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1. Second Amendment to the FY 2021-2022 Annual Action Plan

Anaheim City Council
March 7, 2023

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1. Second Amendment to the FY 2021-2022 Annual Action Plan
Meeting
March 7, 2023
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Anaheim City Council
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CITY OF ANAHEIM

HOME-AMERICAN RESCUE PLAN (ARP)

ALLOCATION PLAN
FY 2021/22

CITY OF ANAHEIM

COMMUNITY AND ECONOMIC DEVELOPMENT
200 SOUTH ANAHEIM BOULEVARD
SUITE 1003
ANAHEIM, CA 92805

CITY OF ANAHEIM
FY 2021/22 HOME-ARP ALLOCATION PLAN

TABLE OF CONTENTS
Consultation .................................................................................................. 1 Public Participation ........................................................................................ 6 Needs Assessment and Gap Analysis .............................................................. 7 Proposed HOME-ARP Activities .................................................................... 19 HOME-ARP Production Housing Goals ......................................................... 21 Preferences, Limitations & Methods of Prioritization ................................... 22 HOME-ARP Refinancing Guidelines .............................................................. 24

APPENDIX

HOME-ARP CERTIFICATIONS
SF424 APPLICATION FOR FEDERAL ASSISTANCE
SF424-B ASSURANCES – NON-CONSTRUCTION PROGRAMS
SF424-D ASSURANCES – CONSTRUCTION PROGRAMS

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City of Anaheim HOME-ARP Allocation Plan

CITY OF ANAHEIM
HOME-ARP Allocation Plan

CONSULTATION
Before developing its plan, a PJ must consult with the CoC(s) serving the jurisdiction’s geographic area, homeless and domestic violence service providers, veterans’ groups, public housing agencies (PHAs), public agencies that address the needs of the qualifying populations, and public or private organizations that address fair housing, civil rights, and the needs of persons with disabilities, at a minimum. State PJs are not r equired to consult with every PHA or CoC within the state’s boundaries; however, local PJs must consult with all PHAs (including statewide or regional PHAs) and CoCs serving the jurisdiction.

Summarize the consultation process:

Consultation played a vital role in the development of this HOME-ARP Allocation Plan. To develop this Plan, the City of Anaheim launched an in -depth and collaborative effort to consult with the local Orange County Continuum of Care, City Departments, the Anaheim Public Housing Agency, and several non-profit agencies that serve homeless, at risk of homelessness, seniors, victims of domestic violence, and other qualifying population groups. Consultation included both a county- wide and personal consultation me eting with the Orange County Health Care Agency, Office of Care Coordination (CoC) and distribution over a two-month period in the Fall of 2021 of Provider Surveys that collected information on service needs among the qualifying population groups.

List the organizations consulted, and summarize the feedback received from these entities.

Agency/Organization
Consulted
Type of Agency /
Organization Method of Consultation Feedback
Orange County
Health Care Agency,
Office of Care
Coordination
Continuum of Care Countywide Grantee Meeting on
November 17, 2021 and
Anaheim-only consultation
meeting on December 2, 2021
Office of Care Coordination
staff provided overview of
HOME-ARP eligible activities
and CoC consultation,
including PIT, HIC, and HM IS
data.

Veterans Legal
Institute
Pro Bono Legal Aid Provider Survey Agency provides
approximately 100 homeless,
veterans, elderly, persons with
disabilities, and low -income
households with free legal aid.

Agency responded that all
affordable housing options and
services are a significant need
in Anaheim.
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City of Anaheim HOME-ARP Allocation Plan
Agency/Organization
Consulted
Type of Agency /
Organization Method of Consultation Feedback
StandUp for Kids Supportive Service
Provider
Provider Survey Agency assists homeless youth
characterized as either
Transitional Aged Youth (TAY)
or McKinney Vento. Agency
reported affordable rental
housing, various housing
services, life skills training,
street outreach services, case
management, credit repair,
and transitional or bridge
housing as the most significant
needs in Anaheim.

Lutheran Social
Services of Southern
California
Supportive Service
Provider
Provider Survey Agency works with all
segments of the qualifying
populations. Of most
significant need are all
affordable housing options,
employment training,
education services, mental
health services, street
outreach, landlord/tenant
liaison services, case
management, services for
victims of domestic violence,
seniors, Veterans, and women
with children.

Dayle McIntosh
Center
Supportive Service
Provider
Provider Survey and participated
in CoC consultation meeting
Agency serves all segments of
the qualifying populations and
finds the greatest need is for
affordable rental housing,
TBRA, PSH, employment
assistance and training,
housing services, emergency
shelters, transportation, case
management, TAY services,
rapid re-housing and homeless
prevention, transitional and
bridge housing.

Mercy House Developer/Owner
of Affordable
Housing, TBRA
Operator,
Supportive Services
Provider, &
Emergency Shelter
Provider Survey and participated
in CoC consultation meeting
Agency provides a variety of
housing options and services to
homeless, Veterans, elderly,
persons with disabilities, and
low-income households.

Agency indicated a significant
need for various housing
options (rental, TBRA, etc.), as
well as food, housing, mental
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City of Anaheim HOME-ARP Allocation Plan
Agency/Organization
Consulted
Type of Agency /
Organization Method of Consultation Feedback
health, life skills,
landlord/tenant liaison,
substance abuse,
transportation, case
management, credit repair,
and homeless prevention
services.

HIS OC Supportive Service
Provider
Provider Survey and participated
in CoC consultation meeting
Agency serves homeless,
transitional aged youth, and
low-income families. Areas of
significant need include
affordable housing and
housing assistance,
landlord/tenant liaison,
emergency shelters, rapid re -
housing and homeless
prevention, transitional and
bridge housing, and
senior/Veteran services.

Fair Housing Council
of Orange County
Fair Housing Provider Survey Agency assists nearly 1,000 Anaheim low- and moderate -
income residents per year .

Agency sees a need for various
affordable housing programs,
and a need for supportive
services in the areas of
housing, legal, mental health,
substance abuse treatment,
transitional aged youth, and
homeless prevention.

Grandma’s House of
Hope
Supportive Service
Provider,
Emergency Shelter
and Transitional
Housing Provider
Provider Survey Grandma’s House of Hope
provides over 4,000 homeless,
victims of domestic violence,
Veteran, elderly, disabled, and
low-income households with
services each year. They see a
need for all housing options,
and services such as food,
housing, mental health, l ife
skills, outpatient health, street
outreach, substance abuse,
transportation, case
management, transitional
aged youth, domestic violence,
homeless prevention, senior,
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City of Anaheim HOME-ARP Allocation Plan
Agency/Organization
Consulted
Type of Agency /
Organization Method of Consultation Feedback
Veterans, and women services
for the qualifying populations.

Big Brothers Big
Sisters of Orange
County
Youth Mentorship
Agency
Provider Survey Agency serves 340 homeless,
victims of domestic violence,
and transitional age youth with
youth mentorship services
each year and sees a significant
need for all affordable housing
programs (rental, tenant based
rental assistance,
bridge/transitional, rapi d re -
housing), education services,
employment assistance/job
training, mental health
services, life skills training,
street outreach services,
additional emergency shelters,
translation services,
senior/Veteran services, and
services of women, infants and
children.

Interval House Emergency Shelter
Operator
Provider Survey Assists homeless, victims of
domestic violence, and low -
income families with tenant
based rental assistance and
also operates local emergency
shelters that offer wrap around
services. Si gnificant need for
affordable housing options,
employment assistance/job
training, food, housing
services, case management,
and rapid re -
housing/homeless prevention.

Various Agencies Supportive Service
Provider
CoC meeting with Anaheim to
discuss plans for HOME-ARP
projects
On December 2, 2021, the
following agencies attended
the one -on-one consultation
meeting between the City of
Anaheim and the Orange
County CoC to go over
Anaheim’s proposed HOME -
ARP projects. There was no
rejection to Anaheim’s plan.
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City of Anaheim HOME-ARP Allocation Plan
Agency/Organization
Consulted
Type of Agency /
Organization Method of Consultation Feedback
The following agencies were in
attendance:
• Illumination Foundation
(homeless housing and
services)
• Family Assistance Ministries
(all qualifying populations,
food, housing and other
supportive services)
• Jamboree Housing
(developer of affordable
rental housing)
• Pathways of Hope (food,
shelter, and housing to
homeless and at risk of
homelessness)
• Orange County Community
Resources (housing and
community development)
• Community Action
Partnership Orange County
(homeless, at risk of
homelessness, job and
educational services,
advocacy for racial equity
services)
• South County Outreach
(homeless prevention, rapid
re-housing, rental and utility
assistance, food, and
educational programs)
• Saddleback Church
(Celebrate Recovery,
counseling, mental health,
support groups for all
qualifying populations)
• Orange County Health Care
Agency (homeless, children
and family services)
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City of Anaheim HOME-ARP Allocation Plan

PUBLIC PARTICIPATION
PJs must provide for and encourage citizen participation in the development of the HOME -ARP allocation plan. Before submission of the plan, PJs must provide residents with reasonable notice and an opportunity to comment on the proposed HOME-ARP allocation plan of no less than 15 calendar days. The PJ must follow its ad opted requirements for “reasonable notice and an opportunity to comment” for plan amendments in its current citizen participation plan. In addition, PJs must hold at least one public hearing during the development of the HOME -ARP allocation plan and prior to submission.

For the purposes of HOME-ARP, PJs are required to make the following information available to the public:
• The amount of HOME-ARP the PJ will receive,
• The range of activities the PJ may undertake.

Describe the public participation process, including information about and the dates of the public comment period and public hearing(s) held during the development of the plan:
• Public comment period: start date – 02/13/2023 end date – 03/01/2023. • Public hearing: 03/01/2023.

The City of Anaheim provided several opportunities for the public to participate in the HOME- ARP planning process. The City held a public hearing with its Housing and Community Development Commission on March 1, 2023 where the HOME-ARP Allocation Plan was presented with no comment or objection. The City also published a public hearing notice in the Anaheim Bulletin on February 9, 2023 to notify the public of the Plan’s availability for review and comment from February 13, 2023 through March 1, 20 23, and also to invite interested persons to the public hearing to approve the Plan. Finally, the Plan was presented to the Anaheim City Council on March 7, 2023.

Describe any efforts to broaden public participation:

In an effort to broaden public participation in the development of the HOME-ARP Allocation Plan, the City followed citizen participation steps outlined in its Citizen Participation Plan which includes publishing a Public Notice for the Public Hearing in the City’s adjudicated newspaper. In the Public Notice, there is information made available for members of the public to request disability-related accessibility, translation services, and/or reasonable accommodations. The Plan was made available upon request at the front desk of the City’s Housing & Community Development Department at 201 S. Anaheim Blvd. Suite 1003 Anaheim, CA 92805 , Monday through Friday (except for legal holidays) from 8:00 a.m. to 4:00 p.m. Additionally, the Plan was also available for citizen review upon request during normal business hours at the City’s Central Library Circulation Desk at 500 W Broadway, Anaheim, CA 92805 as well as on the City’s website at https://www.anaheim.net/839/HUD-Programs .
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City of Anaheim HOME-ARP Allocation Plan
A PJ must consider any comments or views of residents received in writing, or orally at a public hearing, when preparing the HOME-ARP allocation plan.

Summarize the comments and recommendations received through the public participation process:

None received
Summarize any comments or recommendations not accepted and state the reasons why:

N/A, none received

NEEDS ASSESSMENT AND GAP ANALYSIS
PJs must evaluate the size and demographic composition of qualifying populations within its boundaries and assess the unmet needs of those populations. In addition, a PJ must identify any gaps within its current shelter and housing inventory as well as the service delivery system. A PJ should use current data, including point in time count, housing inventory count, or other data available through CoCs, and consultations with service providers to quantify the individuals and families in the qualifying populations and their need for additional housing, shelter, or services.

The PJ may use the optional tables provided below and/or attach additional data tables to this template.

OPTIONAL Homeless Needs Inventory and Gap Analysis Table Data Sources: 1. 2019 Point in Time Count (PIT); 2. Continuum of Care Housing Inventory Count (HIC); 3. Consultation Homeless
Current Inventory Homeless Population Gap Analysis
Family Adults Only Vets Family
HH (at
least 1
child)
Adult
HH
(w/o
child) Vets
Victims
of DV
Family Adults Only
# of
Beds
# of
Units
# of
Beds
# of
Units
# of
Beds
# of
Beds
# of
Units
# of
Beds
# of
Units
Emergency
Shelter 118 703
Transitional
Housing 9 62
Permanent
Supportive
Housing
441 368
Other Permanent
Housing
Sheltered
Homeless 79 429 25
Unsheltered
Homeless 69 625 33
Current Gap
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City of Anaheim HOME-ARP Allocation Plan
OPTIONAL Housing Needs Inventory and Gap Analysis Table Non-Homeless
Current Inventory Level of Need
# of Units # of Households
Total Rental Units 56,040
Rental Units Affordable to HH at 30% AMI
(At-Risk of Homelessness) 17,270
Rental Units Affordable to HH at 30% - 50%
AMI (Other Populations) 12,850
0%-30% AMI Renter HH w/ 1 or More
Severe Housing Problems
(At-Risk of Homelessness)
14,080
30%-50% AMI Renter HH w/ 1 or More
Severe Housing Problems
(Other Populations)
7,075
Data Sources: 1. 2021 American Community Survey (ACS); 2. 2015-2019 Comprehensive Housing Affordability Strategy (CHAS)
Describe the size and demographic composition of qualifying populations within the PJ’s boundaries:

HOMELESS
The U.S. Department of Housing and Urban Development (HUD) requires that all Contin uum of Care jurisdictions across the country complete a biennial unsheltered count and an annual sheltered count of all individuals experiencing homelessness in the community on a single point in time during the last ten days of January. Orange County’s 20 19 Sheltered Point in Time (PIT) Count took place the night of Tuesday, January 22, 2019, with client -level demographic information collected from all emergency shelter and transitional housing programs throughout the County. The 2019 Unsheltered PIT Count took place over two days, Wednesday January 23 and Thursday January 24, to ensure the 800 square mile county jurisdiction was canvassed effectively. Because of an improved PIT process, methodology and data quality from the use of GIS technology, the resul ts of the 2019 PIT reflect the most accurate count of Orange County’s homeless population ever. It is important to note that the new PIT Count goes beyond just the physical counting of persons experiencing homeless ness and, in some instances, uses a formula to extrapolate the total number of homeless present. Also important to note is that there was a more recent count performed in February 2022; however, the Point in Time Summary for 2022 did not contain some key stati stical data found in the 2019 Point in Time Summary Report.

Therefore, the City of Anaheim will be relying on 2019 counts for this HOME-ARP Allocation Plan.

Where data is available for 2022, those figures will be provided in parentheses and italics in the analysis below.
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City of Anaheim HOME-ARP Allocation Plan
The January 2019 PIT count enumerated 1,202 homeless individuals in the City of Anaheim (1,074 in 2022). Among the 1,202 homeless counted, 508 (42%) were in some kind of emergency or transitional shelter, while the remaining 694 were found to live in places not designed for or ordinarily used as a regular sleeping accommodation for human beings, including a car, park, abandoned building, bus or train station, airport, or camping ground (508 sheltered and 694 unsheltered in 2022). Most of the homeless counted, 1,054 (88%), were individuals, whereas 148 (12%) were part of a family. Homeless persons characterized as “transitional age youth” (18 -24 years old) made up 3.4% (41 persons) of the homeless count in Anaheim. There were also 9 9 seniors and 58 veterans among the 1,202 total homeless persons counted as part of the 2019 PIT count.

The 2019 PIT Report did not include specific demographic composition data for Anaheim’s homeless population; however, Anaheim is one of 14 city’s that make up the North Service Planning Area (SPA). The 2019 PIT reported 2,765 homeless persons in the North SPA which is made up of 71% White, 10% that identified with Multiple or Other Races, and 8% Black or African American persons. Additionally, 35% of al l homeless persons in this count reported being of Hispanic ethnicity.

AT RISK OF HOMELESSNESS
To account for persons at‐risk of becoming homeless, the most recent (20 15-2019) Comprehensive Housing Affordability Strategy (CHAS) data was analyzed. This da ta contains three particular characteristics of households that meets the definition of “at risk of homelessness” found in 24 CFR Part 91.5. First, the CHAS data breaks down occupied housing units by HUD Area Median Family Income (HAMFI), including 30% and below of HAMFI. Next, the CHAS data provides information on occupied housing units with households that are severely cost burdened; that is, they are spending more than 50% of their income on housing related expenses. For renters, that includes rent and utilities. For homeowners, it includes the mortgage payment, utilities, association fees, insurance, and real estate taxes. And finally, the CHAS data contains information on housing units in which there reside more than 1.5 people per room , which is considered to be severely over-crowded.

The CHAS data shows that of the 56,040 renter households in the city of Anaheim, 17,270 or 31% are occupied by households earning 30% or less of the HAMFI. Further, of these households, 91% (15,660) have one or mor e housing problems, defined as housing units that: 1) lack complete kitchen facilities; 2) lack complete plumbing facilities; 3) are over overcrowded; and 4) are cost burdened. A household is said to have a housing problem if they have any one or more of these four problems. The CHAS data shows that Hispanics make up an overwhelming share of households that meet both criteria (earn 30% or less of HAMFI and have one or more housing problems) at 57%, with White households ranked second at 2 2%, and Asian households third at 15%. Black or African American households constitute 4% of these households.

With regard to age, 30% of households earning less than 30% of the HAMFI and with one or more housing problems are seniors (62+ years of age). This c ategory of seniors have a higher risk of 10 | P a g e
City of Anaheim HOME-ARP Allocation Plan
homelessness due to the ever increasing cost of living in California (rising housing, utilities, food, and gas prices) while at the same time living on fixed incomes.

Finally, the CHAS data revealed that of the 17,270 households earning less than 30% HAMFI, 75% are severely cost -burdened, and 1 6% are severely overcrowded. Severely cost burdened households are spending more than 50% of their income on housing related expenses, leaving the remaining 50% or less of their income available for other daily necessities such as food, gas, child and healthcare. Together, th ese make up 8,900 households that specifically meet the definition of “at risk of homelessness” at 24 CFR Part 91.5.

Renter-Occupied Housing Units with Households Earning <= 30% HAMFI 17,270 One or More Housing Problems* 15,660 91%
Race/Ethnicity White 3,425 22%
Black or African American 610 4%
Asian 2,305 15%
American Indian or Alaska Native 45 < 1%
Pacific Islander 45 < 1%
Other Race/Multiple Races 340 2%
Hispanic 8,890 57%
Age Non-Elderly 10,945 70%
62-74 Years Old 2,970 19%
75+ Years Old 1,745 11%
Housing
Problem Households with No Kitchen or Plumbing Facilities 625 4% Households with 1.5+ Persons per Room 1,840 12%
Households with 1 – 1.5 Persons per Room 2,735 17%
Households Over 50% Cost Burdened 8,880 57%
Households 30-50% Cost Burdened 1,585 10%
* 1) lack complete kitchen facilities; 2) lack complete plumbing facilities; 3) are over overcrowded; and 4) are cost burdened

FLEEING, OR ATTEMPTING TO FLEE, DOMESTIC VIOLENCE, DATING VIOLENCE, SEXUAL ASSAULT,

STALKING, OR HUMAN TRAFFICKING
The City has seen a n increase in domestic violence‐related calls for assistance to the Anaheim Police Department. From 2011-2015, there was an average of 1,214 domestic violence‐related calls per yea r while the most recent data ( 2016-2020) shows an average of 1,374 domestic violence‐related calls per year (State of California Department of Justice, http://oag.ca.gov/crime/cjsc/stats/domestic‐violence ).

The 2019 Orange County Point in Time count reported 29 households living in units designated for victims of domestic violence in the North SPA which includes the city of Anaheim. Of the 29 households, four were one -person households and the remaining 25 we re households with children. The 2022 Orange County Housing Inventory Count shows one housing project , The Eli Home Children of Addicts Recovery (CARP) Program, dedicated to victims of domestic violence with 18 year-round beds. The Program provides housing and extensive case managed program 11 | P a g e
City of Anaheim HOME-ARP Allocation Plan
services to homeless children and their mothers with substance use disorders (SUDS). Services include a support system, sobriety assistance, legal assistance, vocational training and assistance, individual and group counseling, and referral of services and resources.

OTHER POPULATIONS
Other Families Requiring Services or Housing Assistance to Prevent Homelessness:

As discussed above, the 2019 Point in Time Count reported 508 sheltered individuals in the city of Anaheim (589 in 2022). Of these, 429 or 84%, were individuals and 79 were part of a family unit. Additionally, of the 508 sheltered homeless, 17 were considered transitional age youth (18- 24 years old), 60 were seniors, and 25 were veterans. Race and ethnicity data was not available for these homeless subpopulations. All 508 persons were previously qualified as “homeless” as defined under 24 CFR Part 91.5 before entering temporary or emergency shelter. The fact that they reside in temporary or emergency shelter, undoubtedly makes them more vulnerable to entering homelessness again if services and/or housing assistance is terminated.

At Greatest Risk of Housing Instability
Persons at greatest risk of housing instability are those that: 1) are earning 30% or below the HAMFI and are severely cost-burdened (paying 50% or more on housing); or 2) are earning 50% or less of HAMFI and meet one of the following conditions:

1. Has moved 2 or more times in the 2-months immediately preceding their application for homelessness prevention assistance.

2. Is living in the home of another because of economic hardship.

3. Has been formally notified of eviction within 21 days after the date of applicat ion for assistance.

4. Lives in a hotel or motel and the cost of staying at the hotel or motel is not borne by a Federal, State, or local government program.

5. Lives in an over-crowded (more than 1 person per room) single-room occupancy (SRO) or efficiency apartment units, or lives in a severely overcrowded (more than 1.5 persons per room) larger housing unit.

6. Is exiting a publicly funded institution, or system of care (health care facility, mental health facility, foster care or other youth facility, or correction program or institution).

7. Otherwise lives in housing that has characteristics associated with instability and an increased risk of homelessness, as identified in the recipient’s approved Consolidated Plan.

For the first group of persons/households at greatest risk of instability, that is, they earn less than or equal to 30% of HAMFI and are severely cost-burdened, the 2015-2019 CHAS data reports that there are 15,450 households that meet this criterion. Of these, 83% or 12,900 are households that rent, making them more vulnerable to housing instability and homelessness.

Information on each of the conditions listed above for the second category of persons at greatest risk of housing instability is not readily available, with the exception of data on overcrowding.

The 2015-2019 CHAS data described 5,635 households earning 50% or less of HAMFI living in 12 | P a g e
City of Anaheim HOME-ARP Allocation Plan
overcrowded conditions, 9 0% of which were renter households. Worse, the data showed an additional 3,430 households experiencing severe overcrowding, and 94% of them were renters.

VETERANS AND FAMILIES THAT INCLUDE A VETERAN FAMILY MEMBER According to the 2021 American Community Survey (ACS), Anaheim currently has a population of 8,254 veterans in the city. This is made up of 7,736 males, and 518 females. The number of veterans that are homeless make up less than 1% (58 persons) of the veteran population, pursuant to the 2019 Point in Time Count. Of this, 57% were unsheltered and 43% were sheltered. Review of the 2021 Orange County Housing Inventory Count found that no units available specifically to veterans exist in Anaheim.

Describe the unmet housing and service needs of qualifying populations, including but not limited to: Sheltered and unsheltered homeless populations; Those currently housed populations at risk of homelessness; Other families requiring services or housing a ssistance or to prevent homelessness; and Those at greatest risk of housing instability or in unstable housing situations:

According to the U.S. Department of Health & Human Services, “…poverty, unemployment, and lack of affordable housing are commonly r ecognized causes of homelessness. These risk factors can be exacerbated by personal vulnerabilities such as mental and substance use disorders, trauma and violence , domestic violence, justice-system involvement, sudden serious illness, divorce, death of a partner, and disa bilities.” The City of Anaheim is no exception to this finding. As the number of homeless persons in Anaheim continues to increase, so does the need for additional affordable housing and supportive services aimed to move them out of homelessness and housing instability.

As reported in the 2019 Point in Time Count, Anaheim is home to over 500 homeless people experiencing homelessness with shelter (589 in 2022 ), and another almost 700 people experiencing homelessness without shelter (485 in 2022 ). Further, according to the 2015-2019 Comprehensive Housing Affordability Strategy (“CHAS”), of the 5 6,040 renter households in the City, 42% (23,550 households) are paying the normal or expected 30% or below of their income on housing related expenses; howe ver, that means that the remaining 58% of all renter households are experiencing some level of cost burden. The cost burdens are more serious for households with the lowest incomes (at or below 30% of Area Median Income), with 27% (15,225 households) cost burdened (paying more than 30% of their income toward rent) and 23% severely cost burdened (paying more than 50% of their income toward rent) making them more at risk of homelessness . These significant housing cost burdens affect thousands of Anaheim residents, and it is critical that Anaheim continue developing new affordable housing for people with the lowest incomes in the community.

According to the 2021 Orange County Housing Inventory Count, t he City of Anaheim has 568 family beds and 1,133 adult -only beds, for a total of 1,701 beds within the city. While it would appear that Anaheim has sufficient bed capacity to meet the shelter needs of the City’s homeless population, it should be noted that nearly half of these beds (48%) are in emergency homeless 13 | P a g e
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shelters. Emergency shelters are often used for short -term solutions to homelessness and are offered with a variety of services to navigate the needs and plans of its clientele. However, emergency shelters are not the f inal solution for longer -term housing stability. The emergency shelters also do not exclusively serve Anaheim residents; they are open and available to any homeless person regardless of residency.

Ultimately, what this means is that there is a shortage o f affordable and long-term housing options for those that are homeless or at risk of homelessness in Anaheim. Despite the 880 beds in transitional and permanent supportive housing, there remains 727 unsheltered homeless individuals, and nearly 13,000 renter households earning below 30% HAMFI that are severely cost burdened making them at risk of homelessness.

With regard to needed services, The PIT report for Orange County (information not available for Anaheim only) describes homeless persons as:
• 36% chronically homeless
• 26% with substance abuse issues
• 21% with a physical disability
• 24% with mental health disorders
• 9% with developmental disabilities
• 8% are victims of domestic violence
With a variety of issues afflicting and often contributing to homelessness, as seen above, services to support the homeless is crucial for longstanding success. Case management and other housing and shelter programs can help address the root causes of homelessness through a range of essential support services, including childcare, mental and substance abuse treatments, domestic violence advocacy, employment training, and other wrap around services. As was learned from the consultation process, many of these services are already being carried out at local emergency shelters and other housing sites for homeless persons.

Referring once again to the U.S. Department of Health & Human Services website, it is reported that “research suggests that intervention services to prevent homelessness is more cost effective than addressing issues after someone is already homeless. The longer a person is homeless, the harder and more expensive it becomes to re -house this person.” In tha t vein, services such as rapid re-housing, providing food support, childcare, benefits advocacy, Veteran’s services, rental and/or utility assistance, security deposit assistance, and trauma or domestic violence support systems, can be very beneficial to prevent homelessness in the first place.

Identify and consider the current resources available to assist qualifying populations, including congregate and non -congregate shelter units, supportive services, TBRA, and affordable and permanent supportive rental housing:

The City of Anaheim is a recipient of the annual Community Development Block Grant (CDBG), Home Investment Partnership Act Program (HOME), Emergency Solutions Grants Program (ESG), 14 | P a g e
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and the Housing Opportunities for Persons with Aids Program (HOPWA). Together, the City receives approximately $9.1 million from these entitlement programs to address affordable housing and low- and moderate -income community development needs, homelessness, and housing for persons living with Aids/HIV. Additionally, the City received special allocations of CDBG, ESG, and HOPWA in 2019 as a response to the COVID -19 pandemic in the sum of nearly $17.5 million.

Anaheim uses it’s federal funding on a variety of projects and programs that serve the qualifying populations already. For example, ESG funds are being used to fund emergency shelters for 310 homeless persons and to provide needed goods such as PPE, furnishings, bed linens, soap, portable showers, and other necessary items. ESG is also used for rap id re-housing, homeless prevention, and street outreach services.

HOME and HOPWA funds are currently being used to provide tenant based rental assistance to approximately 155 total households that would likely enter homelessness but for the financial assistance they are receiving from the City.

The CDBG program funds several supportive services for qualifying populations, as well. Anaheim is currently funding Access California Services’ (AccessCal) which assists with health coverage access, mental health services, employment services, client advocacy, educational classes including after -school program and parenting classe s, emergency financial assistance, microenterprise classes, and immigration and citizenship assistance. Meals on Wheels Orange County also receives CDBG funding to carry out a home -delivered meals program to seniors in Anaheim. The Boys & Girls Club of Ana heim is also a recipient of CDBG funding and assists low- income and homeless children by offering free food, educational assistance, and after school care. Finally, CDBG assists the City’s Veteran population by funding organizations such the Veterans Legal Institute. The Veterans Legal Institute helps to increase self -sufficiency for homeless, disabled, and/or low -income Veterans through strategic and free legal aid services.

Other resources available to Veterans regionally include peer career counseling via the Goodwill of Orange County’s Tierney Center for Veteran Services; employment training and assistance through Chrysalis Enterprises and the Veteran’s Employment -Related Assistance Program (VEAP); and homeless or at risk of homelessness services offered by the Veteran Housing Resource Fairs.

The Anaheim Housing Authority (AHA) administers federally funded programs and grants allocated by the Department of Housing and Urban Development (HUD) in the City of Anaheim.

The Housing Choice Voucher (HCV) progr am offers two housing options: tenant -based and project-based. The tenant-based program allows assisted households to use a rental assistance voucher in open rental market units. And the project -based program ties a voucher to a specific unit in which an assisted household can move into.

The Tenant-Based Housing Choice Vouchers Program has a waiting list that is currently open only to individuals who qualify for the mainstream preference. To qualify for the mainstream preference, a household member must sat isfy all three eligibility criteria: (1) must be between 15 | P a g e
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18 to 61 years old, (2) must be disabled, and (3) must currently be homeless or transitioning out of an institutional or other segregated setting and have nowhere else to go. The Project-Based Housing Choice Voucher Program, on the other hand, offers a variety of housing options at specific housing locations. Some buildings are intended for families, while others are age restricted, intended for seniors only. The AHA also offers a number of PBV locations that provide amenities and/or services specifically for persons with disabilities. The City of Anaheim has a total of 5,497 households receiving Housing Choice Vouchers, and another 166 households who have been approved for Housing Choice Vouchers and are currently looking for units.

The City of Anaheim also has an Affordable Housing Program consisting of multifamily apartment complexes throughout the City that include affordable units. The City has agreements with the owners of these units to maintain rents at levels below regular market rent rates. Interest lists are open and potential tenants are notified when availability occurs . Potential tenants must live and/or work in Anaheim and meet income requirements to be eligible. Anaheim currently has a portfolio of 3,850 affordable housing units in the City , including 2,510 family , 1,234 senior, and 106 special needs units.

Affordable and permanent supportive housing developments in Anaheim have long wait lists for entry. The Orange County Coordinated Entry generally assesses thousands of people each year, and offers housing to a small fraction. With over 1,202 people experiencing homelessness and tens of thousands of cost burdened renters in Anaheim, additional affordable and permanent supportive housing is desperately needed. The 2014 -2021 Regio nal Housing Needs Allocation (RHNA) for the City of Anaheim echoes this sentiment. The RHNA reports that the City of Anaheim has a total housing need of 17,453 units. From this allocation, the RHNA designates:
• 3,767 units for very low -income families, with incomes at or below 50% of Average Median Income (AMI)
• 2,397 units for low-income families with an AMI ranging from 51% to 80%. • 2,945 units for moderate-income families with an AMI ranging from 81% to 120%. • 8,344 units for above moderate-income families with an AMI above 120% Anaheim is also home to the Anaheim Emergency Shelter located at 1455 S. Salvation Plan. This congregate site is operated by the Sal vation Army using City of Anaheim and state funding and was recently expanded in 2020 to increase capacity to 325 beds. Additionally, Anaheim utilizes ESG funding to partner with various subrecipients to offer emergency family beds throughout the City.

Identify any gaps within the current shelter and housing inventory as well as the service delivery system:

As presented earlier in this Plan, the number of individuals and families that meet the criteria of a qualifying population under the HOME-ARP guidance far exceeds the number of available units to house them. The City has 1,202 homeless individuals when last counted in 2019 (1,074 in 2022), 694 that are unsheltered (485 in 2022 ) and 508 that are sheltered (589 in 2022 ) and 16 | P a g e
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presumably sharing bed-availability at the local emergency shelters with homeless persons from neighboring cities. The number of homeless reveals the need for additional housing units, along with the services to support them. Moreover, the thousands of renter households that are both living in poverty and are severely cost burdened or severely overcrowded are indications of the serious deficit of homes affordable and available to the qualified populations. This h ousing shortage in Anaheim demonstrated above by the CHAS and RHNA data, shows the dire need for additional Permanent Supportive Housing and non-congregate shelter options, including through opportunistic acquisitions of existing multifamily buildings, hotels, and motels.

Anaheim passed out 40 Provider Surveys to local service agencies that provide a variety of services ranging from homeless services, legal aid, affordable housing, and tenant based rental assistance to name a few. Ten agencies responded to the survey. As seen in the table below, affordable rental housing and transitional/bridge housing ranked first among all of the services and programs listed on the survey with 100% of respondents identifying this as a significant need among their clientel e. Tenant based rental assistance, housing related services, and rapid re - housing/homeless prevention services ranked second in most significant needs in Anaheim.

Emergency shelters, permanent supportive housing, and case management round out the next two most significant needs as seen by the respondents.
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Services Determined to be of Significant Need
Rank Service
1 (100%)
Affordable Rental Housing
Transitional/Bridge Housing
2 (90%)
Tenant Based Renal Assistance
Housing-Related Services (housing search, security deposits, utility assistance, moving costs, first and last month’s rent)
Rapid Re-Housing/Homeless Prevention
3 (80%) Emergency Shelter
4 (70%)
Permanent Supportive Housing
Case Management
5 (60%)
Mental Health Services
Street Outreach Services
Transitional Age Youth Services
6 (50%)
Employment Assistance/Job Training/Career Counseling
Food
Life Skills Training
Landlord/Tenant Liaison
Services for Victims of Domestic Violence/Dating Violence/Sexual Assault/Human Trafficking 7 (40%)
Substance Abuse Treatment Services
Transportation
Senior/Veteran Services
Women, Infant, & Children Services
8 (30%)
Education Services
Credit Repair
9 (20%)
Legal Services
Outpatient Health Services
Translation Services
10 (10%) Mediation
Identify the characteristics of housing associated with instability and an increased risk of homelessness if the PJ will include such conditions in its definition of “other populations” as established in the HOME-ARP Notice:

Housing associated with instability and an increased risk of homelessness are those that 1) are occupied by persons earning 30% or below the HAMFI and are severely cost-burdened (paying 50% or more on housing); or 2) inhabit persons that are earning 50% or less of HAMFI and are severely overcrowded (living with 1.5 or more persons per room). Households meeting these definitions tend to live in housing with deferred maintenance and are in need of rehabilitation.

Identify priority needs for qualifying populations:

Without a doubt, analysis of the 2019 and 2022 Point in Time Count s, CHAS data , American Community Survey data, and consultation with the various agencies conducted as part of this Plan reveal the need for more affordable housing and housing -related supportive services. 18 | P a g e
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People without homes, need homes. The high and rapidly escalating housing costs combined with the COVID-19 pandemic and economic displacement in Orange County creates harmful instability for the qualified populations. It is difficult for members of the qualified populations to find affordable housing of any kind in Anaheim. Personal needs and challenges become exponentially worse if you are in poverty, or worse , homeless. Investing in permanent supportive housing allows services to be accessed and for individuals to begin to recover.

Explain how the level of need and gaps in its shelter and housing inventory and service delivery systems based on the data presented in the plan were determined:

The City of Anaheim analyzed several data sources to determine the needs and gaps in the City’s shelter and housing inventory and in the service delivery syste ms. First, the City extracted Anaheim-specific data from the 2019 and 2022 Orange County Point in Time Count s. The PIT ’s provided valuable data on the number of sheltered and unsheltered homeless, families and individual homeless persons, and transitional aged youth, senior, and Veteran homeless persons.

Further, data on the number of homeless persons fleeing domestic viole nce was provided on a County-wide basis.

Next, the City accessed data from the Comprehensive Housing Affordability Strategy (“CHAS”).

CHAS data is provided annually from the U.S. Department of Housing and Urban Development (HUD) and includes custom tabulations of American Community Survey (ACS) data from the U.S.

Census. The data demonstrates the extent of housing problems and needs, particularly for low - income households. CHAS data was used by Anaheim to determine housing tenure by the various income leve ls, the number of households experiencing cost burden and /or overcrowded conditions, race and ethnicity statistics of extremely low -income households, and other data needed to characterize households at risk of homelessness.

Third, the City retrieved data from the City’s 2020-2024 Consolidated Plan, the Regional Housing Needs Allocation (RHNA), and the Orange County Housing Inventory Count to gather information on housing needs, current housing available in Anaheim, and current service programs offered with federal funding.

Finally, the City consulted with various stakeholders including the Orange County CoC, Mercy House, the Dayle McIntosh Center, Lutheran Social Services of Southern California, StandUp for Kids, Veterans Legal Institute, HIS OC , the F air Housing Council of Orange County, Grandma’s House of Hope, Big Brothers Big Sisters of Orange County, and Interval House to find out what they felt are the priority needs of their clientele (homeless persons, Veterans, elderly persons, persons with dis abilities, and victims of domestic violence ). The most pressing need is for affordable rental housing and transitional/bridge housing.

Overall, the City found that the highest need for the qualifying populations in Anaheim was for additional affordable housing with wrap -around supportive services. A decent and affordable place to live, coupled with supportive services, helps homeless and those at risk of homelessness 19 | P a g e
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by freeing them from such physical and mental hardships and placing them on a path of new opportunity and increased confidence and self-reliance.

PROPOSED HOME -ARP ACTIVITIES
Describe the method for soliciting applications for funding and/or selecting developers, service providers, subrecipients and/or contractors and whether the PJ will administer eligible activities directly:

The City of Anaheim will fund one or both affordable rental housing project s described below with HOME-ARP funds.

The Studio 6 Motel Project is a 119-unit conversion project located at 1251 N. Harbor Boulevard, Anaheim that will be developed in partnership with LINC Housing Corp. and American Family Housing. Linc was selected after a Request for Proposals was released on November 2, 2021 in response to the State of California’s Homekey NOFA. The developer was selected for their experience acquiring, rehabilitating, and operating affordable housing, including permanent supportive housing and temporary housing. American Family Housing w as selected to support residents, including case management, career help, and medical and mental health care. The project currently consists of interim housing for homeless, chronically homeless, and those at risk of homelessness. However, the City of Anaheim proposes to utilize HOME-ARP funding for Phase 2 of the project which entails converting the interim housing to permanent housing for homeless and chronically homeless individuals.

The City of Anaheim is also proposing to develop the Tampico Motel, a half-acre lot located at 120 S. State College Boulevard, Anaheim and was purchased with a direct state budget appropriation of $5.5 million by California State Senator Tom Umberg. The motel is currently in escrow with an estimated closing date of April 2023. The project will entail approximately 36 units and the City proposes to make them available to transitional age youth because of no housing currently exists for this homeless subpopulation. Other qualifying populations that will be assisted through this project could include seniors and homeless households.

If any portion of the PJ’s HOME -ARP administrative funds were provided to a subrecipient or contractor prior to HUD’s acce ptance of the HOME -ARP allocation plan because the subrecipient or contractor is responsible for the administration of the PJ’s entire HOME -ARP grant, identify the subrecipient or contractor and describe its role and responsibilities in administering all of the PJ’s HOME-ARP program:

Not applicable. The City of Anaheim does not intend to provide any subrecipients a portion of their HOME-ARP administrative funds.

PJs must indicate the amount of HOME -ARP funding that is planned for each eligible HOMEARP activity type and demonstrate that any planned funding for nonprofit organization operating 20 | P a g e
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assistance, nonprofit capacity building, and administrative costs is within HOME-ARP limits. The following table may be used to meet this requirement.

Use of HOME-ARP Funding
Proposed Funding
Amount
Percent of the
Grant
Statutory
Limit
Supportive Services $ 0
Acquisition and Development of Non-
Congregate Shelters $ 0
Tenant Based Rental Assistance (TBRA) $ 0
Development of Affordable Rental Housing $ 4,656,903
Non-Profit Operating $ 0 0 % 5%
Non-Profit Capacity Building $ 0 0 % 5%
Administration and Planning $ 820,000 14.97 % 15%
Total HOME ARP Allocation $ 5,476,903
Additional narrative, if applicable:

The City of Anaheim will fund one or both affordable rental development projects.

Studio 6 Motel : The City has acquired the Studio 6 Motel located at 1251 North Harbor Boulevard, Anaheim. The motel is an approximately 37,000 square foot, 3-story building with 118 units and one manager unit sitting on a 1.44 -acre site. The City is using the site as a temporary Non-Congregate Shelter (NCS) until the development team, consisting of LINC Housing, American Family Housing, and the City of Anaheim, can submit an application for tax-credit funding. When additional funding is secured, the NCS will be converted to permanent supportiv e housing and HOME-ARP funds will be used for needed rehabilitation to convert the property to permanent housing. Ultimately, the project will cost roughly $36 million to convert the motel to 114 PSH units, 89 of which will be available to the City’s homeless population (29 for chronically homeless, 60 for general homeless), and the remaining 25 will convert to general affordable housing units for low-income households. The units will remain affordable for 55 years.

Tampico Motel: The Tampico Motel is cur rently in escrow to be acquired in April 2023. The project, located at 120 S. State College Boulevard, currently consists of 32 rooms that sits on a half-acre lot. Once purchase of the property is complete, the City intends to release a Request for Proposals (RFP) to solicit plans for a developer to convert and rehabilitate the property to 36- units of affordable housing for primarily transitional aged youth, but possibly also to seniors and homeless persons.

Describe how the characteristics of the shelter and housing inventory, service delivery system, and the needs identified in the gap analysis provided a rationale for the plan to fund eligible activities:
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The City continues to make a considerable effort to increase its inventory of affordable housing units. However, the demand for the available units far outstrips the supply as shown in the tables above. Based on the Point in Time Count, there were 1,202 total homeless persons in Anaheim in 2019 (1,074 in 2022), 694 of them unsheltered (485 in 2022) despite the City’s, County’s, and non-profit industry’s efforts to house and provide needed support services to them. Additionally, there are nearly 13,000 renter households at risk of homelessness. They are reportedly making equal to or less than 30% HAMFI while at the same time, spending over 50% of their incomes on housing related expenses. The RHNA further indicates a need for 1,256 units for very low-income families, with incomes at or below 50% of Average Median Income (AMI).

New affordable housing developments typically take at least 3‐6 years from concept to occupancy. The state Homekey program requires project completion within 12 months of the funding award, which results in affordable units on an expedited timeline. The Studio 6 Motel Project currently provides additional housing units for homeless persons on an immediate basis, but will later utilize HOME-ARP to convert the non-congregate shelter units to permanent affordable rental housing within the next 3 years to homeless and chronically homeless persons.

Further, the Tampico Motel project will add another 36 (approximate) units of affordable rental housing to transitional aged youth for which no specific housing for this population group exists.

HOME -ARP PRODUCTION HOUSING GOALS
Estimate the number of affordable rental housing units for qualifying populations that the PJ will produce or support with its HOME-ARP allocation:

The Studio 6 project will convert 118 motel rooms into 114 permanent supportive housing units for 89 homeless/chronically homeless and 25 low-income households. All qualifying populations – homeless, at risk of homelessness, veterans, persons fleeing domestic violence, etc. – will be invited to apply for housing at this development site, with preference given to homeless or chronically homeless persons.

The Tampico Motel project will provide 36 units of permanent rental housing to homeless youth ages 18-24 (transitional aged youth). Transitional aged youth experiencing homelessness have unique needs. According to the City of Anaheim’s Homelessness Action Plan, this includes coupling services that affirm and foster the development of young people with housing that supports stability. The City was the first jurisdiction in Orange County to partner with and fund Covenant House, a TAY shelter, to provide immediate services to TAY. Covenant House works with StandUp For Kids, a n organization that launched in Orange County in 2003 with a single focus: to end the cycle of youth homelessness. The organization works to provide basic needs, housing, mentoring support, care, and love to at-risk and homeless youth. 22 | P a g e
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Describe the specific affordable rental housing production goal that the PJ hopes to achieve and describe how it will address the PJ’s priority needs:

The proposed Studio 6 Project will convert a total of 118 motel rooms into 114 units (89 for homeless and 25 for general affordable housing). The units will be restricted to formerly homeless households (or other qualifying populations) as long as they meet the definition of “homeless” as defined in 24 CFR Part 91.5 at the time of admission to the HOME-ARP unit. They will remain eligible to retain the HOME-ARP unit even if their income changes or if they no longer meet the definition of “homeless.” This criterion will be in effect for 55 years, ensuring the project will continue to serve qualifying households well beyond the affordability period required by HOME‐ARP.

The proposed Tampico Motel Project is in the process of being acquired . Once acquisition is complete in April 2023, the City will solicit prop osals from qualified developers to develop the site into approximately 36 units of affordable rental housing for primarily transitional aged youth (TAY). The same criterion as stated above will apply to the Tampico Motel Project, as well.

PREFERENCES , LIMITATIONS & METHODS OF PRIORITIZATION
Identify whether the PJ intends to give preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project:
• Preferences cannot violate any applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a). • PJ’s are not required to describe specific projects to which the preferences will apply.

The City of Anaheim intends to give a preference to homeless and chronically homeless persons at the Studio 6 Motel project. This could include any overlapping qualifying populations such as veterans, persons fleeing , or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking, and other populations at risk of homelessness or housing instability.

At the Tampico Motel Project, transitional aged youth (TAY), or homeless youth, will be given a preference for tenancy. The City of Anaheim currently has no housing specifically dedicated to this homeless subpopulation, although the 2019 Point in Time reports over 500 of such persons in Anaheim. Oftentimes, persons considered TAY are also homeless, at risk of homelessness, or victims of domestic violence; therefore, no q ualifying populations will be prohibited from applying for tenancy at the project site.
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If a preference was identified, explain how the use of a preference or method of prioritization will address the unmet need or gap in benefits and services received by individuals and families in the qualifying population or category of qualifying population, consistent with the PJ’s needs assessment and gap analysis:

As previously discussed in the section on unmet needs and gaps in services for people who were homeless, there is a high need for affordable permanent rental housing in Anaheim. This decision was largely based on the data analysis of the Point in Time Count, CHAS data, RHNA projections, and consultation with various non-profit agencies. According to the Point in Time counts in 2019 and 2022, over 1,000 homeless persons reside in Anaheim, despite the efforts of numerous non- profit service agencies working to end homelessness in the area. The City has also invested millions in local, State, and Federal funding towards the development of affordable rental housing, but gaps and unmet needs for homeless housing still exists.

By prioritizing homeless, chronically homeless, and transitional aged youth (homeless youth ages 18-24) at the Studio 6 and Tampico Motel projects , the City hopes to reduce the number of unhoused persons living in Anaheim. The City will work with CityNet , who as of late 2020, was contracted by the City to operate the Anaheim Community Care Response Team (CCRT). The CCRT consists of m ultidisciplinary teams of outreach workers, Master of Social Work clinicians, licensed vocational nurses, drug and alcohol specialists, safety coordinators, and a dedicated live call center. The teams work across the city of Anaheim seven days a week from 7:00 am-9:00 pm responding to the community's needs for homeless services and mental health emergencies. The City plans to make use of the established relationships between CityNet and the homeless community for referrals to the Studio 6 Motel project.

Likewise, the City will work with Covenant House California to connect TAY clients to housing and services offered at the Tampico project. Covenant House is the first and only nonprofit youth organization that provides sanctuary and support for young people overcoming homelessness and trafficking in Orange County for homeless persons aged 18 to 24.

If a preference was identified, describe how the PJ will use HOME-ARP funds to address the unmet needs or gaps in benefits and services of the other qualifying populations that are not included in the preference:

While homeless, chronically homeless, and transitional aged youth have been identified a mong the qualifying populations to receive prioritization at the Studio 6 and Tampico Motel projects, none of the qualifying populations will be prohibited from applying and residing at the developments. As was explained earlier in this Plan, many of the q ualifying populations overlap with one another. A person that is homeless, could also be a veteran. Similarly, a transitional aged youth could also be a person fleeing from domestic violence, or apply as a family household for example. Therefore, all quali fying populations could be assisted by HOME -ARP funded affordable housing.
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Additionally, the City of Anaheim will continue to utilize its annual federal CDBG, ESG, HOME, and HOPWA allocations to provide services and housing to persons in all qualifying populations.

HOME -ARP REFINANCING GUIDELINES
If the PJ intends to use HOME-ARP funds to refinance existing debt secured by multifamily rental housing that is being rehabilitated with HOME -ARP funds, the PJ must state its HOME- ARP refinancing guidelines in accordance with 24 CFR 92.206(b). The guidelines must describe the conditions under with the PJ will refinance existing debt for a HOME-ARP rental project, including:

Establish a minimum level of rehabilitation per unit or a required ratio between rehabilitation and refinancing to demonstrate that rehabilitation of HOME-ARP rental housing is the primary eligible activity
Not applicable. The City of Anaheim does not intend to refinance existing debt secured by multifamily rental housing.

Require a review of management practices to demonstrate that disinvestment in the property has not occurred; that the long-term needs of the project can be met; and that the feasibility of serving qualified populations for the minimum compliance period can be demonstrated.

Not applicable.

State whether the new investment is being made to maintain current affordable units, create additional affordable units, or both.

Not applicable.

Specify the required compliance period, whether it is the minimum 15 years or longer.

Not applicable.

State that HOME-ARP funds cannot be used to refinance multifamily loans made or insured by any federal program, including CDBG.

Not applicable.

Other requirements in the PJ’s guidelines, if applicable:

Not applicable.

Appendix
City of Anaheim HOME-ARP Allocation Plan

APPENDIX

HOME-ARP CERTIFICATIONS
SF424 APPLICATION FOR FEDERAL ASSISTANCE
SF424-B ASSURANCES – NON-CONSTRUCTION PROGRAMS
SF424-D ASSURANCES – CONSTRUCTION PROGRAMS

02/27/2023

02/27/2023

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