent research has bolstered the evidence that where affordable and
mixed-income housing is developed has a long-term impact on the households that occupy
that housing. For example:
Dr. Raj Chetty’s well known Equality of Opportunity research found positive economic
returns for adults who had moved out of high poverty neighborhoods when they were
children. The gains were larger the earlier children moved.
A companion study by Dr. Chetty examining social mobility isolated the neighborhood
factors that led to positive economic mobility for children. Children with the largest
upward economic mobility were raised in neighborhoods with lower levels of
segregation, lower levels of income inequality, higher quality schools, and greater
community involvement (“social capital”).
A similar study by researchers at Johns Hopkins University found that when assisted
housing is located in higher quality neighborhoods, children have better economic
outcomes. The study also concluded that because low income African American
children are more likely than low income white children to live in assisted housing, the
location of assisted housing in poor quality neighborhoods has a disproportionate
impact on African American children’s long-term economic growth.
This research is counter to years of housing policies and programs that focused on building
large multifamily complexes to house persons living in poverty, often placing these
developments in the least desirable areas in a city. Fortunately, more recent housing policy
activism has focused more intently on remedying the damage done by decades of
intentional segregation. The remaining part of this section examines locational housing
choice.
Location of affordable rental (LIHTC) developments. Figure V-14 shows a
map of the city’s community housing rental inventory. The majority of the inventory is
located north of Main Street/U.S. Hwy 191, with most of the rental units located east of 19th
Street, south of I-90, and west of N Rouse Avenue/State Highway 86. The units located
south of Main Street are nearly all LIHTC units. Of the City’s community housing rental
inventory, 742, or 61% of the units are solely LIHTC developments. Of note, most of the
units in the city’s community housing rental inventory are located in Census Tract 6, which
is home to a concentration of residents living with disabilities, as well as Hispanic and
Indigenous residents. The tract also has one of the lowest median household incomes
($44,762) and the highest rates of poverty in the city (23.5%).
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 21
Figure V-14.
Community Housing Rental Inventory, Bozeman
Note: Underbanked definition is based on the following AFS: check cashing, money order, remittance, payday loan, rent-to-own
service, pawn shop loan, refund anticipation loan, and auto title loan.
Source: HUD Affirmatively Furthering Fair Housing Data and Mapping Tool
As the rental market has become more competitive, low-income renters find it increasingly
challenging to find market rate units. Those renters with any type of perceived challenge—
income from a variety of sources, a past eviction, a minor criminal infraction, a need for a
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 22
reasonable accommodation—are often passed over for renters who are perceived as
easier tenants. In some cases, these criteria can disproportionately affect certain protected
classes; some of these effects are evident in the housing and community needs survey.
Recent experience seeking housing. Overall, 69% of survey respondents
seriously looked for housing to rent or buy in Bozeman in the past five years, where
“serious” looking includes touring homes or apartments, putting in applications or applying
for mortgage financing. These respondents identified issues they experienced when
seeking housing to rent or buy.
Residents who reported differential treatment while seeking housing included:
American Indian/Alaska Native and Hispanic respondents, respondents with large
families, and respondents whose household includes a member with a disability were
more likely to be told units were available over the phone, but after they arrived in
person, were told the housing was no longer available.
Respondents whose household includes a member with a disability, students, and
respondents in large households were more likely than other respondents to have a
landlord not return their calls or emails asking about a unit.
Bozeman survey respondents who believe they have experienced discrimination when
looking for housing are most likely to be American Indian/Alaska Native, a respondent
whose household includes a member living with a disability, have household incomes
less than $25,000, and a single parent.
Housing voucher holders. HRDC manages approximately 700 housing vouchers
throughout the region. With the acknowledgement that waiting lists do not reflect the total
scale of community needs, there are approximately 1,200 households on the waitlist for
Housing Choice Vouchers with the HRDC. In addition to the waitlist for tenant-based
vouchers, there are approximately 300 applicants on HRDC’s homebuyer education
program. The only HUD-certified course in the Bozeman area, residents who complete the
course received a HUD certificate of Homebuyer Education completion, which many
lenders ask for. Additionally, as of spring 2024, the waitlist for HRDC’s subsidized
developments is approximately 18 months.
Difficulty using vouchers. A total of 45 survey respondents (6%) participate in the
Housing Choice Voucher/Section 8 program. Of those with vouchers, nearly six in ten
respondents (57%) indicated that it is “somewhat difficult” to find a landlord that accepts a
housing voucher while more than a quarter of respondents (27%) indicated that it is “very
difficult.” When asked what made it difficult to find a landlord, the most common
responses include:
Voucher is not enough to cover the rent for places I want to live (21 of 37);
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION V, PAGE 23
Have a hard time finding information about landlords that accept Section 8 (17 of 37);
Landlords have policies of not renting to voucher holders (13 of 37); and
Not enough time to find a unit before the voucher expires (13 of 37).
Residents and stakeholders shared many of the same concerns about landlords and added
that residents face other obstacles getting housed including a criminal history, evictions on
their record, bad credit, and application fees and deposits required to move into a unit.
Publicly subsidized housing. Publicly supported housing makes up approximately
7.4% of the overall housing inventory in Bozeman, as shown in Figure V-15 below.
Figure V-15.
Share of Housing
Units that are
Publicly Supported
Housing
Source:
City of Bozeman, stakeholders, and
2022 ACS 5-year estimates.
Public Housing Authority Policy Review
The City of Bozeman and Gallatin County do not have a public housing authority within
their jurisdictions. The Human Resource Development Council District IX, or the HRDC,
serves as the de facto housing authority, administering the housing choice voucher
program, developing affordable housing, and providing a wide range of services.
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VI. FAIR HOUSING ENVIRONMENT
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION VI, PAGE 1
SECTION VI.
Fair Housing Environment
This section of the Bozeman Fair Housing Plan assesses private and public barriers to
housing choice within the context of existing fair housing laws, regulations, and guidance.
This analysis is informed by fair housing complaints; legal cases; a review of relevant land
use/public policies and practices; and Bozeman’s current fair housing activities.
Primary Findings and Recommendations
HUD reported seven fair housing complaints in Bozeman between 2019 and 2023.
Most complaints submitted to HUD during this period affected individuals living with
physical disabilities.
Approximately one in five Bozeman survey respondents (19%) reported experiencing
housing discrimination in the last five years. Populations experiencing housing
discrimination at a disproportionate rate include low-income respondents,
respondents with disabilities, single parents, and students. Nearly half of survey
respondents (46%) reported doing nothing about the discrimination because they
were not sure what to do.
The City of Bozeman has tentatively paused its process for updating its Unified
Development Code (UDC). As such, a list of best practices to ensure land use and
zoning regulations don’t serve as barriers to fair housing choice are detailed later in
the section for the consideration of the City to incorporate its UDC update. The
following list of best practices would be beneficial to include during the update of the
code:
➢ Include a definition of “disability” or “person with disabilities” that aligns with
Fair Housing Amendments Act (FHAA) and Americans with Disabilities Act
(ADA) in the development code. In defining disability, it is important to
include the broad definition that has been interpreted by the courts to apply
to the Fair Housing Act (FHA), which includes persons in recovery from
substance abuse challenges and persons with HIV/AIDS.
➢ Establish a standard process for reasonable accommodation requests in the
development code.
➢ Implement residential unit classifications, zone districts, and site design
requirements for alternative housing types (e.g. tiny homes, cottage
housing, courtyard development, micro-homes, and cooperative housing).
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION VI, PAGE 2
➢ Include a statement in the purpose of the zoning ordinance that discusses
fair housing law or include a cross-reference that identifies the adopted
planning documents that discuss and contain policies related to fair
housing.
Legal Framework
Fair housing rights and protections are governed by the federal and state fair housing acts.
Federal Fair Housing Act. The Federal Fair Housing Act, passed in 1968 and
amended in 1988, prohibits discrimination in housing on the basis of race, color, national
origin, religion, gender/sex, familial status and disability. The Fair Housing Act—Amended
(FHAA) covers most types of housing including rental housing, home sales, mortgage and
home improvement lending and land use and zoning. Excluded from the FHAA are owner-
occupied buildings with no more than four units, single family housing units sold or rented
without the use of a real estate agent or broker, housing operated by organizations and
private clubs that limit occupancy to members and housing for older persons.1
HUD has the primary authority for enforcing the FHAA. HUD investigates the complaints it
receives and determines if there is a “reasonable cause” to believe that discrimination
occurred. If reasonable cause is established, HUD brings the complaint before an
Administrative Law Judge. Parties to the action can also elect to have the trial held in a
federal court (in which case the Department of Justice brings the claim on behalf of the
plaintiff).2
State ordinance. The State of Montana has a law (“Montana Human Rights Act”) that
prohibits housing discrimination (Montana Code Annotated, Title 49, Chapter 2, Part 3 –
Discrimination in Housing).3 The state law includes additional protected classes’ marital
status, creed, and age. The Montana Human Rights Bureau (MHRB) enforces the state’s fair
housing law and is charged with enforcing specific state and federal laws that prohibit
unlawful discrimination. The Bureau informally investigates complaints that are filed with
the Department of Labor & Industry’s Human Rights Bureau. Residents who think that have
been discriminated against have only 180 days from when the adverse act occurred to file
a written complaint with the bureau. Additionally, the MHRB also “…provides quality
education and training opportunities to employers, employees, housing providers, tenants,
and all Montana residents.”4
1 “How Much Do We Know? Public Awareness of the Nation’s Fair Housing Laws”, The U.S. Department of Housing and Urban Development, Office of Policy and Research, April 2002.
2 Ibid.
3 See https://leg.mt.gov/bills/mca/title_0490/chapter_0020/part_0030/section_0050/0490-0020-0030-0050.html for the actual text of the law.
4 https://erd.dli.mt.gov/human-rights/
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Course of Action
Bozeman residents who believe they have experienced discrimination in violation of the
Federal Fair Housing Act (FHA) or state fair housing laws may report their complaints to the
following entities:
U. S. Department of Housing and Urban Development (HUD).
Montana Human Rights Bureau.
Other entities that are responsible for receiving and investigating complaints of fair
housing discrimination in Bozeman include:
Montana Fair Housing.
Additionally, Montana Legal Services Association (MLSA) provides civic legal aid services to
low-income Montanans.
Department of Housing and Urban Development (HUD). Housing
discrimination complaints filed with HUD may be done online5; by calling toll free at 1-800-
669-9777; or by contacting the Office of Fair Housing and Equal Opportunity in Washington
D.C., or the HUD Denver Regional Office of Fair Housing and Equal Opportunity.
When HUD receives a complaint, HUD will notify the person who filed the complaint and
will normally notify the alleged violator and allow that person to submit a response. The
complaint will be investigated to determine whether there has been a violation of the Fair
Housing Act.
A complaint may be resolved in a number of ways. First, HUD will try to reach an
agreement between the two parties involved. A conciliation agreement must protect the
filer of the complaint and public interest. If an agreement is signed, HUD will take no
further action unless the agreement has been breached. HUD will then recommend that
the Attorney General file suit.
If HUD has determined that a state or local agency has the same housing powers
(“substantial equivalency”) as HUD, they will refer the complaint to that agency and will
notify the complainant of the referral. The Montana Human Rights Bureau is not a
substantially equivalent local agency.
If during the investigative review and legal processes, HUD finds that discrimination has
occurred, the case will be heard in an administrative hearing within 120 days, unless either
party prefers the case to be heard in Federal district court.
5 http://www.hud.gov/complaints/housediscrim.cfm.
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If a person needs immediate help to stop a serious problem that is being caused by a Fair
Housing Act violation, HUD may be able to assist as soon as a complaint is filed. HUD may
authorize the Attorney General to go to court to seek temporary or preliminary relief,
pending the outcome of the complaint, if irreparable harm is likely to occur without HUD's
intervention and there is substantial evidence that a violation of the Fair Housing Act
occurred.
Montana Human Rights Bureau (HRB). The Montana Human Rights Bureau
(HRB) is charged with enforcing the state's anti-discrimination laws in the areas of
employment, housing, education, and public accommodations.
The HRB encourages people who believe they have experienced illegal discrimination to
contact their offices at 406-444-2884 or 1-800-542-0807. If the alleged act of discrimination
falls within the jurisdiction of the HRB, those who believe they have experienced illegal
discrimination will schedule a telephone interview with a trained investigator. If the facts of
the incident point to a credible instance of illegal discrimination, the trained investigator
will use the information gathered during the intake call to draft a formal complaint. A
signature by the complainant is required. A formal complaint must be filed with the HRB
within 180 days of the date of the alleged discrimination.
The Human Rights Bureau is a neutral administrative agency throughout this process. The
individual filing the complaint is referred to as the “charging party,” while the business or
entity against whom the complaint is filed is called the “respondent.” Once the complaint
has been filed, the respondent is notified within 10 days.
Before the complaint moves forward through the process, the HRB offers a variety of
options for voluntary resolution of discrimination complaints. Not only can voluntary
resolutions save both parties time and money but negotiations are confidential and most
parties who choose voluntary resolution see their cases successfully resolved. Additionally,
“before or during the informal investigation, if the parties are able to resolve the matter on
their own, then the Human Rights Bureau would ask that the parties provide the Bureau
with a copy of the settlement agreement and a signed withdrawal form…which withdraw[s]
the complaint from the administrative process.”6
If parties voluntary resolve the complaint after a cause finding has been established, HRB
may seek affirmative relief to correct or prevent discrimination. Moreover, “if the parties
reach a voluntary resolution without the participation of the Human Rights Bureau the
Bureau may seek a separate agreement with the Respondent.”7
6 https://erd.dli.mt.gov/human-rights/voluntary-resolution
7 Ibid
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Once the complaint has been filed, an investigator assigned to the case will begin an
information investigation to determine if illegal discrimination occurred. The Respondent
will receive the opportunity to provide a position statement about the alleged
discrimination, which the Complainant will have the opportunity to review and provide a
rebuttal. As part of the informal investigator, the investigatory might request additional
information, perform an on-site inspection, or hold an in-person fact finding, which is an
informal sit down that provides both the Complainant and Respondent to present their
position in the case. The investigator will aim to work with both parties to reach a voluntary
no-fault resolution of the case.
The investigation must be completed within 180 days (120 days in housing cases). If a case
is unable to be resolved, a Final Investigative Report is produced, which summarizes the
investigation and recommends a finding of “reasonable cause”—meaning there is reason
to believe that illegal discrimination occurred— or “no reasonable cause”—meaning the
evidence does not support a finding that illegal discrimination occurred. This report is sent
to both parties.
If a reasonable cause finding is issued, HRB staff will attempt to conciliate the case with
both parties, which may include “…compensation for any losses incurred…modifying any
practices having an adverse effect on protected classes; and taking other affirmative steps
needed to eliminate discrimination.”8 If the parties are unable to conciliate, a public hearing
will be held by the Department of Labor and Industry. As such, “a hearing examiner will
conduct a formal hearing subject to the rules of evidence and procedure, similar to a non-
jury trial in district court. The hearing examiner will issue a Final Agency Decision regarding
whether discrimination occurred. If appropriate, the hearing officer will award monetary
damages, and other affirmative relief. This decision can be appealed to the Montana
Human Rights Commission”9
Montana Fair Housing. Montana Fair Housing’s mission is to promote and ensure
non-discrimination through outreach, education, dispute resolution, and enforcement. The
organization “…investigates allegations of discrimination in housing, counsels victims of
discrimination, and facilitates both the state and federal complaint process. [MFH] also
assists victims of housing discrimination, under specific circumstances, in securing the
representation of counsel when the filing of a complaint in court is deemed the best
option.”10 MFH also maintains a list of housing accessible to people requiring a mobility
device and provides dispute resolution services, upon request. MFH can be contacted
8 https://erd.dli.mt.gov/human-rights/filing-a-complaint/
9 Ibid
10 https://www.montanafairhousing.org/index.php
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online through its contact form11 or by phone at 1-406-782-2573. The MFH offices are
located at 501 E Front Street, Butte, MT 59701.
Montana Legal Services Association (MLSA). The Montana Legal Services
Association or MLSA, is a statewide organization dedicated to protecting and enhancing the
civil legal rights of, and promoting systemic change for, Montanans living in poverty. MLSA
can be contacted online12 or can be reached by phone at 1-800-666-6899. MLSA has
physical offices in Helena, Billings, and Missoula. MLSA provides non-criminal legal
information, civic legal aid, and advice for thousands of Montanans each year, including
representing families living in unsafe housing conditions.
Housing Discrimination, Complaints, and Legal Cases
This section provides an overview of residents’ perceptions of discriminatory behavior from
responses to the community survey conducted for this Fair Housing Plan and a review of
FHAA related complaints and legal cases filed in the city over the last decade.
Experience with housing discrimination. According to the housing and
community needs survey, approximately one in five respondents (19%) has experienced
discrimination when looking for housing in Bozeman over the last five years. Specific
survey respondents that experienced housing discrimination at a disproportionate rate
compared to survey respondents overall include:
Respondents with income less than $25,000 (39% of respondents indicated they have
experienced housing discrimination in the last five years);
Respondents whose household include a member living with a disability (36%);
Single parents (31%); and
Students (27%).
While sample sizes is small (n=12), 42% of American Indian/Alaska Native indicated they
have experienced housing discrimination in the last five years.
Common reasons cited by survey respondents about why they were discriminated against
included age, income, disability, being a part of (or supporting) the LGBTQ+ community,
race, and citizenship status. Survey respondents were asked to expand on their
experiences with housing discrimination in Bozeman. Below are a sample of responses.
“Application fees are discriminatory against the working class! It’s unfair someone
would pay hundreds of dollars to APPLY to housing to then be rejected. Management
11 https://www.montanafairhousing.org/contactform.php
12 https://www.mtlsa.org/contact/
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CITY OF BOZEMAN FAIR HOUSING PLAN SECTION VI, PAGE 7
companies are currently incentivized to let people apply with no intention of renting to
them because of exorbitant application fees.”
“Folks I work with have criminal records and most private landlords made no
exceptions for felony charges.”
“He felt discriminated against because he is black and his application was declined
despite his excellent credit and rental history.”
“I was wearing a pride pin and told they ‘don’t rent to people like me.’ Several
friends have cited similar conversations.”
“Many of the clients I work with are discriminated against by the way they look,
arrest records, the costs to even fill out an application (over and over again adds
up just to be denied).”
“Race (one Black, one Native household member).”
“They don’t speak English and are undocumented immigrants.”
Survey respondents were asked about when the most recent instance of housing
discrimination occurred. Of the 140 survey respondents who had reported experiences of
housing discrimination:
39% reported that the discrimination occurred in the past year;
48% reported that the discrimination occurred between 2 to 5 years ago;
11% reported that the discrimination occurred over five years ago; and
2% did not remember.
When asked about what the respondent did in response to the discrimination, the most
common responses included:
46% of respondents reported they did nothing about the discrimination because they
were unsure of what to do;
39% of respondents reported moving or finding another place to live; and
15% of respondents reported they did nothing about the discrimination because they
were afraid of being evicted or harassed.
When asked about what type of fair housing activities are most needed in the city, the most
common responses included:
46% of respondents wanted to see more resident education available;
36% of respondents wanted to see education and training made available for local
officials and staff;
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27% of respondents wanted to see assistance made available for filing fair housing
complaints; and
14% of respondents identified implementing testing programs in the city to ensure
people are not denied housing due to unlawful discrimination.
Fair housing complaints. The U.S. Department of Housing and Urban
Development (HUD) receives and investigates housing complaints. HUD provided data on
complaints from January 1, 2019, through September 30, 2023, for this study. Seven
complaints were received by HUD in the city of Bozeman during this period.
Figure VI-1 shows the number of complaints by protected class from 2019 to 2023. The
most common protected classes affected are physical disability (5 complaints). The other
two cases during this time period were filed on the basis of race and retaliation,
respectively.
Figure VI-1.
Count of Protected
Classes in all
Complaints, City of
Bozeman, January
2019 to September
2023
Note:
Complaints can have more than one
protected class.
Source:
U.S. Department of Housing and
Urban Development (HUD)
Complaint Responsive Records,
2019-2023
Figure VI-2 shows the number of complaints by resolution. Of the seven complaints filed
between 2019 and 2023, two were resolved through a successful conciliation settlement,
one was resolved through a no cause determination, and the other complaint was
withdrawn without resolution.
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Figure VI-2.
Count of Resolution of Complaints, City of Bozeman, January 2019 to
September 2023
Note: Closure reason not provided for three cases.
Source: U.S. Department of Housing and Urban Development (HUD) Complaint Responsive Records, 2019-2023
Legal cases. To support the complaint analysis, we searched U.S. Department of Justice
for housing and civil enforcement section cases in Bozeman. There was one case identified
at the time of this report.
United States v. Katz and All Real Estate Services in Montana, LLC (Disability).13
This 2014 case involved alleged violations that a property manager with All Real Estate
Services in Bozeman, Montana charged a $1,000 pet deposit for a service animal owned by
a tenant with a traumatic brain injury, despite being requested to waive the deposit as a
reasonable accommodation pursuant to Section 804(f) of the Fair Housing Act. The
complaint also alleged that the defendant threatened to evict the tenant after the tenant
sought the return of the deposit in violation of Section 818 of the Fair Housing Act. In 2017,
the jury returned a verdict in favor of the plaintiff, awarding the tenant approximately
$31,000 in compensatory and punitive damages and approximately $6,000 in compensatory
damages to the fair housing group that assisted the tenant with the HUD complaint.
Land Use, Public Policies, and Practices
The Federal Fair Housing Act’s requirement to affirmatively further fair housing includes
avoiding policies and/or practices that limit the fair housing choice of the individuals and
households protected by the Act.
Land development codes cannot contain standards, definitions, or procedures that result
in differential treatment in housing which can disproportionately affect the classes
protected under the FHA. In addition, land development regulations that increase
development costs, e.g., through density or design requirements that make residential
development overly expensive, can limit the supply of affordable housing. In some
communities, this has a direct impact on racial and ethnic minorities, larger households
and families with children, and persons living with disabilities because these groups are
disproportionately represented among those residing in lower cost housing. Limits or
13 https://www.justice.gov/crt/case/united-states-v-katz-and-all-real-estate-services-montana-llc-d-mont
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prohibitions on multifamily housing or restrictions on household occupancy are other
examples of how land development codes can negatively affect the groups protected
under FHA.
The Americans with Disabilities Act (ADA) prohibits discrimination based on disability,
defined by ADA as a physical or mental impairment. The ADA requires accessibility in public
places (i.e., open to and used by the public) and also requires that “reasonable
accommodations” be allowed when necessary to permit persons with disabilities equal
opportunity to enjoy such places. The accessibility provision in the FHAA governs
residential accessibility, and requires that multifamily buildings built after March 13, 1991
have specific accessible design features and be adaptable. In addition, the FHAA ensures
that persons living with disabilities have the right to request and be granted modifications
to residential units—as well as local regulations and standards—to make a residence or
building accessible to them.
Common regulatory barriers. Some of the key factors in land development codes
that most commonly result in barriers to fair housing choice and reasonable
accommodation include:
Site standards. Large lots or excessive setbacks between structures or from streets
that can increase development costs, e.g., special infrastructure;
Limits on density. Restriction on or prohibition of multifamily housing; low floor
area ratios (FAR) for multifamily or mixed-use development; or low density
requirements;
Use-specific standards. Special site or operational requirements for group homes
for persons with disabilities that are not required for other residences or groups;
Differences in quality and access to public services. Additional requirements
for infrastructure or essential municipal services not required for other residences or
dwelling units;
Definition of family and occupancy restrictions. Definitions of family or
occupancy limits that prohibit or limit the number of unrelated persons in a
household;
Procedures for development or rezone reviews. Extensive review procedures,
public hearings, or notice requirements for different housing types, housing for
protected classes, or low-income housing;
Housing types. Limits or prohibitions on alternative affordable housing options
such as accessory dwelling units (ADUs), modular or manufactured homes, and mixed-
use developments;
Spacing. Minimum distance between group homes that are not required for other
residences or groups and make development of group homes difficult;
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Reasonable accommodations. Regulations inhibiting modifications to housing
for persons with disabilities or their ability to locate in certain neighborhoods; and
Code language. Local land development codes and standards that are not aligned
with federal and state regulations governing fair housing and reasonable
accommodation.
Zoning and land use review. In 2022, the City of Bozeman began the process of
updating its Unified Development Code (UDC) to implement the vision and goals
established in the city’s guiding documents, such as the 2020 Community Plan (a.k.a.,
Growth Policy), the Climate Plan, and strategic priorities like affordable housing. In late
2023, the Mayor and City Commission decided to put the UDC update on hold to offer
more opportunities for residents to provide their feedback.
As such, the zoning and land use review for this Fair Housing Plan will focus on providing
best practices based on a checklist developed by the Region IX HUD office (“Review of
Public Policies and Practices—Zoning and Planning Code). The checklist poses a series of
questions related to common zoning regulations that impact fair housing. These best
practices will be considered for incorporation into the City’s new UDC once the process
resumes.
1. Is there a definition of “family” and does it discriminate against group living for
persons with disabilities?
Some jurisdictions have moved away from defining “family” to avoid potential FHAA
conflicts and instead rely on occupancy standards to regulate residential overcrowding.
The “Scarborough 11” case in Hartford, Connecticut provides a strong case for
removing narrow definitions of family from local codes. Current best practices indicate
a broader definition of family increases housing opportunity and flexibility for all
residents by allowing more unrelated people to live together. The best practice
definition of family, “does not distinguish among housekeeping units on the basis of
blood, marriage, or adoptive relationship, which avoids the problem of discrimination
against individuals residing in group living facilities.” 14
2. Are there any occupancy standards or maximum occupancy limits?
According to HUD, “unreasonable occupancy limits on the number of persons who may
occupy a unit may violate the Act’s prohibition on discrimination against families with
children. HUD guidance advises that as a general rule, an occupancy policy of two
persons per bedroom is reasonable under the Act.”15 However, the reasonableness of
the policy might depend on certain factors, such as the size and/or configuration of the
14 Group Homes: Strategies for Effective and Defensible Planning and Regulation; Connolly, Brian and Merriam, Dwight.
15 https://www.hud.gov/program_offices/fair_housing_equal_opp/general_faq_housing_providers_and_fair_housing
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unit and sleeping areas.16 HUD’s guidance is intended to help determine whether the
occupancy limits applied by a housing provider may discriminate based on familial
status.
3. Is the number of unrelated disabled individuals residing together restricted but
there is no restriction for other persons?
A best practice to minimize potential conflict with FHAA is to allow housing with support
services for persons with disabilities serving six or fewer persons as a permitted use in
all residential zones and in all other zone districts that permit any residential use. The
facility should be reviewed under the same review procedures and requirements as for
the permitted dwelling-type to be occupied by the facility. Requiring discretionary
review in the form of a conditional use permit explicitly for seniors and individuals with
developmental disabilities—regardless of the number of occupants—leaves the city
open for litigation.
Group Homes: Strategies for Effective and Defensible Planning and Regulation states, “Local
governments should be wary of employing discretionary review proceedings during the
approval process for housing for people with disabilities [or seniors], primarily because
of the discretionary processes’ potential to attract litigation and because of the
difficulty of crafting such a process in a way that comports with the FHAA.” 17
4. Is “disability” defined and is the definition the same as FHAA?
Including a definition of “disability” or “person with disabilities” that aligns with FHAA
and ADA is a best practice. A definition can be included in the definitions section of the
zoning code. Codes with a section detailing the process to request a reasonable
accommodation could be improved by adding a definitions sub-section that
consolidates key words or phrases, including “disability” or “person with disabilities” for
ease of reference. Language could be added to clarify that the definitions contained in
the reasonable accommodation section apply to all other sections of the zoning or land
development code.
In defining disability, it is important to include the broad definition that has been
interpreted by the courts to apply to the Fair Housing Act, which includes persons in
recovery from substance abuse challenges and persons with HIV/AIDS.18
5. Are housing opportunities for persons with disabilities restricted or
mischaracterized as a “boarding or rooming house”?
16 https://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDF
17 Group Homes: Strategies for Effective and Defensible Planning and Regulation; Connolly, Brian and Merriam, Dwight.
18 Group Homes: Strategies for Effective and Defensible Planning and Regulation; Connolly, Brian and Merriam, Dwight.
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Group living can sometimes be mischaracterized as “boarding” or “rooming” homes.
This can occur when land development codes do not include a land use category or
categories for group living situations. Terms such as “congregate care,” “group living,”
“care facility,” or “residential home” may be used. Residences offering the same living
situation to similar groups of people may be placed in different land use categories.
Those land uses may be allowed in different zone districts or processed under different
review procedures. Terminology can be confusing or may specify only certain groups of
persons (i.e., certain types of disabilities). This can create barriers to group living for
people living with disabilities and are impediments to fair housing choice. Group living
situations should be based on land use attributes rather than the occupants of the
facility or residence and overlapping definitions should be removed.
6. Does the zoning code allow housing with on-site support services for persons
with disabilities?
Regardless of whether group homes provide on-site, in-home services or not, group
homes should be allowed in all residential zone districts where single-family housing is
allowed by right.
7. Are there definitions for “special group residential housing” and if so, do the
definitions align with FHAA?
Please see the discussion under items three and five above.
8. Is there a process to allow waivers of zoning and building code regulations for
reasonable accommodation for persons with disabilities?
A best practice is to implement a procedure for providing a reasonable accommodation
in land use, zoning and building regulations, policies, practices and procedures. Some
codes identify typical requests, such as a setback waiver for wheelchair ramps, as
administrative in nature when it does not exceed a certain amount. Such requests are
processed the same as any other building permit. Other reasonable accommodation
requests are processed with a more detailed administrative review using criteria that
comply with FHAA and ADA. This clarifies how a reasonable accommodation is
reviewed and removes such requests from consideration under procedures and criteria
that do not fit the circumstances of the request. When the reasonable accommodation
request does not qualify for administrative review, a review before an appointed body
can be used. However, the same criteria for deciding the request must be used:
➢ Whether the person to be accommodated has a disability;
➢ Whether the modification requested is reasonably necessary to
accommodate that disability; and
➢ Whether the modification would fundamentally and unreasonably alter the
nature or purposes of the zoning ordinance. The burden is on the
municipality to prove this would occur.
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The International Building Code (IBC) allows appeal of decisions of the building official
and decisions can be made based on “alternate equivalency” to meeting the IBC
requirement. The building code does not tie the determination of an alternative to the
physical characteristics of the property or building, making the standard appeal process
available to process requests for reasonable accommodation. Examples may include
lower sink heights to accommodate a person in a wheelchair, or special positioning of
grab bars to accommodate different types of disabilities.
9. Are public hearings required for exceptions to land use codes for disabled
applicants but no hearing is required for all other applicants?
Please see discussion under item three above.
10. Are mixed-uses allowed and is housing for persons with disabilities and other
protected classes permitted where mixed-use is allowed?
A best practice is to include mixed-use zone districts as base zone districts with all
zoning requirements established in the zoning code. This minimizes procedural delays
and public hearings associated with planned development and overlay districts. Mixed-
use zone districts should allow a range of housing types as permitted uses and include
group living facilities.
11. What type of residential land uses are allowed and what standards apply?
a. Is there variety in allowed single-family and multi-family residential land uses?
A best practice is to incorporate residential unit classifications, zone districts, and
site design requirements for alternative housing types (e.g. tiny homes, cottage
housing, courtyard development, micro-homes, and cooperative housing). This
minimizes delay in the approval process, reduces costs, and educates zoning and
building officials and the entire community about these housing types and who it
will serve.
b. Do densities and development standards (lot size, height, etc.) support low- and
middle-income housing options?
A best practice is to allow flexibility for “gentle density” such as duplexes to
triplexes, to accommodate demand for missing middle housing, promote economic
integration, and meet current preferences in housing. Some communities allow
these densities if the units carry a level of affordability (e.g., 80-120% AMI to
facilitate middle income ownership).
c. Are accessory dwelling units (ADU) allowed?
A best practice is to permit accessory dwelling units by right in all residential
districts.
d. Is design review required for multi-family housing or group living?
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If design review is required for certain housing types, a best practice is to ensure
that design requirements are consistent and can be objectively met, as well as
ensuring the process of design review is predictable and efficient.
e. Are there special site improvement standards for certain types of housing?
If site improvement standards are established for certain types of housing, a best
practice is to ensure that the standards are consistent and can be objectively met.
12. Does the zoning code describe any areas as exclusive?
It is a best practice to remove exclusionary language from the code.
13. Are there restrictions for senior housing and if so, do the restrictions comply with
Federal law on housing for older persons?
See discussion in item three on group homes for seniors.
14. Is senior housing a specific land use and if so, is a special or conditional use
permit required but is not required for single-family or multi-family residential
uses?
Group homes for seniors should be permitted by right where single-family residential
used are allowed.
15. Is a conditional or special use review permit required for housing for persons
with disabilities but is not required for single-family or multi-family residential
uses?
Group homes for individuals with developmental disabilities should be permitted by
right where single-family residential used are allowed.
16. Are there any references to fair housing or a statement about fair housing in the
zoning code?
A best practice is to include a statement in the purpose of the zoning ordinance that
discusses fair housing law or to include a cross-reference that identifies the adopted
planning documents that discuss and contain policies related to fair housing.
17. Are there specific references to the accessibility requirements of FHAA or ADA in
the development codes?
It is a best practice to include references to the FHAA or ADA accessibility requirements
in the code. Specifically, minimum standards for handicap parking for multi-family
housing, as well as standards for accessible routes (e.g., sidewalks and access through
parking lots), should be articulated.
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Jurisdictional review. Stakeholders consulted in the development of this Fair
Housing Plan expressed concerns with regulatory barriers to affordable housing
development in Bozeman. The following best practices are aimed at improving local zoning
regulations and policies to promote the construction of affordable housing in jurisdictions.
Expedite the process. Stakeholders shared that the entitlement process can be
onerous and lengthy in some cases and inconsistent information and lack of urgency
to move developments through the process can add costs to a project. Expediting the
permitting process for affordable housing is common and is considered a best practice
for encouraging affordable housing construction cost effectively.
➢ In the 2020 Community Housing Action Plan, the City identified “Removal of
Regulatory Barriers” as one of its Action Plan strategies. One of the sub-
strategies is “ensur[ing] the process is predictable, transparent, useful and
that codes produce what we want.”
Make design standards more objectives. Stakeholders felt that current design
standards are cost prohibitive and burdensome with no substantive benefits to
developing affordable housing. Stakeholders suggested updating the code to simplify
design standards or make them objective.
Increase local resources for housing. Stakeholders advocated for increased funding
for affordable housing projects in municipal and county budgets.
➢ In the 2020 Community Housing Action Plan, the City identified “Taxed
Dedicated to Housing” and “Commercial Linkage” as two strategies to
increasing dedicated funding to affordable housing development.
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Bozeman Fair Housing Activities
The City of Bozeman’s new Annual Action Plan proposes that CDBG funds be used for the
following affordable housing activities and housing related public service activities that will
support the city’s efforts to affirmatively further fair housing:
The City will develop a fair housing page on its website, which will include information
on the Federal Fair Housing Act, the Montana Human Rights Act, fair housing-related
education and training opportunities, and local resources and organizations available
to help residents learn more about fair housing.
One of the goals articulated in the City’s Belonging in Bozeman plan is to “Increase
community knowledge in housing issues.” As such, the City will work with a variety of
partners to host workshops on the Montana Tenant Act and Fair Housing Act for
landlords and tenants, becoming a Housing Choice Voucher landlord, and resident-
owned community models.
Fair housing activities since 2018. This section provides a summary of activities
undertaken by the City to improve fair housing choice since 2018.
Belonging in Bozeman—Equity and Inclusion Plan. The City of Bozeman recently
completed the region’s first Equity and Inclusion Plan. During the Equity Indicators Project,
the City set out to characterize what inequity looks like in Bozeman, a city where about 55%
of residents are renters and about 86% of the population is white, non-Hispanic.
Bozeman’s Equity Indicator Project found housing access to affordable housing was the top
need identified by 69% of survey respondents. The housing goals and recommendations
outlined include:
Develop a coordinated strategy to address homelessness;
Reduce displacement of residents who work and go to school in Bozeman but cannot
afford to live here;
Promote aging-in-place and universally accessible residential development;
Increase community knowledge in housing issues; and
Support and defend local housing solutions at the state legislature.
Code Audit to Create and Preserve Housing. The City’s first Inclusionary Zoning
policy was adopted in 2007. In 2021, the Montana State Legislature passed a bill prohibiting
local governments from requiring the creation of affordable housing with residential
development. As a result, communities must now use incentives to encourage developers
to build affordable housing rather than requiring that they do so. The City now offers
incentives to property owners and developers willing to construct housing at levels of
affordability consistent with the housing needs and goals identified in the Bozeman
Community Plan, the Community Housing Needs Assessment, and the Community Housing
Action Plan.
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Ordinance 2104 establishing new Planned Development Zones (PDZ) and Ordinance 2105
establishing the new Affordable Housing Ordinance (AHO) have both received final
adoption from the Bozeman City Commission and took effect in October 2022.
Affordable housing ordinance. Removing regulatory barriers does not ensure that
more affordable housing will be created, or that more permanently affordable housing will
be created, but can represent a set of incremental changes that, cumulatively, can improve
both housing availability and affordability.
The purpose of the new Affordable Housing Ordinance (AHO) is to:
Create more affordable housing; preserve existing affordable housing;
Make development standards more predictable;
Rethink the housing review process; and
Revise the zoning map.
Planned development zone ordinance. The purpose of the Planned Development
Zone (PDZ) district is to provide a structure and plan for specific properties to encourage
flexibility and innovations that: create distinct neighborhoods with quality urban design
and mutually supportive issues; support implementation of community plans and goals,
including the City’s adopted growth policy; provide community benefits through the
creation of affordable housing, inclusion of environmentally sustainable design features,
and retention of historic structures; and protect and promote the health, safety, and
general welfare of the community.
Departures for housing creation ordinance and accessory dwelling units. The
intent of this provision is to allow minor departures from existing residential standards
when the City determines that the departure will reduce the cost of production of and an
increase production of housing while maintaining consistency with the City’s adopted
growth policy. These departures are especially applicable to infill sites and missing middle
housing. The departures ordinance also includes provisions making Accessory Dwelling
Units (ADUs) easier and more cost effective for property owners to build. ADUs may be
permitted in all zoning districts.
2019 Community Housing Needs Assessment. The Community Housing Needs
Assessment was completed to help the City identify, understand, and address the housing
challenges and problems faced by local residents and employees in the city. The
Assessment states that more housing more diversity in housing needed at prices that
residents and employees can afford and that provides them choices, the ability to move as
life circumstances change and that allows employers to fill jobs, recruit and retain
employees and support business, resident and student growth. The goal should be to meet
the spectrum of needs. The Assessment calls for the creation of a comprehensive
Affordable Housing Action Plan that includes: mandates the creation of affordable housing
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across all dwelling types; provides prescribed flexibility in the manner in which the
mandate can be accomplished; provides a substantial, broad-based and reliable source of
funding for the construction of affordable housing and for affordable housing loans; and to
actively encourages Bozeman’s major employers to develop workforce housing programs
for their employees.
2020 Community Housing Action Plan. The Bozeman Community Housing Action
Plan (CHAP) outlines a partnership framework to address affordable housing in Bozeman
over a five-year period. The partnership framework for accelerating community housing in
Bozeman is based on the recognition that no one entity can solve the local housing
challenges – it takes a community to build a community. The Plan presents a set of actions
that address a range of community housing needs. It was developed to begin addressing
identified community housing needs and to create a lasting framework for implementation
that will evolve as the community and its housing needs continue to evolve. The CHAP
defines community housing as: homes that those who live and/or work in Bozeman can
afford to purchase or rent. This includes apartments, townhomes, condominiums,
emergency shelters, accessory dwelling units, mobile homes, and single-family homes – all
dwelling types – serving the entire spectrum of housing needs.
2020 Bozeman Community Plan (Growth Policy). The Bozeman Community Plan
establishes goals to increase the supply of affordable housing in the city. To fulfill these
goals, the community plan, or growth policy, establishes numerous objectives to promote
housing affordability and diversity through increased supply of certain types of housing.
The Bozeman Community Plan makes clear that although Bozeman is very focused on
improving the affordability of housing, it remains thoroughly committed to the quality of
buildings, neighborhoods, and life for all residents. There should be no visible distinction
between the quality of planning, connectivity, open space, or building design between the
approved development plans for more and less affordable parts of the city.
This commitment to equity is both laudable and important. Households with fewer choices
are often denied full integration into a community’s quality of life, and that denial often has
disproportionate impacts on households that are lower income and/or headed by persons
of color, women, and those experiencing disability. As a practical matter, one of the most
effective ways to ensure equitable access to the City’s quality of life is to ensure that new
opportunities for more affordable housing are not geographically isolated or focused in a
particular area but are instead spread throughout Bozeman and served by the same types
of public spaces and services provided to other Bozeman residents. Growth policy goals
and actions include:
Encouraging distribution of affordable housing units throughout the city with priority
given to locations near commercial, recreational, and transit assets; and
Development of affordable housing through coordination of funding for affordable
housing and infrastructure.
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2018 Bozeman Strategic Plan. Limited housing opportunities within the city negatively
impacts economic development, transportation networks, and sustainability. Affordable
housing needs must be addressed to maintain a sufficient resident workforce in all fields of
employment, and to ensure the public safety and general welfare of the residents of the
city, affordable housing needs must be addressed.
The Bozeman City Commission identifies affordable housing as one of its top strategic
goals: “Housing and Transportation Choices – Vigorously encourage, through a wide variety
of actions, the development of sustainable and lasting housing options for under-served
individuals and families and improve mobility options that accommodate all travel modes.”
The Strategic Plan also outlines frameworks to:
Create a safe, healthy and welcoming inclusive community;
Ensure Bozeman continues to welcome diversity through policies and public
awareness; and
Anticipate, celebrate, and incorporate an increasingly diverse population into the
community, city advisory boards, and city staff.
Regional Housing Coalition. The Regional Housing Coalition (RHC) is a cross-sector
group of diverse partners and resources that creates solutions to address the most
pressing housing-related needs in Gallatin County. RHC members include elected officials
and public sector leaders, nonprofit affordable housing developers, homeless service
providers, banks, realtors, employers, and more. The RHC is working to create housing
solutions for some of our most at-risk populations.
The City of Bozeman is a key partner in the work of the RHC. The RHC partners with City
staff and elected officials around several of the City Commission’s priorities. The RHC’s
‘Unhoused to Housed Initiative’ brings together representatives from the City of Bozeman,
Belgrade, Big Sky, West Yellowstone, Three Forks, HRDC, Family Promise and a number of
other organizations that interface with our unhoused populations to develop a single
regional strategy, eliminate siloes, and conduct a needs assessment that will inform where
resources should be directed.
The RHC ‘Permanent Affordability Workgroup’ is bringing City staff together with the
region’s key affordable housing stakeholders to determine how to develop deed-restricted
housing faster and more efficiently. This work is essential to identifying ways to expand
future affordable housing development.
The RHC ‘Communications Workgroup’ is working in partnership with a communications
and marketing firm to develop a comms plan that will ensure that all RHC member
organizations can deploy coordinated messaging around housing so that the public can
gain more informed understanding of the work being done to address the current housing
shortage as well as the factors impacting affordability.
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Between the quarterly RHC meetings and multiple workgroups, the RHC provides many
valuable connections and services to the City.
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Version April 2020
RESOLUTION 5604
A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF BOZEMAN,
MONTANA, ADOPTING THE 2024-2029 CONSOLIDATED HOUSING PLAN, 2024-2029
FAIR HOUSING EQUITY PLAN, AND THE 2024 ANNUAL HOUSING ACTION PLAN.
WHEREAS, the Consolidated Plan, Annual Action Plan, and Fair Housing Plan support
the work of the City of Bozeman in the administration of the Community Development Block
Grant (CDBG) fund. The CDBG Entitlement Program provides annual grants on a formula basis
to entitled cities to develop viable urban communities by providing decent housing and a suitable
living environment, and by expanding economic opportunities, principally for low-and moderate-
income persons.
WHEREAS, eligibility for participation as an entitlement community is based on
population data provided by the U.S. Census Bureau and metropolitan area delineations published
by the Office of Management and Budget. The U.S. Department of Housing and Urban
Development (HUD) determine the amount of each entitlement grantee’s annual funding
allocation by statutory dual formula which uses several objective measures of community needs,
including the extent of poverty, population, housing overcrowding, age of housing and population
growth lag in relationship to other metropolitan areas.
WHEREAS, the Consolidated Plan guides policy and investment for housing, economic,
and other community development in Montana. It is designed to meet requirements set forth by
HUD and various housing and community development acts passed by the U.S. Congress. The
Consolidated Plan documents needs as affordable housing, homelessness, infrastructure,
community facilities, and economic development.
WHEREAS, on August 24, 2023, the City of Bozeman received notification from HUD’s
Region VIII Office of Community Planning and Development that the city has the sufficient
population to meet the definition of a Metropolitan City under the CDBG program and is eligible
to become what is known as an “entitlement jurisdiction” and is therefore eligible to receive CDBG
funding directly from HUD.
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Version April 2020
WHEREAS, on May 18, 2024 the City of Bozeman received notification from the Office
of Community Planning and Development (CPD) that the City’s Fiscal Year 2024 allocation for
the Community Development Block Grant (CDBG) is $325,859.00. These grant funds provide the
financial tools to support low- and moderate-income individuals, families, and communities to
address homelessness, affordable housing challenges, aging infrastructure, and economic
hardship.
WHEREAS, the Belonging in Bozeman Equity and Inclusion Plan outlines a collective
vision for the City of Bozeman where housing is available, affordable, accessible, and safe. The
plan proposes making equitable and inclusive housing a reality in Bozeman by focusing
strategically on homelessness, displacement, aging in place and universal building accessibility,
increasing community knowledge, and lobbying for local solutions at the state level, so that
Bozeman residents of all ages, abilities, and income levels can feel confident and secure in call
Bozeman their home.
WHEREAS, on June 15, 2024, a public hearing was held before the Economic
Development Board to provide the public an opportunity to comment on the plan development
process, community engagement strategy, and to identify other significant housing and community
development needs in the community. The Board unanimously agreed that addressing
homelessness is a critical need in the community and that the City should focus on the most at-risk
population with CDBG funding.
WHEREAS, the Bozeman Strategic Plan, adopted on April 16, 2018, via Resolution 4852,
calls for the City of Bozeman to vigorously encourage, through a wide variety of actions, the
development of sustainable and lasting housing options for underserved individuals and families
and improve mobility options that accommodate all travel modes.
WHEREAS, The Bozeman City Commission has demonstrated a strong commitment to
funding and facilitating safe, accessible, and affordable housing in Bozeman.
NOW, THEREFORE, BE IT RESOLVED by the City Commission of the City of
Bozeman, Montana, to wit:
Section 1
The 2024-2029 Consolidated Housing Plan, 2024-2029 Fair Housing Plan, and the 2024 Annual Housing Action Plan for the City of Bozeman, attached hereto as Exhibit A, are hereby adopted serving as a framework to identify housing and community development priorities that align with focus funding from HUD’s Community Planning and Development Programs.
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Version April 2020
Section 2
The City Manager is hereby authorized to submit the 2024-2029 Consolidated Housing
Plan, 2024-2029 Fair Housing Equity Plan, and the 2024 Annual Action Plan to the U.S.
Department of Housing and Urban Development for approval.
Section 3
The City Manager is further authorized to take all necessary actions to implement the strategies and objectives outlined in the Consolidated Plan, including but not limited to the
allocation and administration of federal funds received through HUD programs.
Section 4
Effective Date
The Resolution shall be in full force and effective upon passage.
PASSED, ADOPTED, AND APPROVED by the City Commission of the City of
Bozeman, Montana, at a regular session thereof held on the _____ day of ________, 20____.
___________________________________
TERRY CUNNINGHAM
Mayor
ATTEST:
___________________________________
MIKE MAAS
City Clerk
APPROVED AS TO FORM:
___________________________________
GREG SULLIVAN
City Attorney
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Community Development Block Grant Program Categories of Eligible Activities v 2-1
CHAPTER 2
CATEGORIES OF
ELIGIBLE ACTIVITIES
PurposePurpose This chapter describes in some detail the many categories of activity types
which may be assisted using CDBG funds. It also discusses a number of
activities that may not be so assisted. The chapter also contains guidance on
documenting compliance and making the best choice for selecting the
category to carry out an activity when more than one may apply.
The purpose of the chapter is to help ensure that grantees will: (1) use
CDBG funds only for activities that fall under an authorized category of
basic eligibility; (2) properly classify the activity; and (3) provide adequate
documentation as required by the category it selects for each such activity.
The importance of using CDBG funds only for eligible activities is self-
evident. The proper classification of each assisted activity by one of these
categories of eligibility is also important because the statute and regulations
place specific requirements on particular categories and not on others. For
example, there is a statutory and regulatory limitation on the amount of
CDBG funds which may be used for activities assisted under the category of
Public Services. Some services that are assisted under the program may also
be eligible under a category other than Public Services and, if properly
classified by the grantee as such, would therefore not be subject to the 15%
public service cap. There is also a limitation on the amount of CDBG funds
which may be used for activities under the categories of Planning and
Capacity Building and Program Administration. Likewise, there are other
categories under which these types of activities might also qualify and thus
not be subject to that cap.
The statute and regulations also place special requirements on certain
categories of eligible activities, such as Code Enforcement and Special
Economic Development Activities. An improperly classified activity may be
unnecessarily subject to additional program requirements. Conversely, an
activity may be carried out in a manner that does not meet the requirements
of the selected category but it might be eligible under the requirements of
another category not selected by the grantee for that activity.
347
2-2 v Categories of Eligible Activities Community Development Block Grant Program
ActivityActivity
CategoriesCategories
This chapter describes separately each category of basic eligibility under the
program, in the following order:
CATEGORIES OF ELIGIBLE ACTIVITIES PAGE
Acquisition of Real Property 2-3
Disposition 2-9
Public Facilities and Improvements 2-11
Clearance 2-18
Public Services 2-22
Interim Assistance 2-29
Relocation 2-33
Loss of Rental Income 2-35
Privately-Owned Utilities 2-36
Rehabilitation 2-38
Construction of Housing 2-47
Code Enforcement 2-51
Special Economic Development Activities 2-55
Microenterprise Assistance 2-63
Special Activities by CBDOs 2-66
Homeownership Assistance 2-73
Planning and Capacity Building 2-75
Program Administration Costs 2-77
Miscellaneous Other Activities 2-82
This chapter also discusses activities that are specifically ineligible and
further covers ways of documenting compliance with the activity selected
and how grantees can make the best choices, given the available options.
348
Community Development Block Grant Program Categories of Eligible Activities v 2-3
Acquisition ofAcquisition of
Real PropertyReal Property
EligibleEligible
ActivitiesActivities
The statute and regulations authorize the use of CDBG funds by a grantee or
a public or private nonprofit entity to acquire real property in whole or in part
by purchase, long-term lease, donation, or otherwise. In order to be
considered acquisition, a permanent interest in the property must be
obtained. Long-term leases are considered to constitute a permanent interest
for this purpose if the lease is for a period of 15 years or more.
More specifically, CDBG funds may be used under this category by:
4 The grantee,
4 Any other public agency,
4 A public nonprofit entity, or
4 A private nonprofit entity.
to acquire real property for any public purpose. This authority is subject to
the limitations at §570.207 (a)(1) which would preclude the acquisition cost
attributable to a building to be used for the general conduct of government
and §570.207(a)(3) which would preclude the acquisition of property to be
used for political activities. Reference: §570.201(a)
ExampleExample Real property to be acquired may be:
·Land,
·Air rights,
·Easements,
·Water rights,
·Rights-of-way,
·Buildings and other real property improvements, or
·Other interests in the real property.
Costs that may be paid for with CDBG funds under this category include the
cost of surveys to identify the property to be acquired, appraisals, the
preparation of legal documents, recordation fees, and other costs that are
necessary to effect the acquisition.
Real property acquisition under this category does not include:
v The costs of moveable equipment, furnishings, or machinery if this is
the principal purpose of the activity, since such items are not real
property. They may, however, qualify under another category, such
as Special Economic Development Actvities when needed for
349
2-4 v Categories of Eligible Activities Community Development Block Grant Program
carrying out an economic development project, or under Public
Services. (See discussion of these categories later in this chapter.)
v Acquisition of property which is then expected to be donated or sold
at less than the purchase price to the same entity from which the
property was purchased. This is not an eligible activity since it is not
considered to involve a legitimate change of ownership.
v Acquisition of newly-constructed housing or an interest in the
construction of new housing, unless such housing is already
constructed and for sale on the open market at the time that a
commitment is made to use CDBG funds for such a purchase. The
prohibition of this type of acquisition is based on the fact that such
acquisition would be considered to constitute assisting new new
housing construction, which is generally ineligible for CDBG
assistance. Reference: §570.207(b)(3)
Note: Acquisition of real property that does not meet the limitations for
eligibility under this category may be eligible for CDBG assistance under
other categories of basic eligibility. For example, CDBG funds may be
provided to private individuals and private for-profit entities to acquire real
property in the following situations:
v Under certain circumstances, CDBG funds may be provided to
private individuals and private for-profit entities to acquire property
to be rehabilitated, if the property is then rehabilitated and used or
sold for residential purposes. Reference: §570.202(b)(1)
v Private non-profit entities may use CDBG funds to acquire real
property for commercial or industrial uses, and private for-profit
entities may also do so when appropriate for an economic
development project. References: §570.203(a) and (b)
ComplyingComplying
With NationalWith National
ObjectivesObjectives¾¾
Acquisition ofAcquisition of
Real PropertyReal Property
Qualifying an acquisition activity under one of the CDBG national objectives
depends entirely on the use of the acquired real property following its
acquisition. A preliminary determination of compliance may be based on the
planned use. The final determination must be based on the actual use of the
property, excluding any short-term, temporary use. Where the acquisition is
for the purpose of clearance which will eliminate specific conditions of blight
or physical decay, the clearance activity may be considered the actual use of
the property. However, any subsequent use or disposition of the cleared
property must be treated as a “change of use” under §570.503(b)(8) or
§570.505, as applicable. If property is to be acquired for a general purpose,
such as housing or economic development, and the actual specific project is
not yet identified, the grantee must document the general use it intends for
the property, the national objective category it expects will be met, and make
a written commitment to use the property only for a specific project under
that general use that will meet the specified national objective.
350
Community Development Block Grant Program Categories of Eligible Activities v 2-5
Acquisition of real property may qualify as meeting a national objective in
any of the ways shown in the charts that follow.
AdditionalAdditional
ConsiderationsConsiderations
If property acquired with CDBG funds, or any interest therein, is
subsequently transferred to another entity, the property or interest must be
sold to the entity at the current fair market value unless the property will
be used for an activity which meets a CDBG national objective. Sale
proceeds would be program income.
The purchase of real property by the grantee or other entities under this
eligibility category is subject to the requirements of the Uniform Relocation
Assistance and Real Property Acquisition Policies Act of 1970. Among
other things, this could mean that persons displaced as a result of the
acquisition must be provided with financial assistance. Temporary
easements, acquisition from another public agency, and voluntary offers in
response to a public solicitation are exempt from Uniform Act requirements.
Reference: §570.606.
Since the ultimate use of the property determines how a national objective
will be met, whenever the use differs from that contemplated at the time of
acquisition, a review must be made of the new use to ensure it will meet a
national objective. When such review results in the determination that the
national objective being met differs from that ascribed to the activity initially,
an adjustment must be made to the program records for the program year in
which the acquisition occurred to reflect this change, provided that the
records for that year are still available at the time the new use is determined.
If the objective claimed for the original acquisition costs was that of benefit
to L/M income persons, and the objective being met by the new use falls
under either of the other two national objectives, the new use of the property
would be authorized only if the classification of the acquisition costs to the
new objective would not result in a violation of the “overall expenditures
certification” that the grantee made for the program year in which such costs
were incurred. See Chapter 4 of this Guide for further information on this
certification issue.
351
NATIONAL OBJECTIVES ¾¾ ACQUISITION OF REAL PROPERTY
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The property will be used for an activity
the benefits of which are available to all
the residents in a particular area that is
primarily residential, and at least 51% of
those residents (or fewer if the exception
criteria apply) are L/M income persons.
Purchasing land to be used as a park
serving a primarily residential
neighborhood that is predominantly L/M
income.
For more information, see page 3-7.
L/M Income
Limited
Clientele
The property will be used for an activity
the benefits of which will be limited to a
specific group of people, at least 51% of
whom are L/M income persons.
Buying a building to be converted into a
shelter for the homeless.
For more information, see page 3-14.
L/M Income
Housing
The property will be used for housing to
be occupied by L/M income persons.
Buying an apartment house to provide
dwelling units to L/M income
households at affordable rents, where at
least 51% of the units will be occupied
by L/M income households.
For more information, see page 3-19.
352
NATIONAL OBJECTIVES ¾¾ ACQUISITION OF REAL PROPERTY
Objective Qualifies If Example Additional Information
L/M Income
Jobs
The property acquired is to be used for
an economic development project that
will create or retain permanent jobs at
least 51% of which will benefit L/M
income persons.
Acquiring vacant property that is planned
to be used for a commercial purpose, and
will be made available for that purpose
only if the business commits to provide
at least 51% of the new permanent jobs
that will be created to L/M income
persons.
For more information, see page 3-24.
Slum or
Blighted Area
The acquired property is in an area
designated by the grantee as a slum or
blighted area, and the property will be
used in a manner which addresses one or
more of the conditions which contributed
to the deterioration of the area.
Using CDBG funds to acquire several
deteriorated buildings located in a
slum/blight area for rehabilitation or
demolition.
For more information, see page 3-35.
Spot Blight The acquisition of property is located
outside a designated slum/blight area and
the acquisition is a prerequisite for
clearance which will eliminate specific
conditions of blight or physical decay on
a spot basis.
The acquisition of a dilapidated property
being used as a “crack house” for the
purpose of eliminating that use, which is
detrimental to public health and safety,
through demolition and clearance.
For more information, see page 3-38.
353
NATIONAL OBJECTIVES ¾¾ ACQUISITION OF REAL PROPERTY
Objective Qualifies If Example Additional Information
Urban Renewal
Completion
The real property acquired is located
within an urban renewal project area or
an NDP (Neighborhood Development
Program) action area designated under
Title 1 of the Housing Act of 1949 and
the acquisition is necessary to complete
the current urban renewal plan.
The current, approved plan calls for a
specific property to be used for middle-
income housing which is currently being
used for other purposes. The acquisition
will allow the property to be cleared and
to be included with other contiguous
parcels for sale to an interested housing
developer.
For more information, see page 3-40.
Urgent Needs The acquisition is part of an activity
designated to alleviate existing
conditions and the grantee certifies that
those conditions are a serious and
immediate threat to the health or welfare
of the community, they are of recent
origin or recently became urgent, the
grantee is unable to finance the activity
on its own, and other sources of funds
are not available.
Acquisition of property located in a flood
plain which was severely damaged by a
recent flood.
For more information, see page 3-41.
354
Community Development Block Grant Program Categories of Eligible Activities v 2-9
DispositionDisposition
EligibleEligible
ActivitiesActivities
Under this category, CDBG funds may be used to pay costs incidental to
disposing of real property acquired with CDBG funds, including its
disposition at less than fair market value, provided the property will be used
to meet a national objective of the CDBG program.
The property may be disposed of through:
3 Sale,
3 Lease,
3 Donation, or
3 Otherwise.
CDBG funds may also be used under this category to pay reasonable costs
of temporarily managing such property (or property acquired with Urban
Renewal funds) until final disposition of the property is made. Reference:
§570.201(b).
ExampleExample Disposition costs include preparation of legal documents, as well as fees paid
for:
·Surveys,
·Marketing,
·Financial services, and
·Transfer taxes and other costs involved in the transfer of
ownership of property.
Caveat: Because this category only authorizes the costs of temporarily
managing property pending its disposition, care should be taken to avoid
spending CDBG funds to manage properties for which there are no plans for
disposition in the near future or where the market is such that it is not likely
to be sold in the near future, such as properties acquired many years ago
under the Urban Renewal program.
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
DispositionDisposition
For disposition costs to be eligible, the use of the CDBG-acquired property
after disposition must meet a national objective of the CDBG program.
When property is disposed of for the same purpose as that for which it was
acquired, the costs of disposition will be considered to meet the same
national objective ascribed to the CDBG funds spent on its acquisition. For
examples on how such acquired property may meet a national objective, see
the charts on National Objectives—Acquisition of Real Property on pages 2-
6 through 2-8.
355
2-10 v Categories of Eligible Activities Community Development Block Grant Program
If the property is being disposed of for a purpose other than that for which it
was acquired, the new activity must be reviewed to determine whether a
national objective will be met by the new use. See the discussion in the
preceding section on Acquisition of Real Property on page 2-4 for more
details. Property acquired with CDBG funds may be used for purposes that
do not meet a national objective, but only under conditions specified under
§570.503(b)(8) and §570.505.
AdditionalAdditional
ConsiderationsConsiderations
Gross proceeds from the disposition of real property acquired with CDBG
funds that are received by the grantee or a subrecipient are program income.
References: §570.201(b) and §570.500(a)(1)
356
Community Development Block Grant Program Categories of Eligible Activities v 2-11
Public Facilities andPublic Facilities and
ImprovementsImprovements
EligibleEligible
ActivitiesActivities
CDBG funds may be used by the grantee or other public
or private nonprofit entities for the:
3 Acquisition (including long term leases for periods of 15 years or
more),
3 Construction,
3 Reconstruction,
3 Rehabilitation (including removal of architectural barriers to
accessibility), or
3 Installation.
of public improvements or facilities (except for buildings for the general
conduct of government). Reference: §570.201(c)
Neither the statute nor the regulations define the terms “public facilities” or
“public improvements.” However, in the CDBG program, these terms are
broadly interpreted to include all improvements and facilities that are either
publicly owned or that are traditionally provided by the government, or
owned by a nonprofit, and operated so as to be open to the general public.
This would include neighborhood facilities, firehouses, public schools, and
libraries. Public improvements include streets, sidewalks, curbs and gutters,
parks, playgrounds, water and sewer lines, flood and drainage
improvements, parking lots, utility lines, and aesthetic amenities on public
property such as trees, sculptures, pools of water and fountains, and other
works of art. The regulations specify that facilities that are designed for use
in providing shelter for persons having special needs are considered to be
public facilities (and not permanent housing), and thus are covered under this
category of basic eligibility. Such shelters would include nursing homes,
convalescent homes, hospitals, shelters for victims of domestic violence,
shelters and transitional facilities/housing for the homeless, halfway houses
for run-away children, drug offenders or parolees, group homes for the
developmentally disabled, and shelters for disaster victims.
In the CDBG program, site improvements of any kind that are made to
property that is in public ownership are considered to be a “public
improvement” eligible for assistance under this category. This distinction
would be of particular importance if new housing is to be constructed on the
property and direct CDBG assistance to that construction would not be
eligible under program rules.
357
2-12 v Categories of Eligible Activities Community Development Block Grant Program
With one notable exception, this category does not authorize expenditures
for “buildings for the general conduct of government.” The exception is that
CDBG funds may be used to remove from such buildings material and
architectural barriers that restrict the mobility and accessibility of elderly or
severely disabled persons. Reference: §570.207(a)(1)
v As defined in the statute, the term “buildings for the general conduct
of government” means “city halls, county administrative buildings,
State capitol or office buildings or other facilities in which the
legislative, judicial or general administrative affairs of government
are conducted.” The term includes court houses but does not include
jails or prisons. It does not include buildings which are used to
deliver services to the public, such as police stations or fire stations.
“Mini-city halls,” which are used by some large communities to
make certain services available closer to the public, are also not
included under this term. Generally speaking, buildings which house
administrative functions of the government are considered to be
“buildings for the general conduct of government.” Thus, CDBG
assistance to a building in which the chief of police and the fire
captain of a city have their offices would generally be ineligible. For
small communities where one building provides both the
administrative functions and services directly to the public, a
determination should be sought from HUD as to whether the
building may be assisted under this category.
Public facilities and improvements authorized
under this category also do not include: Reference
v Costs of operating or maintaining public §570.207(b)(2)
facilities/improvements;
v Costs of purchasing construction §570.207(b)(1)(i)
equipment;
v Costs of furnishings and other personal §570.207(b)(1)(iii)
items such as uniforms; or
v New construction of public housing.§570.207(b)(3)
358
Community Development Block Grant Program Categories of Eligible Activities v 2-13
Complying withComplying with
NationalNational
ObjectivesObjectives¾¾
Public FacilitiesPublic Facilities
andand
ImprovementsImprovements
Except for highly specialized facilities, public facilities and improvements by
their nature are intended to benefit all the residents of an area. Thus, to
qualify under the national objective of benefit to L/M income persons, in
most cases they must serve an area having a sufficiently high percentage of
L/M income persons. The general rule is that the primarily residential area
must have at least 51% L/M income residents. Certain grantees are
authorized to use what is called the “upper quartile” percent in lieu of 51%
or more in the area served. See §570.208(a)(1)(ii). The charts following
Additional Considerations, below, show several ways that facilities and
improvements eligible under this category may meet a national objective of
the CDBG program. Note that public facilities that serve the entire
jurisdiction of the grantee, a main library for example, may qualify under the
L/M Income Benefit national objective only if the percentage of L/M income
persons in the entire jurisdiction is sufficiently high to meet the “area benefit”
test. Jails are considered to benefit the entire community served by the
facility and thus would have this same restriction. Some facilities by their
nature serve an area that is larger (sometimes much larger) than the
grantee’s jurisdiction. Regional parks and prisons fall into this category. In
such cases, it is important to note that the entire area served by the facility
must be considered in determining if it can meet the L/M Income Area
Benefit subcategory of the L/M Income Benefit national objective.
AdditionalAdditional
ConsiderationsConsiderations
Title to public facilities:
v Nonprofit entities frequently hold title to and operate facilities such
as senior centers, centers for the handicapped and neighborhood
facilities. When such facilities are owned by nonprofit entities, they
may qualify for assistance under this category only if they are made
available to the general public. Where applicable, facilities owned by
a nonprofit must be open for use by the general public during all
normal hours of operation. Reference: §570.201(c)
Facilities containing both eligible and ineligible uses:
v If a public facility contains both eligible and ineligible uses,
§570.200(b)(1) of the regulations should be consulted for special
qualifying criteria for the eligible portion of the facility.
Fees:
v Reasonable fees may be charged for the use of the facilities assisted
with CDBG funds, but charges, such as excessive membership fees,
which will have the effect of precluding L/M income persons from
using the facilities are not permitted. Reference: §570.200(b)(2)
359
2-14 v Categories of Eligible Activities Community Development Block Grant Program
Special assessments:
v Because many communities levy special assessments against
property owners to help pay for the costs of certain public facilities,
it is important to be aware of limitations, implications, and
requirements that are unique to the CDBG program in this regard.
v For purposes of the CDBG program, “special assessment” is defined
as the recovery of the capital costs of a public improvement, such as
streets, water or sewer lines, curbs, and gutters, through:
·a fee or charge levied or filed as a lien against a parcel of real
estate as a direct result of a benefit derived from the installation
of a public improvement; or
·a one-time charge made as a condition of access to the public
improvement.
v Where CDBG funds are used to pay all or part of the cost of a public
improvement, the rules (described in Appendix C to this Guide)
apply if special assessments are used to recover capital costs.
Reference: Section 104(b)(5) of the HCD Act
v There is no special category of basic eligibility authorizing the use of
CDBG funds to pay for special assessments. However, because of
the broad use of this technique for funding public improvements, the
use of CDBG funds to pay special assessments on behalf of property
owners for a public improvement has been considered to constitute a
form of using CDBG funds to assist the public improvement and is
thus authorized under this category. Therefore, all the rules
applicable to a CDBG-assisted public improvement apply even if
CDBG funds are only used to pay special assessments for that
improvement, but do not assist in the construction. This means that
Davis-Bacon applies, and the rules described in Appendix C about
the requirements to pay assessments on behalf of L/M income
property owners also apply.
360
NATIONAL OBJECTIVES ¾¾ PUBLIC FACILITIES AND IMPROVEMENTS
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The public facility or improvement will
be used for a purpose the benefits of
which are available to all the residents in
a particular area that is primarily
residential, and at least 51% of those
residents (or less if grantee qualifies to
use the exception rule) are L/M income
persons.
Paving of gravel streets and the
installation of curbs, gutters, and
sidewalks in a predominantly L/M
income neighborhood.
For more information, see page 3-7.
L/M Income
Limited
Clientele
The public facility or improvement will
be used for an activity designed to
benefit a particular group of persons at
least 51% of whom are L/M income
persons.
Rehabilitation of a building to be used as
a center for training severely disabled
persons to enable them to live
independently.
For more information, see page 3-14.
L/M Income
Housing
The public facility or improvement
exclusively assists in the provision of
housing to be occupied by L/M income
persons.
Site improvements on publicly-owned
land to serve a new apartment structure
to be rented to L/M income households
at affordable rents.
For more information, see page 3-19.
361
NATIONAL OBJECTIVES ¾¾ PUBLIC FACILITIES AND IMPROVEMENTS
Objective Qualifies If Example Additional Information
L/M Income
Jobs
The provision of a particular public
improvement needed by one or more
businesses to allow creation or retention
of jobs, primarily for L/M income
persons.*
Rebuilding a public road adjacent to a
factory to allow larger and heavier trucks
access to the facility, determined to be
necessary for plant expansion and the
creation of new jobs, where the business
agrees to fill 51% of the jobs with L/M
income persons.*
For more information, see page 3-24.
Slum or
Blighted Area
The public facilities and improvements
are located in a designated slum or
blighted area and are designed to address
one or more conditions which
contributed to the deterioration of the
area.
Reconstruction of a deteriorated public
park located in an area designated by the
grantee as slum or blighted pursuant to
CDBG rules.
For more information, see page 3-35.
* In certain cases, the area served by a public improvement that enables a business to create or retain jobs may also include other properties
(e.g., bringing new water or sewer service to a fringe area of a community that will not only help a business to locate there but that also will bring
that new water/sewer service to houses that are located in that area). When, overall, the properties served by the public improvement are
primarily residential, the benefits to the residents must also be considered. Therefore, the assisted public improvement in such a case must not
only meet the L/M Income Benefit based on the Jobs criteria but must also meet the Area Benefit criteria Reference: §570.208(d)(3)
(See also the discussion on page 3-27 of this Guide concerning the case where more than one business may create or retain jobs as a result of a
public improvement.)
362
NATIONAL OBJECTIVES ¾¾ PUBLIC FACILITIES AND IMPROVEMENTS
Objective Qualifies If Example Additional Information
Spot Blight The public facilities or improvements are
for the historic preservation or
rehabilitation of blighted or decayed public
facilities/improvements located outside of
a designated slum or blighted area.
Rehabilitation must be limited to the extent
necessary to eliminate specific conditions
detrimental to public health and safety.
Rehabilitation/restoration of a severely
deteriorated building of historic
significance that is being used as a
museum that is located outside a
designated slum or blighted area (and does
not serve a L/M income area).
For more information, see page 3-38.
Urban Renewal
Completion
The public facilities and improvements are
located within an urban renewal project
area (or an NDP action area), designated
under Title I of the Housing Act of 1949,
and the public facilities/improvements are
necessary to complete the urban renewal
plan.
Construction of a publicly-owned parking
garage in an urban renewal project area
where the garage is specified in the urban
renewal plan and is necessary to complete
the plan.
For more information, see page 3-40.
Urgent Needs The acquisition, construction, or
reconstruction of a public facility or
improvement designed to alleviate existing
conditions and the grantee certifies that
those conditions are a serious and
immediate threat to the health or welfare
of the community, the conditions are of
recent origin, and there is no other known
source of funds it can use to implement the
activity.
Reconstruction of a publicly-owned
hospital that was severely damaged by a
tornado.
For more information, see page 3-41.
363
2-18 v Categories of Eligible Activities Community Development Block Grant Program
ClearanceClearance
EligibleEligible
ActivitiesActivities
Under this category, CDBG funds may be used for:
3 Demolition of buildings and improvements;
3 Removal of demolition products (rubble) and other debris;
3 Physical removal of environmental contaminants or treatment of such
contaminants to render them harmless; and
3 Movement of structures to other sites.
Reference: §570.201(d)
Caveat: Demolition of HUD-assisted housing may be undertaken only with
the prior approval of HUD.
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
ClearanceClearance
Clearance activities may qualify as meeting a national objective of the
CDBG program in the ways depicted in the charts on the following pages.
AdditionalAdditional
ConsiderationsConsiderations
Where activities under this category are integral to the construction of a
building or improvement on the cleared property, and where such
construction is also to be assisted with CDBG funds, the clearance activities
may be treated as a part of the construction costs and need not be qualified
separately under the program.
364
NATIONAL OBJECTIVES ¾¾ CLEARANCE
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The cleared property will be used for a
purpose the benefits of which are
available to all the residents in a
particular area, and at least 51% of those
residents (or less if the exception criteria
are applicable) are L/M income persons.
Demolishing a vacant structure and
removing the debris to make a
neighborhood park and playground
serving a predominantly residential L/M
income neighborhood.
For more information, see page 3-7.
L/M Income
Limited
Clientele
The cleared property will be used for an
activity the benefits of which are limited
to a specific group of people, at least
51% of whom are L/M income persons.
Demolishing a dilapidated structure from
the site on which a neighborhood center
will be built, the use of which will be
limited to the elderly.
For more information, see page 3-14.
L/M Income
Housing
The cleared property will be used for
providing housing to be occupied by
L/M income persons. Rental units for
L/M income persons must be occupied
at affordable rents.
Demolishing an abandoned warehouse to
make room for new apartments, where at
least 51% of the units will be occupied
by L/M income households at affordable
rents.
For more information, see page 3-19.
365
NATIONAL OBJECTIVES ¾¾ CLEARANCE
Objective Qualifies If Example Additional Information
L/M Income
Jobs
The clearance is part of an activity that
will create or retain permanent jobs, at
least 51% of which are for L/M income
persons.
Using CDBG funds to clear a site on
which a new business will locate and
agrees that at least 51% of the jobs to be
created will be for L/M income persons.
For more information, see page 3-24.
Slum or
Blighted Area
The clearance activities are in a
designated slum or blighted area and are
designed to address one or more
conditions which contributed to the
deterioration of the area.
Using CDBG funds to demolish one or
more deteriorated buildings located in a
designated slum or blighted area.
For more information, see page 3-35.
Spot Blight The clearance activity is undertaken to
eliminate specific conditions of blight or
physical decay on a spot basis not
located in a designated slum or blighted
area.
Demolition of an abandoned and
deteriorated structure located in an area
that is not designated as a slum or
blighted area.
For more information, see page 3-38.
366
NATIONAL OBJECTIVES ¾¾ CLEARANCE
Objective Qualifies If Example Additional Information
Urban Renewal
Completion
The clearance activities are located
within an urban renewal project area (or
an NDP action area), designated under
Title I of the Housing Act of 1949, and
such activities are necessary to complete
the urban renewal plan.
Clearance of a property located in an
urban renewal project area and which is
specified in the urban renewal plan and
necessary to complete the plan.
For more information, see page 3-40.
Urgent Needs The clearance is part of an activity
designed to alleviate existing conditions
and the grantee certifies that those
conditions are a serious and immediate
threat to the health or welfare of the
community, they are of recent origin or
recently became urgent, the grantee is
unable to finance the activity on its own,
and other sources of funds are not
available.
Clearance of a building that was
destroyed by a major earthquake and that
constitutes a safety hazard to the
community.
For more information, see page 3-41.
367
2-22 v Categories of Eligible Activities Community Development Block Grant Program
Public ServicesPublic Services
EligibleEligible
ActivitiesActivities
Under this category, CDBG funds may be used to provide public services
(including labor, supplies, materials and other costs), provided that each of
the following criteria is met:
(1)The public service must be either:
3 A new service; or
3 A quantifiable increase in the level of a service.
above that which has been provided by or on behalf of the unit of general
local government through funds raised by such unit, or received by such unit
from the State in which it is located during the 12 months prior to
submission of the grantee’s applicable Action Plan. (This requirement is
intended to prevent the substitution of CDBG funds for recent support of
public services by the grantee using local or State government funds.)
An exception to this limitation may be granted by HUD if it is determined
that the level of service from the previous period has decreased for reasons
beyond the unit of local government’s control. Reference: §570.201(e)
(2)The amount of CDBG funds obligated within a program year to support
public service activities under this category may not exceed 15% of the
total grant awarded to the grantee for that year plus 15% of the total
program income it received in the preceding program year or, where
applicable, the amount determined as described in the next paragraph.
(Specific description of how to calculate the Public Services Cap is
located on page 2-27.)
(3)A grantee that obligated more than 15% of its FY 1982 or of its 1983
grant for public service activities during its 1982 or 1983 program year,
respectively, may instead use for this purpose a limitation that exceeds
that described in (2), above. The amount of the alternative cap for such a
grantee shall be as follows:
The maximum amount that the grantee may obligate for public services
under this category is 15% of the program income it received during the
preceding program year; plus the greater of
368
Community Development Block Grant Program Categories of Eligible Activities v 2-23
·the actual dollar amount it obligated during the 1982 or 1983
program year; or
·the percentage of public service obligations comprised of the
grant it received for the 1982 or 1983 program year multiplied
by the grant it will receive for the program year for which the
alternative limitation is being computed. Reference:
§570.201(e)(2).
Note: The exception to the straight 15% limitation that is described in (3)
above is only available to those grantees that received authority from HUD to
exceed the 10% cap on public services for their 1982 or 1983 program year
and legally obligated in excess of 15% for public services that program year.
Public services that are not subject to the cap: Certain types of services fall
under other categories of basic eligibility and are not subject to the dollar
limitation that applies to services carried out under this category. (See
especially the categories of Homeownership Assistance, Special Economic
Development Activities, Microenterprise Assistance, and Special Activities
by CBDOs.) Moreover, under special circumstances, services that would
otherwise be subject to the dollar limitation under this category are exempted
from this limitation. (See especially Appendix E.) A discussion of the
factors to consider in deciding how to categorize public services that a
grantee may be interested in assisting with CDBG funds may be found in the
subsection entitled Making the Best Choice, at the end of this chapter on
page 2-92.
ExampleExample Public services include, but are not limited to:
·Child care,
·Health care,
·Job training (including training a qualified pool of candidates for unspecified
jobs but see Special Economic Development Activities and Special Activities
by CBDOs categories),
·Recreation programs,
·Education programs,
·Public safety services,
·Fair housing activities (but see Program Administration category),
·Services for senior citizens,
·Services for homeless persons,
·Drug abuse counseling and treatment,
·Energy conservation counseling and testing,
·Homebuyer downpayment assistance, and
·Welfare (but excluding provision of income payments described at
§570.207(b)(4)).
Paying the cost of operating and maintaining that portion of a facility in which the
service is located is also considered to fall under the basic eligibility category of
Public Services, even if such costs are the only contributions made by CDBG for those
services.
369
2-24 v Categories of Eligible Activities Community Development Block Grant Program
The following Public services are not eligible
under this category:Reference
v Political activities;§570.207(a)(3)
v Ongoing grants or non-emergency §570.207(b)(4)
payments (defined as more than 3 consecutive
months) to individuals for their food, clothing,
rent, utilities, or other income payments.
Complying withComplying with
NationalNational
ObjectivesObjectives¾¾
Public ServicesPublic Services
Public service activities may qualify as meeting a national objective of the
CDBG program as depicted in the charts on the following pages.
AdditionalAdditional
ConsiderationsConsiderations
Applicability of Public Services Cap to subrecipients:
v Public services carried out by subrecipients and some such services
carried out by CBDOs are subject to the Public Services Cap.
Substitution of CDBG funds for private or other Federal funds:
v The prohibition on substituting CDBG funds for recent local or State
government funding of a public service, as described on page 2-22,
does not extend to prohibiting the substitution of CDBG funds for
private or other Federal funding of a public service.
v It also does not prevent continued funding of a CDBG-funded public
service at the same or smaller level in the subsequent program year.
Reference: §570.201(e)
Purchase or lease of personal property for a public service:
v The purchase or lease of furnishings, equipment, or other personal
property needed for an eligible public service may be paid for with
CDBG funds. Reference: §570.207(b)(1)(iii)
370
NATIONAL OBJECTIVES ¾¾ PUBLIC SERVICES
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The public service is available to all the
residents in a particular primarily
residential area, and at least 51% of
those residents (or less if the exception
criteria are applicable) are L/M income
persons.
Increased police and fire protection
services in a predominantly L/M income
neighborhood.
For more information, see page 3-7.
L/M Income
Limited
Clientele
The public service is limited to a specific
group of people, at least 51% of whom
are L/M income persons. Services
qualifying under this category serve a
specific clientele, rather than providing
service to all the persons in a geographic
area.
Provision of meals to the homeless.
(Most public services qualify under this
category.)
For more information, see page 3-14.
L/M Income
Housing
Not applicable.Not applicable.Not applicable.
L/M Income
Jobs
Not applicable.Not applicable.Not applicable.
371
NATIONAL OBJECTIVES ¾¾ PUBLIC SERVICES
Objective Qualifies If Example Additional Information
Slum or
Blighted Area
The public service is provided within a
designated slum or blighted area, and is
designed to address one or more
conditions which contributed to the
deterioration of the area.
Provision of crime prevention counseling
to residents of a designated slum/blight
area.
For more information, see page 3-35.
Spot Blight Not applicable.Not applicable.Not applicable.
Urban Renewal
Completion
Not applicable.Not applicable.Not applicable.
Urgent Needs The public service is designed to
alleviate existing conditions that pose a
serious and immediate threat to the
health or welfare of the community, they
are of recent origin or recently became
urgent, and the grantee is unable to find
other available funds to support the
activity.
Additional police protection to prevent
looting in an area damaged by a tornado.
For more information, see page 3-41.
372
Community Development Block Grant Program Categories of Eligible Activities v 2-27
Public Services CapPublic Services Cap
Follow the steps below in order to determine the maximum amount which your entitlement community may
obligate for Public Services during a program year:
1.Enter the amount of the Entitlement Grant awarded for
the program year, as shown in the Grant Agreement on
line 11.b of the Funding Approval Form (HUD-7082 dated 4/14/93).$___________
2.Multiply the amount on line 1 by 0.15 and enter
the product here.$___________
3.If applicable to this community, enter here the amount
determined as described in the note below.$___________
4.Enter here the total amount of program income received
by the grantee and all of its subrecipients during the
program year preceding the year for which this cap is
being determined.$___________
5.Multiply the amount on line 4 by 0.15 and enter the
product here.$___________
6.Add the amount on line 5 to the amount on line 2
(or, where applicable, to the amount on line 3)
and enter the sum here. This is the maximum amount
that this community may obligate during the program
year for activities carried out under the category of
Public Services and under the category of Special
Activities by CBDOs which are not expressly exempt
from the cap.$___________
*Note: If the grantee, with the expressed consent of HUD, obligated more than 15% of its annual entitlement
grant during either its 1982 or 1983 program year for public services, the grantee may use for this calculation,
in lieu of 15% of its current grant, the greater of the following two amounts:
enter here the amount the grantee actually obligated for
public services during that program year $__________;
or
identify the percentage of the grant obligated for public services
during that program year and multiply the amount on line 1., above,
by the decimal equivalent of this percentage in lieu of 0.15 and enter
the product here $___________.
373
2-28 v Categories of Eligible Activities Community Development Block Grant Program
Determining Compliance with the CapDetermining Compliance with the Cap
Compliance with the public service cap for entitlement grantees is determined by performing the following
calculation at the end of each program year:
Determine the total amount of CDBG funds expended during
program year for activities that are classified as eligible
under §570.201(e) plus any public services carried out by a CBDO
under §570.204 that are not exempt from the cap as provided
under §570.204(b)(2)(i) or (ii) and enter the total here:$___________
Identify the total amount of unliquidated obligations for activities
under these same two categories, as of the end of the program year
and enter the total here:$___________
Add the above two numbers and enter the subtotal here:$___________
Identify the total amount of unliquidated obligations for these
two categories, as of the end of the preceding program year and
enter that amount here:$___________
Subtract the figure in the line directly above from the preceding
subtotal and enter the balance here. (This is the amount of net
obligations for public services that were incurred during the program
year and are subject to the cap.)$___________
If the amount of net obligations incurred during the program year does not exceed the amount determined on
the previous page as the maximum amount allowed for the year, the grantee is in compliance with this
limitation.
374
Community Development Block Grant Program Categories of Eligible Activities v 2-29
Interim AssistanceInterim Assistance
EligibleEligible
ActivitiesActivities
CDBG funds may be used for certain activities on an interim basis, provided
that the activities meet a national objective.
There are two subcategories of interim assistance activities:
(1)The first subcategory covers limited improvements to a deteriorating
area as a prelude to permanent improvements. To qualify under this
subcategory:
v The area must be exhibiting objectively determinable signs of
physical deterioration.
v The grantee must determine that immediate action is needed to arrest
the deterioration and that permanent improvements will be
undertaken as soon as practicable. Documentation of this
determination must be maintained.
v The activities that may be carried out with CDBG funds under this
subcategory are limited to:
(A)The repair of:
·streets,
·sidewalks,
·public buildings,
·parks and playgrounds, and
·publicly-owned utilities.
(B)The execution of special (i.e., beyond that normally provided):
·garbage,
·trash, and
·debris removal, including neighborhood cleanup
campaigns.
References: §570.201(f)(1) and §570.200(e)
375
2-30 v Categories of Eligible Activities Community Development Block Grant Program
(2)The second subcategory covers activities to alleviate an emergency
condition. To qualify under the second subcategory:
v The grantee’s chief executive officer must determine that emergency
conditions threatening the public health and safety exist in the area
and require immediate resolution. Documentation of that
determination must be maintained.
v The activities that may be carried out with CDBG funds under this
subcategory are limited to:
·activities eligible under the first subcategory, except for the
repair of parks and playgrounds;
·clearance of streets, including snow removal and similar
activities; and
·improvements to private properties.
These activities may not go beyond what is necessary to alleviate the
emergency condition. References: §570.201(f)(2) and §570.200(e)
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
InterimInterim
AssistanceAssistance
Interim assistance activities may qualify as meeting a national objective of
the CDBG program as shown in the charts on the following pages.
AdditionalAdditional
ConsiderationsConsiderations
Because activities carried out under this category might otherwise be either
ineligible or subject to the cap on public services, it is critical that the grantee
maintain the documentation that is called for above to make the activities
eligible as Interim Assistance.
376
NATIONAL OBJECTIVES ¾¾ INTERIM ASSISTANCE
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The interim assistance activities benefit
all persons in a primarily residential area
where at least 51% (or less if the upper
quartile applies) are L/M income persons
residing in the area and who are
benefiting from those activities.
Removal of storm damaged tree limbs
from streets in a predominantly L/M
income neighborhood and blocking
emergency vehicle entrance.
For more information, see page 3-7.
L/M Income
Limited
Clientele
Not applicable.Not applicable.Not applicable.
L/M Income
Housing
Not applicable.Not applicable.Not applicable.
L/M Income
Jobs
Not applicable.Not applicable.Not applicable.
377
NATIONAL OBJECTIVES ¾¾ INTERIM ASSISTANCE
Objective Qualifies If Example Additional Information
Slum or
Blighted Area
The interim assistance activities are
carried out in a designated slum or
blighted area.
Improvements to private properties in a
designated slum/blight area which
require immediate resolution because of
public safety concerns.
For more information, see page 3-35.
Spot Blight Not applicable.Not applicable.Not applicable.
Urban Renewal
Completion
Not applicable.Not applicable.Not applicable.
Urgent Needs The interim assistance is designed to
alleviate existing conditions that the
grantee certifies as posing a serious and
immediate threat to the health or welfare
of the community, they are of recent
origin or recently became urgent, the
grantee is unable to finance the activity
on its own, and other sources of funds
are not available.
Emergency treatment of health problems
caused by a flood.
For more information, see page 3-41.
378
Community Development Block Grant Program Categories of Eligible Activities v 2-33
RelocationRelocation
EligibleEligible
ActivitiesActivities
CDBG funds may be used for relocation payments and assistance to
displaced persons, including:
3 Individuals,
3 Families,
3 Businesses,
3 Non-profit organizations, and
3 Farms
where required under section 570.606 of the regulations.
CDBG funds may be used for optional relocation payments and assistance
to persons (individuals, families, businesses, non-profit organizations, and
farms) displaced by an activity that is not subject to the requirements
described above. This may include payments and other assistance for
temporary relocation (when persons are not permanently displaced.)
Optional relocation payments and assistance may also include payments and
assistance at levels higher than those required.
Unless optional payments and assistance are made pursuant to State or local
law, the grantee may make such payments and assistance only upon the basis
of a written determination that such payments and assistance are appropriate,
and only if the grantee adopts a written policy available to the public setting
forth the relocation payments and assistance it elects to provide.
This written policy must also provide for equal payments and assistance
within each class of displacees. References: §570.201(i) and §570.606(d)
ComplyingComplying
With NationalWith National
ObjectivesObjectives¾¾
RelocationRelocation
The compliance of relocation activities with the national objectives of the
CDBG program must be determined in one of two ways, depending on
whether the relocation assistance is mandatory for the grantee.
Where such assistance is required under the Uniform Act or the CDBG
statute, the activity may qualify as meeting the national objective of
benefiting L/M income persons only where the acquisition or rehabilitation
causing the relocation can also qualify under that objective.
379
2-34 v Categories of Eligible Activities Community Development Block Grant Program
If the grantee acquires property for construction of a public facility that will
serve an area that qualified under the slums/blight objective, but cannot
qualify as benefiting L/M income persons, the payment of assistance to those
displaced by such activity would qualify under the slums/blight objective
even if most or all of the displacees are L/M income.
This is because the grantee is required by law to make such payments and
therefore it must be viewed as an integral part of the displacing activity.
In any case where the payment of such assistance is voluntary on the part of
the grantee, however, the relocation payments could qualify either on the
basis of the re-use of the property or the income of the recipients of the
relocation assistance, at the grantee’s option.
Thus, HUD would accept a claim of addressing the L/M income benefit
objective where the voluntary payment of relocation benefits is made to L/M
income persons who were displaced by an activity that could not be
considered to meet that objective. This is because the payment of such
benefits clearly would not be needed to make possible the activity causing
the displacement.
AdditionalAdditional
ConsiderationsConsiderations
Because of the relationship of the optional versus mandatory aspects of
relocation payments to the national objectives determinations, it is critical
that the grantee make this distinction in its program files and identify the
displacing project.
380
Community Development Block Grant Program Categories of Eligible Activities v 2-35
Loss of Rental IncomeLoss of Rental Income
EligibleEligible
ActivitiesActivities
CDBG funds may be used to pay housing owners for the loss of rental
income incurred in holding, for temporary periods, housing units to be used
for the relocation of individuals and families displaced by CDBG-assisted
activities.
The statutory requirements concerning displacement require certain
replacement housing to be made available to displacees. If the displaced
household requires a type of housing unit that is scarce in that community, it
may be necessary for the grantee to have an existing, available unit held open
for the household for a short period until the displacement actually occurs.
Reference: §570.201(j)
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
Loss of RentalLoss of Rental
IncomeIncome
Compliance of this activity with the national objectives of the CDBG
program must be determined based on the underlying relocation activity.
If the activity resulting in the relocation assistance to the displaced household
qualified on the basis of benefit to L/M income persons, then paying housing
owners for losses incurred in holding units for those displacees also qualifies
as benefiting L/M income persons, even if the displaced household itself is
not L/M income.
Note: If the relocation assistance to displacees qualified under the
“Slum/Blight” or “Urgent Needs” national objectives, then paying housing
owners for losses incurred in holding units for those displacees also would
qualify under “Slum/Blight” or “Urgent Needs,” as applicable.
AdditionalAdditional
ConsiderationsConsiderations
Because the eligibility of this activity is dependent upon the housing unit
being required to relocate a household displaced by another CDBG-funded
activity, it is critical that the displacing activity and the displaced household
be documented as well as the basis upon which the grantee determined that
the housing was needed to be kept available for the displaced household.
381
2-36 v Categories of Eligible Activities Community Development Block Grant Program
Privately-Owned UtilitiesPrivately-Owned Utilities
EligibleEligible
ActivitiesActivities
The grantee, other public agencies, private nonprofit entities, and for-profit
entities may use CDBG funds to:
3 Acquire,
3 Construct,
3 Reconstruct,
3 Rehabilitate, or
3 Install
the distribution lines and related facilities for privately-owned utilities.
Reference §570.201(1)
Definition: A privately-owned utility may be defined as a publicly-regulated
service which is provided through the use of physical distribution lines to
private properties and that is owned and operated by a non-public entity.
Utilities include, but are not necessarily limited to, natural gas, electricity,
telephone, water, sewer, and television cable services.
Example:Example:A grantee could use CDBG funds to:
·Pay the costs of placing underground new or existing power lines and
telephone lines where such lines are owned by private companies.
·Pay the costs of installing water lines where the water service is owned
and operated by a private company.
Complying withComplying with
NationalNational
ObjectivesObjectives¾¾
Private-OwnedPrivate-Owned
UtilitiesUtilities
Privately-owned utilities may qualify as meeting a national objective of the
CDBG program in the same ways as are applicable to Public Facilities and
Improvements (see page 2-11).
382
Community Development Block Grant Program Categories of Eligible Activities v 2-37
AdditionalAdditional
ConsiderationsConsiderations
The inclusion of this category of basic eligibility serves to ensure that
publicly-regulated utilities may be assisted with CDBG funds without regard
to whether the utility is publicly- or privately-owned. Thus, the CDBG
program does not constitute a barrier to a community’s determination to shift
one or more of its publicly-owned utilities to private ownership where
economic considerations dictate.
383
2-38 v Categories of Eligible Activities Community Development Block Grant Program
RehabilitationRehabilitation
EligibleEligible
ActivitiesActivities
CDBG funds may be used to finance the costs of rehabilitation as shown
below.
Eligible types of property
Residential—Residential property, whether privately or publicly owned.
This includes manufactured housing when such housing constitutes part
of the community’s housing stock.
Commercial/industrial—Commercial or industrial property, but where
such property is owned by a for-profit, rehabilitation under this category
is limited to exterior improvements of the building and the correction of
code violations. (Further improvements for such buildings may qualify
under the category of Special Economic Development Activities.)
Other—Nonprofit-owned, nonresidential buildings and improvements
that are not considered to be public facilities or improvements under
§570.201(c) of the CDBG program regulations.
Note: Additions to existing buildings may be assisted under this
category when they are incidental to the rehabilitation of the property,
and may be provided as a part of other rehabilitation if the addition does
not materially increase the size or function of the building.
Eligible types of assistance
Costs—Costs of labor, materials, supplies and other expenses required
for the rehabilitation of property, including repair or replacement of
principal fixtures and components of existing structures (e.g., the heating
system).
Financing—Grants, loans, loan guarantees, interest supplements and
other forms of financial assistance may be provided under this category.
(A grantee may make a “lump sum draw down” for the purpose of
financing rehabilitation of privately-owned properties. See §590.513 for
details.)
Refinancing—Loans for refinancing existing indebtedness secured by a
property being rehabilitated with CDBG funds, if such refinancing is
determined by the grantee to be necessary or appropriate to achieve its
community development objectives.
384
Community Development Block Grant Program Categories of Eligible Activities v 2-39
Property acquisition—Assistance to private individuals and entities
(whether profit or not-for-profit) to acquire for the purpose of
rehabilitation and to rehabilitate properties for use or resale for
residential purposes.
Security devices—Installation costs of sprinkler systems, smoke
detectors and dead bolt locks, and other devices for security purposes.
Insurance—The costs of initial homeowner warranty premiums and,
where needed to protect the grantee’s interest in properties securing a
rehabilitation loan, hazard insurance premiums as well as flood insurance
premiums for properties covered by the Flood Disaster Protection Act of
1973, as amended, pursuant to §570.605.
Conservation—Costs required to increase the efficient use of water
(e.g., water saving faucets and shower heads) and improvements to
increase the efficient use of energy in structures through such means as
installation of storm windows and doors, insulation, and modification or
replacement of heating and cooling equipment.
Water and sewer—Costs of connecting existing residential structures to
water distribution lines or local sewer collection lines.
Tools—Costs of acquiring tools to be lent to owners, tenants and others
who will use the tools to carry out rehabilitation.
Barrier removal—Costs to remove material and architectural barriers
that restrict the mobility and accessibility of elderly and severely disabled
persons to buildings and improvements that are eligible for rehabilitation
under this category.
Landscaping, sidewalks, and driveways—The costs of installation or
replacement of landscape materials, sidewalks, and driveways when
incidental to other rehabilitation of the property.
Renovation of closed buildings—The conversion of a closed building
from one use to another (e.g., the renovation of a closed school building
to residential use).
Historic preservation—This category also authorizes the costs of
preserving or restoring properties of historic significance, whether
privately- or publicly-owned, except that buildings for the general
conduct of government may not be restored or preserved with CDBG
assistance (see the section on Public Facilities and Improvements
concerning this limitation). Historic properties are those sites or
structures that are either listed in or eligible to be listed in the National
Register of Historic Places, listed in a State or local inventory of historic
places, or designated as a State or local landmark or historic district by
appropriate law or ordinance.
385
2-40 v Categories of Eligible Activities Community Development Block Grant Program
Lead-based paint hazard evaluation and reduction—The costs of
evaluating and treating lead-based paint may be undertaken under this
category whether alone or in conjunction with other rehabilitation.
Rehabilitation services—Staff costs and related expenses required for
outreach efforts for marketing the program, rehabilitation counseling,
screening potential applicant households and structures, energy auditing,
preparing work specifications, loan underwriting and processing,
inspections, and other services related to assisting owners, tenants,
contractors, and other entities who are participating or seeking to
participate in rehabilitation activities eligible under this category; under
the Section 312 of the Housing Act of 1964, as amended; under Section
810 of the Act; or under Section 17 of the United States Housing Act of
1937.
Business in a residence—In some cases where a business is conducted
in a residential unit, it may be necessary to make improvements to the
residence in order to conduct the business. (This would be the case
where, for example, the business is providing child care and local
requirements for such business dictate that modifications be made to the
housing unit.) In any case where the improvements are of such nature
that, in addition to facilitating the business, they also provide a benefit to
the resident(s), such rehabilitation costs may be covered under this
category. Other improvements not meeting this test needed for such a
business could be eligible under the category of Special Economic
Development.
Reference: §570.202
Rehabilitation does not include:
v Creation of a secondary housing unit attached to a primary unit;
v Installation of luxury items, such as a swimming pool;
v Costs of equipment, furnishings, or other personal property not an
integral structural fixture, such as:
·a window air conditioner; or
·a washer or dryer (but a stove or refrigerator is allowed); or
v Labor costs for homeowners to rehabilitate their own property.
386
Community Development Block Grant Program Categories of Eligible Activities v 2-41
Use of Subrecipients
Nonprofit entities are often used by grantees in carrying out a rehabilitation
program. Where the nonprofit entity is acting in the same capacity as the
grantee in selecting properties to be rehabilitated, they are appropriately
designated as a subrecipient under the CDBG program and thus subject to
subrecipient requirements. However, there are instances where a nonprofit
entity may not be considered to be a subrecipient with respect to the use of
CDBG funds for rehabilitation. Simply put, where the nonprofit owns
property that is in need of rehabilitation and they take advantage of the
grantee’s program of using CDBG funds for such rehabilitation (in the same
manner as other property owners do), the entity should not be considered to
be a subrecipient for purposes of the program. Perhaps the most significant
aspect of this is that any income the nonprofit might receive from the use or
rental of the rehabilitated property would not be considered to be CDBG
program income. If there is any question as to whether a nonprofit entity
should be considered to be a subrecipient with respect to a particular use of
CDBG funds for rehabilitation, contact the local HUD field office for advice.
Drawing Down Funds for Rehabilitation
The general Treasury rules for drawing Federal funds require that funds not
be drawn until needed. In the CDBG program, this usually means that the
grantee or subrecipient should not draw funds from the line of credit (the
Treasury) in an amount greater than that which it expects to use within the
next three business days. The rules also require that any program income on
hand must be used before drawing additional funds from the Treasury [but
see the special rule applying to revolving funds at §§570.500(b) and
570.504(b)(2)]. There are, however, two regulatory provisions that allow
drawing funds from the Treasury in advance which apply with respect to
rehabilitation. They are: (a) Lump Sum Drawdown; and (b) Escrow
Accounts. Each of these is discussed below.
Lump Sum Drawdown—The grantee may draw, as a single
amount, the total amount needed for rehabilitation if it enters into an
agreement with a financial institution that meets the requirements set
forth in §570.513(b)(2) and if the grantee complies with other
requirements under §570.513. Some of the key requirements
outlined in that provision include: the agreement may not exceed
two years; the financial institution must agree to provide certain
benefits in conjunction with the activities paid for from the account;
there are time benchmarks for when the rehabilitation carried out
with funds in the account must begin and the pace at which the funds
must be used; and there are limits to what the funds can be used for.
If the grantee is interested in using this authority but has questions
about the requirements, it should consult with its local HUD field
office for assistance. Reference: §570.513
387
2-42 v Categories of Eligible Activities Community Development Block Grant Program
Escrow Account—Some grantees have experienced difficulty in making
timely payments from their CDBG account to contractors engaged in
rehabilitation. Where the grantee’s program makes use of small and
minority contractors or subcontractors, delays in making payment for
invoices presented by such entities can mean that the contractors or
subcontractors are unable to participate in CDBG-assisted rehabilitation,
since they cannot afford to wait long for payment. In such cases, the
grantee may establish an escrow account for purposes of making timely
payments from that account rather than from the program account,
provided it does so in conformance with the requirements set forth at
§570.511. Some of the key requirements contained in that provision
include: the use of this feature must be limited to residential
rehabilitation; the account may not hold more than the amount expected
to be disbursed within ten working days; and interest earned on the funds
on deposit is to be returned to HUD at least quarterly. It should be noted
that, if the grantee has a lump-sum account, as described in the
subsection above, it may serve the same purpose as an escrow account
and the two may not need to be used together. If a grantee has an
interest in establishing an escrow account but has some questions or
concerns about the matter, the local HUD field office should be
contacted for advice. Reference: §570.511
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
RehabilitationRehabilitation
Section 105(c)(3) of the authorizing statute, the Housing and Community
Development Act of 1974, requires that, in order for an activity that involves
the acquisition or improvement of property for housing to qualify as
benefiting L/M income persons, the housing must be occupied by such
persons. Even though a particular housing activity may provide a clear
benefit to an area containing predominantly L/M Income residents, it cannot
qualify on that basis. Instead, the housing must be occupied by L/M Income
households. (See page 3-3 of the Guide for a discussion about the distinction
between L/M households and L/M persons in this regard.) That limitation is
reflected in the charts that follow which provide general guidance on how
rehabilitation activities may qualify as meeting a national objective under the
CDBG program. This section of the statute also limits the extent to which
CDBG expenditures for housing activities may count towards the Overall
Expenditures Benefit requirement, as discussed in Chapter 4 of this Guide.
It should also be noted that the section on L/M Income Benefit for housing in
Chapter 3 of this Guide covering National Objectives contains important
information on the rules that must be followed concerning housing activities
that are not covered in the following charts in this section. That chapter also
discusses the circumstances under which occupancy of a CDBG-assisted
housing unit by a L/M income household may qualify for the assistance to
that unit without regard to the income of households occupying any other
units that may be located in the same structure.
388
Community Development Block Grant Program Categories of Eligible Activities v 2-43
AdditionalAdditional
ConsiderationsConsiderations
When CDBG funds are used under this category for refinancing, the grantee
should maintain documentation showing that the rehabilitation was done with
CDBG funds and that the borrower needed the refinancing in order to make
the rehabilitation affordable. References: §570.202(b)(3) and §570.200(e)
If the grantee or a subrecipient makes a number of loans for rehabilitation, it
will be important that appropriate steps be taken to manage its portfolio of
loans. Some guidance and advice on this matter is contained in Appendix G,
Selling or Securitizing CDBG Loans.
389
NATIONAL OBJECTIVES ¾¾ REHABILITATION
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
Rehabilitation of a building to be used
for a purpose that will benefit all the
residents of a qualifying L/M income
primarily residential area.
Facade improvements to a commercial
structure serving a predominantly L/M
income primarily residential area.
For more information, see page 3-7.
L/M Income
Limited
Clientele
Not applicable.Not applicable.Not applicable.
L/M Income
Housing
Rehabilitation of housing to be occupied
by L/M income persons. Rental units
must be occupied at affordable rents.
Conversion of an abandoned warehouse
into rental housing for L/M income
households at affordable rents. Also
improvements to a single family
residence used as a place of business
provided the improvements generally
benefit the unit’s residential occupants.
For more information, see page 3-19.
L/M Income
Jobs
Rehabilitation of nonresidential property
that will create or retain jobs for L/M
income persons
Correction of code violations that will
enable a business to survive and retain
jobs the majority of which are held by
L/M income persons.
For more information, see page 3-24.
390
NATIONAL OBJECTIVES ¾¾ REHABILITATION
Objective Qualifies If Example Additional Information
Slum or
Blighted Area
Rehabilitation of residential structures
located in a designated slum or blighted
area; the structure to be rehabilitated is
considered substandard under local
definition before rehabilitation, and all
deficiencies making the structure
substandard are corrected before less
critical work is undertaken. Reference:
§570.208(b)(1)(iv)
Rehabilitation of substandard housing
located in a designated blighted area and
where the housing is expected to be
brought to standard condition and sold to
non-L/M income households.
For more information, see page 3-35.
Spot Blight Rehabilitation of a structure located
outside a designated slum or blighted
area, where the rehabilitation is limited to
the extent necessary to eliminate specific
conditions of blight or decay that are
detrimental to public health and safety.
Rehabilitation of the deteriorated exterior
of an abandoned building located in an
area that has not been designated as slum
or blighted and where the rehabilitation
is limited to removal of the exterior
blight. Rehabilitation of plumbing in a
building located in an area that has not
been designated as slum or blighted and
where rehabilitation is limited to
corrections of code violators that are
detrimental to public health and safety.
For more information, see page 3-38.
391
NATIONAL OBJECTIVES ¾¾ REHABILITATION
Objective Qualifies If Example Additional Information
Urban Renewal
Completion
Rehabilitation of property located in an
Urban Renewal area and for a use that is
specified in the latest approved plan for
the area.
Conversion of a warehouse to residential
housing in an Urban Renewal project
area, necessary to complete the urban
renewal plan.
For more information, see page 3-40.
Urgent Needs The rehabilitation is part of an activity
designed to alleviate existing conditions
for which the grantee certifies are a
serious and immediate threat to the
health or welfare of the community, the
conditions are of recent origin or recently
became urgent, the grantee is unable to
finance the activity on its own, and other
sources of funds are not available.
Rehabilitation of housing that has been
badly damaged by an earthquake.
For more information, see page 3-41.
392
Community Development Block Grant Program Categories of Eligible Activities v 2-47
Construction of HousingConstruction of Housing
EligibleEligible
ActivitiesActivities
Under this category, CDBG funds may be used in certain specified
circumstances to finance the construction of new permanent residential
structures. The following identifies those limited circumstances:
3 Grantees may use CDBG funds in a housing construction project
that has received funding through a Housing Development Grant (a
HODAG). Reference: §570.201(m)
3 Grantees may construct housing of last resort under 24 CFR Part 42,
Subpart I. (This is housing that the grantee has determined must be
constructed in order to provide suitable replacement housing for
persons to be displaced by a contemplated CDBG project, subject to
the Uniform Act, and where the project is prevented from
proceeding because the required replacement housing is not
available otherwise.) Reference: §570.207(b)(3)
Note: Other than these two situations, new housing construction is ineligible
under the CDBG program, unless carried out under the authority of the basic
eligibility category, “Special Activities by CBDOs.”
Reference: §570.207(b)(3)
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
ConstructionConstruction
of Housingof Housing
New housing construction may qualify as meeting a national objective of the
CDBG program as depicted in the charts on the following pages.
AdditionalAdditional
ConsiderationsConsiderations
It is important to note that several activities which support new housing may
be carried out using CDBG funds even though the actual housing
construction costs are being supported by other resources. The following are
examples of supportive activities:
v Acquisition of sites on which buildings will be constructed for use or
resale as housing. Reference: §570.201(a);
v Clearance of toxic contaminants of property to be used for the new
construction of housing. Reference: §570.201(d);
393
2-48 v Categories of Eligible Activities Community Development Block Grant Program
v Site improvements to publicly-owned land to enable the property to
be used for the new construction of housing, provided the
improvements are undertaken while the property is still in public
ownership Reference: §570.201(c); and
v The cost of disposing of real property, acquired with CDBG funds,
which will be used for new construction of housing. Reference:
§570.201(b).
In addition, certain “soft costs” necessary for the new construction of
housing that would otherwise be ineligible may be eligible if the limitations
of §570.206(g) are waived by HUD. Such soft costs include:
v Surveys,
v Site and utility plans, and
v Application processing fees.
Note: A waiver of §570.206(g) is needed because the regulatory provision
currently limits costs to that associated with developing new housing
identified in the grantee’s HUD-approved Housing Assistance Plan (HAP).
Since the HAP is no longer required in the program, the use of this provision
must be authorized by HUD by waiving this limitation. HUD would
consider granting such a waiver if the grantee could meet the threshold
requirements of §570.5 and demonstrate that the housing is clearly needed to
support the grantee’s housing and community development objectives, as
shown in the grantee’s Consolidated Plan. However, soft costs incurred in
support of eligible new housing construction activities may be paid for as
part of the cost of the new construction itself.
Conversion: It should be noted that the cost of converting an existing non-
residential structure to residential is not generally considered to constitute
new construction under the CDBG program and is thus covered under the
basic eligibility category of Rehabilitation. However, in some cases, the
conversion may involve construction that goes beyond the envelope of the
non-residential structure. Where this is the case, the grantee should consult
with the local HUD field office to ensure that the extent of such construction
would not constitute new construction of housing and thus be ineligible for
CDBG assistance. Reference: §570.202
394
NATIONAL OBJECTIVES ¾¾ CONSTRUCTION OF HOUSING
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
Not applicable.Not applicable.Not applicable.
L/M Income
Limited
Clientele
Not applicable.Not applicable.Not applicable.
L/M Income
Housing
The new housing will be occupied by
L/M income households. Rental units
must be occupied at affordable rents.
New construction of “last resort”
housing needed for a L/M income
household being displaced by a CDBG-
assisted project.
For more information, see page 3-19.
L/M Income
Jobs
Not applicable.Not applicable.Not applicable.
395
NATIONAL OBJECTIVES ¾¾ CONSTRUCTION OF HOUSING
Objective Qualifies If Example Additional Information
Slum or
Blighted Area
New housing qualifies if:
(1) The new housing is located with a
designated slum or blighted area, and
(2) Development of new housing
addresses one of the conditions which
contributed to the deterioration of the
area.
Luxury apartments constructed with
HODAG assistance on a site in a
designated slum/blight area.
For more information, see page 3-35.
Spot Blight Not applicable.Not applicable.Not applicable.
Urban Renewal
Completion
The new housing is:
(1) Located within an Urban Renewal
project or an NDP action area designated
under Title I of the Housing Act of 1949,
and
(2) Necessary to complete the Urban
Renewal plan.
Last resort housing constructed in the
Urban Renewal project area on a site
calling for such housing in the Urban
Renewal plan.
For more information, see page 3-40.
Urgent Needs The new housing is needed to respond to
a threat to the health or welfare of the
community of recent origin and no other
funding is available to meet the threat
and the new construction is eligible (or
the statutory waiver Authority for
Presidentially-declared disasters is
exercised.
Housing needed to replace units
completely destroyed by a flood and
needed to be built in a new location.
For more information, see page 3-41.
396
Community Development Block Grant Program Categories of Eligible Activities v 2-51
Code EnforcementCode Enforcement
EligibleEligible
ActivitiesActivities
Code enforcement involves the payment of salaries and overhead
costs directly related to the enforcement of state and/or local codes.
CDBG funds may be used for code enforcement only in deteriorating or
deteriorated areas where such enforcement, together with public or private
improvements, rehabilitation, or services to be provided, may be expected to
arrest the decline of the area. Reference: §570.202(c)
ExampleExample CDBG funds may be used to pay the salaries of inspectors enforcing codes
in a blighted area being renewed through comprehensive treatment.
Code enforcement does not include:
v Inspections for the purpose of processing applications for
rehabilitation assistance and overseeing such rehabilitation. Such
inspections may be eligible under the Rehabilitation category and
they are not limited by the restrictions on the eligibility of code
enforcement.
v Correcting code enforcement violations identified during inspections.
ComplianceCompliance
with Nationalwith National
ObjectivesObjectives¾¾
CodeCode
EnforcementEnforcement
Code enforcement may qualify as meeting a national objective of the CDBG
program as shown in the charts on the following pages.
AdditionalAdditional
ConsiderationsConsiderations
Code enforcement expenditures should not be included in costs subject to the
20% limit on planning and administration, even though all expenditures are
for staff and related costs because they are considered to be an activity
delivery cost.
397
NATIONAL OBJECTIVES ¾¾ CODE ENFORCEMENT
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The code enforcement is targeted at a
deteriorated or deteriorating area
delineated by the grantee and:
(1) At least 51% (or less if the upper
quartile applies) of the residents of the
area are L/M income persons; and
(2) The code enforcement, together with
public improvements, rehabilitation, and
services to be provided, may be expected
to arrest the decline of the area.
Code enforcement efforts in a L/M
income deteriorated neighborhood
targeted for rehabilitation assistance,
construction of a neighborhood facility,
and street reconstruction.
For more information, see page 3-7.
L/M Income
Limited
Clientele
Not applicable.Not applicable.Not applicable.
L/M Income
Housing
Not applicable.Not applicable.Not applicable.
L/M Income
Jobs
Not applicable.Not applicable.Not applicable.
398
NATIONAL OBJECTIVES ¾¾ CODE ENFORCEMENT
Objective Qualifies If Example Additional Information
Slum or
Blighted Area
The code enforcement is targeted at a
designated slum or blighted area and:
(1) Is designed to address one or more
of the conditions which contributed to
the deterioration of the area; and
(2) The code enforcement, together with
public improvements, rehabilitation, and
services to be provided, may be expected
to arrest the decline of the area.
Building inspections for code violations
in a designated blighted area, which are
part of a comprehensive effort to arrest
decline in that area.
For more information, see page 3-35.
Spot Blight Not applicable.Not applicable.Not applicable.
Urban Renewal
Completion
While this situation is unlikely to occur,
it is possible for code enforcement to
qualify under this category if the code
enforcement is necessary to complete an
Urban Renewal plan.
Building inspections for code violations
in a designated blighted area, which are
part of a comprehensive effort to arrest
decline in an Urban Renewal area.
For more information, see page 3-40.
399
NATIONAL OBJECTIVES ¾¾ CODE ENFORCEMENT
Objective Qualifies If Example Additional Information
Urgent Needs While this situation is likely to be
infrequent, it is possible for code
enforcement to qualify if:
(1) The code enforcement is targeted at
a deteriorated or deteriorating area;
(2) The code enforcement, together with
public or private improvements,
rehabilitation, and services to be
provided, may be expected to arrest the
decline of the area; and
(3) The grantee is able to certify that the
existing conditions which the code
enforcement is designed to alleviate pose
a serious and immediate threat to the
health or welfare of the community, they
are of recent origin or recently became
urgent, the grantee is unable to finance
the activity on its own, and other sources
of funds are not available.*
* In cases where disaster causes the blight of
an area, it may be easier to qualify the code
enforcement under the “Slum or Blighted
Area” category than under the “Urgent
Need” category.
Code enforcement activities taking place
in an area that has been severely affected
by a flood, and is part of the
community’s overall response to the
emergency.
For more information, see page 3-41.
400
Community Development Block Grant Program Categories of Eligible Activities v 2-55
Special EconomicSpecial Economic
Development ActivitiesDevelopment Activities
PrefacePreface The purpose of this preface is to distinguish the concept of “economic
development” from the term “special economic development activities”
as used in the CDBG program. “Economic development” is generally
thought of in two ways within the context of CDBG activities: the very broad
concept of the term as distinguished from “special economic development
activities” as that term is used at 24 CFR 570.203.
“Economic development” can be interpreted very broadly to include all
endeavors aimed at sustaining or increasing the level of business activity.
Under this broad concept, most CDBG activities could, under the right
circumstances, be viewed as economic development. For example, the level
of business activity in a jurisdiction could be helped through development of
a community economic development plan, improvements to the public
infrastructure, through better housing, or an enhanced level of public
services.
When the Consolidated Plan regulations were published in January 1995, the
term “expanded economic opportunities” was defined at 24 CFR 91.1
(a)(1)(iii) as including:
“...job creation and retention; establishment, stabilization and
expansion of small businesses (including microbusinesses); the
provision of public services concerned with employment; the
provision of jobs involved in carrying out activities under programs
covered by this plan to low-income persons in areas affected by
those programs and activities; availability of mortgage financing for
low-income persons at reasonable rates using nondiscriminatory
lending practices; access to capital and credit development activities
that promote the long-term economic and social viability of the
community; and empowerment and self-sufficiency opportunities for
low-income persons to reduce generational poverty in federally
assisted and public housing.”
This was a very broad statement of purpose for Consolidated Plan goal-
setting purposes and was designed, in part, to cover what is the primary
objective of the CDBG program (section 101(c) of the Housing and
Community Development Act of 1974 as amended).
401
2-56 v Categories of Eligible Activities Community Development Block Grant Program
In contrast, the term “special economic development activities” is used in
the CDBG program to identify three types of activities described below and
at §570.203(a), (b), and (c) of the regulations.
As a consequence of changes to the CDBG program legislation in 1992,
significant alterations were made to the program regulations to facilitate the
use of CDBG funds for economic development purposes, both in terms of
eligibility and national objectives. The resultant flexibility has sprinkled
activities often considered as more directly linked to “special economic
development activities,” such as microenterprise assistance and technical
assistance to nonprofits to build economic development capacity, more
broadly throughout the eligible activities in the regulations (Subpart C), thus
removing them from the requirements specific to funding activities under
§570.203.
An economic development project in the CDBG program may be supported
by a range of CDBG-funded activities, including both special economic
development activities and other categories of basic eligibility, each of which
must meet a national objective of the CDBG program.
EligibleEligible
ActivitiesActivities
CDBG funds may be used for the following special economic development
activities:
v Commercial or industrial improvements carried out by the grantee
or a nonprofit subrecipient, including:
·acquisition,
·construction,
·rehabilitation,
·reconstruction, or
·installation of commercial or industrial buildings or structures
and other related real property equipment and improvements.
v Assistance to private for-profit entities for an activity determined
by the grantee to be appropriate to carry out an economic
development project. This assistance may include, but is not limited
to:
·grants;
·loans;
·loan guarantees;
·interest supplements;
·technical assistance; or
·any other form except for those described as ineligible in
§570.207(a), such as political activities.
402
Community Development Block Grant Program Categories of Eligible Activities v 2-57
Under this type of assistance, the grantee shall minimize, to the
extent practical, displacement of existing businesses and jobs in
neighborhoods.
v Economic development services in connection with the above
subcategories, including outreach efforts to market available forms
of assistance, screening of applicants, reviewing and underwriting
applications for assistance, preparation of agreements, management
of assisted activities, and the screening, referral, and placement of
applicants for employment opportunities generated by CDBG-
eligible economic development activities. The costs of providing
necessary job training for persons filling those positions may also be
provided.
Reference: §570.203(a), (b) and (c)
ExampleExample Special economic development activities may include:
·Construction by the grantee or subrecipient of a business incubator
designed to provide inexpensive space and assistance to new firms to
help them become viable businesses,
·Loans to pay for the expansion of a factory or commercial business,
·Technical assistance to a business facing bankruptcy, and
·Providing training needed by persons on welfare to enable them to
qualify for jobs created by CDBG-assisted special economic
development activities.
Public Benefit: The previous requirement that certain Special Economic
Development Activities meet a particular kind of financial analysis (known
as the “appropriate” determination) has been replaced with a requirement
that the level of public benefit to be derived from the activity must be
appropriate given the amount of CDBG assistance being provided. This
requirement, which is found at §570.209 and is further discussed in
Appendix B of this Guide, applies to all activities under the category of
Special Economic Development Activities at §570.203. Grantees are still
expected to perform due diligence through financial underwriting of any
assistance being provided to a for-profit business and HUD has provided
some guidelines which a grantee may use for this purpose. It is important to
note, however, that grantees are not required to use the HUD-supplied
underwriting guidelines.
403
2-58 v Categories of Eligible Activities Community Development Block Grant Program
Special economic development activities do not include:
v Assistance to a for-profit business in the form of lobbying or other
political activities. Reference: §570.207(a)(3)
v Public facilities and improvements carried out to support or benefit a
private for-profit business. (These activities may, however, be
eligible under the category of Public Facilities and Improvements.)
Reference: §570.201(c)
v New Housing Construction. This activity may be eligible under
either of the categories of Construction of Housing or Special
Activities by CBDOs. When a project to be assisted includes new
construction of housing as part of a commercial structure (e.g., a
“mixed use” project), those costs clearly attributable to the
commercial portion of the project may be eligible as a special
economic development activity. References: §570.201(m) and §570.204
v Planning for economic development projects, including conducting
market surveys to determine an appropriate type of business to
attempt to attract to a particular area, developing individual
commercial or industrial project plans, and identifying actions to
implement those plans. Such planning activities may be eligible
under the category of Planning and Capacity Building. Reference:
§570.205
v Job training, unless part of a CDBG-eligible economic development
activity that will create or retain permanent jobs. Such other training
may be eligible under the categories of Public Services or Special
Activities by CBDOs. References: §570.201(e) and §570.204
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
SpecialSpecial
EconomicEconomic
DevelopmentDevelopment
ActivitiesActivities
Section 105(c)(1) of the authorizing statute specifies certain limitations on
how activities under the category of Special Economic Development
Activities may meet the national objective of benefit to L/M income persons.
These limitations are reflected in the charts that follow which show how
activities in this category may meet the CDBG national objectives.
404
Community Development Block Grant Program Categories of Eligible Activities v 2-59
AdditionalAdditional
ConsiderationsConsiderations
Grantees should take special precautions in the use of the category of Special
Economic Development Activities, particularly when providing assistance to
a for-profit business. First, it should be evident that all business activity
involves more than the average amount of risk and it is possible that the
contemplated results will not materialize. It should also be noted that
businesses may be expected to be focusing heavily on their own interests and
it should not be surprising if they show little interest in the fulfillment of the
community’s goals and objectives or in the particular requirements of the
CDBG program. Grantees must therefore maintain proper documentation in
the activity files and offer technical assistance to avoid program non-
compliance. Ultimately, grantees should take special care to protect the
community’s interests in their dealings with those entities that work in the
economic development sphere.
If the grantee or a subrecipient makes a number of loans for economic
development, it will be important that appropriate steps be taken to manage
the loan portfolio. Some guidance and advice concerning this matter may be
found in Appendix G.
405
NATIONAL OBJECTIVES ¾¾ SPECIAL ECONOMIC DEVELOPMENT ACTIVITIES
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The assistance is to a business which
provides goods or services to residents of
a L/M income residential area.
Assistance to neighborhood businesses
such as grocery stores and laundromats,
serving a predominantly L/M income
neighborhood.
For more information, see page 3-7.
L/M Income
Limited
Clientele
The only use of CDBG is to provide job
training or other employment support
services as part of a CDBG-eligible
economic development project, and the
percent of total project cost contributed
by CDBG does not exceed the percent of
all persons assisted who are L/M
income.
Training for the 30 new employees, 10 of
whom are L/M income, hired by a
manufacturer adding new machinery to
its plant where CDBG pays no more than
one-third of the total cost of the project,
including the training.
For more information, see page 3-14.
L/M Income
Housing
Not applicable.Not applicable.Not applicable.
L/M Income
Jobs
The assisted project involves the creation
or retention of jobs at least 51% of which
benefit L/M income persons.
Financial assistance to a manufacturer
for the expansion of its facilities which is
expected to create permanent jobs, at
least 51% of which will be taken by L/M
income persons.
For more information, see page 3-24.
406
NATIONAL OBJECTIVES ¾¾ SPECIAL ECONOMIC DEVELOPMENT ACTIVITIES
Objective Qualifies If Example Additional Information
Slum or
Blighted Area
The assistance is to a business in a
designated slum or blighted area and
addresses one or more of the conditions
which contributed to the deterioration of
the area.
A low-interest loan to a business as an
inducement to locate a branch store in a
redeveloping blighted area.
For more information, see page 3-35.
Spot Blight The assistance is to a business located
outside of a designated slum or blighted
area where:
(1) The assistance is designed to
eliminate specific conditions of blight or
physical decay; and
(2) The assistance is limited to the
following activities: acquisition,
clearance, relocation, historic
preservation, and building rehabilitation.
Rehabilitation must be limited to the
extent necessary to eliminate specific
conditions detrimental to public safety
and health.
Financial assistance to a business to
demolish a decayed structure it owns in
order to assist the business in
constructing a new building on the site.
For more information, see page 3-38.
407
NATIONAL OBJECTIVES ¾¾ SPECIAL ECONOMIC DEVELOPMENT ACTIVITIES
Objective Qualifies If Example Additional Information
Urban Renewal
Completion
The assistance is to a commercial or
industrial business located in an Urban
Renewal project area or an NDP action
area designated under Title I of the
Housing Act of 1949, and is necessary to
complete the Urban Renewal Plan.
Assistance to a developer for the
construction of commercial structures
located in an urban Renewal project area
where the construction is needed to
complete the approved plan for the
Urban Renewal area.
For more information, see page 3-40.
Urgent Need The assistance to a commercial or
industrial business is designed to
alleviate existing conditions and the
grantee certifies that such conditions
pose a serious and immediate threat to
the health or welfare of the community,
they are of recent origin or recently
became urgent, the grantee is unable to
finance the activity on its own, and other
sources of funds are not available.
Assistance in reconstructing the only
grocery store in a remote part of an
urban county that was damaged by a
hurricane, where no other funds are
available for the reconstruction.
For more information, see page 3-41.
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Community Development Block Grant Program Categories of Eligible Activities v 2-63
MicroenterpriseMicroenterprise
AssistanceAssistance
EligibleEligible
ActivitiesActivities
Under this category, grantees and other public or private organizations may
use CDBG funds to facilitate economic development through the
establishment, stabilization and expansion of microenterprises. Reference:
§570.201(o)
This category authorizes the use of CDBG funds to provide financial
assistance of virtually any kind to an existing microenterprise or to assist in
the establishment of a microenterprise. It also authorizes the provision of:
3 Technical assistance to a new or existing microenterprise or to
persons developing a microenterprise, and
3 General support to owners of microenterprises or to persons
developing a microenterprise.
Note that under the subcategory of “general support,” CDBG funds may be
used to provide services of any kind that may be needed by the owner of or
person developing a microenterprise to enable the establishment,
stabilization, or expansion of the business. This could include, for example,
child care, transportation, counseling, and peer support programs. Any such
services provided under this authority are not subject to the cap on public
services regardless of the entity providing the service.
It should also be noted that financially or technically assisting a
microenterprise may also be carried out under the basic eligibility categories
of Special Economic Development Activities and Special Activities by
CBDOs. However, if carried out under either of those categories, such
assistance would be subject to the requirements concerning Public Benefit.
References: §570.203, §570.204, and §570.209
Definitions:
“Microenterprise” means a business having five or fewer employees, one
or more of whom owns the business.
“Person developing a microenterprise” means any person who has
expressed an interest and who is, after an initial screening, expected to be
actively working towards developing a business that is expected to be a
microenterprise at the time it is formed.
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2-64 v Categories of Eligible Activities Community Development Block Grant Program
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
MicroenterpriseMicroenterprise
AssistanceAssistance
Because microenterprises are for-profit businesses, most of the guidelines
for meeting national objectives under the category of Special Economic
Development Activities also apply here. There is one notable exception,
however. A grantee may qualify under the L/M Income Limited Clientele
subcategory any CDBG assistance under the basic eligibility category of
Microenterprise Assistance that it provides to owners of and/or persons
developing a microenterprise who are L/M income persons. If such
assistance is provided to owners/persons developing a microenterprise who
are not L/M income persons, it would not qualify under Limited Clientele,
but would need to meet the requirements of other subcategories (e.g., Area
Benefit or Jobs). See the following chart for further elaboration on meeting
the L/M Income Benefit national objective. Reference: §570.208(a)(2)(iii)
AdditionalAdditional
ConsiderationsConsiderations
Many grantees have been assisting some microenterprises as part of their
CDBG economic development programs. The creation of a separate
eligibility category for this class of businesses does not mean that such
grantees may no longer do so. First, it should be made clear that just
because a business is small enough to meet the CDBG definition of a
microenterprise would not preclude its being assisted under the category of
Special Economic Development. However, when the grantee provides
assistance to such businesses under that category, all applicable
requirements, including public benefit, will apply. In order to take advantage
of the special advantages available under the Microenterprise Assistance
category, the grantee would need to establish an activity for providing such
assistance separate from all other business assistance it may elect to provide.
This is necessary to avoid the confusion that would result from mixing
assistance under two categories having differing requirements. Therefore,
grantees should consider revamping their CDBG economic development
programs to clearly separate microenterprise assistance from all other forms.
410
NATIONAL OBJECTIVES ¾¾ MICROENTERPRISE ASSISTANCE
Objective Qualifies If Example Additional Information
L/M Income
Area Benefit
The microenterprise assisted provides
services to a residential area that has a
sufficiently high percentage of L/M
income persons.
A small carry-out store in a
neighborhood having more than 51%
L/M income residents.
For more information, see page 3-7.
L/M Income
Limited Income
The microenterprise assistance is
provided to a L/M income person who
owns or is developing a microenterprise.
Assisting a resident of public housing to
establish a business providing child care.
For more information, see page 3-14.
L/M Income
Housing
Not applicable.Not applicable.Not applicable.
L/M Income
Jobs
The microenterprise assisted will create
or retain jobs, 51% or more of which will
benefit L/M income persons.
Assisting in the expansion of a house
cleaning service with two employees that
agrees to hire an additional L/M income
person for the business.
For more information, see page 3-24.
For other national objective possibilities, see pages 2-60 and 2-61.
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2-66 v Categories of Eligible Activities Community Development Block Grant Program
Special Activities by Special Activities by CBDOsCBDOs
PrefacePreface The purpose of this preface is to emphasize the distinction between
subrecipients and Community-Based Development Organizations (CBDOs)
as they relate to the CDBG program.
v The term “subrecipient” is defined at §570.500(c) to mean a public
or private nonprofit agency, authority, or organization, or a for-profit
entity authorized under §570.201(o) to provide microenterprise
assistance, receiving CDBG funds from the grantee to undertake
activities eligible under the CDBG program.
v While the types of organizations that qualify as CBDOs generally
would meet the above description, the subrecipient definition at
§570.500(c) excludes CBDOs unless the CBDO is specifically
designated by the grantee to be a subrecipient for CDBG program
purposes.
v Designation of an entity as a subrecipient affects the following:
·whether any income that may be generated by a CDBG-funded
activity that is received by the entity is considered to be CDBG
program income;
·whether the grantee must enter into a written agreement with the
entity containing requirements specified at §570.503 (although
the grantee could elect to enter into such an agreement with a
CBDO whether or not it is designated as a subrecipient); and
·whether the entity is bound by the general administrative
requirements imposed by the OMB Circulars in its
administration of the CDBG funds provided to it by the grantee
(although a grantee could require a CBDO to abide by these
requirements as a condition of providing CDBG funds to the
entity, without the need to designate it as a subrecipient).
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Community Development Block Grant Program Categories of Eligible Activities v 2-67
v Fundamentally, in order to use the authority provided under this
category of Special Activities by CBDOs, the grantee must ensure
that four key tests are met:
·that the entity selected qualifies as a CBDO under §570.204(c),
·that the project that the CBDO will undertake qualifies under
§570.204(a)(1), (2) or (3),
·that the CBDO will be “carrying out” the activities as defined
at §570.204(a)(4), and
·that the CBDO is not carrying out an activity specifically
prohibited in §570.207(a).
EligibleEligible
ActivitiesActivities
This category authorizes a grantee to designate certain types of entities to
carry out a range of activities that may include activities the grantee may
otherwise not carry out itself. While the “otherwise ineligible” activities
covered by this authority may take many forms, the most frequent use of this
provision in the CDBG program has been to carry out new construction of
housing. However, there are also other advantages of using a CBDO in the
CDBG program: specifically, for the purpose of providing public services
that in certain circumstances are not subject to the expenditures cap
otherwise applicable to Public Services. This exception is explained in more
detail in the following subsections.
EligibleEligible
ProjectsProjects
Under this category, a qualified CBDO can only carry out any or all of the
following three types of projects:
v Neighborhood revitalization: Activities undertaken under this
provision must be of sufficient size and scope to have an impact on
the decline of a designated geographic location within the jurisdiction
of the grantee (but not the entire jurisdiction of an entitlement
community unless it has a population of 25,000 or less). The
activities to be considered for this purpose are not limited to those
funded (or to be funded) with CDBG assistance.
v Community Economic Development: This type of project must
include activities that increase economic opportunity, principally for
low- and moderate-income persons, or that are expected to create or
retain businesses or permanent jobs within the community. Housing
activities may be included within this project type if they can clearly
link the need for affordable housing accessible to existing or planned
jobs, or otherwise address the Consolidated Plan’s definition of
“expanded economic opportunity” at 24 CFR Part 91.1(a)(1)(iii).
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2-68 v Categories of Eligible Activities Community Development Block Grant Program
v Energy Conservation: Activities carried out under this provision are
clearly designed to conserve energy for the benefit of residents
within the grantee’s jurisdiction. An example of this type of project
may involve the construction of energy efficient housing where
substantial savings in heating and/or cooling costs can expect to be
realized.
Application Tips: The typical CDBG eligibility categories (e.g., public
facilities and improvements, public services, rehabilitation) may appear
either singly or in virtually any combination under any one of these three
types of projects. CDBG funds do not have to constitute the only source of
funding in the project.
Note also that the definitions of these terms are not synonymous with the use
of these terms in other parts of the CDBG regulations (see §570.201(p),
570.202(b)(4) and 570.203).
EligibleEligible
EntitiesEntities
In order to qualify as a CBDO, an entity must meet the criteria specified at
§570.204(c)(1), (2), or (3). Generally, this means that the entity must:
v Be organized under State or local law to carry out community
development activities. For entitled communities, the entity must
operate primarily within an identified neighborhood within the
grantee’s jurisdiction.
v Maintain at least 51% of its governing body’s membership to be
made up of any combination of the following:
·low- and moderate-income residents of its area of operation,
·owners or senior officers of private establishments and other
institutions located in and serving its geographic area of
operation, or
·representatives of low- and moderate-income neighborhood
organizations located in its geographic area of operation.
v Require that members of the governing body must be nominated and
approved by the organization’s general membership or by its
permanent governing body (except as otherwise authorized in
§570.204(c)(1)(v)).
v Have as its primary purpose the improvement of the physical,
economic, or social environment of its geographic area of operation,
with particular emphasis on the needs of low- and moderate-income
persons.
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Community Development Block Grant Program Categories of Eligible Activities v 2-69
v Be either nonprofit or for-profit, but, if a for-profit, only incidental
monetary benefits to its members are allowed.
v Not be an agency or instrumentality of the grantee, and not permit
more than one-third of its governing body to be appointed by or
consist of elected or other public officials or employees of the
grantee (or of any other entity that could not qualify as a CBDO),
even if such persons would otherwise meet the requirements
described above.
v Not be subject to the reversion of its assets to the grantee upon
dissolution (although a grantee may specify as a condition of
providing CDBG funds to the entity that any assets related to the
specific CDBG assistance being provided must revert to the grantee,
whether or not the grantee designates the CBDO as a subrecipient.
(Application of the reversion of assets clause under §570.503(b)(8)
would be required for any CBDO designated as a subrecipient and
would function to permit the specific assets purchased with the
CDBG funds to revert back to the grantee. This would not constitute
a violation of the §570.204 requirement.)
v Be free to contract for goods and services from vendors of its own
choosing (a sign that the entity is not an agent of the grantee).
Application Tips: Entities which do not meet the CBDO requirements are
not prohibited from establishing a subsidiary organization to carry out an
activity under this category, but the subsidiary organization in such case
would need to be in control of itself and not be merely a “front” for the
parent organization.
The regulations at §570.204(c)(2) also provide other ways that an entity may
qualify as a CBDO (e.g., Small Business Administration Section 301(d)
entity, Section 501, Section 502, or Section 503 Companies). Most notably,
it qualifies as a CBDO any entity that has been designated by a HOME
participating jurisdiction as a Community Housing Development
Organization (CHDO), and which has a geographic area of operation that
is not greater than one neighborhood and which has received, or expects to
receive, HOME funding. This could include a CHDO that does not meet the
standard 51% board membership requirements discussed above for CBDOs.
It should also be noted that a CHDO that meets the standard requirements to
qualify as a CBDO (and thus does not need to qualify under this exception)
would not be subject to the single neighborhood limitation.
§570.204(c)(3) of the regulations further allows the grantee an opportunity to
show, to HUD’s satisfaction, that an entity that does not meet the specific
criteria at §570.204(c)(1) or (2) is nevertheless sufficiently similar in
purpose, function, and scope to those eligible entities to qualify as a CBDO.
In reviewing such an entity’s charter and by-laws for this purpose, HUD will
be looking for evidence that the organization’s principal purpose is consistent
415
2-70 v Categories of Eligible Activities Community Development Block Grant Program
with the grantee’s objectives for improving the area in question and that key
stakeholders in that area have substantial input in how the organization
operates.
Note: If a grantee is unsure whether a particular organization qualifies as a
CBDO under this category, it should seek assistance from its local HUD
field office.
“Carry out”“Carry out”The authority conveyed under this category requires that the CBDO “carry
out” the funded activities. This means that the CBDO will undertake the
activity directly or through contracts with an entity other than the grantee. In
any case where the CBDO provides CDBG funds to another entity, it must
be clear that the CBDO has a direct and controlling interest in how and
where the activities are undertaken. The purpose of this restriction is to
ensure that the grantee itself is not playing a major and controlling interest in
the funded activities. Perhaps the “litmus test” for this purpose is whether
the entity has the authority, independent of the grantee, to stop the project if
something is going wrong.
Application Tips: The CBDO is not prevented from entering into a contract
with another entity to assist in project implementation so long as the contract
provides the CBDO with sufficient control over the project to ensure
compliance with all program requirements (e.g., a CBDO can contract with a
developer to build housing and not have to use CBDO staff to construct the
units).
IneligibleIneligible
ActivitiesActivities
Special activities by CBDOs do not include:
v Any activity described in §570.207(a) as ineligible. That is,
buildings for the general conduct of government, general government
expenses, and political activities.
v Any activity which would violate the specific limitations described
below:
·provision of public services in violation of the prohibition against
substituting CDBG for State or local funds as set forth in
§570.201(e), or that would exceed the dollar limitations
described under §570.201(e)(1) and (2) unless the regulations
otherwise provide that the services are exempt from that cost
limitation (see discussion under Additional Considerations
subsection, below). Reference: §570.204(b)(2)
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Community Development Block Grant Program Categories of Eligible Activities v 2-71
·provision of assistance for a special economic development
activity eligible under §570.203 that does not comply with the
Public Benefit requirements of §570.209. References:
§570.204(b)(3) and §570.209
·planning and administrative activities that are eligible under
§570.205 or §570.206 which would result in the grantee
exceeding the 20% cost limitation on such activities, unless the
regulations specifically provide that the activity is exempt from
that cost limitation. Reference: §570.204(b)(4)
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
SpecialSpecial
ActivitiesActivities
by by CBDOsCBDOs
Since the majority of activities carried out by a CBDO under this authority
are also eligible under other categories covered in this Guidebook, refer to
the applicable sections in this chapter concerning the considerations
necessary to determine how to meet the CDBG national objectives. Where
otherwise ineligible housing activities are being carried out, see the section
on Construction of Housing for guidance.
AdditionalAdditional
ConsiderationsConsiderations
The use of CDBG funds by a grantee to fund CBDOs does not relieve the
grantee of its responsibility for meeting program requirements on how those
funds are used. Thus, even if the grantee does not designate the CBDO as a
subrecipient, it should nevertheless give serious consideration to developing
a written, contractual agreement with the CBDO that would be comparable
to that required with subrecipients. Such an agreement would include the
scope of work, the activity(ies) to be carried out, the national objective(s) to
be met, time frames, termination criteria, reporting requirements, and
applicability of other requirements (e.g., those specified in Subpart K of the
CDBG regulations).
It is important to note that when an activity is being carried out by a CBDO
under this category and the activity is of such nature that it would also
qualify under the category of Special Economic Development Activities at
§570.203, that activity will be subject to the Public Benefit requirements set
forth in §570.209 and further described in Appendix B of this Guide
(although if the CBDO is carrying out any such activities pursuant to a
HUD-approved Neighborhood Revitalization Strategy [NRS], the grantee
may elect to exempt the activities from the aggregate public benefit
standards.) See Appendix E for information on NRS and Appendix B for
information on the aggregate standards.
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2-72 v Categories of Eligible Activities Community Development Block Grant Program
It should also be noted that, while as a general rule CBDOs cannot carry out
public services that are not subject to the cost limitation on the amount that
the grantee may obligate for public services (i.e.,15% cap), there are two
exceptions to this rule. The exceptions include:
v Any services provided by a CBDO that are specifically designed to
increase economic opportunities through job training and placement
and other employment support services (e.g., peer support programs,
counseling, child care, transportation, and other similar services);
and
v Services of any type being provided by a CBDO pursuant to a
Neighborhood Revitalization Strategy approved by HUD.
(Reference: 24 CFR 91.215(e) and Appendix E of this Guide for
further information on such strategies.)
Note that, if a grantee does not designate the CBDO as a subrecipient, any
revenue generated by its CDBG-funded activities is not classified as CDBG
program income, since by definition, program income is money that is
received by the grantee or a subrecipient. While this may be a way to help a
high-performing CBDO secure ongoing funding to continue its mission
following completion of the CDBG-funded project, it must be noted that,
since such revenue is not program income, it cannot be included in the bases
for calculating the public services or planning/administration caps.
However, when the grantee provides funds to a CBDO in the form of a loan,
any payments made by the CBDO to the grantee on that loan would be
CDBG program income, whether or not the CDBO has been designated as a
subrecipient.
If a grantee intends to fund a CBDO that lacks capacity to carry out complex
development activities without substantial “hand-holding,” careful
consideration must be paid to the “carry out/control” aspect of §570.204 to
ensure that program requirements are not violated. One solution may be to
assist the CBDO in hiring professionals, such as a more experienced
nonprofit, a general contractor, or an architectural and engineering firm, to
provide needed expertise to complete the project. The grantee could also
break a project into two parts and, in the first year, fund capacity building for
the CBDO before the CBDO carries out the project.
Note also that complex development projects may stretch the ablitity of
grantees (or HUD field offices) to adequately monitor (e.g., carrying out
multi-funded, low-income housing tax credit deals). In such cases, grantees
should seek the appropriate expertise to ensure that program requirements
are met.
418
Community Development Block Grant Program Categories of Eligible Activities v 2-73
HomeownershipHomeownership
AssistanceAssistance
Under the provisions at §570.201(n), grantees and their subrecipients may
provide financial assistance to low- and moderate-income households to
assist them in the purchase of a home.
EligibleEligible
ActivitiesActivities
The specific purposes for which financial assistance using CDBG funds may
be provided under this category are to:
3 Subsidize interest rates and mortgage principal amounts, including
making a grant to reduce the effective interest rate on the amount
needed by the purchaser to an affordable level. (The funds granted
would have to be applied towards the purchase price.) Alternatively,
the grantee/subrecipient could make a subordinate loan for part of
the purchase price, at little or no interest, for an amount of funds the
payments on which, together with that required under the first
mortgage, would be affordable to the purchaser.
3 Finance the cost of acquiring property already occupied by the
household at terms needed to make the purchase affordable.
3 Pay all or part of the premium (on behalf of the purchaser) for
mortgage insurance required up-front by a private mortgagee. (This
would include the cost for private mortgage insurance.)
3 Pay any or all of the reasonable closing costs associated with the
home purchase on behalf of the purchaser.
3 Pay up to 50% of the down payment required by the mortgagee for
the purchase on behalf of the purchaser.
Note especially that the use of funds under this category is specifically
limited to assisting low- and moderate-income households. Reference:
§570.201(n)
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
HomeownershipHomeownership
AssistanceAssistance
Because the use of CDBG funds authorized under this category is limited to
assisting low- and moderate-income households, any such use of funds
would clearly qualify under the national objective of benefit to low- and
moderate-income persons-housing activities, and no further consideration
needs to be given here. Reference: §570.208(a)(3)
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2-74 v Categories of Eligible Activities Community Development Block Grant Program
AdditionalAdditional
ConsiderationsConsiderations
Homeownership assistance may also be eligible under the categories of
Public Services or Special Activities by CBDOs. While these categories
don’t have the same restrictions on the type of assistance that may be
provided, they do have to comply with the public services cap. However,
under these provisions, assistance is not specifically limited by statute to
L/M income persons. Therefore, a grantee should carefully consider its
objectives against these factors and select the category that best fits those
objectives in the context of its entire CDBG program.
In the case where HUD has approved a Neighborhood Revitalization
Strategy (NRS) and the grantee plans to provide homeownership assistance
pursuant to that strategy, two further considerations should be given. First, if
the grantee elects to use a CBDO to deliver services in the strategy area, any
services provided by the CDBO (including homeownership assistance)
would be exempt from the expenditures cap on Public Services. This would
remove the main advantage of qualifying the assistance under the
Homeownership Assistance category. Moreover, if the strategy involves
assisting non-L/M income households to purchase houses in the area, CDBG
assistance could not be provided under the Homeownership Assistance
category (which is limited to assistance provided to L/M income
households). The use of a CBDO would be needed for this purpose. It
should also be noted that where CDBG funds are provided to non L/M
income households in a NRS area, meeting the L/M Income Benefit national
objective is made feasible by a special feature offered by an NRS. All
housing units assisted in such an area may be considered to be part of a
single structure for the purpose of meeting the 51%+ occupancy
requirement. See Appendix E to this Guide that describes the NRS feature
of the CDBG program in further detail.
420
Community Development Block Grant Program Categories of Eligible Activities v 2-75
Planning andPlanning and
Capacity BuildingCapacity Building
EligibleEligible
ActivitiesActivities
CDBG funds may be used for:
3 Studies,
3 Analysis,
3 Data gathering,
3 Preparation of plans, and
3 Identification of actions that will implement plans.
ExampleExample The types of plans which may be paid for with CDBG funds include, but are
not limited to:
·Comprehensive plans;
·Individual project plans;
·Community development plans;
·Capital improvement programs;
·Small area and neighborhood plans;
·Analysis of impediments to fair housing choice;
·Environmental and historic preservation studies; and
·Functional plans (such as plans for housing, land use,
energy conservation or economic development).
A more detailed description of planning and capacity building activities is
located at §570.205 of the regulations.
Such funds may also be used under this category for activities designed to
improve the grantee’s capacity (or that of its subrecipients ) to plan and
manage programs and activities for the grantee’s CBDG program.
However, the amount of CDBG funds which may be used for activities
under this category (whether by the grantee or its subrecipients) is subject to
the statutory limitation on planning and administrative cost. Note that the
planning and administrative costs of subrecipients subject to the 20% cap are
limited to those related to the CDBG program as a whole and not for
activity-specific administrative costs related to carrying out other eligible
Subpart C activities which are considered part of the cost of those activities.
(See also the discussion describing the 20% cap which is contained in the
Program Administration Costs category section and the description on how
to calculate the cap following that section.) References: §570.200(g) and
§570.205
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Note, however, that capacity building is also eligible under the category of
Technical Assistance, which is discussed in this Guide under the section of
this chapter entitled Miscellaneous Other Activities. The use of funds under
that category is not subject to the 20% cap, but must be shown to meet a
national objective. Reference: §570.201(p)
Planning and capacity building activities do not include:
v Engineering, architectural and design costs related to a specific
project (e.g., detailed engineering specifications and working
drawings); or
v Other costs of implementing plans.
ExampleExample While developing an economic development strategy for the city or county is
an eligible planning activity, printing brochures promoting the city or county
in order to attract businesses is not.
Complying withComplying with
NationalNational
ObjectivesObjectives¾¾
Planning andPlanning and
CapacityCapacity
BuildingBuilding
Because CDBG funds spent for planning and capacity building costs are
considered to address the national objectives of the CDBG program as a
whole, no documentation of such compliance is required. Reference:
§570.208(d)(4)
AdditionalAdditional
ConsiderationsConsiderations
The cost of implementing plans, while not eligible as planning costs, may
qualify for CDBG funding if the implementing actions are otherwise eligible
activities (i.e., activities eligible under §570.201 through §570.204).
A market study performed on behalf of the grantee to determine the market
for some type of facility or business would be eligible under the category of
Planning, but a market study performed on behalf of a particular business
would only be eligible for CDBG funding under the category of Special
Economic Development Activities. Similarly, conducting a market study on
the need for a new hotel downtown would be eligible under Planning, while
conducting a feasibility study of a specific proposed project (e.g., a hotel) on
a specific site would have to qualify under the Special Economic
Development Activities category.
422
Community Development Block Grant Program Categories of Eligible Activities v 2-77
ProgramProgram
Administration CostsAdministration Costs
EligibleEligible
ActivitiesActivities
CDBG funds may be used to pay reasonable program administration costs
and carrying charges related to the planning and execution of community
development activities assisted in whole or in part with funds provided under
the CDBG or the HOME or Urban Development Action Grants (UDAG)
programs.
Program administration costs include staff and related costs required for
overall program management, coordination, monitoring, reporting, and
evaluation, as described at §570.206(a)(1).
Other activities eligible under this category include:
3 Citizen participation costs Reference: §570.206(b),
3 Fair housing activities Reference: §570.206(c),
3 Indirect costs charged using an accepted cost allocation plan
Reference: §570.206(e),
3 Development of submissions or applications for Federal programs
Reference: §570.206(f), and
3 Certain costs of administering the HOME program or a Federally
designated Empowerment Zone or Enterprise Community Reference:
§570.206(i).
Office space: A grantee may charge to the CDBG program the costs of rent
and maintenance of office space to house the staff involved in program
administration, but may not purchase or construct offices for this purpose.
Proration: Where an individual staff person performs some duties that are
eligible as administration costs as well as other duties that are eligible under
other categories of basic eligibility, the grantee may elect to charge either all
of such person’s costs to administration if the person’s primary duties are
program administration, or only the portion of the staff’s duties that are
covered under this category (provided appropriate time distribution records
are kept).
20% cap: Costs that are charged to administrative costs and to Planning and
Capacity Building per §570.205 and 206 are subject to a statutory limitation
that not more than 20% of grant funds plus program income may be used for
planning and administration. (This limitation is not contained in the Housing
and Community Development Act of 1974, which authorizes the CDBG
program, but has been included in each Appropriations statute for the CDBG
program since 1978.) See the description on how to calculate the amount of
this limitation, shown later in this section.
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Note: 24 CFR 570.206(g) authorizes the use of CDBG funds to pay
administrative expenses to facilitate housing identified in a grantee’s housing
assistance plan (HAP). However, the Comprehensive Housing Affordability
Strategy (CHAS) (now a part of the Consolidated Plan) replaced the HAP.
The CHAS had a broader reach and was not limited exclusively to housing
for L/M income persons. Therefore, this provision of the regulation cannot
be used without a waiver from HUD on the limitation concerning the
identification of the housing in the grantee’s HAP and provided the grantee
otherwise meets the CDBG waiver standards at §570.5. Reference:
§570.206(g)
ExampleExample Overall program management, coordination, monitoring, and evaluation
include, but are not limited to, the following types of assistance:
·Preparing program budgets, schedules and amendments;
·Evaluating program results against stated objectives;
·Coordinating the resolution of audit and monitoring findings;
·Developing systems for assuring compliance with program
requirements;
·Monitoring program activities for progress and compliance with
program requirements;
·Preparing reports and other compliance documents related to the
program for submission to HUD; and
·Developing interagency agreements and agreements with
subrecipients and contractors to carry out program activities.
Program administration does not authorize:
v Political activities. Reference: §570.207(a)(3)
v The acquisition, construction, or reconstruction of space in a
government office building for staff administering the grantee’s
CDBG, UDAG, Rental Rehabilitation, HoDAG, or HOME
programs, since CDBG funds may not be used to assist “buildings
for the general conduct of government.” See the section on Public
Facilities and Improvements for more information on this limitation.
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Community Development Block Grant Program Categories of Eligible Activities v 2-79
v Staff and overhead costs directly involved in carrying out activities
eligible under §570.201 through §570.204, since those costs (often
referred to as “activity delivery costs”) are eligible as part of such
activities.
ComplyingComplying
with Nationalwith National
ObjectivesObjectives¾¾
ProgramProgram
AdministrationAdministration
CostsCosts
Costs that are appropriately charged to this category are presumed to meet a
CDBG national objective, and the grantee does not have to maintain any
other documentation for this purpose. Reference: §570.208(d)(4)
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Planning and Administrative CapPlanning and Administrative Cap
Description
As indicated in the preceding pages, no more than 20% of the sum of any grant plus program income that is
received during the program year may be obligated by the grantee and its subrecipients for planning and
administrative costs, as defined in §570.205 and §570.206, respectively.
Recipients of entitlement grants will be considered to be in conformance with this limitation if total obligations
charged under those categories during the grantee’s most recently completed program year, without regard to
the source year of funds, are not greater than 20% of the sum of the entitlement grant received for that program
year plus the program income received during that program year by the grantee and its subrecipients.
References: Appropriations Acts and §570.200(g)
Calculating the Cap
(1)To determine the base against which the 20% cap will be applied, total the amount of CDBG funds
received during the program year from the following sources:
Entitlement Grant (from line 8.b of the Funding
Approval form, HUD-7082)$___________
Surplus from Urban Renewal (from line 10.b of the
Funding Approval form)$___________
Program income received by the grantee and its
subrecipients $___________
TOTAL $___________
(2)To calculate the amount of the cap, multiply the total
amount determined in Step (1) above by .20 and enter
the number here $___________
This amount represents the maximum dollar level that may be obligated during the program year and charged
to the basic eligibility categories of Planning and Capacity Building and Program Administration, i.e., the cap.
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Community Development Block Grant Program Categories of Eligible Activities v 2-81
Determining Compliance with the CapDetermining Compliance with the Cap
Compliance with the cap is determined for entitlement grantees by performing the following calculation at the
end of each program year:
Determine the total amount of CDBG funds expended during the
program year for activities that are classified as eligible under §570.205
(Planning and Capacity Building) and §570.206 (Program Administration
Costs):$___________
Add to the above amount the total amount of unliquidated obligations
for activities under these same two categories, as of the end of the
program year:$___________
Subtract from the balance the total amount of unliquidated obligations
for these two categories, as of the end of the preceding program year:$(_________)
Enter here the result of the above calculations. This is the amount
of net obligations for Planning Administration during the program
year:$___________
To be in compliance with the 20% cap, the amount determined above as the net amount obligated may not
exceed the amount determined as the cap for the year in the first portion of this subsection (see (2) on the
preceding page).
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MiscellaneousMiscellaneous
Other ActivitiesOther Activities
Other miscellaneous activities eligible under the CDBG regulations are
described in this section of the Guide.
Payment ofPayment of
the Non-Federalthe Non-Federal
ShareShare¾¾
§570.201(g)§570.201(g)
This provision does not make any additional activities eligible for CDBG
assistance because it limits the use of CDBG funds to paying the non-
Federal share only for activities which are otherwise eligible for CDBG
assistance. Therefore, any proposed use of CDBG funds to pay the non-
Federal share of a Federal grant-in-aid should be evaluated against the
requirements of the applicable eligibility category.
It should also be noted that the authority to use CDBG funds for the non-
Federal share of another program does not override any specific restriction
against that use that may be contained in the statute or regulations for that
program. For example, the HOME program requires a non-Federal match,
but specifically states that CDBG expenditures may not count towards
meeting that requirement.
Urban RenewalUrban Renewal
CompletionCompletion¾¾
§570.201(h)§570.201(h)
This provision does not make any additional activities eligible for CDBG
assistance because any cost of completing an urban renewal project funded
under Title I of the Housing Act of 1949 must also be eligible under other
activity categories described in this Guide.
For example: The costs of public improvements required to complete an
urban renewal project would also be eligible under the category of Public
Facilities and Improvements described on page 2-11.
TechnicalTechnical
AssistanceAssistance¾¾
§570.201(p)§570.201(p)
This provision makes eligible the use of CDBG funds to increase the
capacity of public or nonprofit entities to carry out eligible neighborhood
revitalization or economic development activities. (This could include the
grantee itself.) In order to use the funds under this authority, the grantee
must determine, prior to providing the assistance, the eligibility of the
activity for which capacity is to be built and that there is a reasonable
expectation that a national objective can be met once the entity has received
the technical assistance and undertakes the activity. It should be noted that,
while building capacity of an entity under this authority provides an
alternative to using the authority under the category of Planning and Capacity
Building (and thus can help avoid a problem with exceeding the 20% cap),
the program does not provide a presumption concerning national objective
compliance. Thus, it is important that this be considered before charging
costs under this category. Factors that should be considered in determining
428
Community Development Block Grant Program Categories of Eligible Activities v 2-83
if a national objective can be met include the nature of the organization
receiving the assistance, the type and eligibility of the activity to be carried
out, the location of the activity, and the entity’s expected (or traditional)
clientele. Based on a review of these factors, the grantee should have a
reasonable expectation that the activity to be undertaken by the entity would
comply with a national objective before funding capacity building.
AssistanceAssistance
to Institutionsto Institutions
of Higherof Higher
EducationEducation¾¾
§470.201(q)§470.201(q)
This authority may be used by a grantee to provide assistance to an
institution of higher education (i.e., secondary schools or higher) when the
grantee determines that such an institution has demonstrated a capacity to
carry out activities that fall under one or more of the basic eligibility
categories under the CDBG program.
HousingHousing
ServicesServices¾¾
§570.201(k)§570.201(k)
Section 105(a)(20) provides that CDBG funds may be used to pay costs in
support of activities eligible for funding under the HOME program. This
includes services such as housing counseling in connection with tenant-based
rental assistance and affordable housing projects, energy auditing,
preparation of work specifications, loan processing, inspections, tenant
selection, management of tenant-based rental assistance, and other services
related to assisting owners, tenants, contractors, and other entities
participating or seeking to participate in the HOME program. Since such
assistance must also meet HOME income targeting requirements, see the
discussion under L/M Income Housing in Chapter 3 to determine how these
services can meet the CDBG national objectives. (Note that this provision is
not prohibited from qualifying under other CDBG national objectives but the
requirement to comply with HOME criteria makes the L/M Income Housing
Benefit the clear alternative for CDBG compliance.)
(§570.206 also provides that CDBG funds may be used to pay for program
administration of the HOME program.)
ReconstructionReconstruction Reconstruction became explicitly eligible for CDBG assistance as a result of
a legislative change under section 225 of the Omnibus Consolidated
Rescissions and Appropriations Act of 1996 (P.L. 104-234, enacted April
26, 1996). This change [in section 105(a)(4) of the Housing and Community
Development Act of 1974 as amended] broadens grantees’ ability to use
CDBG funds for “reconstruction” of properties. While this eligibility
provision has not yet been codified in the CDBG regulations, it became
effective upon enactment. Grantees have thus been able to make use of this
provision since enacted.
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While the statute does not define the term “reconstruction,” for CDBG
purposes, it is generally defined as meaning the rebuilding of a structure on
the same site in substantially the same manner. Deviations from the original
design are permitted for reasons of safety or if otherwise impractical. The
structure to be reconstructed may be residential or nonresidential, and either
publicly- or privately-owned. For reconstruction involving housing, the
number of housing units on a site may not be increased, but the number of
rooms per unit may be increased or decreased. [Note that any decrease in the
number of units on a site may require compliance with the one-for-one
replacement of L/M income dwelling units at 24 CFR part 42, subpart C.]
Reconstruction of residential structures would also permit replacing an
existing substandard unit of manufactured housing with a new or standard
unit of manufactured housing.
Note that reconstruction is also permitted elsewhere in the regulations under
Public Facilities and Improvements [§570.201(c)], Privately Owned Utilities
[§570.201(1)], and Special Economic Development Activities [§570.203].
In In RemRem Section 105(a) (23) of the Act, as added by Section 807 (a) (4) of the
Housing and Community Development Act of 1992 provided a separate
category of eligibility under the CDBG program regarding the provision of
assistance to housing units acquired through tax foreclosure proceedings.
Specifically, it authorizes activities necessary to make essential repairs and
payment of operating expenses needed to maintain the habitability of housing
units acquired through tax foreclosure proceedings in order to prevent
abandonment and deterioration of such housing in primarily low- and
moderate-income neighborhoods. This provision has not been incorporated
into the regulations at the time of this writing, but is available for use
nevertheless. Some aspects that must be considered for meeting the national
objectives when using this authority should be noted. The statute clarified
that, since these expenses are limited to housing located in primarily low-
and moderate-income neighborhoods, the L/M Income Benefit national
objective is to be met through the Area Benefit subcategory. This means
that, even though these are housing activities, the usual requirement that
occupancy by L/M income households must be demonstrated does not apply
to activities carried out under this authority. Of course, the grantee could
also claim such activities as qualifying under the Slums/Blight objective in
particular circumstances where meeting the criteria for this objective could
be demonstrated.
430
Community Development Block Grant Program Categories of Eligible Activities v 2-85
HandicappedHandicapped
AccessibilityAccessibility
The statute makes specifically eligible the removal of material and
architectural barriers that restrict the accessibility or mobility of elderly or
handicapped persons.
Confusion has emerged concerning the distinction between removing
barriers to accessibility and the need to provide for accessibility. Together,
these issues led some grantees and beneficiaries to the impression that the
involvement of the removal of barriers would qualify an entire activity for
assistance under the CDBG program, or that the additional costs of making
even newly constructed buildings accessible to the handicapped should be
eligible for CDBG assistance under that authority, whether or not the rest of
the building could so qualify.
The passage of the Americans with Disabilities Act (ADA) had much to do
with this confusion. Pressure has mounted on grantees to provide
accessibility in both public and private places. This has led to some attempts
to use CDBG funds to provide accessibility in ways that go well beyond the
simple removal of existing barriers. As a result, it became necessary to
clarify the regulations.
For many years, the CDBG regulations contained the removal of
architectural barriers as a separate category of eligibility. However, this
free-standing category was removed in 1995 because of the confusion it
seemed to be causing and has been woven into other eligibility categories as
appropriate. The regulations also contained (and still contain) a provision
indicating that such barrier removal can meet the national objective of benefit
to L/M income under Limited Clientele.
Where the construction of a building or improvement is eligible for
assistance with CDBG, the costs of making the building or improvement
accessible to persons with handicaps is also eligible as an integral cost of the
construction and there is no need to provide separate eligibility for such a
purpose. The removal of architectural barriers is now clarified as
rehabilitation or reconstruction under the categories of Public Facilities and
Improvements, Rehabilitation, and Special Economic Development
Activities.
The main issue that is presented in the CDBG program with respect to
handicapped accessibility lies in being able to meet a national objective. If
the new construction of a public facility or improvement cannot meet a
national objective based on either area benefit or the clientele to be served,
then the features that are required in such construction in order to provide for
accessibility to handicapped persons also cannot meet a national objective.
The situation is somewhat different with rehabilitation or reconstruction.
Since the cost of removing existing barriers is specifically eligible under the
statute, §570.208(a)(2)(ii) provides that removal of accessibility barriers may
be presumed to meet the L/M Income Limited Clientele criteria if the costs
of such removal is restricted, to the extent practicable, to the removal of such
barriers in:
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2-86 v Categories of Eligible Activities Community Development Block Grant Program
v The reconstruction of a public facility or improvement, or portion
thereof, that does not meet the criteria for L/M Income Benefit under
Area Benefit,
v The rehabilitation of a privately owned nonresidential building or
improvement that does not meet the criteria for L/M Income Benefit
under Area Benefit or Jobs, or
v The rehabilitation of the common areas of a residential structure that
contains more than one dwelling unit and that does not meet the
criteria for L/M Income Benefit under Housing.
In a related matter, the use in the regulations concerning the presumption of
L/M income status of handicapped persons became problematical as the use
of the term “handicapped” broadened over the past several years to include
categories of handicap that do not necessarily heavily impact on a person’s
capacity to work in good paying jobs. Thus, when HUD changed the
regulations concerning the removal of architectural barriers, it also amended
them to revise the term used for this purpose. The regulations now use the
term “severely disabled adult” in lieu of “handicapped.” See the discussion
of this matter under the L/M Income Limited Clientele subsection in Chapter
3 of this Guide.
432
Community Development Block Grant Program Categories of Eligible Activities v 2-87
Activities SpecifiedActivities Specified
as Ineligibleas Ineligible
IneligibleIneligible
ActivitiesActivities
The CDBG program regulations identify certain activities as categorically
ineligible. They also identify certain other activities that are ineligible unless
they are carried out by a CBDO under the authority of §570.204.
The general rule in the CDBG program is that any activity that is not
authorized under the provisions of §§ 570.201-570.206 (or, where
applicable, the statute) is ineligible to be assisted with CDBG funds.
However, the eligible activities are so broad that it is easy to forget that some
things cannot be done under the program. The purpose of this section is to
discuss specific activities that are ineligible and to provide guidance in
determining the eligibility of other activities frequently associated with
housing and community development.
Categorically ineligible
The following activities may not be assisted with CDBG funds under any
circumstance:
v Buildings or portions thereof, used for the general conduct of
government as defined at §570.3 may not be assisted with CDBG
funds. This does not include, however, the removal of architectural
barriers involving any such building, which may be assisted under
the category of Public Facilities and Improvements. Also, where
acquisition of real property includes a building or other improvement
that would be used for the general conduct of government, the
portion of the acquisition cost attributable to the land may be assisted
under the category of Acquisition of Real Property. Reference:
§570.207(a)(1)
v General government expenses. Except as otherwise specifically
authorized in Subpart C of Part 570 or under OMB Circular A-87,
expenses required to carry out the regular responsibilities of the unit
of general local government are not eligible for assistance under this
part. Reference: §570.207(a)(2)
v Political activities. CDBG funds may not be used to finance the use
of facilities or equipment for political purposes or to engage in other
partisan political activities, such as candidate forums, voter
transportation, or voter registration. However, a facility originally
assisted with CDBG funds may be used on an incidental basis to
hold political meetings, candidate forums, or voter registration
campaigns, provided that all parties and organizations have access to
the facility on an equal basis, and are assessed equal rent or use
charges, if any. Reference: §570.207(a)(3)
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Generally ineligible
The following activities may not be assisted with CDBG funds unless
authorized as Special Economic Development Activities under §570.203 or
when carried out by a CBDO under the provisions of §570.204.
v Purchase of equipment. The purchase of equipment with CDBG
funds is generally ineligible.
·Construction equipment. The purchase of construction
equipment is ineligible, but compensation for the use of such
equipment through leasing, depreciation, or use allowances
pursuant to OMB Circulars A-21, A-87, or A-122 as applicable
for an otherwise eligible activity is an eligible use of CDBG
funds. However, the purchase of construction equipment for use
as part of a solid waste disposal facility is eligible under the
category of Public Facilities and Improvements [see
§570.201(c)].
·Fire protection equipment. Fire protection equipment is
considered for this purpose to be an integral part of a public
facility. Thus, purchase of such equipment would be eligible
under the category of Public Facilities and Improvements. This
includes fire engines and specialized tools such as “jaws of life”
and life-saving equipment as well as protective clothing worn by
fire fighters [see §570.201(c)].
·Furnishings and personal property. The purchase of
equipment, fixtures, motor vehicles, furnishings, or other
personal property not an integral structural fixture is generally
ineligible. CDBG funds may be used, however, to purchase or
to pay depreciation or use allowances (in accordance with OMB
Circulars A-21, A-87, or A-122, as applicable) for such items
when necessary for use by a recipient or its subrecipients in the
administration of activities assisted with CDBG funds, or when
eligible as fire fighting equipment, or when such items constitute
all or part of a public service pursuant to §570.201(e). Also,
these items are eligible when carried out by a for-profit business
as part of CDBG assistance under the authority of §570.203(b).
Reference: §570.207(b)(1)
v Operating and maintenance expenses. The general rule is that any
expense associated with repairing, operating, or maintaining public
facilities, improvements, and services is ineligible. Specific
exceptions to this general rule are operating and maintenance
expenses associated with public service activities [see §570.201(e)],
interim assistance [see §570.201(f)], and office space for program
staff employed in carrying out the CDBG program (see §570.206).
For example, the use of CDBG funds to pay the allowable costs of
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Community Development Block Grant Program Categories of Eligible Activities v 2-89
operating and maintaining a facility used in providing a public
service (e.g., salaries, rent) would be eligible under §570.201(e),
even if no other costs of providing the service there are assisted with
such funds. Examples of operating and maintenance expenses that
are generally ineligible include:
·Maintenance and repair of publicly-owned streets, parks,
playgrounds, water and sewer facilities, neighborhood facilities,
senior centers, centers for persons with disabilities, parking, and
other public facilities and improvements. Examples of
maintenance and repair activities for which CDBG funds may
not be used include the filling of pot holes in streets, repairing of
cracks in sidewalks, the mowing of grass in city or county parks,
and the replacement of street light bulbs.
·Payment of salaries for staff, utility costs, and similar expenses
necessary for the operation of public works and facilities.
Reference: §570.207(b)(2)
v New housing construction. See the discussion of this activity type
under the earlier sections of this chapter entitled Construction of
Housing and Special Activities by CBDOs. Reference: §570.207(b)(3)
v Income payments. The general rule is that CDBG funds may not be
used for income payments. For purposes of the CDBG program,
“income payments” is defined as a series of subsistence-type grant
payments made to an individual or family for items such as food,
clothing, housing (rent or mortgage), or utilities, but excludes
emergency grant payments made over a period of up to three
consecutive months directly to the provider of such items or services
on behalf of an individual or family. One time grants, emergency
type grants, or loans for such purposes may be authorized under the
category of Public Services [see §570.201(e)]. Reference:
§570.207(b)(4)
Note: Certain activities, even if they would otherwise be eligible under the
category of Special Economic Development Activities, cannot be assisted
with CDBG funds if they are specifically ineligible under the provisions of
the Public Benefit standards under §570.209. For example, assisting a
business to create jobs that would cost more than $50,000 in CDBG funds
per job would be unallowable. Also, providing assistance to a professional
sports team is not allowed. See Appendix B for further details.
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Documenting ComplianceDocumenting Compliance
This section of the chapter provides special guidance on the requirement the
grantee must document that each assisted activity falls within a specified
category and that it meets the requirements that apply to that category.
The requirement
The nature of the program is that the Federal government provides funds
that a grantee may use in a variety of ways, at its option. There are
limitations within which the grantee must operate, however. In order to
ensure that HUD can carry out its statutory responsibilities to review
grantee performance to determine that program requirements have been
met, the grantee must maintain certain records which are identified in
§570.506 of the CDBG program regulations. §570.506(a) specifies that
the grantee must keep records which provide a full description of each
activity that is selected for assistance, including its location, the amount
of CDBG funds budgeted, obligated and expended for the activity,
and—with particular respect to the subject of this chapter of the Guide—
the provision of the regulations (or in certain cases, the statute) under
which the activity is eligible.
The earlier portions of this chapter have identified the many categories of
basic eligibility that are (at the time of this writing) currently available for
selection. As is evident by a review of those sections, there are aspects that
must be considered in order to make sure that program rules are honored in
the case of almost every category. The files must document all relevant
eligibility considerations that apply. For example, Acquisition of Real
Property is an eligible activity only if it is carried out by a public or private
nonprofit entity. Therefore, the records kept by the grantee in fulfillment of
§570.506(a) must clearly indicate the entity that carried out the acquisition
and the nonprofit status of that entity.
Certain categories of eligibility require, as a condition of such eligibility, that
the grantee must make, and document, a particular local determination.
§570.200(e) identifies those determinations which must be made and
documented as a condition of eligibility.
While a grantee is not required to keep in its own files the records
concerning the eligibility of an activity carried out by a CBDO or a
subrecipient, the grantee must make sure that the required records are kept
by that entity.
436
Community Development Block Grant Program Categories of Eligible Activities v 2-91
The OMB Circulars require recipients of Federal assistance to keep source
documentation to justify all expenditures. For example, for an expenditure
for rehabilitation, the grantee (or its CBDO or subrecipient) should be able to
show an invoice that identifies what the payment was made for, to and by
whom, and the physical location of the property that was rehabilitated.
Where applicable, the rehabilitation contractor, in turn, would be obligated to
be able to produce detailed records showing specifically the costs that it
incurred and for which the invoice was presented. Similarly, a for-profit
entity that receives a working capital loan should have sufficient source
documentation to show the actual use of the CDBG funds.
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Making the Best ChoiceMaking the Best Choice
This section of the chapter stresses the desirability of considering alternative
categories of eligibility for certain types of activities. Several examples are
provided for key program areas to illustrate possible alternatives that may be
available and the considerations that should guide the grantee in making the
wisest choice among them.
The most common among these activity types and the requirements that the
grantee should consider are:
v Public services (public services cap),
v Commercial/industrial projects (public benefit requirements), and
v Planning and administration (planning/admin cap).
The following discussion of these key areas is intended to assist grantees in
thinking through the alternatives that may be available, the factors that
should be considered, and some ground rules that may be helpful in this
process.
Public Services
While the CDBG program was, from the onset, intended to be a physical
development program, it was recognized that certain services can be very
helpful to stabilize a neighborhood and to make for a sustainable
redevelopment of areas needing revitalization. Therefore, the program
authorizes the use of funds to provide services generally, but with a dollar
limitation (usually no more than 15% of program funds may be used for
services). However, there are certain situations where the regulations
provide that services are not subject to this dollar limitation.
The most notable types of services that are not subject to the cap are:
v Financial assistance for homeownership, under the authority of
§570.201(n);
v Employment services (including job training) related to employment
opportunities generated by CDBG-eligible economic development
activities, under the authority of §570.203(c);
v Services provided by a CBDO under the authority of §570.204 and
that are specifically designed to increase economic opportunities
though job training and placement and other related support services,
such as child care and transportation;
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Community Development Block Grant Program Categories of Eligible Activities v 2-93
v Services of any kind that are provided by a CBDO under the
authority of §570.204 and that are carried out pursuant to a
Neighborhood Revitalization Strategy approved by HUD under
§91.215(e)(2) (see also Appendix E of this Guide); and
v General support services provided to owners of and/or persons
developing microenterprises, under the authority of §570.201(o).
If a grantee’s CDBG program is operating at or near its cap on public
services, it is probably wise to review activities planned for future years to
determine if any public services could be reclassified. In doing so, it is
important to remember that shifting employment services from the Public
Services category to that of Special Economic Development Activities would
mean subjecting the services to public benefit requirements. For some
grantees, it may also not be feasible to provide the services they have in mind
through a CBDO because of the lack of a qualified entity in the applicable
area. With respect to homeownership assistance, it should also be
recognized that the alternative category may also have certain limitations.
Commercial/Industrial Projects
Usually, when a commercial or industrial project is assisted in the CDBG
program as a Special Economic Development Activity, or when it is carried
out by a CBDO as a Special Activity by a CBDO, the assistance will be
subject to the public benefit requirements described in §570.209 (and
discussed further in Appendix B of this Guide). While those requirements
may not prevent the project from going forward as planned, it may
nevertheless be useful to consider whether any other category could be used
that may be more desirable.
The alternatives that should be considered in this regard are:
v Employment services that are eligible under §570.203(c) are also
eligible under the Public Services category;
v Depending on the size of the business, assistance that is eligible
under §570.203(b) or (c) may also be eligible under the
Microenterprise Assistance category of 570.201(o);
v Property acquisition that is undertaken by a nonprofit under the
authority of §570.203(a) may also be eligible under the category of
Acquisition of Real Property at 570.201(a);
439
2-94 v Categories of Eligible Activities Community Development Block Grant Program
v Reconstruction of a commercial or industrial property that is eligible
under the authority of §570.203(a) would also be eligible under the
category of Rehabilitation at 570.202;
v Rehabilitation of a commercial or industrial property under the
authority of §570.203(b) may be eligible, at least in part, under the
category of Rehabilitation at 570.202; and
v Provision of one or more public improvements or utilities needed by
the business may qualify under the category of Public Improvements
at §570.201(c) or Privately-Owned Utilities at §570.201(l).
Moreover, an economic development project often involves a number of
different activities that could be assisted in lieu of the specific assistance
requested by a business. Consider, for example, a business that wants to
expand and has requested financial assistance to pay for the construction of a
building. It may be that the business needs to purchase land for the
expansion or might be planning to pay to have the street widened or
otherwise improved to support truck traffic. Either of these needs could be
met with CDBG funds, under other categories than Special Economic
Development Activities, which might be more desirable for the grantee to
provide in order to help the project go forward. This sort of assessment of
alternative activities might also help determine whether Davis-Bacon would
apply to the form of assistance being contemplated.
Planning/administration
There are a few activities eligible under the categories of Planning and
Capacity Building and Program Administration Costs that are also eligible
under other categories of basic eligibility. Since costs charged to §570.205
or 570.206 are subject to the 20% cap, it may be useful to consider any
alternative classification if the grantee is at or near its cap.
Such activities include:
v Fair housing counseling,
v Environmental assessments required for compliance with 24 CFR
part 58,
v Capacity building, and
v Staff cost for persons carrying out program administration activities
but also performing functions in direct support of activities being
carried out under other categories of basic eligibility.
440
Community Development Block Grant Program Categories of Eligible Activities v 2-95
A brief discussion of each of the preceding activities follows:
Fair Housing Counseling
Grantees in the CDBG program have a responsibility to affirmatively further
fair housing. Activities carried out pursuant to this responsibility may be
charged to Program Administration. When the grantee is planning to
provide counseling to advise persons of their rights under the Fair Housing
Act or otherwise assist them in this regard, such activities could also be
eligible under the category of Public Services. While both of these
alternatives involve an overall cost limitation (i.e., the 20% cap and the 15%
cap), it is not likely that a grantee would reach both caps in the same
program year, thus allowing the grantee to shift the costs of these services to
the appropriate category.
Environmental Assessments
The costs of performing the assessment and related public notices as
required under 24 CFR part 58 are considered to be “activity delivery costs”
and are thus part of the costs of carrying out the activity under the same
basic eligibility category applicable to that activity. As such, these costs are
not subject to the 20% cap. Alternately, it should be noted, however, that the
regulations allow charging these costs under §570.205. It would generally
not be desirable for a grantee if it is at or near its 20% cap to elect this
alternative. There are some reasons, however, to think about this where
possible. Where environmental assessment costs incurred with respect to an
activity would create a problem for that activity, it may be preferable to
charge that cost to the category of Planning and Capacity Building.
Although this would be rare, it might occur in the case where the supported
activity falls under the categories of Public Services or Special Economic
Development Activities, and the grantee is in danger of exceeding the 15%
cap or failing the public benefit requirements. Furthermore, a grantee may
prefer to charge all its environmental assessment costs to §570.205 for
administrative convenience, so as to avoid the need to shred the costs of one
or more staff persons performing the assessments.
Capacity Building
A discussion of the alternatives available for the costs of capacity building
may be found under the sections of this chapter entitled Miscellaneous Other
Activities (see Technical Assistance) and Planning and Capacity Building.
441
2-96 v Categories of Eligible Activities Community Development Block Grant Program
Split-function Staff
Many grantees, especially the smaller ones, and some subrecipients have
staff that perform both program administration and activity delivery
functions. The regulations provide such grantees (and subrecipients) the
option of prorating the costs according to the extent of time involved in each,
or, in the case of staff whose primary function is program administration,
charging all the person’s time to the category of Program Administration.
The implications to be considered in evaluating this option are virtually the
same as those for the environmental assessment function discussed above.
442
Memorandum
REPORT TO:Community Development Board
FROM:Elizabeth Cramblet, Associate Planner
Chris Saunders, Community Development Manager
Erin George, Interim Director of Community Development
SUBJECT:NEHMU Zone Text Amendment to Modify the City's Development Code to
Allow Apartments as a Permitted Use with No Restrictions in Area on the
Second and Subsequent Floors, and Basements of Buildings, and to Allow
Lobbies on the Ground Floor When Associated with Residential Uses in the
NEHMU District (Northeast Historic Mixed Use District), Application 24225.
MEETING DATE:July 15, 2024
AGENDA ITEM TYPE:Community Development - Legislative
RECOMMENDATION:Having reviewed and considered the staff report, draft ordinance, public
comment, and all information presented, I hereby adopt the findings
presented in the staff report for application 24225 and recommend approval
of the NEHMU Zone Text Amendment.
STRATEGIC PLAN:4.2 High Quality Urban Approach: Continue to support high-quality planning,
ranging from building design to neighborhood layouts, while pursuing urban
approaches to issues such as multimodal transportation, infill, density,
connected trails and parks, and walkable neighborhoods.
BACKGROUND:This application includes a privately initiated proposal to modify the City's
development code to allow apartments as a permitted use with no
restrictions in area of the second and subsequent floors, and basements, and
to allow lobbies on the ground floor when associated with residential uses in
the NEHMU District (Northeast Historic Mixed Use District). Currently the
NEHMU zoning district only allows apartments as an accessory use that
occupies less than fifty percent (50%) of the gross floor area of the building,
and not on the ground floor, only the second and subsequent floors. The
change would essentially allow multi-story residential buildings within the
NEHMU district that are currently not allowed.
The Northeast Historic Mixed Use District is located in the northeast section
of the city that encompasses approximately 40 acres and is located within
the Neighborhood Conservation Overlay District. With the exception of a few
outlier parcels, a majority of the district is bounded by E Tamarack Street to
the north, N Rouse Avenue to the west, E Peach Street to the south, and
Front and Plum Street to the east. The district was created in 2002 to
legitimize a historically diverse land use pattern that did not fit districts then
443
in existence. The area was primarily industrial but also had a considerable
amount of lower density residential uses. The intent of the northeast historic
mixed use district is to provide recognition of an area that has developed
with a blend of uses not commonly seen under typical zoning requirements.
The unique qualities and nature of the area are not found elsewhere in the
city and should be preserved as a place offering additional opportunities for
creating integration of land uses. The intent of this area is to allow private
and case-by-case determination of the most appropriate use of land in a
broad range of both non-residential and residential uses.
Nearby municipal zoning to the north is M-1 (Light Manufacturing District)
and B-2M (Community Business District Mixed). West of the site is zoned PLI
(Public Lands and Institutions) and R-2 (Residential Moderate Density
District). South and southeast is zoned R-2, M-1, and B-2M, and east is zoned
M-1 and M-2 (Manufacturing and Industrial District). The future land use
designation of the NEHMU area changed from Industrial to Community
Commercial Mixed Use in 2020.
UNRESOLVED ISSUES:There are no identified conflicts on this application at this time.
ALTERNATIVES:1. Recommend approval of the application and associated ordinance;
2. Recommend approval of the application with modifications to the
recommended zone text amendment;
3. Recommend denial of the application based on the Commission's findings
of noncompliance with the applicable criteria contained within the staff
report; or
4. Recommend to open and continue the public hearing on the application,
with specific direction to staff or the applicant to supply additional
information or to address specific items.
FISCAL EFFECTS:No unusual fiscal effects have been identified. No presently budgeted funds
will be changed by this Zone Text Amendment.
Attachments:
24225 NEHMU ZTA CDB SR.pdf
Draft Ordinance 24225 NEHMU ZTA.pdf
Report compiled on: July 9, 2024
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Page 1 of 20
24225 Staff Report for the NEHMU Zone Text Amendment
Public Hearings: Community Development Board (Zoning Commission) meeting is on
July 15, 2024 at 6:00 p.m.
City Commission meeting is on August 27, 2024 at 6:00 p.m.
Project Description: A Zone Text Amendment to modify the City’s development code to
allow apartments as a permitted use with no restrictions in area on the second and
subsequent floors, and basements of buildings, and to allow lobbies on the ground
floor when associated with residential uses in the NEHMU District (Northeast Historic
Mixed Use District).
Project Location: The proposed revision to the UDC Table 38.310.040.C would be
applicable to any lot within the NEHMU District, city wide.
Recommendation: Meets standards for approval.
Recommended Community Development Board Zone Text Motion: Having reviewed and
considered the staff report, draft ordinance, public comment, and all information
presented, I hereby adopt the findings presented in the staff report for application
24225 and recommend approval of the NEHMU Zone Text Amendment.
Recommended City Commission Zone Text Motion: Having reviewed and considered the
staff report, draft ordinance, application materials, public comment, recommendation
of the Community Development Board in their capacity as the Zoning Commission,
and all information presented, I hereby adopt the findings presented in the staff report
for application 24225 and move to approve the NEHMU Zone Text Amendment, with
contingencies required to complete the application processing.
Report: July 9, 2024
Staff Contact: Elizabeth Cramblet, Associate Planner
Agenda Item Type: Action – Legislative
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Staff Report for the NEHMU Zone Text Amendment Page 2 of 20
EXECUTIVE SUMMARY
This report is based on the application materials submitted and public comment received to
date.
Unresolved Issues
There are no identified conflicts on this application at this time.
Project Summary
This application includes a proposal to modify the City’s development code to allow
apartments as a permitted use with no restrictions in area on the second and subsequent floors,
and basements, and to allow lobbies on the ground floor when associated with residential uses
in the NEHMU District (Northeast Historic Mixed Use District). Currently the NEHMU
zoning district only allows apartments as an accessory use that occupies less than fifty percent
(50%) of the gross floor area of the building, and not on the ground floor, only the second and
subsequent floors. The change would essentially allow multi-story residential buildings within
the NEHMU district that are currently not allowed.
The Northeast Historic Mixed Use District is located in the northeast section of the city that
encompasses approximately 40 acres and is located within the Neighborhood Conservation
Overlay District. With the exception of a few outlier parcels, a majority of the district is
bounded by E Tamarack Street to the north, N Rouse Avenue to the west, E Peach Street to the
south, and Front and Plum Street to the east. The district was created in 2002 to legitimize a
historically diverse land use pattern that did not fit districts then in existence. The area was
primarily industrial but also had a considerable amount of lower density residential uses.
The intent of the northeast historic mixed use district is to provide recognition of an area that
has developed with a blend of uses not commonly seen under typical zoning requirements. The
unique qualities and nature of the area are not found elsewhere in the city and should be
preserved as a place offering additional opportunities for creative integration of land uses. The
intent of this area is to allow private and case-by-case determination of the most appropriate
use of land in a broad range of both non-residential and residential uses.
Nearby municipal zoning to the north is M-1 (Light Manufacturing District) and B-2M
(Community Business District Mixed). West of the site is zoned PLI (Public Lands and
Institutions) and R-2 (Residential Moderate Density District). South and southeast is zoned R-
2, M-1, and B-2M, and east is zoned M-1 and M-2 (Manufacturing and Industrial District).
The future land use designation of the NEHMU area changed from industrial to Community
Commercial Mixed Use in 2020.
In determining whether the criteria applicable to this application are met, Staff considers the
entire body of plans and regulations for land development. Standards which prevent or mitigate
446
Staff Report for the NEHMU Zone Text Amendment Page 3 of 20
possible negative impacts are incorporated in many locations in the municipal code but are
principally in Chapter 38, Unified Development Code. References in the text of this report to
Articles, Divisions, or in the form xx.xxx.xxx are to the Bozeman Municipal Code.
Alternatives
1. Recommend approval of the application and associated ordinance;
2. Recommend approval of the application with modifications to the recommended zone
text amendment;
3. Recommend denial of the application based on the Commission’s findings of non -
compliance with the applicable criteria contained within the staff report; or
4. Recommend to open and continue the public hearing on the application, with specific
direction to staff or the applicant to supply additional information or to address specific
items.
447
Staff Report for the NEHMU Zone Text Amendment Page 4 of 20
TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................................................................ 2
Unresolved Issues ........................................................................................................ 2
Project Summary.......................................................................................................... 2
Alternatives.................................................................................................................. 3
SECTION 1 - MAP SERIES .............................................................................................. 5
SECTION 2 - RECOMMENDATION AND FUTURE ACTIONS………………………….8
SECTION 3 - ZONE TEXT AMENDMENT STAFF ANALYSIS AND FINDINGS........... 8
PROTEST NOTICE FOR ZONING AMENDMENTS ..................................................... 19
APPENDIX A - DETAILED PROJECT DESCRIPTION AND BACKGROUND ............. 19
APPENDIX B - NOTICING AND PUBLIC COMMENT................................................. 20
APPENDIX C - OWNER INFORMATION AND REVIEWING STAFF .......................... 20
FISCAL EFFECTS .......................................................................................................... 20
ATTACHMENTS……………………………………………………………………………20
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Staff Report for the NEHMU Zone Text Amendment Page 5 of 20
SECTION 1 - MAP SERIES
Figure 1: Project Vicinity Map (2023 image)
NEHMU
District
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Staff Report for the NEHMU Zone Text Amendment Page 6 of 20
Figure 2: Future Land Use Designations (2023 image)
NEHMU
District
Urban
Neighborhood
Community
Commercial
Mixed Use
Public Lands
& Institutions
Traditional
Core
Industrial
Community
Commercial Mixed
Use
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Staff Report for the NEHMU Zone Text Amendment Page 7 of 20
Figure 3: Current Zoning Map (2023 image)
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Staff Report for the NEHMU Zone Text Amendment Page 8 of 20
SECTION 2 – RECOMMENDATION AND FUTURE ACTIONS
Having considered the criteria established for a zone map amendment, staff finds the criteria
for approval to be met and therefore recommends approval of the application as submitted. The
Development Review Committee (DRC) considered the amendment. The DRC did not identify
any infrastructure deficiencies.
The Community Development Board, acting in their capacity as the Zoning Commission, will
hold a public hearing on this zone text amendment on July 15, 2024 and will forward its
recommendation to the City Commission on the zone text amendment. The meeting will begin
at 6 p.m. in the Commission Room at City Hall, 121 N. Rouse Avenue, Bozeman, Montana.
Members of the public will also be able to participate remotely. Instructions for joining the
meeting remotely will be included on the meeting agenda. The agenda is available in the Events
portion of the City’s website at https://www.bozeman.net/home at least 48 hours prior to the
meeting.
SECTION 3 - ZONE TEXT AMENDMENT STAFF ANALYSIS AND
FINDINGS
In considering applications for plan approval under this title, the advisory boards and City
Commission must consider the following criteria (letters A-K). As an amendment is a
legislative action, the Commission has broad latitude to determine a policy direction. The
burden of proof that the application should be approved lies with the applicant.
A zone text amendment must be in accordance with the growth policy (criteria A) and be
designed to secure safety from fire and other dangers (criteria B), promote public health, public
safety, and general welfare (criteria C), and facilitate the provision of transportation, water,
sewerage, schools, parks and other public requirements (criteria D). Therefore, to approve a
zone map amendment the Commission must find Criteria A-D are met.
In addition, the Commission must also consider criteria E-K, and may find the zone text
amendment to be positive, neutral, or negative with regards to these criteria. To approve the
zone text amendment, the Commission must find the positive outcomes of the amendment
outweigh negative outcomes for criteria E-K.
In determining whether the criteria are met, Staff considers the entire body of plans and
regulations for land development. Standards which prevent or mitigated negative impacts are
incorporated throughout the entire municipal code but are principally in Chapter 38, Unified
Development Code. For information about how the code as a whole applies examples of
specific code sections and the timing of future application is provided as part of the analysis
below.
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Staff Report for the NEHMU Zone Text Amendment Page 9 of 20
Section 76-2-304, MCA (Zoning) Criteria
A. Be in accordance with a growth policy.
Criterion met. The Bozeman Community Plan 2020, Chapter 5, p. 73, in the section titled
Review Criteria for Zoning Amendments And Their Application, discusses how the various
criteria in 76-2-304 MCA are applied locally. Application varies depending on whether an
amendment is for the zoning map or for the text of Chapter 38, BMC.
“In a text amendment, policy statements weigh heavily as the standards being created or
revised implement the growth policy’s aspirations and intent. The City must balance many
issues in approving urban development.”
The proposed amendment does not change the zoning map. Therefore, it is unnecessary to
analyze compliance with the future land use map; however, staff notes that the NEHMU district
is an implementing district for the Community Commercial Mixed Use future land use
designation. A change in permitted uses must be evaluated for alignment with goals listed for
the land use designations within the Bozeman Community Plan 2020. The change in future
land use designation in 2020 is cause to evaluate the best fit of existing standards in the district.
The basic planning precepts on page 20 of the BCP 2020 include, “The health and well-being
of the public is an essential focus and influences and is influenced in turn by urban design and
land development.” Also, “The City intends to create a healthy, safe, resilient, and sustainable
community by incorporating a holistic approach to the design, construction, and operation of
buildings, neighborhoods, and the City as a whole.” The proposed amen dments provide for
public health, safety, and welfare of the community by providing clear standards and
administrative processes for development of critical infrastructure concurrently with new
residential development that will meet the needs of our growing city.
The applicant further states that “The Future Land Use Map in the Bozeman Community Plan
2020 designates the property as Community Commercial Mixed Use. The intent of Community
Commercial Mixed Use is to promote commercial areas necessary for econ omic health and
vibrancy. Residences on upper floors, in appropriate circumstances, are encouraged. The
urban character expected in this designation includes urban streetscapes, plazas, outdoor
seating, public art, and hardscaped open space and park amenities. High density residential
areas are expected in close proximity. This proposed change to NEHMU will further the intent
of this FLUM Category and will further several other goals and objectives of the Community
Plan.”
Several relevant goals and objectives have been identified by the applicant or staff. No points
of conflict with the text of the growth policy have been identified.
Goal DCD-1: Support urban development within the City.
DCD-1.2 Remove regulatory barriers to infill.
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Staff Report for the NEHMU Zone Text Amendment Page 10 of 20
The applicant states “When the Community Plan was adopted, it changed the direction of this
neighborhood from industrial to mixed use. Currently, one of the most significant factors
holding back the NEHMU district from being a viable mixed use district is the cap on the
percentage of residential use that can be built within a structure. Removing the 50% cap and
making apartments unrestricted (on subsequent floors) will remove regulatory barriers for
infill and will support compact neighborhoods.” Much of the industrial component in the
NEHMU district has been replaced by commercial development over the last ten years.
Currently there is ample commercial development within this zone district that would benefit
from additional residential units.
Goal N-1: Support well-planned, walkable neighborhoods.
N-3.7 Support compact neighborhoods, small lot sizes, and small floor plans, especially
through mechanisms such as density bonuses.
The proposed amendment would allow additional residential units in buildings providing
additional housing opportunities within the NEHMU district.
M-1.1 Prioritize mixed-use land use patterns. Encourage and enable the development of
housing, jobs, and services in close proximity to one another.
The introduction to Theme 2 in the Bozeman Community Plan 2020 says in part “Mixed
neighborhoods can help provide the density of people needed to support nearby commercial
activities.” As stated earlier, one of the intents and purposes of the NEHMU District is to
support of mix and variety of non-residential and residential uses. It is expected that the lots
within this district will continue to develop under a variety of uses which may increase or
decrease in scope in any given portion of the district.
B. Secure safety from fire and other dangers.
Criterion met. As stated in the introduction to this Section 3, the Bozeman evaluates proposals
against the municipal code as a whole. Building code standards for fire resistance, exiting, and
other protections remain in place and will continue to protect the public. The proposed
amendment does not alter any standard adopted to address this criterion. Therefore, the code
as a whole continues to satisfy this requirement. The following are examples of existing code
sections that will address this criterion.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
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Staff Report for the NEHMU Zone Text Amendment Page 11 of 20
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.400.010 Streets,
general
Access for
emergency services
Transportation
Master Plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, site plan,
and building permit
C. Promote public health, public safety, and general welfare.
Criterion met. The existing standards addressing this criterion remain in place such as
floodplain protections, provisions of water and sewer services, and similar standards.
Standards remain for setbacks, light and air, emergency services, and other issues to protect
health and physical safety. Apartments are currently allowed in the NEHMU district on a
limited basis. The amendment allows apartments as a permitted and primary use within the
district. Each site development application will need to be processed as are other applications
ensuring compliance with these requirements.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.070
Municipal water,
sewer systems
Location and
requirement to
install.
Sewer collection
facilities plan,
Water facilities plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
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Staff Report for the NEHMU Zone Text Amendment Page 12 of 20
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
D. Facilitate the provision of transportation, water, sewerage, schools, parks
and other public requirements.
Criterion met. The City conducts extensive planning for municipal transportation, water,
sewer, parks, and other facilities and services provided by the City. The adopted plans allow
the City to consider existing conditions and identify enhancements needed to provide
additional service needed by new development. The City implements these plans through its
capital improvements program that identifies individual projects, project construction
scheduling, and financing of construction. The proposed text amendment does not alter any
requirements or standards associated with the provision of transportation , water, sewerage,
schools, parks, and other public requirements.
The applicant adds “the NEHMU district already contemplates apartments as a use. This
change only changes the threshold within a building that can be apartments. It should also be
mentioned that this was likely studied during the Community Plan Update to ensure there were
adequate facilities to service a mixed-use neighborhood. Additionally, conformance with these
standards will be verified with each development application and any negative impacts will be
required to be mitigated.”
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
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Staff Report for the NEHMU Zone Text Amendment Page 13 of 20
38.410.060
Easements
Location and form
of easements for
utilities
Transportation
Master Plan, Sewer
collection facilities
plan, Water
facilities plan
Annexation for collector
and arterial streets.
Subdivision or site plan
for all others.
38.410.070
Municipal water,
sewer systems
Location and
requirement to
install.
Sewer collection
facilities plan,
Water facilities plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, site plan,
and building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
E. Reasonable provision of adequate light and air.
Criterion met. The proposed amendments to not alter existing standards for setbacks,
maximum heights, open space, park dedication, or other related issues. The standards
previously adopted to address this criteria remain in place. Considering the code as a whole,
the standards listed in this criterion are not being changed with these amendments and therefore
the standard continues to be met.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
38.520.060 On-site
residential and
commercial open
space
Private land open
area requirements
Site plan
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Staff Report for the NEHMU Zone Text Amendment Page 14 of 20
F. The effect on motorized and non-motorized transportation systems.
Criterion met. The City conducts extensive planning for municipal transportation, trails, and
parks related to this criterion and services provided by the City. The adopted plans allow the
City to consider existing conditions and identify enhancements needed to provide additional
service needed by new development. The proposed amendments do not alter these plans or
associated standards.
The NEHMU is largely the same area as the Northeast Neighborhood Urban Renewal District.
The urban renewal district has been investing in upgraded streets in the area including Peach
Street and Tamarack Street.
Individual development applications are reviewed against the following adopted standards to
ensure adequate transportation services.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.060
Easements
Location and form
of easements for
utilities
Transportation
Master Plan,
Annexation for collector
and arterial streets.
Subdivision or site plan
for all others.
38.420.110
Recreation
Pathways
Location and
requirement to
install.
Park, Recreation,
and Active
Transportation Plan
Annexation for Class 1
Trails easement.
Subdivision or site plan
for all else.
G. Promotion of compatible urban growth.
Criterion met. Development standards and zoning districts ensure the City grows in a
compatible manner. The City has defined compatible development as:
“The use of land and the construction and use of structures which is in harmony with
adjoining development, existing neighborhoods, and the goals and objectives of the city's
adopted growth policy. Elements of compatible development include, but are not limited to,
variety of architectural design; rhythm of architectural elements; scale; intensity; materials;
building siting; lot and building size; hours of operation; and integration with existing
community systems including water and sewer services, natural elements in the area,
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Staff Report for the NEHMU Zone Text Amendment Page 15 of 20
motorized and non-motorized transportation, and open spaces and parks. Compatible
development does not require uniformity or monotony of architectural or site design, density
or use.”
There is no one pattern or method in which to build a community. Many different
configurations of uses and buildings can coexist as well. The City has adopted many standards
to avoid and mitigate demonstrable negative impacts of development. Other standards
addressing compatibility, such as setbacks, building mass, and zone edge transitions, are not
being modified through these amendments. Compliance with City standards is considered
adequate to avoid negative impacts of development and ensure compatible development.
Therefore, considering the code as a whole, staff concludes the criterion is met.
The applicant further suggests that “This neighborhood (and zoning district) is planned to be
mixed use in nature with residential on upper floors of the building. This is currently limited
in the NEHMU district due to the fact that apartments are limited to 50% of the building. This
proposed change will eliminate this threshold. Allowing more apartments in a building
promotes more people to live in the neighborhood, which will hopefully allow the commercial
mixed-use areas be more successful.”
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan,
building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan,
building permit
38.320.060 Zone
Edge Transitions
Height adjustments
on the edge of some
zones
Site plan
38.340 Overlay
District Standards
Historic
preservation
SOI Standards for
Historic
Preservation,
Design Guidelines
for Historic
Preservation
Site plan and building
permit
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
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Staff Report for the NEHMU Zone Text Amendment Page 16 of 20
H. Character of the district.
Criterion met. Section 76-2-301, MCA says “Municipal zoning authorized. For the purpose of
promoting health, safety, morals, or the general welfare of the community, the city or town
council or other legislative body of cities and incorporated towns in hereby empowered to
regulate and restrict the height, number of stories, and size of buildings and other structures;
the percentage of lot that may be occupied; the size of yards, courts and other open spaces; the
density of population; and the location of use of buildings, structures, and land for trade,
industry, residence, or other purposes.”
Section 76-2-302, MCA says “…legislative body may divide the municipality into districts of
the number, shape, and area as are considered best suited to carry out the purposes [promoting
health, safety, morals, or the general welfare of the community] of this part.” Emphasis added.
The proposed amendment does not create or delete a district or modify the geographic extent
of a district. The City has adopted form and intensity standards in Division 38.320 as part of
the implementation of the zoning enabling language cited above. The City has adopted building
and site design standards in Divisions 38.510 and 38.530 also as part of the implementation of
the zoning enabling language cited above. These are applied to all development according to
the district in which the development is located. Uses for districts are established in Division
38. 310. The proposed amendments do not add or remove permitted uses in districts. They do
alter the extent to which those uses can be developed by removing a restriction on the
proportion of a mixed use building which can be used for residences. The original limitation
of less than 50% was originally adopted when the area was planned for primarily industrial
uses. The change in future land use designation in 2020 to Community Commercial Mixed Use
fundamentally alters the expected character of the area. Revisions to the zoning standards
consistent with the new future land use designation is appropriate as zoning must be “in
accordance” with an adopted growth policy.
Character of a district is made up of many different elements; including but not limited to uses,
size of lots, and building features. There is no one pattern or method in which to build a
community. The City has adopted a range of zoning districts to address different needs. The
zoning districts are amended from time to time as needs of the City and its residents change.
Many different configurations of uses and buildings can coexist well and the City does not
restrict specific architectural styles. The City’s growth policy and allowed land uses per zoning
district encourage mixed uses. This proposal amends the text only and not the zoning map. The
proposal does not add or delete zoning districts.
The combination of uses and other characteristics remain intact and were previously found to
be consistent with this criterion. Therefore, this criterion remains met.
The applicant further suggests “The character of the district (NE Neighborhood) has been
evolving over the last decade. There is a great mix of uses that range from single household
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Staff Report for the NEHMU Zone Text Amendment Page 17 of 20
dwellings to 4-story apartment buildings, to commercial and multistory mixed use buildings.
Apartments are currently allowed as an accessory use (capped at 50% of building). The
proposed change would eliminate the threshold cap. Adding apartments has a permitted use
(capped to second and subsequent floors) does not fundamentally change the character of the
district but will allow for the creation of more units in the neighborhood, which arguably will
make it more vibrant and successful. Finally, the Northeast Neighborhood Association (NENA)
has been engaged in our proposed edits and supports the changes.”
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan,
building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan,
building permit
38.320.060 Zone
Edge Transitions
Height adjustments
on the edge of some
zones
Site plan
38.340 Overlay
District Standards
Historic
preservation
SOI Standards for
Historic
Preservation,
Design Guidelines
for Historic
Preservation
Site plan and building
permit
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
I. Peculiar suitability for particular uses.
Criterion met. Apartments are already allowed in the NEHMU district. The amendments will
allow residential uses as a primary use in buildings. New development will continue to be
processed according to the BMC as it is now in this district. This amendment will not affect
the suitability of uses in the NEHMU district. In essence, the proposed amendment changes
the NEHMU district from a mix of the M-1 and R-2 zoning districts when it was originally
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Staff Report for the NEHMU Zone Text Amendment Page 18 of 20
created to a blend of M-1 and R-4 zoning districts. As apartments are currently allowed,
although on a more limited basis, the amendment does not alter the earlier decisions that
NEHMU is appropriate with a mix of uses in this area.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.600 Natural
Resource Protection
Protect watercourses
and wetlands
FEMA Floodplain
study
Subdivision, site plan
review, building permit
J. Conserving the value of buildings.
Criterion met. The proposed amendments may alter the use of existing buildings; however, any
proposal will need to be in compliance with standards outlined in the BMC. Site specific review
for compliance with standards prior to construction will continue to be required. This
amendment is consistent with the growth policy including the future land use map, see
Criterion A. Therefore, the criterion is met.
K. Encourage the most appropriate use of land throughout the jurisdictional
area.
Criterion met. See the discussion under Criterion A as well. The zoning map and the future
land use map of the growth policy identify areas where specific uses are generally appropriate.
The proposed amendment allows for an increase in residential area in buildings where such
uses are already allowed. Higher intensity of uses and residences on upper floors are
encouraged in appropriate circumstances within the Community Commercial Mixed Use
designation.
The applicant further states “Community Commercial Mixed Use calls for a mix of uses, with
multistory buildings and residential on upper stories of the building. Changing apartments
from an accessory use to a permitted use (on upper floors) directly speaks to this goal of the
CCMU district. Additionally, this will help promote and build upon th e vibrancy of the
neighborhood.”
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Staff Report for the NEHMU Zone Text Amendment Page 19 of 20
PROTEST NOTICE FOR ZONING AMENDMENTS
IN THE CASE OF WRITTEN PROTEST AGAINST SUCH CHANGES SIGNED BY THE
OWNERS OF 25% OR MORE OF THE AREA OF THE LOTS WITHIN THE AMENDMENT
AREA OR THOSE LOTS OR UNITS WITHIN 150 FEET FROM A LOT INCLUDED IN A
PROPOSED CHANGE, THE AMENDMENT SHALL NOT BECOME EFFECTIVE EXCEPT
BY THE FAVORABLE VOTE OF TWO-THIRDS OF THE PRESENT AND VOTING
MEMBERS OF THE CITY COMMISSION.
The City will accept written protests from property owners against the proposal
described in this report until the close of the public hearing before the City Commission.
Pursuant to 76-2-305, MCA, a protest may only be submitted by the owner(s) of real property
within the area affected by the proposal or by owner(s) of real property that lie within 150 feet
of an area affected by the proposal. The protest must be in writing and must be signed by all
owners of the real property. In addition, a sufficient protest must: (i) state the writing is a
“protest”, rather than merely expressing opposition; (ii) contain a description of the action
protested sufficient to identify the action against which the protest is lodged; and (iii) contain
the application number and a statement of the protestor's qualifications (including listing all
owners of the property and the physical address), to protest the action against which the protest
is lodged, including ownership of property affected by the action. Signers are encouraged to
print their names after their signatures. A person may in writing withdraw a previously filed
protest at any time prior to final action by the City Commission. Protests must be delivered
to the Bozeman City Clerk, 121 North Rouse Ave., PO Box 1230, Bozeman, MT 59771-
1230.
APPENDIX A - DETAILED PROJECT DESCRIPTION AND
BACKGROUND
This application includes a proposal to modify the City’s development code to allow
apartments as a permitted use with no restrictions in area on the second and subsequent floors,
and basements, and to allow lobbies on the ground floor when associated with residential uses
in the NEHMU District (Northeast Historic Mixed Use District). Currently the development
code only allows apartments as an accessory use that occupies less than fifty percent (50%) of
the gross floor area of the building, and not on the ground floor, only the second and subsequent
floors. The change would essentially allow multi-story residential buildings within the
NEHMU district that are currently not allowed.
The northeast historic mixed use district is located in the northeast section of the city that
encompasses approximately 40 acres and is located within the Neighborhood Conservation
Overlay District. The intent of the northeast historic mixed use district is to provide recognition
of an area that has developed with a blend of uses not commonly seen under typical zoning
requirements. The unique qualities and nature of the area are not found elsewhere in the city
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Staff Report for the NEHMU Zone Text Amendment Page 20 of 20
and should be preserved as a place offering additional opportunities for creative integration of
land uses. The intent of this area is to allow private and case-by-case determination of the most
appropriate use of land in a broad range of both non-residential and residential uses.
During the development and adoption of the Bozeman Community Plan 2020 (BCP 2020) the
underlying Future Land Use designation was modified from Industrial to Community
Commercial Mixed Use. This action paved the way for subsequent zoning changes that differ
from the prevailing historical uses of the area an d indicate a shift in character over time.
NEHMU is currently an implementing district of the Community Commercial Mixed Use land
use designation.
APPENDIX B - NOTICING AND PUBLIC COMMENT
Notice for text amendments must meet the standards of 38.220.410 & 420. Notice was
published in the Bozeman Daily Chronicle on 6/22/2024, 7/06/2024, and 8/10/2024 and
contained all required elements. The notice and text was also provided through the City’s
Community Development web viewer. Notice was provided at least 15 and not more than 45
days prior to the City Commission public hearing. That hearing is tentatively scheduled for
August 27, 2024. No written public comments have been received so far on this Ordinance.
Comments are available through the Laserfiche archive. If comments are received, they will
be placed in the project folder in Laserfiche.
APPENDIX C - OWNER INFORMATION AND REVIEWING STAFF
Applicant: Tyler Steinway, Intrinsik Architecture, 106 E Babcock Su. 1A, Bozeman, MT 59715
Representative: Erik Nelson, Nest Partners, 113 E Oak Street 4B, Bozeman, MT 59715
Report By: Elizabeth Cramblet, Associate Planner
FISCAL EFFECTS
No unusual fiscal effects have been identified. No presently budgeted funds will be changed by
this Zone Text Amendment.
ATTACHMENTS
The full application and file of record can be viewed at the Community Development Department
at 20 E. Olive Street, Bozeman, MT 59715.
The application materials for this application are available at Laserfiche folder [External link].
464
Version February 2023
Ord. 2161
Page 1 of 7
ORDINANCE 2168
AN ORDINANCE OF THE CITY COMMISSION OF THE CITY OF BOZEMAN,
MONTANA AMENDING TABLE 38.310.040.C OF CHAPTER 38 OF THE BOZEMAN
MUNICIPAL CODE TO ALLOW APARTMENTS AS A PERMITTED USE WITH NO
RESTRICTIONS IN AREA ON THE SECOND AND SUBSEQUENT FLOORS, AND
BASEMENTS OF BUILDINGS, AND TO ALLOW LOBBIES ON THE GROUND FLOOR
WHEN ASSOCIATED WITH RESIDENTIAL USES IN THE NEHMU DISTRICT
(NORTHEAST HISTORIC MIXED USE DISTRICT), APPLICATION 24225.
WHEREAS, the City of Bozeman (the “City”) has adopted land development and use
standards to protect public health, safety and welfare and otherwise execute the purposes of
Montana Code Annotated §§ 76-1-102, 76-2-304, 76-3-102, and 76-3-501; and
WHEREAS, pursuant to the Bozeman City Charter, the City of Bozeman has adopted and
is hereby relying upon its self-government powers recognizing pursuant to Montana law such self-
government powers must be liberally construed in favor of such power; and
WHEREAS, pursuant to Chapter 38, Section 38.260.010.A of the Bozeman Municipal
Code (BMC), Bangtail Partners, LLC, Nest Partners submitted application number 24225 for a
specific zoning text amendment for Table 38.310.040.C to allow apartments as a permitted use
with no restrictions in area on the second and subsequent floors, and basements of buildings, and
to allow lobbies on the ground floor when associated with residential uses in the NEHMU District;
and
WHEREAS, pursuant to BMC Section 38.260.020, upon receipt of such application, the
Community Development Department initiated the required investigation of facts bearing on such
proposed amendment to ensure that the action is consistent with the intent and purposes of Chapter
38, Section 38.100.040 to protect health, safety and general welfare; and
WHEREAS, on July 15, 2024, the Bozeman Community Development Board, acting as
the Bozeman Zoning Commission, voted to recommend ______________ to the Bozeman City
Commission; and
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WHEREAS, pursuant to Sections 38.220.420 and 38.260.030, public notice of the July
15, 2024 public hearing on the proposed amendment before the Community Development Board
and of the August 27, 2024 public hearing before the Bozeman City Commission was given by
publication in a general circulation newspaper on June 22, 2024, July 6, 2024, and August 10,
2024, which is not less than 15 or more than 45 calendar days prior to the public hearings; and
WHEREAS, after proper notice, the City Commission held its public hearing on August
27, 2024, to receive and review all written and oral testimony on the proposed amendments; and
WHEREAS, the City Commission has reviewed and considered the applicable
amendment criteria established in Montana Code Annotated (MCA) § 76-2-304, considered the
Community Development Board recommendation, and all the information presented by staff and
the Applicant at the July 15, 2024 public hearing, and found that the proposed amendments to
Table 38.310.040.C presented by the Applicant was preferred to that recommended by the
Community Development Board and found that the Applicant’s zone text amendment is ___
compliance with the MCA criteria; and
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COMMISSION OF THE
CITY OF BOZEMAN, MONTANA:
Section 1
Legislative Findings
The City Commission hereby makes the following findings in support of adoption of this
Ordinance:
1. The City adopted a growth policy, the Bozeman Community Plan 2020, by Resolution
5133 to establish policies for development of the community including zoning;
2. The Bozeman Community Plan 2020, Chapter 5, sets forth the policies by which the City
reviews and applies the criteria for amendment of zoning established in 76-2-305, MCA;
3. Zoning, including text amendments, must be in accordance with an adopted growth policy;
4. A staff report analyzing the required criteria for a zone text amendment, including
accordance to the Bozeman Community Plan 2020, has found that the required criteria are
satisfied;
5. The two required public hearings were advertised as required in state law and municipal
code and all persons have had opportunity to review the materials applicable to the
application and provide comment prior to a decision;
6. The Bozeman Community Development Board as the Zoning Commission has been
established as required in state law and conducted their required public hearing; and after
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Page 3 of 7
consideration of application materials, staff analysis and report, and all submitted public
comment recommended approval of the application.
7. The City Commission conducted a public hearing to provide all interested parties the
opportunity to provide evidence and testimony regarding the proposed amendment prior to
the City Commission acting on the application.
8. The City Commission considered the application materials, staff analysis and report, the
Community Development Board recommendation, all information presented by staff and
the Applicant, and all other relevant information.
9. The City Commission determines that, as set forth in the staff report and incorporating the
staff findings, Community Development Board’s amendment and recommendation, and
staff and Applicant presentation at the public hearing as part of their decision, the required
criteria for approval of the proposed Bozeman Unified Development Code (UDC) Table
38.310.040.C text amendment to allow apartments as a permitted use with no restrictions
in area on the second and subsequent floors, and basements of buildings, and to allow
lobbies on the ground floor when associated with residential uses in the NEHMU District.
Section 2
Table 38.310.040.C—Permitted residential uses in commercial, mixed use, and industrial zoning
districts. Permitted uses for the NEHMU District—shall be amended to read as follows with all
other elements of the table and footnotes remaining unchanged.
Zoning Districts
Commercial Mixed Use Industrial PLI
B-11 B-2 B-2M B-3 UMU
(38.310.050)
REMU
(38.310.060)
NEHMU BP M-1 M-2
General residential
Accessory
dwelling unit
(38.360.040)
----
----
----
----
----
P
P
---
---
---
---
Apartments*ᶟ P⁴ P⁴ P⁵ P⁵ P P A⁶ P⁴ --- A⁶ A⁶ ---
Apartment
buildings*ᶟ
---
S
P
P⁵
P
P
---
---
---
---
---
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Ordinance No. 2161, Amend Residential Emphasis Mixed Use Alley Rear Yard Setback
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Cottage
housing*
(38.360.120)
---
---
---
---
---
P
---
---
---
---
---
Single
household
dwelling
(38.360.220)
---
---
---
---
---
P
P
---
---
---
---
B-11 B-2 B-2M B-3 UMU REMU NEHMU BP M-1 M-2 PLI
Three
household
dwelling or four
household
dwelling
(38.360.220)
---
---
---
---
---
P
---
---
---
---
---
Townhouses*ᶟ
& rowhouses*
(38.360.250)
---
S⁷
P⁷
P⁷
---
P⁸
P
---
---
---
---
Two-household
dwelling
(38.360.220)
---
---
---
---
---
P
P
---
---
---
---
Live-work units* P P P P P P P --- --- --- ---
Ground floor
residential
S
P⁵
P⁵
---
---
---
---
---
---
---
Group residences
Community
residential
facilities with
eight or fewer
residents*
P⁴
P⁴˒⁵
P⁴˒⁵
P⁴˒⁵
P⁴˒⁵
P
P
---
---
---
---
Community
residential
facilities serving
nine or more
residents*
---
S
S
---
P
P
---
---
---
---
---
Cooperative
household* --- --- --- --- --- P S --- --- --- ---
Group living
(38.360.135)* P⁴ P⁴ P⁵ P⁴ --- P P --- --- --- ---
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Ordinance No. 2161, Amend Residential Emphasis Mixed Use Alley Rear Yard Setback
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Lodging houses* --- S S⁵ Sᶟ P P --- --- --- --- ---
Transitional and
emergency
housing and
related services
(38.360.140)*
---
S
S
S
S
S
S
S
S
---
S
Notes:
1. In the B-1 district, the footprint of individual buildings must not exceed 5,000 square feet.
2. Authorized uses in the NEHMU district include those uses allowed in the R-2 district (some of
which aren’t addressed in this table).
3. May be subject to the provisions of chapter 38, article 380.
4. When located on the second or subsequent floor, or basement as defined in section 38.700.030
of this chapter. Lobbies associated with residential uses are allowed on the ground floor.
5. Non-residential uses (except for lobbies associated with residential uses) are required on the
ground floor to a minimum depth of 20 feet from front building façade on properties adjacent to
designated storefront streets per section 38.500.010.
6. For the purpose of this section, accessory means less than 50 percent of the gross floor area of
the building, and not located on the ground floor.
7. Five or more attached units.
8. Five or fewer attached units.
Section 3
Repealer.
All provisions of the ordinances of the City of Bozeman in conflict with the provisions of
this ordinance are, and the same are hereby, repealed and all other provisions of the ordinances of
the City of Bozeman not in conflict with the provisions of this ordinance shall remain in full force
and effect.
Section 4
Savings Provision.
This ordinance does not affect the rights and duties that matured, penalties that were
incurred or proceedings that were begun before the effective date of this ordinance. All other
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Ordinance No. 2161, Amend Residential Emphasis Mixed Use Alley Rear Yard Setback
Page 6 of 7
provisions of the Bozeman Municipal Code not amended by this Ordinance shall remain in full
force and effect.
Section 5
Severability.
That should any sentence, paragraph, subdivision, clause, phrase or section of this
ordinance be adjudged or held to be unconstitutional, illegal, or invalid, the same shall not affect
the validity of this ordinance as a whole, or any part or provision thereof, other than the part so
decided to be invalid, illegal or unconstitutional, and shall not affect the validity of the Bozeman
Municipal Code as a whole.
Section 6
Codification.
The provisions of Section 2 of this Ordinance shall be codified as appropriate in the
Bozeman Municipal Code.
Section 7
Effective Date.
This ordinance shall be in full force and effect thirty (30) days after final adoption.
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Ordinance No. 2161, Amend Residential Emphasis Mixed Use Alley Rear Yard Setback
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ADOPTED by the City Commission of the City of Bozeman, Montana, on first reading at
a regular session held on the 27th day of August, 2024.
____________________________________
TERENCE CUNNINGHAM
Mayor
ATTEST:
____________________________________
MIKE MAAS
City Clerk
FINALLY PASSED, ADOPTED AND APPROVED by the City Commission of the
City of Bozeman, Montana on second reading at a regular session thereof held on the ___ of
____________________, 2024. The effective date of this ordinance is ______________, 2024.
_________________________________
TERENCE CUNNINGHAM
Mayor
ATTEST:
_______________________________
MIKE MAAS
City Clerk
APPROVED AS TO FORM:
_________________________________
GREG SULLIVAN
City Attorney
471
Memorandum
REPORT TO:Community Development Board
FROM:Tom Rogers, Senior Planner
Chris Saunders, Community Development Manager
Erin George, Interim Director of Community Development
SUBJECT:South Range Crossing (SRX) II Growth Policy Amendment Application to
Revise the Future Land Use Map from Urban Neighborhood to Community
Commercial Mixed Use on Approximately 7.644 acres in Association with a
Zone Map Amendment (Application 24196) on Property Located on the
Northeast Corner of South 19th Avenue and Graf Street, Application 24195
MEETING DATE:July 15, 2024
AGENDA ITEM TYPE:Community Development - Legislative
RECOMMENDATION:Having reviewed and considered the application materials, public comment,
and all information presented, I hereby move to adopt the findings
presented in the staff report and recommend the City Commission approve
the growth policy amendment application 24195.
STRATEGIC PLAN:4.1 Informed Conversation on Growth: Continue developing an in-depth
understanding of how Bozeman is growing and changing and proactively
address change in a balanced and coordinated manner.
BACKGROUND:The City received an application to modify the Bozeman Community Plan
2020 Future Land Use map from Urban Neighborhood to Community
Commercial Mixed Use. The request stems from the associated application
to rezone the subject property from lower density residential to REMU and
B-2M (Community Commercial Mixed), see application 24196. The B-2M
zoning district is not an implementing district for the Urban Neighborhood
future land use designation and therefore, must be changed before the
property can be zoned B-2M. If the governing body does not approve the
Growth Policy Amendment application, the rezoning application for the area
is moot. No change to the text or the plan is proposed.
The SRX II GPA is a revised application previously reviewed and denied by
the City Commission on March 5, 2024, Application 23063, and an associated
zone map amendment number 23059. The original application requested
modifying 17.5 acres from Urban Neighborhood to Community Commercial
Mixed Use. In short, the Commission determined the size and location of the
request was beyond what the community considered during the recent
creation and adoption of the Bozeman Community Plan 2020 adopted by
Resolution 5133 on November 17, 2020. Further, the size and configuration
472
would stretch the commercial corridor that conflicts with a variety of the
goals and policies of the BCP 2020. Finally, the size and configuration of the
area would likely not serve the goal of neighborhood commercial activity the
application stated the desired outcome of the application. The record of the
hearing and deliberations can be viewed at the following link. The hearing
starts at time stamp 1:31:45.
[Video Link]
The city prepares the growth policy based on best available information at
the time. As new information becomes available it is appropriate to consider
possible amendments. An application for an amendment to the future land
use map of the Bozeman Community Plan 2020 has been submitted by the
landowner. The applicant proposed modifying the future land use
designation from Urban Neighborhood to Community Commercial Mixed
Use.
The Bozeman Community Plan 2020 and the associated Future Land Use
Map is the fundamental building block for many future development
decisions including zoning, community character, intensity, density, parking,
and other aspects. Changes to the plan are infrequent and are reviewed with
gravitas.
Considerable development is occurring around the subject property
including the Nexus Point and Graf apartments across 19th Street to the
west, the South University District to the north, South Range Crossing on the
south, Jarret Major Subdivision, Allison Subdivision to the east, and others.
Discussion and criteria for deciding on this growth policy application are
limited to those in this report. Other elements of the future development
will be addressed separately in the future.
Application materials [External Link] are available through the City’s website.
No public comment has been received as of the writing of this report.
UNRESOLVED ISSUES:No unresolved issues have been identified at this time.
ALTERNATIVES:1. Approve the application,
2. Deny the application finding non-compliance with the review criteria,
3. Open and continue the public hearing on the application, with specific
direction to staff or the applicant to supply additional information or to
address specific items.
FISCAL EFFECTS:No unusual fiscal effects have been identified. No presently budgeted funds
will be changed by this growth policy amendment.
Attachments:
24195 SRX II GPA CDB SR.pdf
473
Report compiled on: July 10, 2024
474
Page 1 of 28
24195, Staff Report for the SRX II Growth Policy Amendment (GPA)
Public Hearing Dates:
Community Development Board July 15, 2024.
City Commission August 6, 2024.
Project Description: A growth policy amendment to revise the future land use map from
Urban Neighborhood to Community Commercial Mixed Use on approximately 7.644
acres.
Project Location: The property is located on the northeast corner of South 19th Avenue and
Graf Street. The property is legally described as a Tract of Land located in the
Southwest One-Quarter (SW ¼) of the Northwest One-Quarter (NW ¼) of Section 24,
Township Two-South (T2S), Range Five-East (R5E), P.M.M., City of Bozeman,
Gallatin County, Montana.
Recommendation: Meets standards for approval with contingencies
Community Development Board Motion: Having reviewed and considered the application
materials, public comment, and all information presented, I hereby move to adopt the
findings presented in the staff report and recommend the City Commission approve
the growth policy amendment application 24195.
City Commission Recommended Motion: Having reviewed and considered the application
materials, public comment, Community Development Board recommendation, and all
the information presented, I hereby move to adopt the findings presented in the staff
report and move to approve Application 24195, the SRX II Growth Policy
Amendment.
Report: July 10, 2024
Staff Contact: Tom Rogers, Senior Planner
Agenda Item Type: Action – Legislative
EXECUTIVE SUMMARY
Unresolved Issues
No unresolved issues have been identified at this time.
475
24195, Staff Report for the SRX II Growth Policy Amendment (GPA) Page 2 of 28
Project Summary
The City received an application to modify the Bozeman Community Plan 2020 Future Land Use
map from Urban Neighborhood to Community Commercial Mixed Use. The request stems from
the associated application to rezone the subject property from lower density residential to REMU
and B-2M (Community Commercial Mixed), see application 24196. The B-2M zoning district is
not an implementing district for the Urban Neighborhood future land use designation and
therefore, must be changed before the property can be zoned B-2M. If the governing body does
not approve the Growth Policy Amendment application, the rezoning application for the area is
moot. No change to the text or the plan is proposed.
The SRX II GPA is a revised application previously reviewed and denied by the City Commission
on March 5, 2024, Application 23063, and an associated zone map amendment number 23059.
The original application requested modifying 17.5 acres from Urban Neighborhood to Community
Commercial Mixed Use. In short, the Commission determined the size and location of the request
was beyond what the community considered during the recent creation and adoption of the
Bozeman Community Plan 2020 adopted by Resolution 5133 on November 17, 2020. Further, the
size and configuration would stretch the commercial corridor that conflicts with a variety of the
goals and policies of the BCP 2020. Finally, the size and configuration of the area would likely
not serve the goal of neighborhood commercial activity the application stated the desired outcome
of the application. The record of the hearing and deliberations can be viewed at the following link.
The hearing starts at time stamp 1:31:45.
https://bozeman.granicus.com/player/clip/2233?view_id=1&redirect=true
The city prepares the growth policy based on best available information at the time. As new
information becomes available it is appropriate to consider possible amendments. An application
for an amendment to the future land use map of the Bozeman Community Plan 2020 has been
submitted by the landowner. The applicant proposed modifying the future land use designation
from Urban Neighborhood to Community Commercial Mixed Use.
The Bozeman Community Plan 2020 and the associated Future Land Use Map is the fundamental
building block for many future development decisions including zoning, community character,
intensity, density, parking, and other aspects. Changes to the plan are infrequent and are reviewed
with gravitas.
Considerable development is occurring around the subject property including the Nexus Point and
Graf apartments across 19th Street to the west, the South University District to the north, South
Range Crossing on the south, Jarret Major Subdivision, Allison Subdivision to the east, and others.
Discussion and criteria for deciding on this growth policy application are limited to those in this
report. Other elements of the future development will be addressed separately in the future.
476
24195, Staff Report for the SRX II Growth Policy Amendment (GPA) Page 3 of 28
Application materials are available through the City’s website. No public comment has been
received as of the writing of this report.
Community Development Board Summary
The Community Development Board in their capacity as the Planning Board is scheduled to
consider the application on July 15, 2024. Upon completion of their review and recommendation
a summary will be presented to the City Commission based on the record presented.
Alternatives
1. Approve the application,
2. Deny the application finding non-compliance with the review criteria,
3. Open and continue the public hearing on the application, with specific direction to staff or the
applicant to supply additional information or to address specific items.
TABLE OF CONTENTS
EXECUTIVE SUMMARY ...................................................................................................... 1
Unresolved Issues ............................................................................................................... 1
Project Summary ................................................................................................................. 2
Community Development Board Summary........................................................................ 3
Alternatives ......................................................................................................................... 3
SECTION 1 - MAP SERIES .................................................................................................... 4
SECTION 1 - MAP SERIES .................................................................................................... 7
SECTION 2 - CONTINGENCIES OF APPROVAL ............................................................. 11
SECTION 3 - RECOMMENDATIONS AND FUTURE ACTIONS .................................... 11
SECTION 4 - STAFF ANALYSIS AND FINDINGS ........................................................... 12
APPENDIX A - PROJECT SITE ZONING AND GROWTH POLICY ............................... 25
APPENDIX B - NOTICING AND PUBLIC COMMENT .................................................... 28
APPENDIX D - OWNER INFORMATION AND REVIEWING STAFF............................ 28
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SECTION 1 - MAP SERIES
Map 1: Location Map
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Map 2: View of existing area Future Land Use Map designations
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Map 3: Current zoning
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SECTION 1 - MAP SERIES
Map 4: Large Scale Location Map
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Map 5: View of existing area Future Land Use Map designations, Bozeman Community Plan 2020
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Map 6: Large Scale Current Zoning Map
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Map 7 - Application Exhibit
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SECTION 2 - CONTINGENCIES OF APPROVAL
If the City Commission approves the application, the following contingencies are recommended.
Please note that these contingencies are necessary for the City to complete the processing of the
proposed amendment.
Recommended Contingencies:
1) The applicant shall submit, within forty-five (45) days of approval by the City Commission,
an 8½ x 11-inch or 8½ x 14-inch exhibit titled “SRX II Growth Policy Amendment” and
PDF file to the Department of Community Development containing an accurate description
of the property for which the growth policy designation is being amended. The exhibit must
be acceptable to the Department of Community Development.
2) The resolution for the growth policy amendment shall not be drafted until the applicant
provides an exhibit of the entire area to be re-designated, which will be utilized in the
preparation of the resolution to officially amend the Future Land Use Map of the Bozeman
Community Plan 2020.
SECTION 3 - RECOMMENDATIONS AND FUTURE ACTIONS
Having considered the criteria established for a growth policy map amendment, Staff recommends
approval for the application as submitted, with analysis provided in Section 4 below.
The Development Review Committee (DRC) considered the amendment on May 15, 2024, and
finds no limitations on approval. This determination means the city’s utility and infrastructure plan
anticipated capacities can adequately accommodate any proposed use for either the Urban
Neighborhood or Community Commercial Mixed Use future land use designation.
The Community Development Board in their capacity as the Planning Board will hold a public
hearing on July 15, 2024, to make a recommendation to the City Commission for the growth policy
map amendment. After consideration of all materials and matters they recommended approval or
disapproval of the amendment. The hearing begins at 6:00 p.m. Meetings will be held in the
location and manner identified on the meeting agenda.
The City Commission will hold a public hearing on the growth policy map amendment on August
6, 2024. The hearing begins at 6:00 p.m. Meetings will be held in the location and manner
identified on the meeting agenda.
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SECTION 4 - STAFF ANALYSIS AND FINDINGS
Analysis and resulting recommendations are based on the entirety of the application materials,
municipal codes, standards, plans, public comment, and all other materials available during the
review period. Collectively this information is the record of the review. The analysis in this report
is a summary of the completed review.
In considering applications for approval under this title, the advisory boards and City Commission
must consider the following criteria. As an amendment is a legislative action, the Commission has
broad latitude to determine a policy direction.
The burden of proof that the application should be approved lies with the applicant. See the
application materials for the applicant’s response to criteria and arguments in favor of approval.
To reach a favorable decision on the proposed application the City Commission must find that the
application meets all of criteria 1 – 4 of Chapter 5 | Plan Amendments, Review Triggers
Amendments, and Amendment Criteria, page 67, Bozeman Community Plan 2020. In making
these findings, they may identify that there are some negative elements within the specific criteria
with the final balance being a positive outcome for approval. When an amendment to either the
text of the Plan or the future land use map is requested, it must be reviewed against the criteria
cited herein and listed below:
1. The proposed amendment must cure a deficiency in the growth policy or improve the
growth policy to better respond to the needs of the general community;
2. The proposed amendment does not create inconsistencies within the growth policy, either
between the goals and the maps or between different goals and objectives;
3. The proposed amendment must be consistent with the overall intent of the growth policy;
and
4. The proposed amendment may must not adversely affect the community as a whole or any
significant portion thereof by:
a. Significantly altering land use patterns and principles in a manner contrary to those
established by this Plan,
b. Requiring unmitigated improvements to streets, water, sewer, or other public facilities
or services, thereby impacting development of other lands,
c. Adversely impacting existing uses because of inadequately mitigated impacts on
facilities or services, or
d. Negatively affecting the health and safety of the residents.
1. The proposed amendment must cure a deficiency in the growth policy or improve the
growth policy to better respond to the needs of the general community;
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Criterion met. This criterion contains two alternate parts. A favorable finding for either part
supports a positive finding. The time horizon for the BCP2020 is 20 years and the future land
use map and other elements such as the city’s facility plans extend further into the future. In
the words of John Heywood, “Rome wasn’t built in a day, but they were laying bricks every
hour.” The plan is the city’s fundamental land-use planning document that helps the
Commission determine how and where to apply limited resources in the most impactful and
financially sustainable manner.
The BCP2020 lists seven themes that describe the vision of the city with numerous goals and
objectives designed to achieve the outcome. There is often tension between some of the goals
and objectives and importance of a given goal may change over time. And, perhaps most
important, these goals and objectives are dependent on one another. A key responsibility of the
City Commission in implementing the BCP2020 is balancing the competing priorities that the
plan must address. That balance may be adjusted over time as one issue takes greater
importance.
The Future Land Use Map (FLUM) for the Planning Area is an indispensable part of this Plan.
It utilizes ten land use categories to illustrate and guide the intent, type of use, density, and
intensity of future development. The map does not always represent existing uses but does
reflect the uses that are desired.
The subject area has been designated for urban density residential use since at least the
adoption of the 1990 Growth Policy and shows areas for commercial development just north
and south of the subject property. As shown on Map 2 and 3, commercial nodes are identified
at the corners of South 19th and Stucky and Blackwood Roads totaling 327 acres.
The 160-acre Community Commercial Mixed-Use property on the southwest corner of
Blackwood Road and South 19th Avenue is not annexed. The Commercial Mixed-Use property
on the northwest corner of Stucky Road and South 19th is annexed, and development has begun.
The Plan addressed the need for additional commercial land on the southwest side of the city.
The southwest side of the city has been slow to develop compared to other parts of the city,
however, that has changed. The amount and scope of development occurring in the southwest
quadrant is considerable.
In total over 2,000 dwelling units are in the hopper. These, plus existing developments such as
Meadow Creek, Southbridge, Gran Cielo, Alder Creek, Blackwood Groves, and other existing
neighborhoods such as the Figgins subdivision, means the number of people residing in this
area may be surpassing expectations of the BCP2020.
In terms of whether the current proposal better responds to the needs of the general community
and/or improves the growth policy, one primary question arises: Would the new designation
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and associated land uses better respond to the needs of the general community and/or improve
the growth policy?
The applicant states the proposed modification to the FLUM responds to community needs by
altering the designation from Urban Neighborhood to Community Commercial Mixed Use. A
variety of zoning districts are used to implement these designations. The descriptions of the
existing and requested future land use map designations follow.
1. URBAN NEIGHBORHOOD (UN)
The category primarily includes urban density homes in a variety of types, shapes,
sizes, and intensities. Large areas of any single type of housing are discouraged. in
limited instances, an area may develop at a lower gross density due to site constraints
and/or natural features such as floodplains or steep slopes. Complementary uses such
as parks, home-based occupations, fire stations, churches, schools, and some
neighborhood-serving commerce provide activity centers for community gathering
and services. The Urban Neighborhood designation indicates that development is
expected to occur within municipal boundaries. This may require annexation prior
to development.
Applying a zoning district to specific parcels sets the required and allowed density.
Higher density residential areas are encouraged to be, but are not required or
restricted to, proximity to commercial mixed-use areas to facilitate the provision of
services and employment opportunities without requiring the use of a car.
5. COMMUNITY COMMERCIAL MIXED USE (CCMU)
The Community Commercial Mixed-Use category promotes commercial areas
necessary for economic health and vibrancy. This includes professional and personal
services, retail, education, health services, offices, public administration, and
tourism establishments. Density is expected to be higher than it is currently in most
commercial areas in Bozeman and should include multi-story buildings. Residences
on upper floors, in appropriate circumstances, are encouraged. The urban character
expected in this designation includes urban streetscapes, plazas, outdoor seating,
public art, and hardscaped open space and park amenities. High density residential
areas are expected in close proximity.
Developments in this land use area should be located on one or two quadrants of
intersections of the arterial and/or collector streets and integrated with transit and
non-automotive routes. Due to past development patterns, there are also areas along
major streets where this category is organized as a corridor rather than a center.
Although a broad range of uses may be appropriate in both types of locations, the
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size and scale is to be smaller within the local service areas. Building and site designs
made to support easy reuse of the building and site over time is important. Mixed
use areas should be developed in an integrated, pedestrian friendly manner and
should not be overly dominated by any single use. Higher intensity uses are
encouraged in the core of the area or adjacent to significant streets and intersections.
Building height or other methods of transition may be required for compatibility
with adjacent development.
Smaller neighborhood scale areas are intended to provide local service to an area of
approximately one half-mile to one mile radius as well as passersby. These smaller
centers support and help give identity to neighborhoods by providing a visible and
distinct focal point as well as employment and services. Densities of nearby homes
needed to support this scale are an average of 14 to 22 dwellings per net acre.
The term “neighborhood commercial” is germane to the conversation. Commercial
development is generally characterized as neighborhood, community, regional, or corridor
commercial development. Neighborhood commercial would be smaller in scale and provides
daily convenience goods and services easily accessible to the residents of the immediate area.
Neighborhood commercial areas might contain a grocery store, bakery, neighborhood
restaurant, drug store, gas station and convenience store, daycare, or some office space. For
comparison:
1) COSTCO 16 acres
2) Target 10 acres
3) Bozeman Public Safety Center 7.9 acres
4) Safeway 5.5 acres
5) The MSU College Street B-1 (Neighborhood Commercial) area that includes four
restaurants, two convenience stores, a grocery store, two coffee shops, and several
personal service businesses. 4.25 acres
6) Whole Foods 4 acres
7) Town & Country east (the old Heebs) 2.1 acres
Given the size of this site at 7.644 acres, large scale commercial development is unlikely unless
structured parking is utilized to meet parking requirements. The College Street commercial
area may be the best example of a neighborhood commercial area of those listed above. This
area is accessible by residents in the vicinity without a car and provides goods and services
that most people can reasonably carry a short distance. In addition, a primary determiner of a
neighborhood commercial area is: “whether it feel safe and inviting for all modes of travel?”
Crossing arterial and/or collector type streets can be difficult for many individuals.
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Any decision to alter the future land use must be made knowing what zoning districts
implement that designation. In this case a wide variety of zoning districts are used to implement
the CCMU designation. The existing Urban Neighborhood designation focuses on residential
use and if zoned REMU, allows commercial and office activities in proportion to the amount
of residential.
The CCMU designation is commercial in character. While residential uses are permitted by
right, the mass and scale of development promotes commercial areas necessary for economic
health and vibrancy including such activities as professional and personal services, retail,
education, health services, offices, public administration, and tourism establishments.
Developments in this land use area should be located on one or two quadrants of intersections
of the arterial and/or collector streets and integrated with transit and non-automotive routes.
As the applicant states the property is located on major streets.
Population density is necessary to support neighborhood and community commercial areas.
As noted in the BCP2020 the city desires simultaneous emergence of residential and
commercial activity. Sufficient density of population is needed to make commercial activity
viable if not dependent on the vehicle. As noted above, the area is rapidly developing and
includes developments such as Nexus Point and Graf Street apartments, among others. The
area is experiencing considerable residential development with more in the works.
Chapter 1 | Basics, Basic Planning Precepts of the BCP discusses the principals the City used
to prepare the policies, goals, objectives, land use designations, and future land use map in this
Plan. See page 20. Most of these precepts relate to this and all map amendments. Five of them
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stand out in relation to this application. These are overarching precepts above any one or
several specific goals or actions.
▪ Variety in housing and employment opportunities are essential.
▪ Land use designations must respond to a broad range of factors, including
infrastructure, natural, and economic constraints, other community priorities, and
expectations of all affected parties concerning private development.
▪ Infill development and redevelopment should be prioritized, but incremental compact
outward growth is a necessary part of the City’s growth.
▪ The needs of new and existing development coexist, and they should remain in
balance; neither should overwhelm the other.
▪ The City intends to create a healthy, safe, resilient, and sustainable community by
incorporating a holistic approach to the design, construction, and operation of
buildings, neighborhoods, and the City as a whole. Developments should contribute
to these goals and be integrated into their neighborhood and the larger community.
The proposed FLUM change both furthers and hinders a variety of Community Plan goals and
objectives when analyzed through the lens of responding to the needs of the general
community. The applicant lists numerous goals and objectives the application furthers, listed
below, and attached in the applicant submittal.
When considering this application staff leans on the existence of significant commercial areas
in the immediate vicinity, relatively low density of housing in the area to support corridor type
commercial development, the critical need for a variety of housing, the physical barriers for
multi-modal transportation to the site, and the BCP2020 shows suitable commercial nodes in
the future land use map. Relevant goals and objectives to this application include the following:
N-2.1 Ensure the zoning map identifies locations for neighborhood and community
commercial nodes early in the development process.
Rationale: The Future Land Use map depicts area designated for all types of city
functions. The current plan shows the location for anticipated commercial development
that are in concert with the existing infrastructure to support such activities. As noted
above there are approximately 327 acres of land in the vicinity designated for
commercial development. While some properties are developed and some are not, little
commercial development has occurred in the southwest quadrant of the City.
Using the intersection of Lincoln Street and South 11th as a destination which
includes Town and Country Foods, and a variety of other businesses, the
development of Gran Cielo is 2 miles away and people must cross South 19th.
Similarly, Meadow Creek is 2.3 miles away and Alder Creek 1.4 miles although on
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the east side of 19th making access easier for other forms of transportation. Staff
concurs with the applicant’s statement that, “According to the EPA Demographic
and Real Estate Market Assessment of January 2018, a population size of 6,500
could support 128,000 square feet of commercial area. This site is the best location
for the creation of a neighborhood commercial center due to its proximity to dense
multi-family housing (directly across the street from a future LIHTC Project) and
single household dwellings. Furthermore, it is situated along a Principal Arterial
and Collector, which provides appropriate separation between commercial and
residential uses. This positioning also allows for ease of access to the site from
adjacent neighborhoods and all South Bozeman.”
DCD-2.2 Support higher density development along main corridors and at high
visibility street corners to accommodate population growth and support businesses.
Rationale: The existing zoning of R-1 and R-2 are generally not in conformance with
the BCP2020. The existence of non-conforming zoning does not necessitate change, an
alternate designation would be more supportive of the plan. The request is for B-2M
which in turn requires this FLU amendment. Currently there is a dearth of commercial
activity to meet general needs of residents on the southwest quadrant of the city. The
BCP2020 shows areas for future commercial development, they are larger in area, little
development has occurred, and the node on the southwest corner of Blackwood and
19th is not annexed with substantial infrastructure needs to develop.
South 19th is a Major Arterial Street and Graf is a designated Collector. These two street
classifications support greater development capacity.
DCD-2.5 Identify and zone appropriate locations for neighborhood-scale commercial
development.
Rationale: The Future Land Use map depicts area designated for all types of city
functions. The current plan shows the location for anticipated commercial
development that are in concert with the existing infrastructure to support such
activities. As noted above there are approximately 327 acres of land in the vicinity
designated for commercial development. While some properties are developed and
some are not, the plan anticipates the long term needs of the city by creating the
framework to accommodate needs as they evolve over time. The city plans for longer
than the current use.
However, community needs change, and the market responds. As noted by the
applicant, the argument can be made that this area is better suited for commercial
development. The discussion above suggests “neighborhood commercial” flourishes
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in a different context of being more imbedded in residential neighborhoods, does not
have major impediments for all users to access, and size of development tends to be
constrained.
According to the Demographic and Real Estate Market Assessment, 2018 [External
PDF] (EPS) report and the Bozeman 2023 Economic and Market Update [External
PDF], Bozeman has an excess of commercially zoned lands for current needs.
According to the BCP2020 FLUM there are two large commercially designated areas
within one-half mile of the subject property that include approximately 327 acres of
Community Commercial Mixed-Use lands. See section two: maps. Underutilized
commercially designated areas already exist in vicinity. Conversion of additional
lands from UN to CCMU may exacerbate this fact. However, there appears to be an
emerging trend in Bozeman to promote dispersed commercial nodes which doesn’t
negate planned area for commercial development, rather suggest larger regional
commercial development nodes may not be appropriate for this area.
The burden to show that the proposed growth policy is amendment is curing a deficiency or
improving the growth policy to better respond to the needs of the general community lies with
the applicant. The applicant provides the following argument.
“Yes, this amendment results in an improved growth policy. The project site was
initially designated for the Yellowstone Theological Institute, which had plans to
establish a community center. However, subsequent changes in vision have led to a
shift in plans for the property. At the time, the zoning and Community Plan Future Land
Use Map Category considerations were not extensively explored due to ongoing
planning and design efforts for the community center. Since then, a new vision has
emerged, one that is better aligned with the goals of the Community Plan. The
transition to Community Commercial Mixed-Use future land use represents an
improved growth policy, advancing a wider range of goals and objectives.
In Bozeman’s 2020 Community Plan, it states that a primary goal and strategy guiding
growth is to create neighborhoods that “Pursue simultaneous emergence of
commercial nodes and residential development through diverse mechanisms in
appropriate locations.”
Unfortunately, this has not yet been achieved under the 2020 Growth Plan for this
southern area of Bozeman. The area south of Kagy lacks any significant commercial
services, and certainly lacks anything that would be considered walkable for residents.
In addition, existing neighborhoods are largely homogeneous regarding product type,
with single households comprising a significant majority of the product type in this
area. This has created a wide area of single-family subdivisions that are not dense, and
a lifestyle that forces residents to solely rely on motor vehicles to reach amenities and
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services. This being said, it should also be recognized that there is now a significant
portion of multifamily being proposed/built in this area. While this is a step in the right
direction, this increased density needs to be supported by simultaneously developed
commercial nodes that allow residents in this area to access essential goods and
services.
Although City staff has recognized the need for land use patterns that enable improved
walkability, the entire subject property in question was recently designated as Urban
Neighborhood in the City’s 2020 Community Plan. Principles applied within this
designation include integrating “urban density homes in a variety of types, shapes,
sizes, and intensities.” and a “some neighborhood-serving commerce provide activity
centers for community gathering and services.” While this designation was
appropriate for a portion of this property, amending a portion of the site to the
Community Commercial Mixed-Use growth designation will help more Community
Plan goals be achieved. Principles applied within the Community Commercial Mixed-
Use designation include promoting “commercial areas necessary for economic health
and vibrancy.” and “located on one or two quadrants of intersections of the arterial
and/or collector streets and integrated with transit and non-automotive routes.” The
addition of the Community Commercial Mixed-Use growth designation to a portion of
this site would support the Community Plan’s goal of simultaneous emergence of
commercial nodes and residential development. For the development of this site, the
proposed change would allow this property to provide a neighborhood scaled
commercial node that is both supported by future residents on this property and
surrounding properties. Each of the following principles are captured within the goals
of the Community Commercial Mixed-Use and Urban Neighborhood growth
designations and REMU and B-2M zoning designations, which allow the property and
these specific zoning designations to cure an existing deficiency in the 2020 Community
Plan for this area of Bozeman.
The list below identifies a series of goals and policies that apply to this Growth Policy
Amendment.
N-1.5 - Encourage neighborhood focal point development with functions, activities,
and facilities that can be sustained over time. Maintain standards for placement of
community focal points and services within new development.
Goal N-2: Pursue simultaneous emergence of commercial nodes and residential
development through diverse mechanisms in appropriate locations.
N-2.1 Ensure the zoning map identifies locations for neighborhood and community
commercial nodes early in the development process.
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The subject site, which is the former site of the Yellowstone Theological Institute,
is centrally located on the south side, which will create a focal point and potential
node along the south side of Bozeman. This area has a significant amount of
residential development that is planned, under construction, and already built.
By quick estimation there are over 6 thousand units that are either already built
or currently in the planning stage. According to the EPA Demographic and Real
Estate Market Assessment of January 2018, a population size of 6,500 could
support 128,000 square feet of commercial area. This site is the best location for
the creation of a neighborhood commercial center due to its proximity to dense
multi-family housing (directly across the street from a future LIHTC Project) and
single household dwellings. Furthermore, it is situated along a Principal Arterial
and Collector, which provides appropriate separation between commercial and
residential uses. This positioning also allows for ease of access to the site from
adjacent neighborhoods and all South Bozeman.
N-2.2 Revise the zoning map to support higher intensity residential districts near
schools, services, and transportation.
As documented above, this project site is in close proximity to several schools.
Additionally, this site is located at the intersection of two high classification
roadways. The higher density residential is being built without any real access to
goods or services. The result of this is more vehicle trips and more congestion in
other neighborhoods. Allowing for some commercial in this area will
dramatically increase the access that these neighborhoods desperately needed.
This access is surrounded by a great multi-modal transportation network, so
access to the site via an alternative mode of transportation is viable. With the
development of this neighborhood as well as the surrounding ones to the east,
one will be able to get from Main Street to the project site largely on a network
of trails.
N-2.3 Investigate and encourage development of commerce concurrent with, or soon
after, residential development. Actions, staff, and budgetary resources relating to
neighborhood commercial develop.
There is a significant amount of residential in the area and now is the right time
for commercial development to follow. This site is in the best location to achieve
this given its access to the existing street network, its central location within this
largely residential area, and access to the existing multimodal network.
DCD-1.1 Evaluate alternatives for more intensive development in proximity to high
visibility corners, services, and parks.
DCD-1.2 Remove regulatory barriers to infill.
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DCD-1.5 Identify underutilized sites, vacant, and undeveloped sites for possible
development or redevelopment, including evaluating possible development incentives.
The Yellowstone Theological Institute originally subdivided this site in 2017 but
it has largely been undeveloped since then. It's worth noting that the Growth
Policy likely wasn't revised to include community commercial zoning in this area,
largely due to the original vision for the property. However, with the change in
vision, it's evident that updating the growth policy is necessary. This Growth
Policy and Zone Map Amendment will allow for this vacant site to be developed.
DCD-2.2 Support higher density development along main corridors and at high
visibility street corners to accommodate population growth and support businesses.
DCD-2.5 Identify and zone appropriate locations for neighborhood-scale commercial
development.
This site being centrally located on the south side in addition to being along two
major roadways make it the best location for neighborhood-scale commercial
development. Furthermore, the rapidly expanding multi-modal network makes
this site perfect for commercial development.
M-1.1 Prioritize mixed-use land use patterns. Encourage and enable the development
of housing, jobs, and services in close proximity to one another.
The Larger South Range Crossing II Project will offer a diverse range of housing
options, including deed-restricted LIHTC housing. By strategically situating
amenities and services near denser residential areas and main transportation
routes, residents may find themselves relying less on personal vehicles or needing
to travel far distances. This approach aims to reduce overall traffic congestion
and minimize the need for extensive commuting throughout the community.”
Locating commercial property is complex and beyond the scope of this report. However,
the city has examined the amount needed and generally considered the most appropriate
locations to serve the city needs. These locations are based on anticipated residential
development, transportation corridors, existing commercial areas, adopted infrastructure
plans and conformance with the community plan. Based on the analysis discussed above,
staff concludes the proposed FLUM amendment responds better to the needs of the general
community
There is an associated zone map amendment, see application 23059 requesting B-2M
zoning for the subject property. If the Commission determines the applicant did not
overcome their burden of proof showing the amendment cures a deficiency in the growth
policy or improves the growth policy to better respond to the needs of the general
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community, the zone map amendment is moot. On the other hand, if the Commission finds
that this condition is met, the zone map amendment may be considered.
2. The proposed amendment does not create inconsistencies within the growth policy,
either between the goals and the maps or between different goals and objectives.
Criterion met. Staff reviewed the growth policy goals and objective and future land use
map. The proposed amendment does not create any identified significant inconsistencies
within the growth policy goals or between goals and maps. See discussion for Criterion 1.
However, there is concern and an acknowledgment that removing residential land from the
inventory and replacing with commercial land may, depending on how the city develops,
be contrary to some goals and policies of the BCP2020.
All future development must demonstrate compliance with all regulatory standards
addressing transportation, parks, building design, and all other standards. The standards
have been crafted and adopted to implement the goals and objectives of the growth policy.
Therefore, compliance with the standards will ensure this criterion is met.
Properties to the west and east are designated as residential areas. Properties to the north
are designated as mixed-use and commercial while lands directly to the south residential.
Bozeman’s zoning districts are dynamic and generally allow a variety of uses both
horizontally and vertically which, depending on the building’s configuration can be viewed
as a positive or negative depending on one’s perspective.
3. The proposed amendment must be consistent with the overall intent of the growth
policy.
Neutral. The overall intent of the growth policy is to proactively and creatively address
issues of development and change while protecting public health, safety and welfare (page
20). If approved, the proposed amendment to the future land use map will allow the site to
be considered for future applications that, if approved, would allow development or further
development of the site.
The growth policy discusses the primary issue of “Does the City Have to Grow” and the
subsequent equation, if so how, see pages 12 – 15 Bozeman Community Plan 2020. This
discussion illustrates, in part, why this application is generally consistent with the overall
intent of the plan. Specific goals and objectives found in Chapter 2 further this statement.
The City supports development within its boundaries where municipal services can be
effectively and efficiently provided. The property has been annexed and the Development
Review Committee considered the application and did not find infrastructure constraints
that cannot be addressed through further development review. The BCP2020 in several
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themes encourages infill and densification of area already served with utilities. Utilities
and transportation are available and being extended into the site. The change, if approved,
will facilitate placement of substantial employment near increasing residential
development and is adjacent to existing arterial and collector streets.
The priorities found in the BCP2020 must be balanced by evolving community needs and
market forces.
4. The proposed amendment will not adversely affect the community as a whole or
significant portion thereof by:
a) Significantly altering land use patterns and principles in a manner contrary to
those established by this Plan,
Criterion Met. The proposed map amendment is for a modest sized area and does not
significantly alter land use patterns from those established by the plan for the city. The
existing land use designation is Urban Neighborhood, and the proposed land use
designation is Community Commercial Mixed Use. The former is primarily residential and
the latter commercial although both allow a diverse use and allow for intensive
development.
As shown in the maps section, the property is surrounded by other Urban Residential area,
it is not uncommon to have islands of different categories in this scale.
Although there is a change in designation, Staff finds the change will not significantly alter
the land use pattern contrary to the Bozeman Community Plan. As discussed in Criterion
1, the proposed amendment advances some goals and principles and hinders others,
although is not contrary to the growth policy.
b) Requiring unmitigated improvements to streets, water, sewer, or other public
facilities or services, thereby impacting development of other lands,
No negative impacts to other lands or the community are anticipated because of the
proposed growth policy amendment. The site is located within the service boundary for
municipal infrastructure and all city services are constructed and directly adjacent to the
subject property.
Prior to development, additional review is required. Adopted city standards will ensure
essential transportation, water, sewer, and communication utilities within the site. The
proposed change in future land use designation does not alter the essential layout of
municipal services. The property is adjacent to arterial and collector streets. No unusual
impacts on infrastructure are expected.
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c) Adversely impact existing uses because of inadequately mitigated impacts on
facilities and services,
No adverse impacts have been identified at this time. The DRC considered impacts of both
outcomes and found no limitations that cannot be addressed with further review. Additional
review will occur during site development and mitigation of any potentially adverse
impacts will be addressed at that time, as required by municipal code. This approach
enables mitigation to be proportionate to the proposed development as required by law.
The applicant provided analysis for the new uses which indicate that municipal services
are not materially impacted by the potential change.
d) Negatively affecting the health and safety of the residents.
The change from Urban Neighborhood to Commercial development will change the
character of the site. However, both development types generate traffic, noise, and other
impacts inherent in the presence of people. These changes will affect adjacent residents
positively and negatively. These changes will occur regardless of the land use designation.
What may be different is the scope of the changes.
Designation of this site as Community Commercial Mixed Use, if approved, will provide
more opportunity for commercial uses on the property while still allowing residential uses.
The exact mix and nature will be influenced by the future decision of an implementing
zoning district. If the project is designed appropriately, it can remain compatible with
surrounding land uses and should not negatively affect the livability of the area or the health
and safety of residents. The land use change would allow for additional opportunity for a
mixed-use neighborhood with conveniently located commercial uses and employment
opportunities to meet the expanding demands of the new neighborhood and growing
surrounding neighborhoods in an area that is appropriate and compatible for such uses. The
standards for mitigating development impacts contained in Chapter 38 of the municipal
code remain in place for either designation. These have been adopted to protect health and
safety and also to protect livability of the community. Therefore, staff does not find any
negative affects to this criterion.
APPENDIX A - PROJECT SITE ZONING AND GROWTH POLICY
Zoning Designation and Land Uses:
The property is inside Bozeman city limits and is zoned low and moderate density residential (R-
1 and R-2). There is an associated zone map amendment to change the zoning to REMU and the
subject property of this GPA to B-2M, see application 24196. These zoning districts are consistent
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with the existing Urban Neighborhood future land use designation. If the Commission approves
the GPA then the R-1 and R-2 zoning would not be.
Adopted Growth Policy Designations:
The following designations are applicable to this application.
Existing designation: URBAN NEIGHBORHOOD.
The category primarily includes urban density homes in a variety of types, shapes, sizes,
and intensities. Large areas of any single type of housing are discouraged. in limited
instances, an area may develop at a lower gross density due to site constraints and/or natural
features such as floodplains or steep slopes. Complementary uses such as parks, home-
based occupations, fire stations, churches, schools, and some neighborhood-serving
commerce provide activity centers for community gathering and services. The Urban
Neighborhood designation indicates that development is expected to occur within
municipal boundaries. This may require annexation prior to development.
Applying a zoning district to specific parcels sets the required and allowed density. Higher
density residential areas are encouraged to be, but are not required or restricted to,
proximity to commercial mixed-use areas to facilitate the provision of services and
employment opportunities without requiring the use of a car.
Proposed Designation: COMMUNITY COMMERCIAL MIXED USE
The Community Commercial Mixed-Use category promotes commercial areas necessary
for economic health and vibrancy. This includes professional and personal services, retail,
education, health services, offices, public administration, and tourism establishments.
Density is expected to be higher than it is currently in most commercial areas in Bozeman
and should include multi-story buildings. Residences on upper floors, in appropriate
circumstances, are encouraged. The urban character expected in this designation includes
urban streetscapes, plazas, outdoor seating, public art, and hardscaped open space and park
amenities. High density residential areas are expected in close proximity.
Developments in this land use area should be located on one or two quadrants of
intersections of the arterial and/or collector streets and integrated with transit and non-
automotive routes. Due to past development patterns, there are also areas along major
streets where this category is organized as a corridor rather than a center. Although a broad
range of uses may be appropriate in both types of locations, the size and scale is to be
smaller within the local service areas. Building and site designs made to support easy reuse
of the building and site over time is important. Mixed use areas should be developed in an
integrated, pedestrian friendly manner and should not be overly dominated by any single
use. Higher intensity uses are encouraged in the core of the area or adjacent to significant
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streets and intersections. Building height or other methods of transition may be required
for compatibility with adjacent development.
Smaller neighborhood scale areas are intended to provide local service to an area of
approximately one half-mile to one mile radius as well as passersby. These smaller centers
support and help give identity to neighborhoods by providing a visible and distinct focal
point as well as employment and services. Densities of nearby homes needed to support
this scale are an average of 14 to 22 dwellings per net acre.
Zoning Correlation with Land Use Categories
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APPENDIX B - NOTICING AND PUBLIC COMMENT
Notice was sent via US first class mail to the owners of the subject property and all owners of
property located within 200 feet of the perimeter of the site. The project site was posted with
a copy of the notice on site. The notice was published in the Legal Ads section of the Bozeman
Daily Chronicle on June 15 and 22, 2024.
The Planning Board public hearing is scheduled for Monday, July 15, 2024.
The City Commission is scheduled and advertised to conduct a public hearing on the
application on Tuesday, August 6, 2024.
No written public comments have been received regarding this project at this time.
APPENDIX D - OWNER INFORMATION AND REVIEWING STAFF
Owner: SRXII, LLC, 1450 Twin Lakes Avenue, Bozeman MT 59718
Applicant: Providence Development, 1450 Twin Lakes Avenue, Bozeman MT 59718
Report By: Tom Rogers, AICP, Senior Planner
FISCAL EFFECTS
No unusual fiscal effects have been identified. No presently budgeted funds will be changed by
this growth policy amendment.
ATTACHMENTS
The full application and file of record can be viewed at the Community Development Department
at 20 E. Olive Street, Bozeman, MT 59715.
Application materials are available through the City’s website.
502
Memorandum
REPORT TO:Community Development Board
FROM:Elizabeth Cramblet, Associate Planner
Chris Saunders, Community Development Manager
Erin George, Interim Director of Community Development
SUBJECT:The South Range Crossing II Zone Map Amendment Requesting Amendment
of the City Zoning Map to Change the Zoning on the Western Half of an
Existing Site From R-1 (Residential Low Density District) and R-2 (Residential
Moderate Density District) to REMU (Residential Emphasis Mixed Use) on
the Northwest Corner Containing 9.26 Acres, and B-2M (Community
Business District Mixed) on the Southwest Corner Containing 9.12 Acres. The
Subject Site is Located on the East Side of S 19th Avenue Between Arnold
Street and Graf Street, Application 23127.
MEETING DATE:July 15, 2024
AGENDA ITEM TYPE:Community Development - Legislative
RECOMMENDATION:Having reviewed and considered the staff report, application materials,
public comment, and all information presented, I hereby adopt the findings
presented in the staff report for application 24196 and move to recommend
approval of the South Range Crossing II Zone Map Amendment, with
contingencies required to complete the application processing.
STRATEGIC PLAN:4.2 High Quality Urban Approach: Continue to support high-quality planning,
ranging from building design to neighborhood layouts, while pursuing urban
approaches to issues such as multimodal transportation, infill, density,
connected trails and parks, and walkable neighborhoods.
BACKGROUND:Prior to this application, the applicant submitted an application for the
entire subject site named the South Range Crossing North Zone Map
Amendment, application 23059, to rezone the eastern half of the property
from R-1 and R-2 to REMU and the western half of the site from R-1 and R-2
to B-2M. At the February 6, 2024 City Commission hearing, the City
Commission approved the request to rezone the eastern half of the subject
site to REMU, but the City Commission was not in favor of rezoning the
entire western half of the site to B-2M. At the hearing, the applicant
withdrew the request to rezone the western half to B-2M with the intent of
submitting a revised plan for the western half of the site under a new
application.
The application includes a proposal to rezone the western half of an existing
site into two zone districts. The applicant is requesting to rezone the
503
northwest corner from R-1 and R-2 to REMU containing 9.26 acres; and the
southeast corner from R-1 and R-2 to B-2M containing 9.12 acres.
Accompanying this application is a Growth Policy Amendment (application
24195) to amend the future land use map from Urban Neighborhood to
Community Commercial Mixed Use for the southwest portion of the
property to allow B-2M on the subject site. The Growth Policy Amendment
must be approved prior to approval of the zone map amendment. Should
the City Commission deny the growth policy amendment for application
24195, the proposal to rezone the 9.12 acres from R-1 and R-2 to B-2M
cannot be approved since the proposed zone district (B-2M) is not an
allowed zone district in Urban Neighborhood.
This portion of the subject site is currently undeveloped and located on the
east side of S 19th Avenue, facing S 19th Avenue. The site sits between the
extension of Arnold Street to the north and Graf Street to the south. Nearby
municipal zoning to the north, south, and east is REMU (Residential
Emphasis Mixed Use). West of the parcel is zoned R-4 (Residential High
Density), R-5 (Residential Mixed Use High Density), B-2M (Community
Business District Mixed), and PLI (Public Lands and Institutions). East and
southeast is zoned R-1 (Residential Low Density) and R-2 (Residential
Moderate Density).
Application 24196 submittal materials are available through the City's
website [External Link].
UNRESOLVED ISSUES:There are no identified conflicts on this application at this time. As noted in
the summary and analysis of zoning criterial the requested B-2M zone
district, accompanying this application is a Growth Policy Amendment (GPA)
application 24195. Zoning analysis for the requested B-2M zone district is
based on approval of the GPA application 24195.
ALTERNATIVES:1. Recommend approval of the application;
2. Recommend modifications to the requested zoning;
3. Recommend deny the application based on findings of non-compliance
with the applicable criteria contained within the staff report; or
4. Open and continue the public hearing on the application, with specific
direction to staff or the applicant to supply additional information or to
address
specific items.
FISCAL EFFECTS:No unusual fiscal effects have been identified. No presently budgeted funds
will be changed by this Zone Map Amendment.
Attachments:
24196 SRX II ZMA CDB SR.pdf
Report compiled on: July 9, 2024
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24196 Staff Report for the South Range Crossing II Zone Map Amendment
Public Hearings: Community Development Board (Zoning Commission) meeting is on
July 15, 2024, at 6:00 pm.
City Commission meeting is on August 6, 2024, at 6:00 pm.
Project Description: The South Range Crossing II Zone Map Amendment requesting
amendment of the City Zoning Map to change the zoning on the western half of an
existing site from R-1 (Residential Low Density District) and R-2 (Residential
Moderate Density District) to REMU (Residential Emphasis Mixed Use) on the
northwest corner containing 9.26 acres, and B-2M (Community Business District-
Mixed) on the southwest corner containing 9.12 acres. Proposal includes amending
the western half (18.38 acres) of an existing site containing a total of 39.86 acres.
Project Location: The subject site is located on the east side of South 19th Avenue between
Arnold Street and Graf Street, and more thoroughly described as a Tract of land in
the SW ¼ NW1/4 of Section 24, Township 2 South, Range 5 East, P.M.M., City of
Bozeman, Gallatin County, Montana.
Recommendation: Meets standards for approval.
Recommended Community Development Board Zoning Motion: Having reviewed and
considered the staff report, application materials, public comment, and all
information presented, I hereby adopt the findings presented in the staff report for
application 24196 and move to recommend approval of the South Range Crossing II
Zone Map Amendment, with contingencies required to complete the application
processing.
Recommended City Commission Zoning Motion: Having reviewed and considered the
staff report, application materials, public comment, recommendation of the
Community Development Board, and all information presented, I hereby adopt the
findings presented in the staff report for application 24196 and move to approve the
South Range Crossing II Zone Map Amendment subject to contingencies required to
complete the application processing.
Report: July 9, 2024
Staff Contact: Elizabeth Cramblet, Associate Planner
Agenda Item Type: Action – Legislative
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Staff Report for the South Range Crossing II Zone Map Amendment Page 2 of 49
EXECUTIVE SUMMARY
This report is based on the application materials submitted and public comment received to
date.
Unresolved Issues
There are no identified conflicts on this application at this time. As noted in the summary
below and analysis of zoning criteria for the requested B-2M zone district, accompanying
this application is a Growth Policy Amendment (GPA) application, 24195. Zoning an alysis
for the requested B-2M zone district is based on approval of the GPA application 24195.
Project Summary
Prior to this application, the applicant submitted an application for the entire subject site
named the South Range Crossing North Zone Map Amendment, application 23059, to rezone
the eastern half of the property from R-1 and R-2 to REMU and the western half of the
property from R-1 and R-2 to B-2M. At the February 6, 2024, City Commission hearing, the
City Commission approved the request to rezone the eastern half of the subject site to REMU,
but the City Commission was not in favor of rezoning the entire western half of the site to B-
2M. At the hearing, the applicant withdrew the request to rezone the western half to B-2M
with the intent of submitting a revised plan for the western half of the site under a new
application.
The application includes a proposal to rezone the western half of an existing site into two
zone districts. The applicant is requesting to rezone the northwest corner from R-1
(Residential Low Density) and R-2 (Residential Moderate Density) to REMU (Residential
Emphasis Mixed Use) containing 9.26 acres; and the southeast corner from R-1 and R-2 to
B-2M (Community Business District-Mixed) containing 9.12 acres.
Accompanying this application is a Growth Policy Amendment (application 24195) to amend
the future land use map from Urban Neighborhood to Community Commercial Mixed Use
for the southwest portion of the property to allow B-2M on the subject site. The Growth
Policy Amendment must be approved prior to approval of the zone map amendment. Should
the City Commission deny the growth policy amendment for application 24195, the proposal
to rezone the 9.12 acres from R-1 and R-2 to B-2M cannot be approved since the proposed
zone district (B-2M) is not an allowed zone district in Urban Neighborhood.
This portion of the subject site is currently undeveloped and located on the east side of S. 19th
Avenue, facing South 19th Avenue. The site sits between the extension of Arnold Street to
the north and Graf Street to the south.
Nearby municipal zoning to the north, south, and east is REMU (Residential Emphasis Mixed
Use). West of the parcel is zoned R-4 (Residential High Density), R-5 (Residential Mixed
Use High Density), B-2M (Community Business District Mixed), and PLI (Public Lands and
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Staff Report for the South Range Crossing II Zone Map Amendment Page 3 of 49
Institutions). East and southeast is zoned R-1 (Residential Low Density) and R-2 (Residential
Moderate Density).
In determining whether the criteria applicable to this application are met, Staff considers the
entire body of plans and regulations for land development. Standards which prevent or
mitigate possible negative impacts are incorporated in many locations in the municipal code
but are principally in Chapter 38, Unified Development Code. References in the text of this
report to Articles, Divisions, or in the form xx.xxx.xxx are to the Bozeman Municipal Code.
Alternatives
1. Recommend approval of the application;
2. Recommend modifications to the requested zoning;
3. Recommend deny the application based on findings of non -compliance with the
applicable criteria contained within the staff report; or
4. Open and continue the public hearing on the application, with specific direction to staff
or the applicant to supply additional information or to address specific items.
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Staff Report for the South Range Crossing II Zone Map Amendment Page 4 of 49
TABLE OF CONTENTS
EXECUTIVE SUMMARY .............................................................................................. 2
Unresolved Issues ...................................................................................................... 2
Project Summary........................................................................................................ 2
Alternatives................................................................................................................ 3
SECTION 1 - MAP SERIES ............................................................................................ 5
SECTION 2 - RECOMMENDED CONTINGENCIES OF ZONE MAP AMENDMENT 12
SECTION 3 - RECOMMENDATION AND FUTURE ACTIONS .................................. 12
SECTION 4 - ZONE MAP AMENDMENT STAFF ANALYSIS AND FINDINGS ........ 13
Section 76-2-304, MCA (Zoning) Criteria (B-2M area) ............................................. 12
Section 76-2-304, MCA (Zoning) Criteria (REMU)................................................... 28
PROTEST NOTICE FOR ZONING AMENDMENTS ................................................... 44
APPENDIX A - DETAILED PROJECT DESCRIPTION AND BACKGROUND ........... 45
APPENDIX B - NOTICING AND PUBLIC COMMENT............................................... 46
APPENDIX C - PROJECT GROWTH POLICY AND PROPOSED ZONING ................ 46
APPENDIX D - PROJECT GROWTH POLICY AND PROPOSED ZONING ................ 48
APPENDIX E - OWNER INFORMATION AND REVIEWING STAFF ........................ 49
FISCAL EFFECTS ........................................................................................................ 49
ATTACHMENTS ......................................................................................................... 49
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SECTION 1 - MAP SERIES
Figure 1: Project Vicinity Map (2023image)
Project
Site S 19th Avenue 509
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Figure 2: Future Land Use Designations (2023 image)
Urban
Neighborhood
Community
Commercial
Mixed Use Residential
Mixed Use
Public
Institutions
Project
Site
510
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Figure 3: Applicant Proposed Future Land Use Designation
Community
Commercial Mixed
Use
Community
Commercial Mixed Use
511
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Figure 4: Current Zoning Map (2023 image)
Subject
Property
REMU
R-1
R-4
B-
2M
PLI
REMU
512
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Figure 5: Applicant Proposed Zoning Map
B-2M
REMU
REMU
R-4
B-
2M
PLI
REMU
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Figure 6: Map of Current Planning Projects
Aaker Phase PP
The
Cottages @
Bzn
Jarrett PP
SRX SP
Graf SP
Gran
Cielo
MSP
Cottages @
Blackwood
Groves
Alpenglow
Apts.
The Flats @
Bzn
SRX II
ZMA/
GPA
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Staff Report for the South Range Crossing II Zone Map Amendment Page 11 of 49
SECTION 2 - RECOMMENDED CONTINGENCIES OF ZONE MAP
AMENDMENT
Please note that these contingencies are necessary for the city to complete the process of the
proposed amendment. These contingencies only apply in the event that the related annexation
request has previously been approved.
Recommended Contingencies of Approval:
1. That the future land use amendment, application 24195, be approved by the City
Commission and the implementing resolution adopted.
2. That all documents and exhibits necessary to establish an initial municipal zoning
designations of REMU and B-2M shall be identified as the “South Range Crossing II
Zone Map Amendment.” All required documents must be returned to the City within 60
days of the City Commission action to annex the property or the preliminary approval
shall be null and void.
3. That the applicant must submit a Zone Amendment map, titled “South Range Crossing II
Zone Map Amendment”. The map must be supplied as a PDF. This map must be
acceptable to the City Engineer’s Office and must be submitted within 60 days of the
action to approve the zone map amendment. Said map shall contain a metes and bounds
legal description of the perimeter of the subject property including adjacent rights-of-way
or street easements, and the individual zoning districts, and total acreage of the property
to be rezoned, unless the property to be rezoned can be entirely described by reference to
existing platted properties or certificates of survey.
4. The Ordinance for the Zone Map Amendment shall not be drafted until the applicant
provides an editable metes and bounds legal description for each zoning district prepared
by a licensed Montana surveyor.
SECTION 3 - RECOMMENDATION AND FUTURE ACTIONS
Zone Map Amendment
Having considered the criteria established for a zone map amendment, the Staff recommends
approval as submitted, contingent on approval of application 24195 to amend the future land
use map.
The Development Review Committee (DRC) considered the amendment. The DRC did not
identify any infrastructure or regulatory constraints that would impede the approval of the
application.
The Zoning Commission will hold a public hearing on this ZMA on July 15, 2024, and will
forward a recommendation to the Commission on the Zone Map amendment. The meeting
will begin at 6 p.m. Instructions on joining the meeting electronically will be included on the
meeting agenda.
The City Commission will hold a public hearing on the zone map amendment on August 6,
2024. The meeting will be held at 121 N. Rouse Avenue, Bozeman. The meeting will begin
at 6 p.m.
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SECTION 4 - ZONE MAP AMENDMENT STAFF ANALYSIS AND
FINDINGS
In considering applications for plan approval under this title, the advisory boards and City
Commission must consider the following criteria (letters A-K). As an amendment is a
legislative action, the Commission has broad latitude to determine a policy direction. The
burden of proof that the application should be approved lies with the applicant.
A zone map amendment must be in accordance with the growth policy (criteria A) and be
designed to secure safety from fire and other dangers (criteria B), promote public health,
public safety, and general welfare (criteria C), and facilitate the provision of transportation,
water, sewerage, schools, parks and other public requirements (criteria D). Therefore, to
approve a zone map amendment the Commission must find Criteria A-D are met.
In addition, the Commission must also consider criteria E-K, and may find the zone map
amendment to be positive, neutral, or negative with regards to these criteria. To approve the
zone map amendment, the Commission must find the positive outcomes of the amendment
outweigh negative outcomes for criteria E-K.
In determining whether the criteria are met, Staff considers the entire body of plans and
regulations for land development. Standards which prevent or mitigated negative impacts are
incorporated throughout the entire municipal code but are principally in Chapter 38, Unified
Development Code. For information about how the code as a whole applies, examples of
specific code sections and the timing of future application is provided as part of the analysis
below. They are presented in table format. Analysis below addresses each of the requested
districts in sequential order. B2-M is evaluated first. Staff analysis of REMU follows the
analysis for B-2M.
Section 76-2-304, MCA (Zoning) Criteria (B-2M)
A. Be in accordance with a growth policy.
Criterion met. The BCP 2020, Chapter 5, p. 73, in the section titled Review Criteria for
Zoning Amendments and Their Application, discusses how the various criteria in 76-2-304
MCA are applied locally. Application of the criteria varies depending on whether an
amendment is for the zoning map or for the text of Chapter 38, BMC. The first criterion for
a zoning amendment is accordance with a growth policy.
Future Land Use Map
The proposed amendment is a change to the zoning map. Therefore, it is necessary to analyze
compliance with the future land use map. Chapter 3 of the BCP 2020 addresses the future
land use map. The introduction to that chapter discusses the importance of the chapter.
Following are some excerpts.
“Future land use is the community’s fundamental building block. It is an illustration of
the City’s desired outcome to accommodate the complex and diverse needs of its
residents.”
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“The land use map sets generalized expectations for what goes where in the community.
Each category has its own descriptions. Understanding the future land use map is not
possible without understanding the category descriptions.”
The area of this application is within the annexed area of the city and where there is
anticipated development within the city as discussed below. As shown on the maps in Section
1, on the excerpt of the current future land use map, the property is designated as Urban
Neighborhood, however, accompanying this application is a Growth Policy Amendment
application, 24195 which includes a proposal to change the future land use map on the
southwest corner from Urban Neighborhood to Community Commercial Mixed Use (see
Figure 3 under Map Series pg. 7). The findings in this criterion are based on the presumption
of a favorable decision on the amendment to the future land use map. If the future land use
map is not approved, then the zone map amendment is not in conformance with the growth
policy as B-2M is not an implementing zoning district for the Urban Neighborhood land use
category.
The Community Commercial Mixed Use designation description reads:
“The Community Commercial Mixed-Use category promotes commercial areas
necessary for economic health and vibrancy. This includes professional and personal
services, retail, education, health services, offices, public administration, and tourism
establishments. Density is expected to be higher than it is currently in most
commercial areas in Bozeman and should include multi-story buildings. Residences
on upper floors, in appropriate circumstances, are encouraged. The urban character
expected in this designation includes urban streetscapes, plazas, outdoor seating,
public art, and hardscaped open space and park amenities. High density residential
areas are expected in close proximity.
Developments in this land use area should be located on one or two quadrants of
intersections of the arterial and/or collector streets and integrated with transit and
non-automotive routes. Due to past development patterns, there are also areas along
major streets where this category is organized as a corridor rather than a center.
Although a broad range of uses may be appropriate in both types of locations, the
size and scale are to be smaller within the local service areas. Building and site
designs made to support easy reuse of the building and site over time is important.
Mixed use areas should be developed in an integrated, pedestrian friendly manner
and should not be overly dominated by any single use. Higher intensity uses are
encouraged in the core of the area or adjacent to significant streets and intersections.
Building height or other methods of transition may be required for compatibility with
adjacent development.
Smaller neighborhood scale areas are intended to provide local service to an area of
approximately one half-mile to one mile radius as well as passerby. These smaller
centers support and help give identity to neighborhoods by providing a visible and
district focal point as well as employment and services. Densities of nearby homes
needed to support this scale are an average of 14 to 22 dwellings per net acre.”
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Staff Report for the South Range Crossing II Zone Map Amendment Page 14 of 49
The correlation between the future land use map of the growth policy and the zoning districts
is presented in Table 4 of the Bozeman Community Plan 2020. As shown in the following
Correlation with Zoning Table the B-2M district is an implementing district of the
Community Commercial Mixed-Use category. It is not an implementing district of the Urban
Neighborhood category.
Goals and Policies
A zoning amendment is also evaluated against the goals and policies of the BCP 2020. Most
of the goals and policies are not applicable to this application. Relevant goals and objectives
have been identified by staff. Conflict with the text of the growth policy have not been
identified.
The Short-Term Action list on page 63 of the BCP 2020 describes 14 items to implement the
growth policy. The first two relate to direct changes to the zoning map in support of listed
goals and objectives. These include increasing the intensity of zoning districts in already
developed areas. Beginning on page 71 of the BCP 2020 in the section titled Zoning
Amendment Review, the document discusses how the city implements zoning for new areas,
amendments to areas, and revisions to existing text. This section includes a discussion of
when the city may initiate a zoning change to a more intensive district to increase
development opportunities. This section demonstrates that the City, as a matter of policy, is
supportive of more intensive zoning districts and development, even within already
developed areas. This policy approach does not specify any individual district but does lean
towards the more intensive portion of the zoning district spectrum.
The applicant suggests numerous goals and objectives that are broadly served with this
application. Staff is in general agreement with the list but notes some goals and objectives
are only marginally promoted by the application. These include:
Goal N-1: Support well-planned, walkable neighborhoods.
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Staff Report for the South Range Crossing II Zone Map Amendment Page 15 of 49
N-1.3 Revise the zoning map to lessen areas exclusively zoned for single -type housing.
The intent of the B-2M community business district mixed is to function as a vibrant
mixed-use district that accommodates substantial growth and enhances the character of
the city. This district provides for a range of commercial uses that serve both the
immediate area and the broader trade area and encourages the integration of multi-
household residential as a secondary use. Design standards emphasizing pedestrian-
oriented design are important elements of this district. Use of this zone is appropriate for
arterial corridors, commercial nodes and/or areas served by transit. The applicant further
suggests “the B-2M zoning would allow for a significant increase in the number of units
that could take the shape of a variety of product types. B-2M allows for a range of
residential housing types primarily based in the multifamily realm.”
N-1.5 Encourage neighborhood focal point development with functions, activities, and
facilities that can be sustained over time. Maintain standards for placement of community
focal points and services within new development.
Goal N-2: Pursue simultaneous emergence of commercial nodes and residential
development through diverse mechanisms in appropriate locations.
N-2.1 Ensure the zoning map identifies locations for neighborhood and community
commercial nodes early in the development process.
The site is currently zoned for low density residential uses. The proposal to rezone to B-
2M would allow a range of commercial uses and as a secondary use, high density housing.
The subject site is located in the south central side of the city which has seen tremendous
residential growth over the last five to six years that include apartment buildings,
condominiums/townhomes, and single-household homes. Additionally, there are a
number of residential projects in the preliminary planning stages (currently being
reviewed) and projects recently approved yet to be constructed as shown in the Map
Series-Figure 6 above. The site is bordered by South 19th Avenue on the west (a
designated Primary Arterial) and Graf Street on the south (a designated collector street)
according to the Bozeman Area Transportation Plan, 2017. Additionally, Arnold Street
and South 15th Avenue will be constructed to a local street standard prior to any
development which further improving access to the site.
The applicant feels there is ample future and existing residential to support community
commercial by stating “This area has a significant amount of residential that is planned,
under construction, and already built. By quick estimations, there are over 6 thousand
units built or going through the planning process. According to the EPS Demographic
and Real Estate Market Assessment of January 2018, a population size of 6,500 could
support 128,000 square feet of commercial area. This site is the best location for the
creation of this neighborhood commercial center and B-2M and REMU are the best
zoning designations to help promote this commercial node.”
The applicant is correct in that a substantial number of residential units are in various
planning stages, however, new development is spread out in the south side region and it
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Staff Report for the South Range Crossing II Zone Map Amendment Page 16 of 49
will take several years to really see the impact of this new development. Careful
placement of commercial nodes is critical to ensure their success. The future land use
map depicts areas suitable for commercial development with implementing zone districts
to provide these services. Making adjustments to this map requires careful consideration
to ensure compliance with the City’s long range growth policy in the Bozeman
Community Plan 2020.
N-2.2 Revise the zoning map to support higher intensity residential districts near
schools, services, and transportation.
The applicant states “this project site is in close proximity to several schools.
Additionally, this site is located at the intersection of two high classification roadways.
Finally, the multimodal network in this area is rapidly expanding and will be further
expanded by any future development. This project site is in the perfect location for
creating a commercial hub on the south side of Bozeman.”
N-2.3 Investigate and encourage development of commerce concurrent with, or soon
after, residential development.
The B-2M district promotes the development of commercial nodes and supports higher
intensity residential uses. The applicant further suggests “there is a significant amount of
residential in the area and now is the right time for commercial development to follow.
This site is in the best location to achieve this given its access to the existing street
network.”
Goal DCD-2: Encourage growth throughout the city, while enhancing the pattern of
community development oriented on centers of employment and activity. Support an
increase in development intensity within developed areas.
DCD-1.5 Identify zone appropriate locations for neighborhood-scale commercial
development.
DCD-2.2 Support higher density development along main corridors and at high visibility
street corners to accommodate population growth and support businesses.
The B-2M district supports higher density and mixed-use developments at the
neighborhood scale. The property highlighted in this application is located adjacent to
19th Avenue and Graf Street, designated a primary arterial and collector street. Both
would be considered main corridors. The applicant agrees with this and argues that since
19th Avenue is “a main corridor through town, placing B-2M next to it meets this
community plan goal. Additionally, Graf Street is a collector street which is also planned
to carry a large percentage of traffic. These two major corridors make the perfect
location for placing commercial and high density residential.”
M-1.1 Prioritize mixed use land use patterns. Encourage and enable the development of
housing, jobs, and services in close proximity to one another.
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Staff Report for the South Range Crossing II Zone Map Amendment Page 17 of 49
The B-2M district is designed as a mixed-use district. Development that is consistent with
the B-2M intent and permitted uses encourage development to be built at densities that
support multimodal transportation and adjacency of housing, jobs, and services.
Staff concurs with a number of these identified goals and objectives. 19 th Avenue is a
designated Primary Arterial and Graf Street is a designated collector street that could serve a
business district. The intent of the B-2M district is to function as a vibrant mixed-use district
that accommodates substantial growth and enhances the character of the city. Substantial
residential development is occurring south of Stucky on the east and west sides of 19th
Avenue. Existing commercial within a quarter mile of the subject site is located at the
southwest corner of South 19th Avenue and Stucky Road located within the county. A half
mile of the subject site is an additional commercial area and a deli located on the south side
of Kagy Boulevard and S. 11th Avenue, and a Town and Country grocery store with some
other local shops and restaurants north of Kagy on 11th Avenue. About a mile out is additional
commercial with restaurants along Kagy Boulevard east of 3rd Avenue. While there are some
nearby commercial shops within a half mile of the site, additional commercial may be
warranted given the number of new residential units in various stages of development in this
south side region.
B. Secure safety from fire and other dangers.
Criterion met. The subject property is currently served by City of Bozeman Fire and Police
Departments. Future development of the property will be required to confo rm to all City of
Bozeman public safety, building and land use requirements, which will ensure this criterion
is met. The change from R-1 & R-2 to B-2M is not likely to adversely impact safety from
fire and other dangers. The on-going relocation of First Station 2 to Kagy will place
emergency services closer with shorter response times than currently exist.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.400.010 Streets,
general
Access for
emergency services
Transportation
Master Plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
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Staff Report for the South Range Crossing II Zone Map Amendment Page 18 of 49
C. Promote public health, public safety, and general welfare.
Criterion met. City development standards included in Chapter 38, Unified Development
Code, building codes, and engineering standards all ensure that this criterion is met. Adequate
water and sewer supply and conveyance provide for public health through clean water. Rapid
and effective emergency response provides for public safety. The City’s standards ensure that
adequate services are provided prior to building construction which advances this criterion.
General welfare has been evaluated during the adoption of Chapter 38 and found to be
advanced by the adopted standards. Provision of parks, control of storm water, and other
features of the City’s development standards also advance the general welfare. Compliance
with the BCP 2020 as described in Section 4, Criterion A shows advancement of the well-
being of the community as a whole. See also Criterion B.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.070
Municipal water,
sewer systems
Location and
requirement to
install.
Sewer collection
facilities plan,
Water facilities plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
522
Staff Report for the South Range Crossing II Zone Map Amendment Page 19 of 49
D. Facilitate the provision of transportation, water, sewerage, schools, parks
and other public requirements.
Criterion met. The BCP 2020, page 74, says the following regarding evaluation of Section 4,
Criteria B, C, & D for zoning amendments:
“For a map amendment, all three of the above elements are addressed primarily by
the City’s long-range facility Plans, the City’s capital improvements program, and
development standards adopted by the City. The standards set minimum sizing and
flow requirements, require dedication of parks, provision of right of way for people
and vehicles, keep development out of floodplains, and other items to address public
safety, etc. It is often difficult to assess these issues in detail on a specific site.”
The City conducts extensive planning for municipal transportation, water, sewer, parks,
sustainability, and other facilities and services provided by the City. The adopted plans allow
the City to consider existing conditions; and identify enhancements needed to prov ide service
to new development. See page 19 of the BCP 2020 for a listing. The City implements these
plans through its capital improvements program (CIP). The CIP identifies individual
projects, project construction scheduling, and financing of construction for infrastructure.
Private development must demonstrate compliance with standards prior to construction .
The subject properties are within the City’s land use, transportation, parks, and utility
planning areas. Those plans show this property as developing within the City when
development is proposed. The 2025-2029 CIP [External Link] shows transportation system
expansion projects on Kagy Blvd and Stucky Road that will improve all mode transportation
system capacity in the area. Development consistent with City standards will improve
connectivity of sidewalks to Blackwood Groves development.
As stated in 38.300.020.C, the designation of a zoning district does not guarantee approval
of new development until the City verifies the availability of needed infrastructure.
38.300.020.C, “Placement of any given zoning district on an area depicted on the
zoning map indicates a judgment on the part of the city that the range of uses allowed
within that district are generally acceptable in that location. It is not a guarantee of
approval for any given use prior to the completion of the appropriate review
procedure and compliance with all of the applicable requirements and development
standards of this chapter and other applicable policies, laws and ordinances. It is
also not a guarantee of immediate infrastructure availability or a commitment on the
part of the city to bear the cost of extendin g services.”
Because this application is accompanied by a growth policy amendment application to
allow for commercial mixed use on the site, additional information was required by the
applicant to determine future water demand, sewer capacity, and traffic demand. Trip
generation projections were submitted for the proposed B-2M and REMU sites based
on the proposed land use densities. The 2017 Bozeman Transportation Master Plan
(TMP) 2017 provides roadway capacities and expected 2040 volumes for roadways
throughout the city. Many roadway projects have been completed as part of the CIP
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Staff Report for the South Range Crossing II Zone Map Amendment Page 20 of 49
program. The proposed change in zoning from R-1 and R-2 to B-2M and REMU is
expected to result in a large increase in traffic demand, but it is not anticipated to exceed
roadway capacities according to the traffic technical report submitted by an engineer
working with the applicant. This report is currently being reviewed by city staff. Water
and sewer technical memos were submitted providing the maximum water demand plus
fire flow and peak hour water demand associated with the proposed zoning. A peak
hour sanitary flow rate associated with the proposed zoning was submitted for
evaluation as well. Engineering staff as indicated from a preliminary review of the water
and sewer calculations within the reports submitted by the applicant, there appears to
be sufficient water and sewer capacity for the proposed zone change. Additional
technical information will be included in all analysis when considering development
applications. All future construction must extend services in conjunction with
subdivision and site development. Those extensions must meet current standards and
will advance this standard.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.060
Easements
Location and form
of easements for
utilities
Transportation
Master Plan, Sewer
collection facilities
plan, Water
facilities plan
Annexation for collector
and arterial streets.
Subdivision or site plan
for all others.
38.410.070
Municipal water,
sewer systems
Location and
requirement to
install.
Sewer collection
facilities plan,
Water facilities plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
524
Staff Report for the South Range Crossing II Zone Map Amendment Page 21 of 49
E. Reasonable provision of adequate light and air.
Criterion met. The B-2M district provides adequate light and air through the Bozeman
Unified Development Code’s standards for park and recreation requirements, on-site open
space for residential uses, maximum building height, lot coverage, and setback
requirements.
The form and intensity standards, Division 38.320, provide minimum lot areas, lot widths,
lot coverage and maximum floor area ratios, and prescribe require minimum separation from
property lines and limits building heights. Section 38.520.030 requires building placement to
ensure access to light and air. Division 38.420 and Section 38.520.060 require dedication of
parks and on-site open spaces to meet needs of residents. The standards provide a reasonable
provision of adequate light and air.
Any future development of the property will be required to conform to City standards for
setbacks, height, lot coverage, and buffering. The criterion is not about personal preferences
but about protection of public health and safety. The adopted standards address protection of
public health and safety.
In addition to the zoning standards, adopted building codes contain more detailed
requirements for air circulation, window placement, and building separation that further
ensure the intent of this criterion is satisfied.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
38.520.060 On-site
residential and
commercial open
space
Private land open
area requirements
Site plan
F. The effect on motorized and non-motorized transportation systems.
Criterion met. Potential future development within a zoning district of B-2M will affect the
City’s motorized and non-motorized transportation system with increased traffic and vehicle
trips along South 19th Avenue and Graf Street. Staff agrees with the applicant’s statement
that “This property is uniquely situated in that it is already served by two high classification
roadways. Future development of the property will be required to comply with
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Staff Report for the South Range Crossing II Zone Map Amendment Page 22 of 49
transportation-related standards and be examined for impacts on surrounding streets,
intersections, and sidewalks. Any future development of the property will likely require a
Traffic Impact Study to gauge the potential impacts of future development.”
The proposed zoning will allow for a higher density of uses than is currently allowed under
R-1 and R-2 zoning districts. The City’s transportation plan is used to evaluate transportation
needs over the long term throughout the City and will evaluate impacts of motorized vehicles
along with bikes and pedestrians. The parks and trails plans also examine and specify options
for extensions of the existing trail network through this site. Future site development will
examine impacts in greater detail on the transportation network, parks, and trails system, and
municipal facilities when specific construction has been identified. Furthermore, these future
development reviews will ensure that development under the new zoning will comply with
the City’s standards for the provision of onsite parking for bicycles and vehicles, as well as
the requirements for onsite circulation.
Traffic impacts will be studied by the development team to demonstrate compliance with the
City’s long-range transportation plans. Future project development will ensure compliance
with the acceptable traffic limits identified in the transportation plans, as well as provide for
the dedication of rights of way, construction or reconstruction of streets and trails, payment
of impact fees, and other contributions as will be applicable to this project.
As previously mentioned, The City conducts extensive planning for municipal transportation,
water, sewer, parks, sustainability, and other facilities and services provided by the City. The
adopted plans allow the City to consider existing conditions; and identify enhancements
needed to provide service to new developmen t.
The subject properties are within the City’s land use, transportation, parks, and utility
planning areas. Those plans show this property as developing within the City when
development is proposed. The 2025-2029 CIP [External link] shows transportation system
expansion projects on Kagy Blvd and Stucky Road that will improve all mode transportation
capacity in the area. Development consistent with City standards will add/improve
connectivity of sidewalks to SRX South development and the Blackwood Groves
development.
Future development and redevelopment of the property will be required to comply with
transportation-related standards and reviewed for impacts on the surrounding streets,
intersections, and sidewalks, and improvements to the transportation network to serve the
site, which will improve the overall transportation system. These improvements include
provisions for non-motorized transportation systems. The change in zoning district will have
a minimal effect on required road improvements, pedestrian or bicycle facilities, or similar
compliance with standards. The site is adjacent to one primary arterial (19th Avenue) and one
collector street (Graf Street), both of which have capacity to carry additional traffic.
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Staff Report for the South Range Crossing II Zone Map Amendment Page 23 of 49
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.060
Easements
Location and form
of easements for
utilities
Transportation
Master Plan,
Annexation for collector
and arterial streets.
Subdivision or site plan
for all others.
38.420.110
Recreation
Pathways
Location and
requirement to
install.
Park, Recreation,
and Active
Transportation Plan
Annexation for Class 1
Trails easement.
Subdivision or site plan
for all else.
G. Promotion of compatible urban growth.
Criterion met. The Bozeman Community Plan establishes a preferred and compatible
development pattern. “The land use map sets generalized expectations for what goes where
in the community… The land use categories and descriptions provide a guide for appropriate
development and redevelopment locations for civic, residential, commercial, industrial, and
other uses. The future land use designations are important because they aim to further the
vision and goals of the City through promoting sustainability, citizen and visitor safety, and
a high quality of life that will shape Bozeman’s future.” (Community Plan p. 51).
The City’s future land use map designates the property as Urban Neighborhood in the BCP
2020. As previously mentioned, accompanying this application is a Growth Policy
Amendment (application (24195) to amend the future land use map from Urban
Neighborhood to Community Commercial Mixed Use on the western half of the lot. The
Community Commercial Mixed-Use designation correlates with several zoning districts
including the B-2M district proposed by the applicants. The districts were developed by the
City to promote appropriate urban growth compatible with the areas of the City and provide
for public and quasi-public uses outside of other districts as identified on the future land use
map. Based on the proposed land use map designation in the Growth Policy Amendment
(application 24195) and correlated zoning districts in the plan and proposed by the applicants,
the zone map amendment would promote compatible urban growth. Also see the discussion
in (H) below.
The applicant provides additional support by stating “the proposed GPA to re-designate a
portion of the property to Community Commercial Mixed Use would allow for the zoning of
B-2M. The growth policy supports development that provides a range of housing options to
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Staff Report for the South Range Crossing II Zone Map Amendment Page 24 of 49
meet the needs of residents. The growing demand for housing suggests the proposed REMU
and B-2M zoning districts are appropriate to facilitate higher densities and variety in housing
options in proximity to commercial areas. Furthermore, the proximity to high classification
roadways and being centrally located makes this an ideal location for a mixed-use
development. Future development on the project site must conform to the City’s zoning
standards, such as setbacks, building heights, and parking requirements, to ensure
compatibility of uses.”
The intent of the B-2M community business district-mixed zone is to function as a vibrant
mixed-use district that accommodates substantial growth and enhances the character of the
city. This district provides for a range of commercial uses that serve both the immediate area
and the broader trade area and encourages the integration of multi-household residential as a
secondary use. Design standards emphasizing pedestrian -oriented design are important
elements of this district. Use of this zone is appropriate for arterial corridors, commercial
nodes and/or areas served by transit.
Looking out about a mile around the subject site illustrates a great deal of new development
and growth in addition to existing development from the last 10 years. A majority of existing
residential units are between one half to one mile east and south of the subject site.
Approximately 2,000 new units are being proposed north, east and south of the subject site.
The Cottages at Bozeman that will construct cottage rental units lies north of the site, and
south is the applicant’s other proposal for South Range Crossing where rental and sale units
are being proposed. East of the subject site is the recently approved Jarrett Zone Map
Amendment for R-2 zoning to include townhouses and single-household homes, and directly
west across 19th Avenue are apartment homes in various stages. Discussed in a separate staff
report the applicant is proposing REMU (Residential Emphasis Mixed Use) on the eastern
side of the subject site where a variety of housing types will be prop osed in a subsequent
application. Providing additional housing and neighborhood commercial services will help
serve a growing student and staff population at Montana State University which lies within a
mile of the subject site.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.320.060 Zone
Edge Transitions
Height adjustments
on the edge of some
zones
Site plan
528
Staff Report for the South Range Crossing II Zone Map Amendment Page 25 of 49
38.340 Overlay
District Standards
Historic
preservation
SOI Standards for
Historic
Preservation,
Design Guidelines
for Historic
Preservation
Site plan and building
permit
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
H. Character of the district.
Neutral. Section 76-2-302, MCA says “…legislative body may divide the municipality into
districts of the number, shape, and area as are considered best suited to carry out the
purposes [promoting health, safety, morals, or the general welfare of the community] of this
part.” Emphasis added.
This proposal amends the zoning map and not the text. Therefore, no element of this
amendment modifies the standards of any zoning district. The character of the districts as
created by those standards remains intact.
As noted above, the City Commission has latitude in considering the geographical extents of
a zoning district. It is not expected that zoning freeze the character of an area in perpetuity.
Rather, it provides a structured method to consider changes to the character. This is especially
true when applying zoning to undeveloped areas as any new construction will alter the
physical characteristics of the area.
The city has defined compatible development as:
“The use of land and the construction and use of structures which is in harmony with
adjoining development, existing neighborhoods, and the goals and objectives of the city's
adopted growth policy. Elements of compatible development include, but are not limited
to, variety of architectural design; rhythm of architectural elements; scale; intensity;
materials; building siting; lot and building size; hours of operation; and integration with
existing community systems including water and sewer services, natural elements in the
area, motorized and non-motorized transportation, and open spaces and parks.
Compatible development does not require uniformity or monotony of architectural or site
design, density or use.”
Community business district-mixed (B-2M)
1. The intent of the B-2M community business district-mixed is to function as a vibrant
mixed-use district that accommodates substantial growth and enhances the character
of the city. This district provides for a range of commercial uses that serve both the
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Staff Report for the South Range Crossing II Zone Map Amendment Page 26 of 49
immediate area and the broader trade area and encourages the integration of multi-
household residential as a secondary use. Design standards emphasizing pedestrian-
oriented design are important elements of this district. Use of this zone is appropriate
for arterial corridors, commercial nodes and/or areas served by transit.
The City has adopted many standards to identify and avoid or mitigate demonstrable negative
impacts of development. These will support the ability of future development in the proposed
B-2M district to be compatible with the proposed adjacent mixed use district, where both will
help serve the expanding residential development within this southern region of the city. The
proposed zone district allows the applicant to construct a variety of commercial-sized
buildings including large scale commercial as well as some secondary residential uses like
townhomes and apartment buildings. A majority of the existing uses within a mile of the
subject site are residential with small pockets of neighborhood commercial and recreational
uses that include medical offices, indoor recreation, retail and office space, and small grocery.
Uses allowed in the B-2M district do expand beyond what is existing, however, this brings
an opportunity to allow much needed new uses that could serve this southern region. The site
is separated from adjacent properties by public right of way for Graf, S 19 th, and Arnold. The
applicant owns the property immediately to the east that is proposed to be zoned as REMU
and which will be separated from the adjacent ownership by 15th Ave. There is physical
separation from all adjacent owners.
The Bozeman Community Plan 2020 on pages 76-77 says in part “Nothing in the zoning
amendment or site review criteria requires the Commission restrict one owner because an
adjacent owner chooses to not use all zoning potential.” The adjacent Alder Creek development
is a mix of single and two home dwellings. It is not inconsistent with the character of the district
to allow the same latitude to the land subject to the application.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.320.060 Zone
Edge Transitions
Height adjustments
on the edge of some
zones
Site plan
38.340 Overlay
District Standards
Historic
preservation
SOI Standards for
Historic
Preservation,
Design Guidelines
Site plan and building
permit
530
Staff Report for the South Range Crossing II Zone Map Amendment Page 27 of 49
for Historic
Preservation
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
I. Peculiar suitability for particular uses.
Criterion met. Future uses for construction on the site are not finalized at this time, so the
suitability of the site for particular uses is not easily evaluated. All uses allowed in the B-2M
district must the considered. The subject site is accessed by South 19th Avenue and Graf Street
which are designated principal arterial and collector streets allowing for easy access to the
project site. The property has access to water lines and sewer extensions along South 19th
Avenue and Graf Street and is currently served by the City of Bozeman Police and Fire
Departments. Considering this, the streets serving the project site, existing city services and
land uses in the immediate area, the proposed B-2M district could offer uses not that are
needed in this region. The applicant states “The proposed REMU and B-2M zoning districts
are directly adjacent to existing REMU zoned lots north , south, and east making the
suitability quite large. Additionally, there are several other parcels in the general vicinity
zoned either R-3 or R-4. The allowed uses in these zoning districts are largely the same. This
creates a condition with large areas of residential uses, without commercial nearby. Allowing
the development of a commercial node in this area would alleviate vehicular traffic on local
roadways by providing residents of this area with walkable community assets .”
As shown in Figures 4 & 5, the property is bounded by REMU to the north, south and east,
and R-3, R-4, R-5, B-2M, and PLI to the west and R-1 and R-2 to the east. The B-2M district
can support many types of urban development that are likely to serve the immediate area as
a result of its location and proximity to residential areas all around the site. Final
determination of suitability will occur during the site development process.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.600 Natural
Resource Protection
Protect watercourses
and wetlands
FEMA Floodplain
study
Subdivision, site plan
review, building permit
531
Staff Report for the South Range Crossing II Zone Map Amendment Page 28 of 49
J. Conserving the value of buildings.
Neutral. The subject site is currently undeveloped. The proposed amendment is for the
zoning map and does not alter allowed uses on adjacent properties. The nearest developed
areas are either separated by S. 19th Avenue or other right of way or over 450 feet away. The
amendment does not modify the existing standards of the B-2M district. The B-2M zone
allows both commercial and residential uses. Future development must comply with the
Bozeman Unified Development Code which will ensure an appropriate scale and intensity of
uses. As a result, the proposed zone map amendment is not anticipated to negatively impact
nearby building and lot values as the permitted uses allowed in the B-2M district will be
appropriate to the surrounding character of the district.
K. Encourage the most appropriate use of land throughout the jurisdictional
area.
Neutral. The Future land use map has this site designated as Urban Neighborhood which does
not allow B-2M as an implementing zone district. As previously mentioned, this analysis is
based on the assumption that the GPA application (24195) is approved to change the land use
designation for the western half of the lot from Urban Neighborhood to Community
Commercial Mixed Use which includes B-2M as an implementing zone district. The location
of this site with access to an existing primary arterial and collector street, with existing
utilities nearby has the opportunity to offer expanded services to a growing region of
residential development in this south side region of the city. The applicant argues “There is
a growing demand for housing in the city, and the while the proposed zoning designation
provide for a variety of housing options to meet this need, the GPA will also address the need
for the development of a commercial node to support these residential uses. The B-2M district
will allow for more focused and significant development to serve both the future residents of
this property and the surrounding communities as well. The need for this commercial node
is ever present on the south side of Bozeman and this central location will allow visitors to
frequent the site from any mode of transportation.”
As this analysis is based on the possible approval of the growth policy amendment, if the
amendment is not approved this criterion is not met. The future land use map from the growth
policy establishes the basic determination of appropriate use of land.
Section 76-2-304, MCA (Zoning) Criteria (REMU)
A. Be in accordance with a growth policy.
Criterion met. The BCP 2020, Chapter 5, p. 73, in the section titled Review Criteria for
Zoning Amendments and Their Application, discusses how the various criteria in 76-2-304
MCA are applied locally. Application of the criteria varies depending on whether an
amendment is for the zoning map or for the text of Chapter 38, BMC. The first criterion for
a zoning amendment is accordance with a growth policy.
532
Staff Report for the South Range Crossing II Zone Map Amendment Page 29 of 49
Future Land Use Map
The proposed amendment is a change to the zoning map. Therefore, it is necessary to analyze
compliance with the future land use map. Chapter 3 of the BCP 2020 addresses the future
land use map. The introduction to that chapter discusses the importance of the chapter.
Following are some excerpts.
“Future land use is the community’s fundamental building block. It is an illustration of
the City’s desired outcome to accommodate the complex and diverse needs of its
residents.”
“The land use map sets generalized expectations for what goes where in the community.
Each category has its own descriptions. Understanding the future land use map is not
possible without understanding the category descriptions.”
The area of this application is within the annexed area of the city and where there is
anticipated development within the City as discussed below. As shown on the maps in Section
1, on the excerpt of the current future land use map, the property is designated as Urban
Neighborhood. The Urban Neighborhood designation description reads:
“This category primarily includes urban density homes in a variety of types, shapes,
sizes, and intensities. Large areas of any single type of housing are discouraged. In
limited instances, an area may develop at a lower gross density due to site constraints
and/or natural features such as floodplains or steep slopes. Complementary uses such
as parks, home-based occupations, fire stations, churches, schools, and some
neighborhood-serving commerce provide activity centers for community gathering
and services. The Urban Neighborhood designation indicates that development is
expected to occur within municipal boundaries. This may require annexation prior to
development.
Applying a zoning district to specific parcels sets the required and allowed density.
Higher density residential areas are encouraged to be, but are not required or
restricted to, proximity to commercial mixed- use areas to facilitate the provision of
services and employment opportunities without requiring the use of a car.”
The correlation between the future land use map of the growth policy and the zoning districts
is presented in Table 4 of the Bozeman Community Plan 2020. As shown in the following
Correlation with Zoning Table the REMU district is an implementing district of the Urban
Neighborhood category.
533
Staff Report for the South Range Crossing II Zone Map Amendment Page 30 of 49
Goals and Policies
A zoning amendment is also evaluated against the goals and policies of the BCP 2020. Most
of the goals and policies are not applicable to this application. Relevant goals and objectives
have been identified by staff. Conflict with the text of the growth policy have not been
identified.
The Short Term Action list on page 63 of the BCP 2020 describes 14 items to implement the
growth policy. The first two relate to direct changes to the zoning map in support of listed
goals and objectives. These include increasing the intensity of zoning districts in already
developed areas. Beginning on page 71 of the BCP 2020 in the section titled Zoning
Amendment Review, the document discusses how the city implements zoning for new areas,
amendments to areas, and revisions to existing text. This section includes a discussion of
when the city may initiate a zoning change to a more intensive district to increase
development opportunities. This section demonstrates that the City, as a matter of policy, is
supportive of more intensive zoning districts and development, even w ithin already
developed areas. This policy approach does not specify any individual district but does lean
towards the more intensive portion of the zoning district spectrum.
The applicant states the proposed zone change is in accordance with the Growth Policy by
stating, “The intent of the REMU designation is to establish areas within Bozeman that are
mixed-use in character and to provide options for a variety of housing, employment, retail
and neighborhood service opportunities within a new or existing neighborhood.” Both the
REMU and B-2M are necessary to achieve the goals of the development in providing services
to local neighborhoods and regional residents that are currently driving across town for
services from the south-side neighborhoods.”
Staff concurs with the applicant regarding the intent and purpose of the REMU district to
provide a vibrant mixed-use district to allow a variety of housing types and neighborhood
services where appropriate. These purposes are accomplished by a variety of objectives that
534
Staff Report for the South Range Crossing II Zone Map Amendment Page 31 of 49
are detailed in Appendix C of this report. The applicant continues to suggest numerous goals
and objectives that are broadly served with this application. Staff is in general agreement with
the list. These include:
Goal N-1: Support well-planned, walkable neighborhoods.
N-1.3 Revise the zoning map to lessen areas exclusively zoned for single -type housing.
Use of this zone is appropriate for sites at least five acres in size and areas located adjacent
to an existing or planned residential area to help sustain commercial uses within walking
distance and a wider range of housing types. The applicant further states “The intent of the
Urban Neighborhood designation is to allow for a variety of types, shapes, sizes and intensity
of homes. Furthermore, the Commu8nity Plan states that large areas of single types of
housing are discouraged. The REMU zoning would allow for a significant increase in the
number of units that could take the shape of a variety of product types.” The proposed change
replaces an area of primarily low density residential with a broader range of allowed
residential and other uses.
N-1.5 Encourage neighborhood focal point development with functions, activities, and
facilities that can be sustained over time. Maintain standards for placement of
community focal points and services within new development.
Goal N-2: Pursue simultaneous emergence of commercial nodes and residential
development through diverse mechanisms in appropriate locations.
N-1.9 Ensure multimodal connections between adjacent developments.
N-2.1 Ensure the zoning map identifies locations for neighborhood and community
commercial nodes early in the development process.
The site is currently zoned for low density residential uses. The proposal to rezone to REMU
would allow a variety of high density housing with a small amount of neighborhood
commercial where appropriate. The subject site is located in the south central side of the city
which has seen tremendous residential growth over the last five to six years that include
apartment buildings, condominiums/townhomes, and single family homes. Additionally, there
are a number of residential projects in the preliminary planning stages (currently being
reviewed) and projects recently approved yet to be constructed as shown in the Map Series-
Figure 6 above. The site is bordered by South 19th Avenue on the west (a designated Primary
Arterial) and Graf Street on the south (a designated collector street) according to the Bozeman
Area Transportation Plan, 2017. Additionally, Arnold Street and South 15th Avenue will be
constructed to a local street standard prior to any development further improving access to
the site.
The applicant states “This area has a significant amount of residential that is planned,
under construction, and already built. By quick estimations, there are over 6 thousand
units built or going through the planning process. According to the EPS Demographic and
Real Estate Market Assessment of January 2018, a population size of 6,500 could support
128,000 square feet of commercial area. This site is the best location for the creation of
535
Staff Report for the South Range Crossing II Zone Map Amendment Page 32 of 49
this neighborhood commercial center and B-2M and REMU are the best zoning
designations to help promote this commercial node.”
The applicant is correct in that a substantial amount of residential units are in various planning
and construction stages, however, new development is spread out in the south side region that
will take several years to really see the impact of this new development. Careful placement
of commercial nodes is critical to ensure their success. The future land use map depicts areas
suitable for commercial development with implementing zone districts to provide these
services. Making adjustments to this map requires careful consideration to ensure compliance
with the City’s long range growth policy in the Bozeman Community Plan 2020. This element
of the zoning amendment address REMU which provides for local service type non-residential
uses.
N-2.2 Revise the zoning map to support higher intensity residential districts near
schools, services, and transportation.
The subject site is just over a half mile from Morningstar Elementary and Sacajawea Middle
School and approximately ½ to 1 mile from existing commercial and retail services. The
applicant argues “Additionally, this site is located at the intersection of two high
classification roadways…. the multimodal network in this area is rapidly expanding and
will be further expanded by any future development.”
Goal N-3: Promote a diverse supply of quality housing units.
N-3.1 Establish standards for provisions of diversity of housing types in a given area.
The applicant argues “The REMU district allows for the construction of a full range of
residential buildings. This supports the opportunity for diversity of supply. Quality of
housing will be assessed and assured during subsequent development review for
compliance with both the UDC and the adopted building codes. Furthermore, the
surrounding area shows the diverse nature of building products in the area.”
N-3.8 Promote the development of “Missing Middle” housing (side by side or stacked
duplex, triplex, live-work, cottage housing, group living, rowhouses/townhouses, etc.)
as one of the most critical components of affordable housing. The applicant states “The
proposed REMU zoning is in alignment with the goals of development for the “missing
middle” housing by allowing higher densities and a more diverse array of housing types
than what is currently allowed in the R-1 and R-2 zoning districts. Multi-household
dwellings, such as apartments, two-and three-household dwellings and
townhouses/rowhouses, are permitted uses within the proposed zoning district. Allowing
these extra housing types will hopefully allow for the creation of smaller units which in
theory could help meet this missing middle demand.”
Staff concurs with a number of these identified goals and objectives. 19th Avenue is a
designated Primary Arterial and Graf Street is a designated collector street that could serve a
high density mixed-use district. The intent of the REMU district is to establish areas within
Bozeman that are mixed use in character and to provide options for a variety of housing,
536
Staff Report for the South Range Crossing II Zone Map Amendment Page 33 of 49
employment, retail and neighborhood service opportunities within a new or existing
neighborhood. While this is a newly developing area, there is substantial new and existing
development south of Stucky on the east and west side of 19th Avenue.
B. Secure safety from fire and other dangers.
Criterion met. The undeveloped subject property is currently served by City of Bozeman Fire
and Police Departments. Future development of the property will be required to conform to all
City of Bozeman public safety, building and land use requirements, which will ensure this criterion
is met. The change from R-1 & R-2 to REMU is not likely to adversely impact safety from fire
and other dangers. The on-going relocation of First Station 2 to Kagy will place emergency
services closer with shorter response times than currently exist.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.400.010 Streets,
general
Access for
emergency services
Transportation
Master Plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
C. Promote public health, public safety, and general welfare.
Criterion met. City development standards included in Chapter 38, Unified Development Code,
building codes, and engineering standards all ensure that this criterion is met. Adequate water
and sewer supply and conveyance provide for public health through clean water. Rapid and
effective emergency response provides for public safety. The City’s standards ensure that
adequate services are provided prior to building construction which advances this criterion.
General welfare has been evaluated during the adoption of Chapter 38 and found to be advanced
by the adopted standards. Provision of parks, control of storm water, and other features of the
City’s development standards also advance the general welfare. Compliance with the BCP 2020
as described in Section 4, Criterion A shows advancement of the well- being of the community
as a whole. See also Criterion B.
537
Staff Report for the South Range Crossing II Zone Map Amendment Page 34 of 49
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.070
Municipal water,
sewer systems
Location and
requirement to
install.
Sewer collection
facilities plan,
Water facilities plan
Subdivision or site plan.
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
D. Facilitate the provision of transportation, water, sewerage, schools, parks
and other public requirements.
Criterion met. The BCP 2020, page 74, says the following regarding evaluation of Section 4,
Criteria B, C, & D for zoning amendments:
“For a map amendment, all three of the above elements are addressed primarily by
the City’s long-range facility Plans, the City’s capital improvements program, and
development standards adopted by the city. The standards set minimum sizing and
flow requirements, require dedication of parks, provision of right of way for people
and vehicles, keep development out of floodplains, and other items to address public
safety, etc. It is often difficult to assess these issues in detail on a specific site.”
The city conducts extensive planning for municipal transportation, water, sewer, parks,
sustainability, and other facilities and services provided by the city. The adopted plans allow
the City to consider existing conditions; and identify enhancements needed to provide service
538
Staff Report for the South Range Crossing II Zone Map Amendment Page 35 of 49
to new development. See page 19 of the BCP 2020 for a listing. The city implements these
plans through its capital improvements program (CIP). The CIP identifies individual
projects, project construction scheduling, and financing of construction for infrastructure.
Private development must demonstrate compliance with standards prior to construction .
The subject properties are within the City’s land use, transportation, parks, and utility
planning areas. Those plans show this property as developing within the City when
development is proposed. The 2025-2029 CIP [External Link] shows transportation system
expansion projects on Kagy Blvd and Stucky Road that will improve all mode transportation
system capacity in the area. Development consistent with City standards will improve
connectivity of sidewalks to adjacent residential districts such as Blackwood Groves.
As stated in 38.300.020.C, the designation of a zoning district does not guarantee approval
of new development until the City verifies the availability of needed infrastructure.
38.300.020.C, “Placement of any given zoning district on an area depicted on the
zoning map indicates a judgment on the part of the city that the range of uses allowed
within that district are generally acceptable in that location. It is not a guarantee of
approval for any given use prior to the completion of the appropriate review
procedure and compliance with all of the applicable requirements and development
standards of this chapter and other applicable policies, laws and ordinances. It is
also not a guarantee of immediate infrastructure availability or a commitment on the
part of the city to bear the cost of extending services.”
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
18.02 International
Fire code
Adopt standards for
fire prevention and
control
Fire/EMS master
plan, International
Fire Code
Site plan and building
permit
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.060
Easements
Location and form
of easements for
utilities
Transportation
Master Plan, Sewer
collection facilities
plan, Water
facilities plan
Annexation for collector
and arterial streets.
Subdivision or site plan
for all others.
38.410.070
Municipal water,
sewer systems
Location and
requirement to
install.
Sewer collection
facilities plan,
Water facilities plan
Subdivision or site plan.
539
Staff Report for the South Range Crossing II Zone Map Amendment Page 36 of 49
38.410.090 Fire
protection
requirements
Development design
Fire/EMS master
plan, International
Fire Code
Subdivision, Site plan,
and building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
E. Reasonable provision of adequate light and air.
Criterion met. The REMU district provides adequate light and air through the Bozeman
Unified Development Code’s standards for park and recreation requirements, on-site open
space for residential uses, maximum building height, lot coverage, and setback requirements.
The form and intensity standards, Division 38.320, provide minimum lot areas, lot widths,
lot coverage and maximum floor area ratios, and prescribe require minimum separation from
property lines and limits building heights. Section 38.520.030 requires building placement to
ensure access to light and air. Division 38.420 and Section 38.520.060 require dedication of
parks and on-site open spaces to meet needs of residents. The standards provide a reasonable
provision of adequate light and air.
Any future and existing development of the property is required to conform to City standards
for setbacks, height, lot coverage, and buffering. The criterion is not about personal
preferences but about protection of public health and safety. The adopted standards address
protection of public health and safety.
In addition to the zoning standards, adopted building codes contain more detailed
requirements for air circulation, window placement, and building separation that further
ensure the intent of this criterion is satisfied.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.420 Parks Standards for
location, type, and
development of
parks and trails
Park, Recreation,
and Active
Transportation Plan
Subdivision or site plan
review
38.520.060 On-site
residential and
Private land open
area requirements
Site plan
540
Staff Report for the South Range Crossing II Zone Map Amendment Page 37 of 49
commercial open
space
F. The effect on motorized and non-motorized transportation systems.
Criterion met. Potential future development within a zoning district of REMU will affect the
City’s motorized and non-motorized transportation system with increased traffic and vehicle trips
along South 19th Avenue and Graf Street. Staff agrees with the applicant’s statement that “This
property is uniquely situated in that it is already served by two high classification roadways.
Future development of the property will be required to comply with transportation- related
standards and be examined for impacts on surrounding streets, intersections, and sidewalks.
Any future development of the property will likely require a Traffic Impact Study to gauge the
potential impacts of future development.”
The proposed zoning will allow for a higher density of uses than is currently allowed under
R-1 and R-2 zoning districts. The City’s transportation plan is used to evaluate transportation
needs over the long term throughout the City and will evaluate impacts of motorized vehicles
along with bikes and pedestrians. The parks and trails plans also examine and specify options
for extensions of the existing trail network through this site. Future site development will
examine impacts in greater detail on the transportation network, parks, and trails system, and
municipal facilities when specific construction has been identified. Furthermore, these future
development reviews will ensure that development under the new zoning will comply with
the City’s standards for the provision of onsite parking for bicycles and vehicles, as well as
the requirements for onsite circulation.
Traffic impacts will be studied by the development team to demonstrate compliance with the
City’s long-range transportation plans. Future project development will ensure compliance
with the acceptable traffic limits identified in the transportation plans, as well as provide for
the dedication of rights of way, construction or reconstruction of streets and trails, payment
of impact fees, and other contributions as will be applicable to this project.
Future development and redevelopment of the property will be required to comply with
transportation-related standards and reviewed for impacts on the surrounding streets,
intersections, and sidewalks, and improvements to the transportation network to serve the
site, which will improve the overall transportation system. These improvements include
provisions for non-motorized transportation systems. The change in zoning district will have
a minimal effect on required road improvements, pedestrian or bicycle facilities, or similar
compliance with standards. The site is adjacent to one primary arterial (19th Avenue) and one
collector street (Graf Street), both of which have capacity to carry additional traff ic. In
addition, Arnold Street and South 15th Avenue will be constructed to a local street standard
prior to any development which will further improve access to the site.
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Staff Report for the South Range Crossing II Zone Map Amendment Page 38 of 49
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.400
Transportation
Facilities and
Access
Streets standards for
size and
construction
Transportation
Master Plan
Subdivision or site plan
review
38.410.060
Easements
Location and form
of easements for
utilities
Transportation
Master Plan,
Annexation for collector
and arterial streets.
Subdivision or site plan
for all others.
38.420.110
Recreation
Pathways
Location and
requirement to
install.
Park, Recreation,
and Active
Transportation Plan
Annexation for Class 1
Trails easement.
Subdivision or site plan
for all else.
G. Promotion of compatible urban growth.
Criterion met. The Bozeman Community Plan establishes a preferred and compatible
development pattern. “The land use map sets generalized expectations for what goes where
in the community… The land use categories and descriptions provide a guide for appropriate
development and redevelopment locations for civic, residential, commercial, industrial, and
other uses. The future land use designations are important because they aim to further the
vision and goals of the city through promoting sustainability, citizen and visitor safety, and
a high quality of life that will shape Bozeman’s future.” (Community Plan p. 51).
The City’s future land use map designates the property as Urban Neighborhood in the BCP
2020. The intent and purpose of the REMU district is to establish areas within Bozeman that
are mixed-use in character and to provide options for a variety of housing, employment, retail
and neighborhood service opportunities within a new or existing neighborhood. The surrounding
area is growing rapidly with a variety of new housing types. Use of this mixed- use zone is
appropriate for areas adjacent to a variety of land uses and can stand alone to develop its own
neighborhood character. Surrounding zoning includes medium to high density residential, and
adjacent REMU districts to the north and south as shown in Section 1. The proposed zoning is
in accordance with the Bozeman Community Plan’s future land use designation of Urban
Neighborhood.
The applicant provides additional support by stating “The growth policy supports development
that provides a range of housing options to meet the needs of residents. The growing demand
for housing suggests the proposed REMU zoning district is appropriate to facilitate higher
densities and a variety in housing options in proximity to commercial areas. Furthermore,
the proximity to high classification roadways and being centrally located makes this an
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Staff Report for the South Range Crossing II Zone Map Amendment Page 39 of 49
ideal location for a mixed-use development. Future development on the project site must
conform to the City’s zoning standards, such as setbacks, building heights, and parking
requirements, to ensure compatibility of uses. The UDC defines compatible urban growth
to not require uniformity in order to ensure compatibility. Furthermore, the City’s zoning
ordinance defines the uses and development standard associated for proposed development
under the auspices of each zoning. The proposed REMU district includes a range of uses that
are appropriate and compatible with the surrounding neighborhoods.”
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.320.060 Zone
Edge Transitions
Height adjustments
on the edge of some
zones
Site plan
38.340 Overlay
District Standards
Historic
preservation
SOI Standards for
Historic
Preservation,
Design Guidelines
for Historic
Preservation
Site plan and building
permit
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
H. Character of the district.
Criterion met. The intent of the REMU zoning district is to“…establish areas within Bozeman
that are mixed-use in character and to provide options for a variety of housing, employment,
retail and neighborhood service opportunities within a new or existing neighborhood.”
Described in Appendix C below the district employs nine aspirational statements to encourage
developers to design and construct developments that meet the intent and purpose of the
district.
1. Emphasizing residential as the primary use, including single household dwellings,
two to four household dwellings, townhouses, and apartments.
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Staff Report for the South Range Crossing II Zone Map Amendment Page 40 of 49
2. Providing for a diverse array of neighborhood-scaled commercial and civic uses
supporting residential.
3. Emphasizing a vertical and horizontal mix of uses in a compact and walkable
neighborhood setting.
4. Promoting neighborhoods that:
a. Create self-sustaining neighborhoods that will lay the foundation for healthy
lifestyles;
b. Support compact, walkable developments that promote balanced transportation
options;
c. Have residential as the majority use with a range of densities;
d. Provide for a diverse array of commercial and civic uses supporting residential;
e. Have residential and commercial uses mixed vertically and/or horizontally;
f. Locate commercial uses within walking distance;
g. Incorporate a wider range of housing types; and
h. Encourage developments that exhibit the physical design characteristics of
vibrant, urban, and pedestrian-oriented complete streets.
5. Providing standards and guidelines that emphasize a sense of place:
a. Support or add to an existing neighborhood context;
b. Enhance an existing neighborhood's sense of place and strive to make it
more self-sustainable;
c. Encourage a new neighborhood commercial center(s) with a unique identity
and strong sense of place;
d. Develop commercial and mixed-use areas that are safe, comfortable,
and attractive to pedestrians; and
e. Reinforce the principle of streets as public places that encourage pedestrian
and bicycle travel, transit, on-street parking and physical elements of complete
streets.
6. Providing standards and guidelines that emphasize natural amenities:
a. Preserve and integrate the natural amenities into the development; and
b. Appropriately balance a hierarchy of both parks and public spaces that
are within the neighborhood.
7. Providing standards and guidelines that emphasize the development of centers:
a. Group uses of property to create vibrant centers;
b. Where appropriate create a center within an existing neighborhood;
c. Facilitate proven, market driven projects to ensure both long and short-
term financial viability;
d. Allow an appropriate blend of complementary mixed land uses including,
but not limited to, retail, offices, commercial services, restaurants, bars,
hotels, recreation and civic uses, and housing, to create economic and
social vitality;
e. Foster the master plan development into a mix of feasible, market driven uses;
f. Emphasize the need to serve the adjacent, local neighborhood and as well as
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Staff Report for the South Range Crossing II Zone Map Amendment Page 41 of 49
the greater Bozeman area; and
g. Maximize land use efficiency by encouraging shared use parking.
8. Promoting the integration of action:
a. Support existing infrastructure that is within and adjacent to REMU zones;
b. Encourage thoughtfully developed master planned communities;
c. Provide flexibility in the placement and design of new developments
and redevelopment to anticipate changes in the marketplace;
d. Provide flexibility in phasing to help ensure both long and short term
financial viability for the project as a whole;
9. Providing standards and guidelines that promote sustainable design:
Use of this zone is appropriate for sites at least five acres in size and areas located
adjacent to an existing or planned residential area to help sustain commercial uses
within walking distance and a wider range of housing types.
Use of this zone is appropriate for sites at least five acres in size and areas located
adjacent to an existing or planned residential area to help sustain commercial uses
within walking distance and a wider range of housing types.”
The REMU district allows for a wide variety of housing types, similar to the moderate and high
density residential districts nearby. The REMU zoning designation is present to the north and south
of the property. The REMU district also allows for commercial use as described in Table
38.310.040A and B [External Link]. Retail uses are limited in size (as proportion of the master
planned site) and noted in the table, with the exception of hotels which can go up to 40,000 square
feet.
Section 76-2-302, MCA says “…legislative body may divide the municipality into districts of
the number, shape, and area as are considered best suited to carry out the purposes [promoting
health, safety, morals, or the general welfare of the community] of this part.” Emphasis added.
This proposal amends the zoning map and not the text. Therefore, no element of this amendment
modifies the standards of any zoning district. The character of the districts as created by those
standards remains intact.
As noted above, the City Commission has latitude in considering the geographical extents of a
zoning district. It is not expected that zoning freeze the character of an area in perpetuity. Rather,
it provides a structured method to consider changes to the character. This is especially true when
applying zoning to undeveloped areas as any new construction will alter the physical
characteristics of the area.
The City has defined compatible development as:
“The use of land and the construction and use of structures which is in harmony with
adjoining development, existing neighborhoods, and the goals and objectives of the
City's adopted growth policy. Elements of compatible development include, but are not
limited to, variety of architectural design; rhythm of architectural elements; scale;
intensity; materials; building siting; lot and building size; hours of operation; and
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integration with existing community systems including water and sewer services,
natural elements in the area, motorized and non-motorized transportation, and open
spaces and parks. Compatible development does not require uniformity or monotony of
architectural or site design, density or use.”
The City has adopted many standards to identify and avoid or mitigate demonstrable negative
impacts of development. These will support the ability of future development in the proposed
REMU district to be compatible with the proposed adjacent development to the north, east, west
and south, and will help serve the expanding residential development within this southern region
of the city. A majority of the existing uses within a mile of the subject site are residential with small
pockets of neighborhood commercial and recreational uses that include medical offices, indoor
recreation, retail and office space, and small grocery. Uses allowed in the REMU district allow
for additional small scale commercial with high density residential that will serve this southern
region of the city. The proposed zone map amendment is compatible and in harmony with the
surrounding area considering the surrounding zone districts and variety of possible uses.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.320.060 Zone
Edge Transitions
Height adjustments
on the edge of some
zones
Site plan
38.340 Overlay
District Standards
Historic
preservation
SOI Standards for
Historic
Preservation,
Design Guidelines
for Historic
Preservation
Site plan and building
permit
38.5 Project Design Site layouts,
landscaping,
building
configuration, signs,
lighting
Site plan and building
permit
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I. Peculiar suitability for particular uses.
Criterion met. Sites north, east and south of the subject site are currently in the preliminary
planning stages or will be under construction in the near future, so the suitability of the site for
particular uses is not easily evaluated. Part of the evaluation is based on submitted proposals and
existing uses surrounding the site along with evaluating existing infrastructure to determine needs
for future development. The subject site is accessed by South 19th Avenue and Graf Street which
are designated principal arterial and collector streets allowing for easy access to the project site.
The property has access to water lines and sewer extensions along South 19th Avenue and Graf
Street and is currently served by the City of Bozeman Police and Fire Departments. Considering
this, the streets serving the project site, existing city services and land uses in the immediate area,
the proposed REMU district could offer uses that are needed in this region. The applicant states
“The proposed REMU and B-2M zoning districts are directly adjacent to existing REMU
zoned lots to both the north, south, and east making the suitability quite large. Additionally,
there are several other parcels in the general vicinity zoned either R-3 or R-4. The allowed
uses in these zoning districts are largely the same. This creates a condition with large areas
of residential uses, without commercial nearby. Allowing the development of a commercial
node in this area would alleviate vehicular traffic on local roadways by providing residents
of this area with walkable community assets.”
As shown in Figures 4 & 5, the property is bounded by REMU to the north, south and east, R-3,
R-4, R-5, B-2M, and PLI to the west and R-1 and R-2 to the east. The REMU district can support
many types of urban development that are likely to serve the immediate area as a result of its
location and proximity to residential areas all around the site. Final determination of suitability will
occur during the site development process.
Municipal Code
Section and Title
Subject Related
Documents
When standard is
applied
38.310 Permitted
Uses
What can be done
where in the city.
Growth policy Subdivision, site plan
review, building permit
38.320 Form and
Intensity Standards
Standards for
building placement
and maximum size
Subdivision, site plan
review, building permit
38.600 Natural
Resource Protection
Protect watercourses
and wetlands
FEMA Floodplain
study
Subdivision, site plan
review, building permit
J. Conserving the value of buildings.
Neutral. The subject site is currently undeveloped. The proposed amendment is for the zoning
map and does not alter allowed uses on adjacent properties. The nearest developed areas are
either separated by S. 19th Avenue or are over 450 feet away. The amendment does not modify
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the existing standards of the REMU district. The REMU zone allows primarily residential uses
with accessory commercial uses. Future development must comply with the Bozeman Unified
Development Code which will ensure an appropriate scale and intensity of uses. As a result, the
proposed zone map amendment is not anticipated to negatively impact nearby building and lot
values as the permitted uses allowed in the REMU district will be appropriate to the surrounding
character of the district.
K. Encourage the most appropriate use of land throughout the jurisdictional
area.
Criterion met. The Future land use map has this site designated as Urban Neighborhood which
lists REMU as an implementing zone district. The location of this site with access to an existing
primary arterial and collector street with existing utilities nearby has the opportunity to offer
expanded services to a growing region of residential development in this south side region of the
city. The applicant argues “There is a growing demand for housing in the city, and...the proposed
zoning designation will provide for a variety of housing options to meet this need.”
PROTEST NOTICE FOR ZONING AMENDMENTS
IN THE CASE OF WRITTEN PROTEST AGAINST SUCH CHANGES SIGNED BY THE
OWNERS OF 25% OR MORE OF THE AREA OF THE LOTS WITHIN THE AMENDMENT
AREA OR THOSE LOTS OR UNITS WITHIN 150 FEET FROM A LOT INCLUDED IN A
PROPOSED CHANGE, THE AMENDMENT SHALL NOT BECOME EFFECTIVE EXCEPT
BY THE FAVORABLE VOTE OF TWO-THIRDS OF THE PRESENT AND VOTING
MEMBERS OF THE CITY COMMISSION.
The City will accept written protests from property owners against the proposal
described in this report until the close of the public hearing before the City Commission.
Pursuant to 76-2-305, MCA, a protest may only be submitted by the owner(s) of real property
within the area affected by the proposal or by owner(s) of real property that lie within 150
feet of an area affected by the proposal. The protest must be in writing and must be signed by
all owners of the real property. In addition, a sufficient protest must: (i) state the writing is a
“protest”, rather than merely expressing opposition; contain a description of the action
protested sufficient to identify the action against which the protest is lodged; and (iii) contain
the application number and a statement of the protestor's qualifications (including listing all
owners of the property and the physical address), to protest the action against which the
protest is lodged, including ownership of property affected by the action. Signers are
encouraged to print their names after their signatures. A person may in writing withdraw a
previously filed protest at any time prior to final action by the City Commission. Protests
must be delivered to the Bozeman City Clerk, 121 North Rouse Ave., PO Box 1230,
Bozeman, MT 59771-1230.
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APPENDIX A - DETAILED PROJECT DESCRIPTION AND
BACKGROUND
A zone map amendment requesting amendment of the City Zoning Map for a parcel consisting of
approximately 39.86 acres into two zone districts, from R-1 and R-2 into REMU on the northwest
corner of the property and B-2M on the southwest corner of the property. Accompanying this
application is a Growth Policy Amendment (application 24195) to amend the future land use map
from Urban Neighborhood to Community Commercial Mixed Use for the southwest portion of
the property to allow B-2M on the subject site. The Growth Policy Amendment must be approved
prior to approval of the zone map amendment. Should the City Commission deny the growth
policy amendment for application 24195, the proposal to rezone the 9.12 acres from R-1 and R-
2 to B-2M cannot be approved since the proposed zone district (B-2M) is not an allowed zone
district in Urban Neighborhood.
The subject site is located at the intersection of South 19th Avenue and Graf Street. South 19th
Avenue lies to the west of the site and Graf is directly south of the site. The site is within proximity
of other residential communities including Gran Cielo, Homestead at Buffalo Run, Meadow
Creek, Southbridge, Alder Creek, South Range Crossing, Allison Subdivision, South University
District and Blackwood Groves. The existing and future residential communities offer a wide
variety of housing options both rental and for sale.
This property was originally annexed and zoned for a residential development in 2007. That
development never proceeded. The site was later subdivided to be the home of the Yellowstone
Theological Institute. The existing zone districts (R-1 and R-2) and subdivision layout was proposed
to help promote the applicant’s goals of creating the theological institute. Today the applicant
believes the R-1 and R-2 zoning are not the best use for the land.
Prior to this application, the applicant submitted an application for the entire subject site named
the South Range Crossing North Zone Map Amendment, application 23059, to rezone the
eastern half of the property from R-1 and R-2 to REMU and the western half of the property
from R-1 and R-2 to B-2M. At the February 6, 2024, City Commission hearing, the City
Commission approved the request to rezone the eastern half of the subject site to REMU, but
the City Commission was not in favor of rezoning the entire western half of the site to B-2M.
At the hearing, the applicant withdrew the request to rezone the western half to B-2M with the
intent of considering comments from the Commission and resubmit with this new proposal.
The REMU district is classified as a mixed-use district. The intent and purpose of the commercial
zoning districts are to establish areas within the city that are primarily commercial in character and
to set forth certain minimum standards for development within those areas. The purpose in having
more than one commercial district is to provide opportunities for a variety of employment and
community service opportunities within the community, while providing predictability. There is a
rebuttal presumption that the uses set forth for each district will be compatible with each other
both within the individual districts and to adjoining zoning districts when the standards of this
chapter are met and any applicable conditions of approval have been satisfied. Additional
requirements for development apply within overlay districts.
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The proposed change from R-1 and R-2 to REMU in building form, and permitted uses is
substantial. Primary differences relate to residential density and the option of including
commercial uses. Please refer to Appendix C for a link to Sec. 38.310.040 showing authorized
uses for commercial, mixed use, and industrial districts (please refer to the REMU column).
While commercial uses in B-2M and REMU are similar, more residential uses are allowed in
REMU. REMU is primarily a residential district with the option of including neighborhood
commercial. B-2M is primarily a commercial business district with a narrow range of residential
uses allowed. Typically, when an applicant requests B-2M over REMU, they are considering a
larger commercial component and a much larger structure. B-2M allows for non-residential
buildings greater than 25,000 square feet whereas REMU is limited to 24,999 square feet, with the
exception of a hotel which can be up to 40,000 square feet.
APPENDIX B - NOTICING AND PUBLIC COMMENT
As required by 38.220 (external link), notice was sent via US first class mail to all owners of
property located inside the site and within 200 feet of the perimeter of the site. The project
site was posted with a copy of the notice. The notice was published in the Legal Ads section
of the Bozeman Daily Chronicle on June 15, 2024. and June 22, 2024. Notice was provided
at least 15 but not more than 45 working days prior to any public hearing. The Community
Development Board hearing is scheduled for July 15, 2024, and the City Commission public
hearing is scheduled for August 6, 2024.
Public comments have not been received on this application at the time of writing this
report. Any received comments will be made available through the City’s Laserfiche
(External Link).
APPENDIX C - PROJECT GROWTH POLICY AND PROPOSED
ZONING
Adopted Growth Policy Designation:
The property is designated as “Urban Neighborhood” in the Bozeman Community Plan
2020.
“This category primarily includes urban density homes in a variety of types, shapes,
sizes, and intensities. Large areas of any single type of housing are discouraged. In
limited instances, an area may develop at a lower gross density due to site constraints
and/or natural features such as floodplains or steep slopes. Complementary uses such
as parks, home-based occupations, fire stations, churches, schools, and some
neighborhood-serving commerce provide activity centers for community gathering
and services. The Urban Neighborhood designation indicates that development is
expected to occur within municipal boundaries. This may require annexation prior to
development.
Applying a zoning district to specific parcels sets the required and allowed density.
Higher density residential areas are encouraged to be, but are not required or restricted
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Staff Report for the South Range Crossing II Zone Map Amendment Page 47 of 49
to, proximity to commercial mixed use areas to facilitate the provision of services and
employment opportunities without requiring the use of a car.”
Proposed Zoning Designation and Land Uses:
The applicant has requested zoning of REMU, Residential Emphasis Mixed Use District whose
intent is to:
Residential emphasis mixed use zoning district (REMU). The intent and purpose of the
REMU district is to establish areas within Bozeman that are mixed-use in character and to
provide options for a variety of housing, employment, retail and neighborhood service
opportunities within a new or existing neighborhood.
These purposes are accomplished by:
1. Emphasizing residential as the primary use, including single household dwellings, two
to four household dwellings, townhouses, and apartments.
2. Providing for a diverse array of neighborhood-scaled commercial and civic uses
supporting residential.
3. Emphasizing a vertical and horizontal mix of uses in a compact and walkable
neighborhood setting.
4. Promoting neighborhoods that:
a. Create self-sustaining neighborhoods that will lay the foundation for healthy
lifestyles;
b. Support compact, walkable developments that promote balanced
transportation options;
c. Have residential as the majority use with a range of densities;
d. Provide for a diverse array of commercial and civic uses supporting
residential;
e. Have residential and commercial uses mixed vertically and/or horizontally;
f. Locate commercial uses within walking distance;
g. Incorporate a wider range of housing types; and
h. Encourage developments that exhibit the physical design characteristics of
vibrant, urban, and pedestrian-oriented complete streets.
5. Providing standards and guidelines that emphasize a sense of place:
a. Support or add to an existing neighborhood context;
b. Enhance an existing neighborhood’s sense of place and strive to make it
more self-sustainable;
c. Encourage a new neighborhood commercial centers(s) with a unique identity
and strong sense of place;
d. Develop commercial and mixed-use areas that are safe, comfortable, and
attractive to pedestrians; and
e. Reinforce the principle of streets as public places that encourage pedestrian
and bicycle travel, transit, on-street parking and physical elements of
complete streets.
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6. Providing standards and guidelines that emphasize natural amenities;
a. Preserve and integrate the natural amenities into the development; and
b. Appropriately balance a hierarchy of both parks and public spaces that are
within the neighborhood.
7. Providing standards and guidelines that emphasize the development of centers:
a. Group uses of property to create vibrant centers;
b. Where appropriate create a center within an existing neighborhood;
c. Facilitate proven, market driven projects to ensure both long and short-term
financial viability;
d. Allow an appropriate blend of complementary mixed land uses including but
not limited to, retail, offices, commercial services, restaurants, bars, hotels,
recreation and civic uses, and housing, to create economic and social
vitality;
e. Foster the master plan development into a mix of feasible, market driven
uses;
f. Emphasize the need to serve the adjacent, local neighborhood and as well
as the greater Bozeman area; and
g. Maximize land use efficiency by encouraging shared use parking.
8. Promoting the integration of action:
a. Support existing infrastructure that is within and adjacent to REMU zones;
b. Encourage thoughtfully developed master planned communities;
c. Provide flexibility in the placement and design of new development and
redevelopment to anticipate changes in the marketplace;
d. Provide flexibility in phasing to help ensure both long and short term
financial viability for the project as a whole;
9. Providing standards and guidelines that promote sustainable design.
APPENDIX D - PROJECT GROWTH POLICY AND PROPOSED ZONING
Adopted Growth Policy Designation (assuming the GPA application has been
approved- #24195):
The property is designated as “Community Commercial Mixed Use” in the Bozeman
Community Plan. Note and describe relevant growth policy components.
“The Community Commercial Mixed-Use category promotes commercial areas
necessary for economic health and vibrancy. This includes professional and personal
services, retail, education, health services, offices, public administration, and tourism
establishments. Density is expected to be higher than it is currently in most commercial
areas in Bozeman and should include multi-story buildings. Residences on upper floors,
in appropriate circumstances, are encouraged. The urban character expected in this
designation includes urban streetscapes, plazas, outdoor seating, public art, and
hardscaped open space and park amenities. High density residential areas are expected
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24196 Staff Report for the Nexus Point Zone Map Amendment Page 49 of 49
in close proximity. Developments in this land use area should be located on one or two
quadrants of intersections of the arterial and/or collector streets and integrated with
transit and non-automotive routes. Smaller neighborhood scale areas are intended to
provide local service to an area of approximately one half -mile to one mile radius as
well as passersby. These smaller centers support and help give identity to
neighborhoods by providing a visible and distinct focal point as well as employment
and services. Densities of nearby homes needed to support this scale are an a verage of
14 to 22 dwelling units per net acre.”
Proposed Zoning Designation and Land Uses:
The applicant has requested zoning of B-2M, Community Business District-Mixed whose
intent is to:
“The intent and purpose of the B-2M community business district-mixed is to function as a
vibrant mixed-use district that accommodates substantial growth and enhance the
character of the city. This district provides for a range of commercial uses that serve both
the immediate area and the broader trade area and encourages the integration of multi-
household residential as a secondary use. Design standards emphasizing pedestrian-
oriented design are important elements of this district. Use of this zone is appropriate for
arterial corridors, commercial nodes and/or areas served by transit.”
Below is a link to permitted uses with a column designated for B-2M
Sec. 38.310.040. – Authorized Uses-Commercial, Mixed-Use, and Industrial
Zoning Districts.
APPENDIX E - OWNER INFORMATION AND REVIEWING STAFF
Owner: Gilhousen Community Property TR DTD 3/30, PO Box 11462, Bozeman MT 59719
Applicant: Providence Development, PO Box 4082, Bozeman, MT 59715
Representative: Parker Lange, PO Box 4082, Bozeman, MT 59715
Report By: Elizabeth Cramblet, Associate Planner
FISCAL EFFECTS
No unusual fiscal effects have been identified. No presently budgeted funds will be changed by
this Annexation or Zone Map Amendment.
The full application and file of record can be viewed at the Community Development Department
at 20 E. Olive Street, Bozeman, MT 59715. In addition, application materials can be viewed
on the City’s development map at the following link: Application 24196 (External Link)
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Memorandum
REPORT TO:Community Development Board
FROM:Chris Saunders, Community Development Manager
Erin George, Community Development Interim Director
SUBJECT:Upcoming Items for the August 5, 2024, Community Development Board
Meeting.
MEETING DATE:July 15, 2024
AGENDA ITEM TYPE:Citizen Advisory Board/Commission
RECOMMENDATION:Information only, no action required.
STRATEGIC PLAN:4.2 High Quality Urban Approach: Continue to support high-quality planning,
ranging from building design to neighborhood layouts, while pursuing urban
approaches to issues such as multimodal transportation, infill, density,
connected trails and parks, and walkable neighborhoods.
BACKGROUND:The following development review items are presently scheduled for the
August 5, 2024, Community Development Board meeting:
1. Bozeman Health Growth Policy Amendment, Application 24118,
considered in capacity as Planning Board.
UNRESOLVED ISSUES:None.
ALTERNATIVES:None.
FISCAL EFFECTS:None.
Report compiled on: July 10, 2024
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