CommunityScale partnered with the City of Pueblo, Colorado to develop a comprehensive 2025-2030 Consolidated Plan, Analysis of Impediments to Fair Housing Choice, and First Year Annual Action Plan to guide the city’s use of federal Community Development Block Grant (CDBG) and HOME Investment Partnerships funding. Through extensive community engagement, data-driven analysis, and strategic planning, the project identified pressing housing affordability challenges and established actionable recommendations to ensure all residents have access to safe, affordable housing regardless of race, disability status, or income level.
A Growing Affordability Crisis
Pueblo, like communities across the United States, has experienced mounting pressure on housing affordability since 2020. Rental apartment units in the Pueblo market saw a 30% increase in average monthly rent from mid-2020 to late 2022, rising from approximately $900 to $1,150 per month. Single-family home prices increased nearly 150% over the past decade, with the average sales price reaching $325,000 by 2024. Meanwhile, new market-rate housing supply stagnated, creating an affordability squeeze that disproportionately impacts lower-income households and members of protected classes.
The City of Pueblo, as a recipient of annual HUD funding through CDBG and HOME programs, is required to prepare a five-year Consolidated Plan and Analysis of Impediments to Fair Housing Choice every five years. With the previous plan dating to 2021 (developed during the height of the COVID-19 pandemic), the City recognized an urgent need to reassess housing conditions, identify current barriers to fair housing access, and develop strategies responsive to today’s market realities.

A Community-Driven Planning Process
CommunityScale’s approach centered on robust community input combined with rigorous data analysis. Our team conducted the planning process from February through May 2025, working closely with the City of Pueblo Housing Department, Pueblo County (as part of the Pueblo HOME Consortium), and dozens of community stakeholders.
The engagement strategy included two in-person trips to Pueblo to maximize face-to-face interaction with residents and stakeholders. We hosted two public meetings at local libraries, held both in-person and via Zoom, with 31 in-person attendees and additional remote participants. The meetings were recorded and shared online to extend the conversation beyond those who could attend live sessions.
To reach residents throughout the community, we distributed flyers at all five public library branches, community centers, coffee shops, and the main transit center. We promoted the meetings through 16 local Facebook community groups and partnered with the Greater Pueblo Chamber of Commerce and Latino Chamber of Commerce to spread the word through their networks.
An anonymous online survey garnered 87 responses from residents and workers in Pueblo, capturing opinions and experiences regarding housing challenges, discrimination, and community development priorities. More than 80% of respondents identified affordable housing as a top priority, with particular emphasis on the need for accessible units for seniors and residents with disabilities.

We also solicited detailed written responses from key stakeholders including the Pueblo Community Health Center, Archway Communities, Pueblo Urban Renewal Authority, Health Solutions, Habitat for Humanity of Pueblo, and NeighborWorks Southern Colorado. These organizations provided frontline perspectives on housing challenges, from deteriorating housing stock in historic neighborhoods to gaps in supportive services for vulnerable populations.
All outreach and analysis was conducted using HUD’s eCon Planning Suite, ensuring full compliance with federal requirements outlined in 24 CFR Part 91.
Critical Findings: Four Impediments to Fair Housing
Through analysis of American Community Survey data, Home Mortgage Disclosure Act (HMDA) lending data, Colorado Civil Rights Division discrimination complaints, and extensive stakeholder input, we identified four primary impediments to fair housing choice in Pueblo:
Impediment #1: Lack of Affordable Housing as Prices Rise Relative to Income. Seventy-two percent of households earning less than 30% of area median income (AMI) are cost-burdened, with 55% severely burdened. Significant cost burden also affects households earning 30-60% AMI (37% cost-burdened), 60-80% AMI (23%), and 80-100% AMI (17%). Rising development and borrowing costs have made new housing construction “marginally infeasible” at current prices without subsidies, creating a supply shortage that drives up costs across the housing market.
Impediment #2: Deteriorating Existing Housing. Pueblo has a large stock of older homes, with the average home age exceeding 55 years. Approximately 24,000 owner-occupied single-family homes (55% of the ownership housing inventory) were built prior to 1980. Stakeholders consistently cited spreading blight, vacant properties, and substandard housing conditions as major concerns. Older homes that are not properly maintained or adapted for residents with disabilities diminish the stock of suitable, affordable housing and force extremely low-income residents into unsafe living conditions.
Impediment #3: Lack of Supportive Housing Services. Nearly a quarter of survey respondents noted that a lack of transitional housing was hurting vulnerable populations. Stakeholders emphasized the need for wrap-around services including emergency sheltering, eviction legal assistance, financial literacy training, mental health and addiction counseling, and job training to help residents retain or secure stable housing.
Impediment #4: Lack of Housing Education and Resources for Protected Populations. Analysis of 2023 HMDA data revealed persistent disparities in mortgage lending. Application denial rates for home purchase loans in Pueblo County were significantly higher for minority applicants: 26.81% for American Indian applicants, 20.19% for Asian applicants, 19.39% for Black applicants, and 19.50% for Hispanic applicants, compared to 16.57% for white applicants. These disparities, consistent with national trends, indicate a need for continued fair housing education, homebuyer counseling targeted to minority households, and proactive outreach to ensure all residents understand their rights and available resources.
Strategic Recommendations for Lasting Change
Based on these findings, CommunityScale developed a comprehensive Fair Housing Action Plan with specific, actionable recommendations across four goal areas:
Ensuring Municipal Policies Affirmatively Further Fair Housing: The City and County are currently updating zoning ordinances to relax restrictions on multifamily housing, particularly in infill areas, and to explore land-use designations that support high-density housing. The plan recommends modernizing codes to facilitate affordable construction methods, streamlining coordination between city and county departments to speed development processes, and educating the public on housing challenges and solutions.
Reducing Construction and Repair Costs: Recommendations include implementing expedited review processes for affordable and “missing middle” housing projects, adjusting design standards to enable more attainable pricing, and creating formal incentive policies for fee waivers, tax increment financing, property tax abatements, and reduced utility tap fees to make development financially feasible.
Replacing Blighted Buildings and Preventing Further Deterioration: The plan calls for creating public-private partnerships for demolition and new construction, supporting Pueblo Urban Renewal Authority efforts to reclaim vacant properties, exploring stricter enforcement of building codes, allocating more funding for repairs in high-blight areas, and launching communications campaigns to inform residents about available repair resources.
Expanding Support Systems and Education for Vulnerable Populations: Recommendations include creating a network of community development services and advocates to share information, providing more mental health and addiction services, offering financial literacy education and homebuyer counseling, expanding sheltering options, finalizing a Language Access Plan to serve limited English proficiency residents, designating a fair housing officer, and formally adopting a Reasonable Accommodation Policy.
Creating Lasting Impact
The final Consolidated Plan, Analysis of Impediments, and First Year Action Plan were delivered to the City of Pueblo in May 2025. The plans provide a clear roadmap for the City and County’s use of approximately $1.4 million in annual CDBG funding and $670,000 in HOME funding over the next five years.
The planning process engaged more than 100 residents, stakeholders, and community leaders, creating shared understanding of housing challenges and building momentum for collaborative solutions. By combining data analysis with authentic community input, the plan reflects both the urgent needs of Pueblo’s most vulnerable residents and the practical realities of housing development in today’s economic environment.
Learn more about the Pueblo Consortium’s housing and community development programs:
City of Pueblo Housing & Community Services Division
Pueblo County Department of Housing and Human Services
