SUBSTANTIAL AMENDMENT TO THE
FISCAL YEAR 2021-2022 ANNUAL ACTION PLAN
Annual Action Plan
Substantial Amendment
HOME-ARP Allocation Plan
City of Fullerton
FY 2021-22
(July 1, 2021 – June 30, 2022)
Prepared pursuant to 24 CFR Part 91
Draft Review Period: March 7, 2023 – March 22, 2023
City Council Approval: March 7, 2023
HUD Approval: Pending
For more information please contact:
Linda Cordova, Housing Consultant to the City of Fullerton (714) 738-6878
SUBSTANTIAL AMENDMENT TO THE
FISCAL YEAR 2021-2022 ANNUAL ACTION PLAN
TABLE OF CONTENTS
PAGE
Introduction ................................................................................................................................ 2 Consultation
Needs Assessment and Gap Analysis ............................................................................................
HOME-ARP Activities
Preferences
Exhibits
Exhibit 1-Comments and Survey Results ...................................................................................... 7 Exhibit 2-Orange County Point in Time (PIT) Summary
Exhibit 3-Orange County Continuum of Care Consultation
Exhibit 4-Pulic Notices
Exhibit 5-Fullerton Affordable Housing Chart/Orange County HMIS Inventory List Exhibit 6-HOME-ARP Applications and Certifications
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SUBSTANTIAL AMENDMENT TO THE
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Introduction
On March 11, 2021, President Biden signed the American Rescue Plan (ARP), into law, which provides over $1.9 trillion in relief to address the continued impact of the COVID-19 pandemic on the economy, public health, State and local governments, individuals, and businesses.
Congress appropriated $5 billion to be administered through the HOME Investment Partnerships Program – American Rescue Plan (HOME -ARP) to provide homelessness assistance and supportive services that benefit one of four qualifying homeless populations whether they be individuals or families. Activities to address the issues include: (1) development and support of affordable housing; (2) Tenant-Based R ental Assistance (TBRA) ; (3) provis ion of supportive services; (4) acquisition and development of non-congregate shelter; (5) non-profit operating and capacity building assistance; and (6) program planning and administration.
The four qualifying populations identified in HOME -ARP are (1) homeless, as defined in section 103(a) of the McKinney-Vento Homeless Assistance Act, as amended (42 U.S.C. 11302(a)) McKinney-Vento (2) at risk of homelessness, as defined in section 401 of McKinney- Vento; (3) fleeing, or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking; or (4) part of other populations where providing supportive services or assistance would prevent a homelessness or would serve those with the greatest risk of housing instability. Veterans and families that include a veteran family member that meet the criteria in one of the four populations above may be given preference.
The City of Fullerton’s HOME-ARP allocation is $1,954,345. The City of Fullerton (City) submitted the federal Annual Action Plan (AAP) in May 2021 to the U.S. Department of Housing and Urban Development (HUD) that detailed the funding strategy for the Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME) programs each year. The A AP implements the Five-Year Consolidated Plan goals and is developed through significant public input, analyses, and planning. This document is the required Substantial Amendment to the City of Fullerton’s Fiscal Year 2021-2022 Annual Action Plan.
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Title 24 Section 91.505 of the Code of Federal Regulations stipulates that participating jurisdictions shall amend their approved plans whenever they make one of the following decisions:
1. To make a change in its allocation priorities or a change in the method of distribution of funds;
2. To carry out an activity, using funds from any program covered by the Consolidated Plan (including program income) not previously described in the action plan; or
3. To change the purpose, scope, location, or beneficiaries of an activity.
In addition, HUD’s, Community Planning and Development Notice CPD-21-10 Requirements for the Use of Funds in the HOME-American Rescue Plan Program, instructs Participating Jurisdictions (PJ), that in order to receive its HOME-ARP funds, a PJ must engage in consultation, facilitate the public participation processes, develop a HOME -ARP allocation Plan that meets the requirements established in section V. of the Notice, and to submit it to HUD as a substantial amendment to its Fiscal Year 2021 AAP.
CPD-21-10 stipulates that HUD will be using the waiver and alternative requirement authority provided by ARP to establish requirements for the HOME -ARP Allocation Plan. The HOME -ARP Allocation Plan must describe how the PJ intends to distribute HOME-ARP funds, including how it will use these funds to address the needs of HOME -ARP qualifying populations. A HOME- ARP Allocation Plan (Plan) must include:
• A summary of the consultation process and results of upfront consultation; • A summary of comments received through the public participation process and a summary of any comments or recommendations not accepted and the reasons why;
• A description of HOME-ARP qualifying populations within the jurisdiction; • An assessment of unmet needs of each qualifying population; • An assessment of gaps in housing and shelter inventory, homeless assistance and services, and homelessness prevention service delivery system; • A summary of the planned use of HOME-ARP funds for eligible activities based on the unmet needs of the qualifying populations;
• An estimate of the number of housing units for qualifying populations the PJ will produce or preserve with its HOME-ARP allocation; and • A description of any preferences for individuals and families in a particular qualifying population or a segment of a qualifying population. • HOME-ARP Refinancing Guidelines
• Certifications and SF-424, SF 424B, and SF-424D forms.
All the above required elements of the HOME -ARP Allocation plan shall be part of the FY 2021 AAP for purposes of the HOME-ARP program. Consequently, PJs are not required to amend their consolidated plans.
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The Regulation further requires that jurisdictions identify in their citizen participation plans the criteria they will use for determining what constitutes a substantial amendment. The proposed HOME-ARP Allocation Plan undertakes new activities with new funding not previously included in the Consolidated Plan or AAP. Therefore, this qualifies as a substantial amendment.
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4 CONSULTATION
HUD requires each PJ consult with agencies and service providers whose clientele include the HOME-ARP qualifying populations. Agencies that must, at a minimum, be consulted include the Continuum of Care (CoC) 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.
HUD also requires that each PJ provide opportunities for the public to comment on the proposed Plan, including the amount of HOME-ARP funds that will be received and the activities that the City may undertake.
The City of Fullerton (City) conducted significant consultation sessions with citizens, elected officials, non -profit agencies, public housing authorities, private developers, governmental agencies, and the Orange County Continuum of Care (CoC) in preparing the HOME-ARP Allocation Plan.
To ensure broad input into the Plan, the City engaged in consultation through a virtual session with the Orange County Continuum of Care (CoC) that took place on February 21, 2023. The session was held in conjunction with the City of Garden Grove in front of the CoC General Membership of public and assisted housing providers and private and governmental health, mental health, and service agencies from across Orange County. During the presentations, the City presented the Plan and time was allowed for feedback and consultation from all attendees.
While the CoC could not share the list of attendees, their general membership list is included in Exhibit 3. Thirty-nine participants signed into the session.
Additional consultation sessions were held during the development of the Plan:
January 24, 2023
Public Meeting for all service providers and the public
February 6, 2023
City Homeless Meeting with various City departments working on homeless issues
February 21, 2023
The above-mentioned CoC lead-consultation
February 28, 2023
Community Development Citizens’ Committee - open to the public
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5 March 21, 2023
Public Hearing before the City Council – open to the public
The following table is a list of organizations that were consulted as a part of the sessions (CoC session participants are not included). All feedback and comments are attached in Exhibit 1.
Agency/Group/
Organization
Agency/Group/
Organization Type
How Consulted
Curtis Gamble Activist 1/24/23- In-Person Consultation Workshop Lutheran Social Services Non-profit Organization 1/24/23- In-Person Consultation Workshop Lutheran Social Services Non-profit Organization 1/24/23 In-Person Consultation Workshop Lutheran Social Services Non-profit Organization 1/24/23- In-Person Consultation Workshop WTLC Non-profit Organization 1/24/23- In-Person Consultation Workshop Fair Housing Foundation Non-profit Organization 1/24/23- In-Person Consultation Workshop Hope Center of OC Non-profit Organization 1/24/23- In-Person Consultation Workshop Hope Center of OC Non-profit Organization 1/24/23- In-Person Consultation Workshop Pathways of Hope Non-profit Organization 1/24/23- In-Person Consultation Workshop Curtis Gamble Activist 2/28/23- Public Meeting
Lutheran Social Services Non-profit Organization 2/28/23- Public Meeting CARE Housing Services Non-profit Organization 2/28/23- Public Meeting CARE Housing Services Non-Profit Organization 2/28/23- Public Meeting Public Participation
In accordance with 24 CFR 91.105(c)(3) for local governments, the substantial amendment Public Notice for the use of HOME-ARP funds was released for citizen review and comments on February 16, 2023 . During the 15 -day public comment period from March 7, 2023, through March 22, 2023, the draft substantial amendment was made available during regular business hours in the offices of the Community and Economic Development Department - Housing Division, 303 W.
Commonwealth Avenue, 3 rd Floor, Fullerton, CA 92832 ; the Fullerton Public Library, 353 W.
Commonwealth Avenue, Fullerton, CA 92832; and on the City’s website. The City Council held a public hearing on March 21, 2023 , at 5:30 p.m. at the City Council Chambers, 303 W.
Commonwealth Avenue, Fullerton CA 92832.
Efforts to Broaden Public Participation
A public notice advertising the availability of the Program Year 2021 AAP Substantial Amendment for the HOME-ARP Allocation Plan and public hearing was published on February 16, 2023, in the Fullerton Tribune in English, La Opinion in Spanish, and in the Korea Daily in Korean.
6 Comments and Recommendations Received:
All comments and survey results are attached (Exhibit 1).
Comments and Recommendations Not Accepted and Reasons Why? No comments were rejected. All comments and survey results are attached (Exhibit 1).
7 Needs Assessment and Gap Analysis
The needs assessment and gap analysis must evaluate the 1) size and demographic composition of HOME-ARP qualifying populations, and 2) unmet needs of HOME-ARP qualifying populations.
In addition, the needs assessment and gap analysis must identify any gaps within its current shelter and housing inventory, and service delivery system. This needs assessment and gap analysis focuses on:
1. Sheltered and unsheltered homeless populations;
2. Currently housed populations at risk of homelessness;
3. Other families requiring services or housing to prevent homelessness; and
4. Those at greatest risk of housing instability or unstable housing situations.
To more accurately identify the unmet needs of the four qualifying populations in Fullerton, at a minimum, the following data was used. The Annual County of Orange 2022 Point in Time (PIT) Summary. The PIT counts th e sheltered and unsheltered homeless persons on a single night during the last 10 days of January. The sheltered count includes emergency shelter, transitional housing, and safe haven projects. The updated Comprehensive Housing Affordability Strategy (CHAS) released September 9, 2022, by HUD’s Office of Policy Development and Research (PD&R) based on 2015/2019 American Community Survey (ACS) 5-year estimates.
Housing Inventory Count (HIC)
According to the 2022 Orange County Housing Inventory Count, the following resources are available to assist qualifying populations, including congregate and non-congregate shelter units, supportive services, TBRA, and affordable and permanent supportive rental housing.
1. Emergency housing beds include emergency shelter a nd transitional housing; emergency shelter generally allows for short-term or nightly stays, while transitional housing generally allows for a stay up to 24 months. Both types of emergency housing may include supportive services designed to facilitate movement to independent living.
2. Rapid re-housing provides security and utility deposits and/or monthly rental and utility assistance for rental units that rent for less than the fair market rent. Assistance is generally provided for the shortest period of time necessary for a household to gain stable housing and can range from 3 to 24 months. Permanent supportive housing provides for an
unlimited lease term; residents receive services necessary to promote continued housing stability.
8 The Orange County Housing Inventory Count reports that the Emergency Bed count shows 634 beds for families and 1,895 beds for individulas with 2,529 provided year-round and 346 overflow and seasonal beds.
Rapid Re-Housing bed count shows 757 beds for families and 340 beds for individuals with 1,097 year-round beds.
The transitional housing bed count has 711 beds for families and 157 beds for individuals with a total of 868 year-round.
Permanent Supportive Housing bed count is 193 beds for families and 763 beds for individuals with a total of 956 year-round.
Other Permanent Housing provides 499 beds for families and 199 for individuals with a total of 698 beds year-round.
Size and Demographic Composition of Qualifying Populations
The May 2022 PIT count of sheltered and unsheltered homelessness is used for this analysis.
The County of Orange is divided into three areas, Fullerton along with Anaheim, Brea , Buena Park, Cypress, La Habra, La Palma, Los Alamitos, Orange, Placentia, Stanton, Villa Park, Yorba Linda, incorporated County areas, and an unknown location for domestic violence victims make up the North Service Planning Area (North SPA). According to the PIT, the City has the second highest concentration of people experiencing homelessness in the North SPA following the City of Anaheim.
For the purposes of the HOME -ARP Allocation Plan, Homeless is defined in 24 CFR 91.5 (1), (2), or (3).
(1) An individual or family who lacks a fixed, regular, and adequate nighttime residence, meaning:
(i) An individual or family with a primary nighttime residence that is a public or private place 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; (ii) An individual or family living in a supervised publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state, or local government programs for low-income individuals); or
(iii) An individual who is exiting an institution where he or she resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution;
9 (2) An individual or family who will imminently lose their primary nighttime residence, provided that:
(i) The primary nighttime 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, e.g., family, friends, faith - based or other social networks needed to obtain other permanent housing; or (3) Unaccompanied youth under 25 years of age, or families with children and youth, who do not otherwise qualify as homeless under this definition, but who:
(i) Are defined as homeless under section 387 of the Runaway and Homeless Youth Act (42 U.S.C. 5732a), section 637 of the Head Start Act (42 U.S.C. 9832), section 41403 of the Violence Against Women Act of 1994 (42 U.S.C. 14043e -2), section 330(h) of the Public Health Service Act (42 U.S.C. 254b(h)), section 3 of the Food and Nutrition Act of 2008 (7 U.S.C. 2012), section 17(b) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b) ), or section 725 of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a);
(ii) Have not had a lease, ownership interest, or occupancy agreement in permanent housing at any time during the 60 days immediately preceding the date of application for homeless assistance;
(iii) Have experienced persistent instability as measured by two move s or more during the 60 - day period immediately preceding the date of applying for homeless assistance; and (iv) Can be expected to continue in such status for an extended period of time because of chronic disabilities, chronic physical health or mental health conditions, substance addiction, histories of domestic violence or childhood abuse (including neglect), the presence of a child or youth with a disability, or two or more barriers to employment, which include the lack of a high school degree or General Education Development (GED), illiteracy, low Engl ish proficiency, a history of incarceration or detention for criminal activity, and a history of unstable employment.
To address homeless, in 2019, the City developed a Fullerton Homeless Planning Committee . In February 2020 the Committee developed a Strategic Plan for Addressing Homelessness. There were four main elements of the Plan:
• Emergency Shelter/Navigation Centers
• Permanent Supportive and Affordable Housing
• Prevention and Diversion Programs
• Public Safety and Outreach Programs
The City provided both capital and operational costs for two North SPA Shelters, in Placentia and Buena Park. The Placentia Homeless Shelter consists of 100 -beds and the Buena Park Homeless Shelter consists of 150 -beds. In addition to the two regional shelters, the City worked with Illumination Foundation in developing a new creative approach - the Fullerton Navigation Center consists of 90-emergency shelter beds and 60-recuperative care beds. The Navigation Center has 10 a full clinic on-site which is staffed by doctors and nurses 24 hours a day. A CDBG-CV allocation of $444,000 was awarded to the Navigation Center to provide additional assistance to the homeless during the COVID -19 pandemic. Fullerton has also contributed to Bridges at Kraemer Place, a 200-emergency bed shelter.
CDBG funds have annually been awarded to the Bridges at Kraemer Place (Mercy House), Pathways of Hope, and to the City Homeless Case Management Program. In 2023, in an effort to be more effective, the City proposes to remove the two part -time Homeless Case Management positions and replace them with one full -time position. This will help the City with recruitment and provide more consistency in meeting and developing trust with the homeless populatio n.
CDBG-CV funds were used to assist 94 individuals through Illumination Foundation and 192 individuals through Pathways of Hope.
Additionally, CDBG -CV funds in the amount of $650,000 were awarded for the building rehabilitation of the new Hope Center loc ated in Fullerton. The newly refurbished building is a central command center for case workers, health and outreach providers, and homeless liaison officers working together to address public health issues with an emphasis on services to homeless people in the North SPA region.
Sheltered Homeless Populations
The Orange County CoC conducts a n annual PIT count, to create a census of unsheltered and sheltered individuals experiencing homelessness. From 20 19 to 2022, the number of homeless residents in Orange County decreased from 6,860 to 5,718 individuals. The share of sheltered individuals in Orange County decreased by over 200 individuals and the share of unsheltered individuals decreased by 900 individuals. According to the 2022 PIT count, there were 272 people experiencing homelessness in Fullerton. Of these 272 people, 202 people were experiencing unsheltered homelessness and 70 people were experiencing sheltered homelessness . Although the PIT does not breakdown the demographic composition of the 272 people, it does breakdown the 5,718 persons in Orange County that were homeless at the time of PIT count:
Unsheltered Sheltered Total
Homeless 3,057 2,661 5,718
Individuals 2,806 1,704 4,510
Families 94 295 389
Victims of DV 289 226 515
Transitional Age
Youth 109 126 235
Seniors 300 418 718
Veterans 145 135 280
The PIT identified 2,661 people experiencing sheltered homelessness in Orange County. The PIT identifies 1,306 sheltered homeless persons in the North SPA with 70 of those being in the City.
People are considered sheltered when they are residing in emergency shelter or transitional
11 housing, but not when they are receiving rapid re -housing assistance or residing in permanent supportive housing. Among individuals experiencing sheltered homelessness in the County:
• 56.97% (1,516) were between the ages of 25-61; 4.74% (126) were age to 24; 22.59% (601) were under age 18; and 15.71% (418) were 62 years of age or older;
• 51.48% (1,370) identified as male, 48.10% (1,280) identified as female, 0.15 % (4) identified as transgender, and 0.4% (1) identified and gender non - conforming;
• 45.32% (1.206) identified as non-Hispanic and 54.68% (1,455) identified as Hispanic;
• 77.26% (2,056) identified as White, 3.53% (94) identified as multiple races,
11.01% (293) identified as Black or African American, 3.72% (99) identified as Asian, 3.49% (93) identified as American Indian or Alaska Native, and .98% (26) identified as Native Hawaiian or Other Pacific Islander; • 38.40% (791) met the definition of experiencing chronic homelessness; • 28.06% (578) were adults with a serious mental illness; • 26.74% (551) were adults with physical or developmental disabilities; • 20.19% (416) were adults with a substance use disorder; • 3.74% (77) were an adult with HIV/AIDS; and
• 10.97% (226) were adult survivors of domestic violence.
Unsheltered Homeless Populations
The PIT identified 3,057 people experiencing unsheltered homelessness in Orange County, 1,113 in the North SPA and 202 of those being in the City. Among individuals experiencing unsheltered homelessness in the County:
• 82.67% (2,527) were between the ages of 25-61; 3.57% (109) were age 18 to 24;
43.96% (121) were under age 18; and 9.81% (300) were 62 years of age or older. • 73.5% (2,247) identified as male; 25.81% (789) identified as female ; .43% (13) identified as transgender; .13% identified as not singularly female or male; and .13% (4) identified as gender non-conforming;
• 67.78% (2,011)) identified as non-Hispanic and 34.22% (1,046) identified as Hispanic;
• 65.42% (2,000) identified as White, 20.35% (622) identified as multiple races, 6.22% (190) identified as Black or African American, 3.14% (96) identified as Asian, 3.86% (118) identified as American Indian or Alaska Native; and 1.01% (31) identified as Native Hawaiian or Other Pacific Islander; • 55.07% (1,617) met the definition of experiencing chronic homelessness;
12 • 29.53% (867) were adults with a serious mental illness; • 41.45% (1,217) were adults with a substance use disorder; • 46.46% (1,364) were adults with physical or development disabilities; • 1.77% (52) were an adult with HIV/AIDS; and
• 9.84% (289) were adult survivors of domestic violence
A growing segment of individu al adults is an increasing share of elderly adults and adult households who are becoming homeless. Adult only households are most likely to be chronically homeless and are most likely to be unsheltered and have a higher duration of days experiencing homelessness. Chronically homeless individuals continue to be a more challenging population to assist, provide services and support in identifying potential housing solutions. Through the City’s Homeless Case Manager program working in conjunction with the Police Department’s Homeless Liaison Officers, the City will be able to reach more homeless individuals and will be able to provide additional support to help them identify suitable long-term housing.
At-risk of Homelessness
The definition of at-risk of homelessness is defined in 24 CFR 91.5.
(i) Has an annual income below 30 percent of median family income for the area, as determined by HUD;
(ii) Does not have sufficient resources or support networks, e.g., family, friends, faith -based or other social networks, immediately available to prevent them from moving to an emergency shelter or another place described in paragraph (1) of the “Homeless” definition in this section; and
(iii) Meets one of the following conditions:
(A) Has moved because of economic reasons two or more times during the 60 days immediately preceding the application for homelessness prevention assistance; (B) Is living in the home of another because of economic hardship; (C) Has been notified in writing that their right to occupy their current housing or living situation will be terminated within 21 days after the date of application for assistance; (D) Lives in a ho tel or motel and the cost of the hotel or motel stay is not paid by charitable organizations or by federal, State, or local government programs for low-income individuals; (E) Lives in a single-room occupancy or efficiency apartment unit in which there reside more than two persons or lives in a larger housing unit in which there reside more than 1.5 people per room, as defined by the U.S. Census Bureau;
(F) Is exiting a publicly funded institution, or system of care (such as a health -care facility, a mental health facility, foster care or other youth facility, or correction program or institution); or (G) 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; 13 (2) A child or youth who does not qualify as “homeless” under this section, but qualifies as “homeless” under section 387(3) of the Runaway and Homeless Youth Act (42 U.S.C. 5732a(3)), section 637(11) of the Head Start Act (42 U.S.C. 9832(11) ), section 41403(6) of the Violence Against Women Act of 1994 (42 U.S.C. 14043e -2(6)), section 330(h)(5)(A) of the Public Health Service Act (42 U.S.C. 254b(h)(5)(A)), section 3(m) of the Food and Nutrition Act of 2008 (7 U.S.C. 2012(m)), or section 17(b)(15) of the Child Nutrition Act of 1966 (42 U.S.C. 1786(b)(15)); or
(3) A child or youth who does not qualify as “homeless” under this section, but qualifies as “homeless” under section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2)), and the parent(s) or guardian(s) of that child or youth if living with her or him.
Households at risk of homelessness are those with incomes below 30% AMI that lack sufficient resources or support networks to prevent homelessness, and 1) have moved more than two times due to economic reasons in the past 60 days, 2) are doubled up with another household due to economic hardship, 3) will be evicted within 21 days, 4) live in a hotel or motel without financial assistance from a nonprofit or government entity, 5) live in an efficien t apartment and are overcrowded, or 6) are exiting a publicly-funded institution or system of care.
HUD CHAS 2015-2019 data Table 10 provides information on overcrowding among households that include more than one family, by household income level. This CHAS data indicates there are approximately 9,560 households renting with incomes below 30% AMI that are at risk of homelessness in the City.
Fleeing or Attempting to Flee Domestic Violence, Dating Violence, Sexual Assault, Stalking or Human Trafficking
For HOME-ARP, this population includes any individual or family who is fleeing, or is attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking. This population includes cases where an individual or family reasonably believes that there is a threat of imminent harm from further violence due to dangerous or life -threatening conditions that relate to vi olence against the individual or a family member, including a child, that has either taken place within the individual’s or family’s primary nighttime residence or has made the individual or family afraid to return or remain within the same dwelling unit. In the case of sexual assault, this also include cases where an individual reasonably believes there is a threat of imminent harm from further violence if the individual remains within the same dwelling unit that the individual is currently occupying, or the sexual assault occurred on the premises during the
90-day period preceding the date of the request for transfer. Domestic violence, dating violence, sexual assault, and stalking are defined in detail in 24 CFR 5.2003.
Human trafficking includes both sex and labor trafficking, as outlined in the Trafficking Victims Protection Act of 2000 (TVPA), as amended (22 U.S.C. 7102). 14 Sex Trafficking means the recruitment, harboring, transportation, provision, obtaining, patronizing, or soliciting of a person fo r the purpose of a commercial sex act, in which the commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age.
Labor trafficking means the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
The 2022 PIT identified 515 sheltered (226) and unsheltered (289) adult survivors of domestic violence in the County. The count of sheltered and unsheltered survivors of domestic violence does not include children in families. Providers of services to survivors of domestic violence indicate the number of individuals in need of shelter is likely undercounted as isolation and physical distancing mandates resulted in increased domestic violence concerns while limiting potential flight from unsafe livin g situations. While the overall County number of victims of domestic violence has seen a slight overall decrease, the sheltered number has increased and the number unsheltered has decreased. Demographic information for this qualifying population is confidential.
For the last several years, CDBG funds have been allocated to Lutheran Social Services of Southern California (LSSSC) for their Victims of Domestic Violence Program. In FY 2021, LSSSC assisted 145 domestic violence victims.
Other Populations
Other populations where providing supportive services or assistance under section 212(a) of NAHA (42 U.S.C. 12742(a)) would prevent the family’s homelessness or would serve those with the greatest risk of housing instability. HUD defines these populations as individuals and households who do not qualify under any of the populations above but meet one of the following criteria:
(1) Other Families Requiring Services or Housing Assistance to Prevent Homelessness is defined as households (i.e. individuals and families) who have previously been qualified as “homeless in 24 CFR 91.5, are currently housed due to temporary or emergency assistance, including financial assistance, serves, temporary rental assistance or some type of other assistance to allow the household to be housed, and who need additional housing assistance or supportive services to avoid a return to homelessness.
(2) At Greatest Risk of Housing Instability is defined as household who meets either
(i) Has annual income that is less than or equal to 30% of the area median income, as determined by HUD and is experiencing severe cost burden (i.e., is paying more than 50% of monthly household income toward housing costs.
15 (ii) Has annual income that is less than or equal to 50& of the area median income, as determined by HUD, AND meets one of the following conditions from paragraph (iii) of the “At risk of homelessness” definition established at 24 CFR 915 (See “At Risk of Homelessness” paragraph above).
Currently housed and at risk of repeat homelessness
The Orange County HMIS (Homeless Management Information System) indicates that approximately 7% of individuals exiting emergency shelter, or transitional or permanent housing in any given year will return to homelessness within six months. In 2022, 3,302 people exited homelessness that year, therefore the risk of repeat homelessness is approximately 221 people in six months and an additional 130 (4%) within twelve months.
At greatest risk of housing instability – Households with incomes < 30% AMI and experiencing severe housing cost burden
2015-2019 HUD CHAS data indicates there are 9,560 renter households with annual income less than 30% AMI that are at greatest risk of housing instability.
At greatest risk of housing instability – Households with incomes 30-50% AMI that meet HUD’s §91.5 definition of at risk of homelessness
Households in this category are those with incomes between 30% and 50% AMI that lack sufficient resources or support networks to prevent homelessness, and 1) have moved more than two times due to economic reasons in the past 60 days, 2) are doubled up with another household due to economic hardship, 3) will be evicted within 21 days, 4) live in a hotel or motel without financial assistance from a nonprofit or government entity, 5) live in an efficiency apartment and are overcrowded, or 6) are exiting a publicly-funded institution or system of care.
HUD CHAS 2015-2019 data Table 10 provides information on households that include more than one family, household income level and overcrowding. This CHAS data indicates there are approximately 6,190 households with incomes between 30% and 50% AMI that are at risk of homelessness in the City.
Unmet Housing and Service Needs of Qualifying Populations
The greatest unmet housing needs of qualifying populations are:
• Permanent rental housing that is affordable to qualifying and other populations; and
• Permanent supportive rental housing that coordinates specialized services with housing that is affordable to qualifying and other populations. 16 Additional unmet service needs of qualifying populations, including sheltered and unsheltered homeless populations, currently housed populations at risk of homelessne ss, other families requiring services or assistance to prevent homelessness, and those at greatest risk of housing instability or in unstable housing situations include the following as described in HUD CPD Notice 2021-10, as may be amended:
a. Case management;
b. Child care;
c. Education services;
d. Employment assistance and job training;
e. Meal or grocery assistance;
f. Housing search and counseling assistance;
g. Coordinated service linkage;
h. Legal services;
i. Outpatient health services;
j. Outreach services;
k. Substance abuse treatment services;
l. Transportation;
m. Credit repair
n. Landlord-tenant liaison services;
o. Services for special populations, including trauma-informed services; and p. Financial assistance to secure stable housing, such as rental application fees, security and utility deposits, and first and last month’s rent.
The greatest unmet service needs of qualifying populations, including sheltered and unsheltered homeless populations, currently housed populations at risk of homelessness, other families requiring services or assistance to prevent homelessness, and those at greatest risk of housing instability or in unstable housing situations are:
a. Mental health;
b. Navigation;
c. Diversion;
d. Life skills; and
e. Vehicle repairs.
17 Current Resources Available to Assist Qualifying Populations
Although limited, current available resources include:
1. Congregate beds and non-congregate shelter units;
2. Supportive services;
3. Tenant-based rental assistance; and
4. Affordable and Permanent Supportive Rental Housing.
Congregate Beds and Non-congregate Shelter Units
In 2022, there were 3,397 congregate beds and 5,497 beds in non -congregate shelter units.
Congregate beds include emergency, safe haven and transitional housing beds and units. Non- congregate shelter includes permanent supportive housing and rapid re-housing.
Supportive Services
The City has the following permanent supportive housing units/projects:
Casa Maria Del Rio 25 units
Fullerton City Lights 137 units
Fullerton Heights 35 units
Harbor View Terrace 25 units
Tenant-based Rental Assistance
The Orange County Housing Authority administers the following tenant-based voucher programs for Fullerton residents (Reported 1/10/23):
A description of each program and the 2021-2022 program accomplishments are as follows:
The Orange County Housing Authority (OCHA) administers the Section 8/Housing Choice Voucher Program within the City of Fullerton. This assistance program is tenant-based rather than project- based. Each tenant may take their assistance and rent any unit within the County that meets the Section 8 Housing Quality Standards and meets the household’s family size requirements. As of Housing Choice Voucher Program (Includes Housing Choice Vouchers, Family Unification, Family Self-Sufficiency, & Veterans Affairs Supportive Housing)* 356
Family Unification* 20
Family Self- Sufficiency* 18
Veterans Affairs Supportive Housing (VASH)* 32
Continuum of Care 55
Portability In 51
Emergency Housing Vouchers 37
18 July 11, 2022, OCHA was providing 367 Housing Choice Vouchers to Fullerton residents, of which, 86 were families, 72 disabled and 209 elderly. This data includes regular Housing Choice Vouchers, Family Unification Program (FUP), Family Self -Sufficiency (FSS), non -elderly disabled program, and Veterans Affairs Supportive Housing (VASH) program. There are no Fullerton non- elderly disabled households being assisted at this time.
The goal of the FSS program is to identify and remove economic barriers and make each household independent of the housing authority within a five -year period. As of July 2022, 19 households were being assisted (2 disabled household) in the City of Fullerton. Through the FSS program, a network of employers, social service agencies, and educational institutions are developed to provide each participating household with job skills and social services to: 1) Increase the household's income; 2) Make the household self -sufficient; and 3) Eliminate the household's need for rental assistance. The participating household signs an agreement to work over a five -year period toward becoming self -sufficient. In exchange for the household's commitment and work, the Housing Authority evaluates the household's specific needs and determines factors that are detrimental to the family's self-sufficiency.
The FUP program helps reunite families that have been separated by court order. Children have been taken into custody and placed in foster homes because families cannot provide adequate housing. The program operates with the same criter ia required for Section 8, but families are given a priority status to avoid the four -five year waiting list. As of July 2022, there were 23 households (16 families, 5 disabled, 2 elderly) in the City of Fullerton.
The VASH program provides permanent housi ng subsidies and case management services to homeless veterans with mental and addictive disorders through a collaboration of the Department of Housing and Urban Development and Veteran Affairs. Of the active VASH vouchers, 35 are Fullerton residents, of which, 10 are families, 4 disabled, and 21 elderly.
The Emergency Housing Voucher (EHV) Program is funded through the American Rescue Plan Act (ARPA) of 2021. Vouchers assist individuals and families who are experiencing homelessness, those at risk of homel essness, fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking, or were recently homeless, and for when providing rental assistance will prevent the family’s homelessness or having high risk of housing instability.
Twenty-three households were assisted (8 families, 14 disabled, 1 elderly).
In addition, the County provided Portability-In vouchers to 51 households in Fullerton (21 family, 15 disabled, 15 elderly) and Continuum of Care assistance to 53 households (38 disabled, 15 elderly).
The City provides a TBRA program for seniors living in mobile homes and veterans throughout the city. There are currently 23 residents on the City’s TBRA program. The following City operated assistance programs were administered or are proposed to be administered during the current 19 2020 Consolidated Plan:
PROGRAM FUNDING
SOURCE
FUNDING
AMOUNT
TBRA – seniors living in mobile homes & veterans - Active An additional amount is proposed for 2023 - Proposed
HOME $600,000
$300,000
Emergency Rental Assistance Program (ERAP) - Active CDBG-CV $194,760 TBRA – citywide - Proposed HOME $500,000
TBRA – victims of domestic violence - Proposed HOME-ARP $500,000
Shelter, Housing and Service Delivery System Gaps
Shelter Gap
Based on the PIT the need for shelter in the County is high as the report shows 3,057 (202 in Fullerton) individuals were unsheltered. There is an estimated need for 45 additional shelter beds and/or transitional housing beds for the homeless population based on the January 2019 point - in-time count.
Shelter Gap Methodology
The shelter gap methodology utilized the 2022 PIT of unsheltered individuals and families in the County. The number of unsheltered individuals and families equaled 3,057 individuals on the streets with 202 of them in Fullerton with only 70 in shelters.
Tenant-based Rental Assistance Gap
There is an estimated gap of 15,158 tenant-based rental assistance vouchers for households with income less than 50% AMI and paying more than 50% of household income for rent, including utilities. There are 15,750 renter households with income less than 50% AMI paying more than 50% of income for rent, including utilities with only 592 vouchers and TBRA slots.
Tenant-based Rental Assistance Gap Methodology
Below shows the number of renter households with income less than 50% of AMI and paying more than 50% of household income for rent, including utilities that could not be covered by a voucher
20 Tenant-based Rental Assistance Gap
OCHA
Vouchers +
HOME-TBRA
Gap
Renter Households with Income <50% AMI paying more than 50% of income for rent, including utilities
592
15,158
Affordable Rental Housing Gap
There is an estimated gap of 1,950 rental units affordable to renter households with income less than 30% AMI. In addition, there is an estimated gap of 4,165 rental units affordable to renter households with income between 30% and 50% AMI.
Affordable Rental Housing Gap Methodology
The number of Affordable Rental Units was calculated using HUD CHAS Data Table 10 and is equal to the number of renter households in each income category paying more than 50% of household income for rent, including utilities.
Affordable Rental Unit Gap
Renter Households with Income <30% AMI paying more than 50% of income for rent, including utilities 9,560
Renter Households with Income 30% to 50% AMI paying more than 50% of income for rent, including utilities 6,190
Total Affordable Rental Unit Need 15,750
Characteristics of Housing Associated with Increased Risk of Homelessness for Other Populations
For other populations, severe housing cost burden, or paying more than 50% of household income for rent and utilities is the primary characteristic of housing associated with increased risk of homelessness throughout the City.
Priority Needs for Qualifying Populations
Priority needs for qualifying populations are:
• Non-congregate shelter;
• Affordable rental housing, including permanent supportive housing;
21 • Supportive services including:
➢ Housing navigation;
➢ Case management;
➢ Child care;
➢ Education services;
➢ Employment assistance and job training;
➢ Meal or grocery assistance;
➢ Housing search and counseling assistance;
➢ Coordinated service linkage;
➢ Legal services;
➢ Life skills training;
➢ Mental health services;
➢ Outpatient health services;
➢ Outreach services;
➢ Substance abuse treatment services;
➢ Transportation, including vehicle repairs and bus passes; ➢ Credit repair;
➢ Landlord-tenant liaison services;
➢ Services for special population, including trauma-informed services; and
➢ Financial assistance to secure stable housing, such as rental application fees, security and utility deposits, and first and last month’s rent.
Other resources available to qualifying populations in the City
Every five years, the City must submit its Five-Year Consolidated Plan to the HUD in order to receive funding for the Community Development Block Grant (CDBG) and the HOME Investment Partnerships (HOME) programs. These federal funds provide for the development of affordable housing, street improvements, park and public facilities improvements, economic development, code enforcement, public services, the expansion and retention of businesses, and for the delivery of services for individuals experiencing homelessness.
Funding for Homeless populations
The CDBG program provides funds annually to programs that assist sheltered and unsheltered homeless individuals, as well as those at risk of homelessness, to quickly regain stability in permanent housing after experiencing a housing crisis and/or homelessness.
Funding for At Risk of Homelessness populations
The HOME program provides funds for a wide range of housing -related activities including building, buying, and/or rehabilitating affordable housing for rent or homeownership, or providing direct tenant-based rental assistance to low-income residents. The program’s flexibility
22 allows HOME funds to be used for grants, direct loans, loan guarantees or other forms of credit enhancements, or tenant-based rental assistance or security deposits to prevent homelessness.
The City is in negotiations with a local developer to add an additional twelve HOME -assisted affordable rental housing units in the City.
Funding for Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking populations
The City’s CDBG funds are used to provide financial assistance to Lutheran Social Services of Southern California. This organization provides services that assist victims of domestic violence.
Funding for Other populations
The City’s TBRA provided assistance to seniors who live in mobile homes and pay more than 30% of their income to housing costs. The need was recognized when the City was doing home improvement s on the mobile homes and realized that many of these seniors were living on very limited incomes.
CDBG -CV funds were awarded to food programs during the pandemic to assist those who had been impacted. Seniors were assisted through the Meals on Wheels – Fullerton ($7,000) and Meals on Wheels – OC ($7,000). Additional senior found themselves in need of assistance as they could not leave their homes and had not one to provide food for them. Feed Fullerton received $268,131 and provided a food voucher program for individuals and families who were financially impacted.
Fullerton receives an annual allocation of approximately $1.3 million. The FY 2020 -2021, 2021- 2022, and 2022-2023 CDBG funds included funding allocations for administration and planning, code enforcement in low- to moderate-income areas of the city to address health and safety violations, fair housing, non-profit and city public services, city capital improvement projects, and single-family rehabilitation grants. Funds were available for econom ic development to provide small business grants, but no applications were submitted. Funds were provided for small business loans under economic development through CDBG-CV in the amount of $194,760. The following programs are being funded to provide serv ices to numerous populations in the community (administration and capital improvement projects are not shown in this table):
Public Service Organizations 2020 Con
Plan awards
to date
AIDS Services Foundation of OC (dba Radiant Health Centers) – HIV Care Services $ 7,500
Boys & Girls Club of Fullerton – After School/Youth Development $ 97,841 CARE Housing Services – Fullerton City Lights Social Services $ 15,000 Community SeniorServ (dba Meals on Wheels Orange County)– Lunch Café Program
$ 46,273
Fair Housing Foundation – Fair Housing Services $ 60,000 23 City of Fullerton – Homeless Case Management Program $ 95,988 City of Fullerton – Housing Rehabilitation Program/CDBG HOME funding
$649,090
$300,000
City of Fullerton – Special Code Enforcement $420,000
Hart Community Homes – Monkey Business Cafe $ 45,000
ICNA Relief USA Programs, Inc. – Crescent Clinic $ 7,500 Lutheran Social Services of So. Cal. – Victims Intervention Program $ 39,273 Meals on Wheels Fullerton – Maintenance of Meals/Supportive Services $ 66,562 Mercy House Living Centers – Bridges at Kraemer Place $ 44,273 Pathways of Hope – Regional Homeless Services Coordination $ 85,803 Wound Walk – Fullerton Street Medic Program $ 14,273
YMCA of Orange County – Youth Achievers $ 32,370
HOME- ARP Activities
Describe the method for soliciting applications for funding and/or selecting developer’s, service providers, subrecipients and/or contractors and whether the PJ will administer activities directly.
HOME-ARP will be administered by the Housing Division of the City of Fullerton (under the direct supervision of the Housing Division Manager, the direction of the Executive Director of Community and Economic Development, and the general supervision of the City Manager).
The City will follow the CDBG application process. Applications will be solicited for funding and/or selecting service providers, subrecipients and/or contractors. The City may administer programs such as the TBRA programs and will be subject to the same application process as non -profit agencies. An application period will be announced. Proposed projects may be for any of the identified activities allowed by HOME-ARP regulations. After all applications are received, staff will review them to determine they are within the HOME -ARP requirements of CPD Notice 21 -10.
Applications will be presented to the CDCC for review, presentations by the applicants w ill be heard, and recommendation for funding will be forwarded to the City Council for final approval.
If additional funding is identified and a project includes acquisition, rehabilitation, or new construction of permanent supportive housing or the devel opment of non -congregate shelter units, the City will issue a Request for Proposals (RFP).
The RFP process will be used to select developers and approve a site. Funding amount is unknown as no other funding has been identified. If the RFP process is needed an announcement will be
24 made to the following parties:
• Interested Developers and Non -profit Organizations on the Housing Division’s List.
• Developers and Non-profit Organizations interested in being added to the RFP Process Database can do so by contacting the City’s Housing Division at any time.
• Other affordable housing membership association resources ( e.g. Southern California Association of Nonprofit Housing, Kennedy Commission, 2-1-1 OC) • Public Notice in the local newspaper
• Published on www.Planetbids.com
A Qualified Developer shall complete and submit to the Housing Division the RFP for HOME-ARP funds and prepare all required attachments and exhibits, including, but not limited to, the project proforma, budget, sources and uses, project management plan, tenant selection and marketing plan, relocation plan (if applicable), signed purchase agreement and escrow instructions, preliminary title report, and limited partnership documents (if applicable).
After the deadline for the RFP, the Housing Division staff shall review the proposal(s) to determine that the minimum program and RFP requirements are met (minimum threshold review) and the proposal(s) is eligible under CPD Notice 21 -10. Proposals that do not meet t he minimum threshold review will be considered non -responsive. If the proposal(s) meets the minimum threshold review, the Housing Division will present the submissions to the CDCC for review. The CDCC’s recommendation will then be presented to City Council for final approval.
If any portion of the PJ’s HOME -ARP administrative funds were provided to a subrecipient or contractor prior to HUD’s acceptance 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
PJs must indicate the amount of HOME-ARP funding that is planned for each eligible HOME- ARP activity type and demonstrate that any planned funding for nonprofit organization operating 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
Eligible Activities Funding Amount
Acquisition and Development of Non-
Congregate Shelters
$ 0
Development of Affordable Rental Housing
Tenant-based Rental Assistance $ 550,000
Provision of Supportive Services $1,111,194
Nonprofit Capacity Building $ 0
Administration and Planning (15% max) $293,151 (10% of allocation) Total HOME-ARP Allocation $1,954,345
25 Additional Narrative:
If applications are not submitted to use the full amount of any particular eligible activity category or if the CDCC and/or the City Council determines that valid applications would better address the unmet needs as described, funds may be moved to meet the eligible activities requests.
HOME-ARP funds may be allocated to either Acquisition and Development of Non-Congregate Shelters or for the Development of Affordable Rental Housing if additional funding is identified.
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:
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 TBRA and Supportive Services to address the need to prevent additional homelessness in the City. Although physical shelters and housing units are needed, the City cannot financial support these activity.
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:
No new affordable rental housing units are expected to be produced . However, TBRA and supportive services for people at risk of homelessness will be assisted with HOME -ARP. TBRA funding will help keep 45 households from experie ncing homelessness and supportive service will assist 134 households from experiencing homelessness or returning from homelessness.
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:
Although the City does not anticipate production of affordable rental housing units with HOME- ARP funds, the City does expect to provide support services to units that house residents who are at risk of becoming or returning to homelessness. It is anticipated that a minimum of 134 household will possibly be supported at Fullerton City Lights.
Preferences
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).
• PJs are not required to describe specific projects to which the preferences will apply.
All four qualifying populations will be assisted. The funds will not be restricted to one qualifying population. Preferences may be made to seniors, veterans, female victims of domestic violence, 26 and/or other eligible preference categories, but funding will not be exclusive to these subpopulations and will be open to all applicants if funds are available after the preference categories are assisted.
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:
Based on the City’s gap analysis it was a local decision to use HOME -ARP funds to assist all four qualifying populations. No population will be excluded from funding consideration. If funds are allocated and go unspent, then City will re-evaluate the use of such funds and may reallocate them to another qualifying population.
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:
Not Applicable