Docusign Envelope ID: 9ACEACD0-D15C-8210-82A6-8FBC595BF230 use of federal funds otherwise imposed by federal law and regulation and is instead principally governed by its MTW Agreement with HUD (as amended from time to time).
As an MTW PHA, in addition to the relief offered by AHA’s MTW Agreement with respect to the use of federal funds, AHA also receives broad relief from many of the requirements of the Housing Act of 1937, including certain provisions of the Housing Opportunities through Modernization Act of 2016 (HOTMA). For example, absent AHA’s future decision to limit itself to the HOTMA statutory provisions, AHA is not subject to HOTMA’s restrictions imposing a cap of 20% of a PHA’s HCV budget for its PBV programs (excluding the additional 10% that a PHA may use as PBV for housing the homeless, elderly, disabled, veterans or involving supportive housing).
HUD-approved MTW Supplemental Reporting by AHA states that AHA intends to use up to 50% of its HCV budget for AHA’s PBV program. Federal law and regulation provide AHA as an MTW PHA with significant discretion over the use and application of the annual budgets, including HCV, that fund the federally-assisted housing it provides to the people of the Alameda. Nevertheless, we understand that MTW status does not provide blanket relief from compliance with the Housing Act of 1937 or otherwise applicable provisions of the code of federal regulations, and our letter cites and provides the basis for our request in light of those otherwise applicable regulatory provisions.
2 The 1994 Base Closure Community Redevelopment and Homeless Assistance Act requires closing military bases to make reasonable accommodations to meet the needs of the homeless. To meet this requirement, APC and the City's predecessor agencies negotiated "Standards of Reasonableness" to delineate a reasonable plan for provision of real property and services at Alameda NAS. This includes the following requirement related to Housing: "Twenty percent of the base "family housing" units available for reuse or an equivalent number of like units in the community will be made available to homeless providers for permanent and transitional housing....Family units are multi bedroom units in either single family or multi-unit buildings." 3 24 C.F.R. §983.51(b)(2) (“Subpart B”). Under Subpart B, a PHA may award PBV HAP in conjunction with another competition involving “housing assisted under a federal, state, or local government housing assistance, community development, or supportive services program that required competitive selection of proposals, where the proposal has been selected in accordance with such program’s competitive selection requirements [...].” AHA’s PHA Administrative Plan permits awards under the provisions set forth in Subpart B. C. 16, 2026 AHA PHA Administrative Plan.
8/19/2026
1 www.alamedahsg.org
Current Status of Funding for Estuary II (NH PSH II)August 19, 2026Sylvia MartinezDirector of Housing Development www.alamedahsg.org
Estuary II•46 0b and 1b units•Co-designed and permitted with other NH Block A properties•All needed public infrastructure was built with first two properties•Meant to be operated jointly with Estuary I•Vouchers awarded in competitive process in 2021, extended through 2025.•Two years of applications have been unsuccessful due to highly competitive environment, lack of soft funds, etc.•2026 No tax credit applications submitted due to voucher uncertainty 1 2
8/19/2026
2 www.alamedahsg.org
Factors to Consider•Meeting the Navy LBA/BRAC obligations for 90 homeless units•AHA cannot honor voucher award due to shortfall. Vouchers or another operating subsidy are needed to serve the formerly homeless or extremely low-income seniors.•Soft funding is expiring and if we don’t apply/win tax credits in 2027, awards will be lost and ICD risks negative points. New HCD funds will not be available until 2029, if the bond passes.•Ongoing intense competition for tax credits•Future cost escalation due to global supply and Buy American requirements www.alamedahsg.org
Future PBV needs•LBA obligations – We need a minimum of 30 units targeted to homeless households for the LBA, and up to 46 targeted units per the MOU with Building Futures and Alameda Point Collaborative.•Lack of vouchers – CTCAC and other underwriters require vouchers or an operating reserve (COSR) for all homeless targeted units to meet Market Study requirements.•Vouchers improve the tiebreaker for tax credits. 3 4
8/19/2026
3 www.alamedahsg.org
Questions or Comments?
5
8/19/2026
1 www.alamedahsg.orgSpecial MeetingStardust GardensCompetition AnalysisAugust 19, 2026Sylvia MartinezDirector of Housing Development www.alamedahsg.orgStardust Gardens –Two Applications
MHP Gap ApplicationAHSC application6/5/20265/28/2025Date submitted8/11/202612/10/2025Date of conditional award$15,000,000 $29,553,361 Amount of conditional awardNone 20-40 vouchers shown to support threshold 15-year positive cash flow, also to support operations, debt, PSH targeted populationVouchersSame20%-50% AMI, averaging 36% AMIAverage Area Median Income served (AMI)None$22,710,602Gap without vouchersMust apply to CDLAC on 9/8/2026 and close in 2027Must close on construction by 12/10/27Commitment 1 2
8/19/2026
2 www.alamedahsg.orgAHSC Consideration of Vouchers1. The application shows voucher income necessary to meet the State Uniform Multifamily Regulation underwriting requirements for 15 years of positive cash flow. This is a threshold requirement.2. The application shows voucher income necessary to support a permanent loan of $6,590,000. Without vouchers, this loan is not available and there is a funding gap.3. The application shows vouchers as ‘YES’ in section 33. The number of vouchers listed is 20 and the term is 20 years.4. The market study requires 40 vouchers for feasibility, in particular 20 vouchers for the homeless units.5. The $ 1,170,000 funding commitment from the Federal Home Loan Bank Affordable Housing Program requires 39 homeless units. Homeless units typically require vouchers or other operating subsidies, as is indicated in the market study. www.alamedahsg.orgMHP GAP Application•Requires AHSC award for eligibility•Reduced total development costs by $1.2 million•Reduced operating costs by 30%.•Reduced perm loan by 90%•Affordability remains at average of 36% AMI (extremely low income on average) and target population says ‘formerly homeless.’ 3 4
8/19/2026
3 www.alamedahsg.orgOptions post MHP GAP Award•Apply for bonds and tax credits in September 2026 and begin construction by June 2027 (approx. 10 months)•Construction period – Approximately 24 months•During 34 months, seek rental assistancevouchers from any valid competition, or from the VA to serve the targeted population. Also, operating subsidies may be available from the City of Alameda or other sources. 5
www.alamedahsg.org
AHA PBV Policy
Tonya Schuler-Cummins
Senior Programs Director
May 21, 2025
Exhibit 2f
www.alamedahsg.org
Project-Based Voucher
(PBV) Policy
• Purpose is to outline methods of selecting PBV units
• Works with:
• MTW Activities
• Admin Plan
• Regulation
• Authorizes AHA to use MTW Activity for Elimination of Selection process for AHA-owned projects and sets
priorities
• Must be a Single Asset Entity (SAE) of AHA
www.alamedahsg.org
PBV Review
• PBV Cap – 50% of ACC under MTW
• Not counted: PBV-VASH (30), RAD (120), EHV
• PBV Cap as of May 1, 2025, is 864
• 317 more units could be used for PBV
• Today, ACC and budget authority cap it at 100
• After current and anticipated
• AHA normally caps at 40 units per complex
www.alamedahsg.org
Awarded PBV
Complex Number of PBV Units
Alameda Point Collaborative 25
Anne B. Diament Plaza 59
Breakers at Bayport 15
China Clipper Plaza 6
Corsair Flats (VASH) 25
Esperanza 37
Everett Commons 12
Everett Commons (VASH) 5
Independence Plaza 25
Independence Plaza 120
Independence Plaza (VASH) 7
Jack Capon 18
Lincoln Willow 3
Littlejohn Commons 25
Park Alameda 15
Parrot Village 36
Rosefield Village (New Construction) 20
Rosefield Village (Rehabilitation) 3
Rosefield Village (VASH) 2
Shinsei Gardens 21
Stanford House 4
Stargell Commons 7
The Starling 17
TOTAL 507
www.alamedahsg.org
120 PBV Units Coming
• AHAPs
• 40 units at The Estuary I
• 40 units at Linnet Corner
• Selected Projects
• 40 units at The
Estuary II
www.alamedahsg.org
Self-Award
• ICD New Construction properties
• AHA/AAHC-owned properties that have existing HAP Contracts under 40 units and financial need
• AHA/AAHC-owned properties that do not have existing HAP Contracts and have financial need
• AHA/AAHC-owned properties that have existing HAP Contracts under 40 units
• ICD-owned properties that have existing HAP Contracts under 40 units and financial need
• ICD-owned properties that have existing HAP Contracts under 40 units
www.alamedahsg.org
Proposed PBV
under Self-Award
Complex Units Proposed to
Add
Total Units under PBV
including Proposed
Units
The Poplar 40 40
The Estuary II (already has
award)
40 40
China Clipper Plaza 6 12
Parrot Village 4 40
Esperanza Apartments 3 40
Rosefield Village 15 30
Eagle Village 6 6
Sherman Street 6 6
Parrot Gardens 8 8
Lincoln Willow 2 5
TOTAL 120 248
Anticipated Order of Award, but may change slightly
www.alamedahsg.org
Other PBV Policies
• Limiting Income on Units
• Location of Units
• Unit Sizes
• AHAP Signing
• HOTMA Contract Additions
• Extending Expiring Contracts
• RFP Elements
www.alamedahsg.org
Questions?
U.S. Department of Housing and Urban Development
Public and Indian Housing
_________________________________________________________________________ Special Attention of: PIH Notice 2013-28
Office Directors of Public Housing;
Regional Directors; Public Housing Issued: December 16, 2013 Agencies.
Expires: Effective until amended,
superseded, or rescinded
Cross References: Notice PIH 2013-12
_________________________________________________________________________ SUBJECT: Guidance on the Use of Outside Sources of Funds in the Housing Choice Voucher (HCV) Program
1. Purpose. This purpose of this Notice is to provide guidance to public housing agencies (PHAs) regarding the use of outside sources of funds for Housing Assistance Payments (HAP) expenses in the Housing Choice Voucher (HCV) Program.
2. Background. HUD has received numerous inquiries from PHAs requesting clarification regarding whether outside sources of funding may be used to make HAP payments. In some cases PHAs are seeking to maintain leasing or increase leasing up to baseline, which without outside sources of funding would not be possible for the PHA in light of the deep proration in renewal funding as a result of sequestration. Other PHAs have asked if outside sources may be used to prevent the termination of families as a result of insufficient funding. This notice clarifies the requirements regarding the use of outside funds for calendar year 2013 and subsequent years.
3. Acceptable Sources of Funds. PHAs administering the HCV program have several acceptable sources of funds available to cover eligible HAP expenses in the HCV program.
These sources of funds include HCV budget authority, HUD-held HAP reserves (undisbursed budget authority), PHA-held Net Restricted Assets (NRA), funds from the HAP Set-aside (if available after PHA application and approval) and Unrestricted Net Assets (UNA – commonly referred to as administrative fee reserves). Use of these sources of funds (other than current year admin fees) are acceptable in order to maintain current leasing, increase leasing, and/or covering increased HAP costs under the HCV program. (The use of current administrative fees may only be used for administrative expenses and may not be used to cover HAP costs until the PHA fiscal year end, when unused administrative fees roll into the administrative fee reserve.) For PHAs participating in the Moving to Work initiative, fungible Public Housing Operating and Capital funds are also acceptable sources of funds to cover eligible HAP expenses in the HCV program. Note also that certain categories of Set- aside funding, such as funding to prevent terminations of families due to insufficient funding, may not be used to place new families under lease in the HCV program. PHAs with any questions regarding the eligible uses of Set-aside funding should contact their financial analyst at the Financial Management Center (FMC) for assistance.
Exhibit 2g
4. Prohibited Augmentation of HCV Funds from Outside Sources of Funds to Expand the HCV Program. No other funds, other than the sources of funds identified in Paragraph 2 above, may be used to expand the HCV program through additional leasing of units, either to lease up to baseline, maintain current leasing levels, or to otherwise mitigate the loss of leased units through attrition necessitated by funding limitations. The following sources of funds are examples of prohibited sources of funds which cannot be used to admit new families under the HCV program: HOME funds, net proceeds from Public Housing demo/dispo, Central Office Cost Center (COCC) funds, State funds, donations from philanthropic parties, and Mod Rehab admin fee reserves emanating from the Housing Certificate Fund. The use of these outside sources of funds for additional leasing of vouchers is prohibited; therefore, PHAs may not report the leasing and costs covered by the prohibited sources in VMS since they cannot be included in the calculation of renewal funding in the subsequent calendar year (CY). PHAs which have funds from outside sources may use those funds to operate a separate and distinct local rental assistance program; however, units leased under that program are not part of the federally funded HCV program and are not eligible for HCV renewal funds or administrative fees. Should a PHA use these types funds to operate a separate and distinct rental assistance program, the leasing and costs associated with these funds may not be reported in the Voucher Management System (VMS).
5. Exception Regarding the Augmentation of HCV funds from Outside Sources of Funds to Prevent the Termination of Assistance of Current Participants. There is one exception for use of outside sources to augment the HCV program. The exception is for PHAs that, despite taking reasonable cost-saving measures, are in a HUD-confirmed shortfall position and need additional funds in order to prevent the termination of current participants. In this instance, PHAs may use outside sources of funds such as net proceeds from Public Housing demo/dispo, Central Office Cost Center (COCC) funds, State funds, donations from philanthropic parties, and Mod Rehab admin fee reserves emanating from the Housing Certificate Fund. Prior HUD approval is required before PHAs may supplement the HCV program with these, or any other, sources of funds. PHAs would then report the leasing and costs covered by these sources in VMS which would then be included in the calculation of renewal funds in the subsequent calendar year.
HOME funds may not, in any instance, be used to augment funds for the HCV program. It is noted, however, that HCV participants whose voucher HAP contracts are being terminated due to insufficient funding could be assisted under the HOME TBRA program. These families could then be provided a local preference to return to the HCV program once funds are available under the HCV program to support the HAP payments of these participants.
6. Confirmation of a Shortfall by HUD: Before determining if a PHA may use an outside source of funds to cover a shortfall in the HCV program, HUD must confirm if a shortfall exists. In determining the shortfall, HUD will use the Two Year Forecasting Tool. PHAs should refer to Appendix B of Notice PIH 2013-12 which provides the criteria HUD will use to determine if the PHA has a HUD-confirmed shortfall and the calculation of the shortfall amount. HUD’s Two Year Forecasting Tool can be found at http://portal.hud.gov/huddoc/FORECASTING_TOOL_v2.XLS and the instructions can be found at http://portal.hud.gov/huddoc/forecast_guidance.pdf.
7. HUD Approval Required Before Use of Outside Sources of Funds to Prevent the Termination of Current Participants. As indicated above, prior HUD approval is required before PHAs may supplement the HCV program with any outside sources of funds to avoid the termination of current HCV participants. PHAs seeking approval for the use of such funds must submit a written request to the Office of Housing Voucher Program’s Financial Management Division (FMD). Requests should be submitted to the following email address: [email protected]. The subject line in the email should be “PHA Request to Use Outside Sources of Funds to Prevent Termination of Current Participants”. FMD will confirm with the Shortfall Prevention Team (SPT) that a shortfall exists, and once confirmed will issue an approval. If the shortfall is not confirmed, the PHA will receive a notice of denial. It is important to emphasize that this outside funding may only be used to protect current participants from termination of assistance due to insufficient funding during the calendar year. For example, the PHA may not use the outside sources to place additional families onto the program or enter into new project-based voucher contracts, or to free up HCV resources that would then be used to place additional families onto the program. PHAs approved for use of outside sources of funds will enter the amount of these funds and the total units covered by the funds in the comments section in the Voucher Management System (VMS).
Paperwork Reduction Act.
The additional information collection requirements contained in this document are approved by the Office of Management and Budget (OMB) under the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). The OMB control number is 2577-0169. In accordance with the Paperwork Reduction Act, HUD may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a currently valid OMB control number.
Further Information.
Any questions concerning this Notice should be directed to the Housing Voucher Financial Management Division, Office of Public Housing and Voucher Programs, at (202) 708-2934 (this is not a toll-free number). Persons with hearing or speech impairments may access these numbers via TTY by calling the toll-free Federal Information Relay Service at (800) 877-8339. __________________/s/__________________________
Sandra B. Henriquez, Assistant Secretary
for Public and Indian Housing