Agenda packet, joint meeting — Glendale City Council, May 5, 2026 (part 8 of 8)

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From: Akopyan, Edgar
To: Simon, Jinette; Neukian, Yvette
Cc: Fortney, Mike; Bolbolian, Arthur; Kassabian, Irina; Jackson, Pamela; Zadoryan, Sipan Subject: FW: Public challenge #3 to draft admin plan:

Date: Monday, May 4, 2026 12:23:37 PM
Attachments: COG_120Anniversary_Signature_128.pnginline1 Formal public challenge to draft FY 2026–2027 PHA Annual Plan - #3.pdf HUD-50075-HCV-_Annual_Plan_2026-2027_3.0.pdf
PIH_2025-19.pdf
2025 Glendale Homeless Count Report.pdf
Importance: High
Hi Jinette,

Please add this to the list of exhibits. Thank you

Yvette, do we need to include the PIH notice, HUD-50075 form and the Homeless Count files in the exhibit or just her challenge?

Edgar Akopyan | Senior Housing Analyst
Community Development
141 N. Glendale Avenue, 2nd Level, Room 202, Glendale, CA 91206 P: +1 (818) 548-3230 | M: +1 (818) 858-3998
[email protected] | GlendaleCA.gov | Follow us! 120 Years of Service to Our Community
From: Ani <[email protected]>
Sent: Monday, May 4, 2026 11:54 AM
To: Akopyan, Edgar <[email protected]>; Kassakhian, Ardashes <[email protected]>; Asatryan, Elen <[email protected]>; Brotman, Daniel <[email protected]>; Gharpetian, Vartan <[email protected]>; Najarian, Ara <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Public challenge #3 to draft admin plan:

CAUTION: This email was delivered from the Internet. Do not click links, open attachments, or reply if you are unsure as to the sender.

Dear Mr. Akopyan,
Please find attached a formal public challenge #3 to elements of the draft FY 2026-2027 PHA Annual Plan, filed pursuant to 24 CFR 903.17 and 903.23(b) along with all its attachments. 1030 of 1125

I am submitting this on Monday May 4th. The plan is scheduled for a vote on adoption Tuesday. I expect this challenge and all incorporated prior comments to be included in the materials presented to all before the vote.

Please confirm receipt.

Thank you,
Ani
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2025 Point-In-Time
Homeless Count
hOMELESS cOUNT dATE
02/19/2025
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TABLE OF CONTENTS
When was the 2025 Count Conducted?......................

Who was Counted?.....................................................

Who was not Counted.................................................

Data Limitations.........................................................

Comparison of 2024 and 2025 Survey Results.........

Demographic Breakdown...........................................

Household Type...................................................

Gender.................................................................

Age......................................................................

Race/Ethnicity.....................................................

Chronic Homelessness .............................................

Unsheltered population.......................................

Disabling Conditions....................................

Length of Residency in Glendale..................

The Cause of Chronic Homelessness............

Sheltered population ..........................................

Subpopulation............................................................

Special Needs .....................................................

Veterans .............................................................

Youth ..................................................................

Unsheltered Count......................................................

Sheltered Count..........................................................

Demographic Breakdown..........................................

Sleeping Conditions..................................................

Gender.......................................................................

Age............................................................................

INTRODUCTION

METHODOLOGY AND DATA COLLECTION
2025 SURVEY RESULTS
1 15
15 15
16 6
7 8
8 8
9 9
9 10
10 11
11 11
13 13
13 14
14 4
4 5
5 UNSHELTERED POPULATION
2 4
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TABLE OF CONTENTS
Comparison of 2024 and 2025..............................

Length of Residency in Glendale...........................

Gender....................................................................

Age.........................................................................

Race and Ethnicity.................................................

Employment Status...............................................

Factors Contributing to Homelessness..................

Disabling Conditions............................................. 2025 Count Results.............................................

Supopulations..................................................

Homelessness Among Glendale Residents...........

Trends 2023-2025...............................................

HOMELESSNESS AMONG GLENDALE

RESIDENTS
25 26
27 28
20 20
20 20
20 21
21 22

HIGHLIGTS

CONCLUSION AND RECOMMENDATIONS
Conclusion and Recommendations....................... 24

SHELTERED POPULATION
Age........................................................................

Gender...................................................................

Race and Ethnicity...............................................

Households with Children......................................

Households without Children................................. 18 18
19 19
19 5
6 7
8 Race/Ethnicity.........................................................

Disabling Conditions...............................................

Employment Status.................................................

Factors Contributing to Homelessness.................... 16 17
17 18
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INTRODUCTION
When Was the 2025 Count Conducted?
Due to wildfires in January, the 2025 PIT Count was rescheduled and conducted on February 19, during two time windows: 5:00 AM–9:00 AM and 7:00 PM–11:00 PM.

During these periods, teams were dispatched throughout Glendale to identify and survey unsheltered individuals. The count also incorporated data from emergency shelters and transitional housing programs, capturing individuals who had stayed in these facilities the previous night.

Who Was Counted?
In accordance with the U.S. Department of Housing and Urban Development (HUD) guidelines, individuals were considered homeless, and therefore included in the Point-in-Time Count, if they were residing in any of the following locations on the night of the count:
2025 Homeless Count Report
4 Each year, the City of Glendale conducts its annual Point-in-Time (PIT) Count to measure the scope of homelessness within the community. This count includes both sheltered and unsheltered individuals experiencing homelessness and serves as a vital tool for understanding local trends, evaluating existing programs, and identifying the needs of the unhoused population in Glendale. The PIT Count is part of a nationwide initiative to provide a comprehensive "snapshot" of homelessness on a single day each year.

While the U.S. Department of Housing and Urban Development (HUD) requires local jurisdictions to conduct the PIT Count biennially, typically during the last 10 days of January, to remain eligible for Continuum of Care (CoC) funding, Glendale goes further by conducting the count annually. This approach allows the city to maintain a more consistent, data-driven strategy for addressing homelessness. As one of over 400 jurisdictions that apply annually for HUD CoC funding, Glendale’s yearly count strengthens its ability to respond to emerging needs.
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2025 Homeless Count Report
Data Limitations
While the Point-in-Time (PIT) Count provides valuable insights, it also comes with inherent limitations that should be considered when interpreting the results. One key limitation is its temporal scope—because the count is conducted on a single night, it cannot fully capture the dynamic nature of homelessness throughout the year. Seasonal changes, policy shifts, and economic conditions may all cause fluctuations that are not reflected in this one-day snapshot.

Another significant limitation is the potential for underreporting. The PIT Count relies on visual identification and in-person interviews, which may miss individuals who are in hidden or hard-to- reach locations. People who avoid contact or reside in less visible, informal shelters may not be counted, leading to an underestimation of the true extent of homelessness. To address these gaps, Glendale also relies on data from the Homeless Management Information System (HMIS).

Unlike the PIT Count, HMIS tracks individuals over time, capturing patterns of entry into and exit from homelessness.

For instance, our annual data consistently reveals a higher number of unsheltered individuals in Glendale than what is recorded in the PIT Count. In 2024, the PIT Count identified 80 unsheltered individuals, while our services reached 1,075 unduplicated unsheltered individuals throughout the year. Similarly, the 2025 PIT Count recorded 87 unsheltered individuals, but between January Who Was Not Counted?
Individuals were not included in the homeless count if they were staying in:

Medical facilities (e.g., hospitals, psychiatric facilities, or nursing homes) Jails, prisons, or juvenile detention centers
Substance abuse treatment or detox centers
Foster care homes or group homes for minors
Places not meant for human habitation, such as cars, tents, parks, sidewalks, or abandoned buildings
Emergency shelters
Hotels or motels paid for by government programs
Transitional housing designated for people experiencing homelessness Safe Havens
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The unsheltered count focuses on areas within Glendale that have high concentrations of homelessness. These high-priority areas are identified using local data, prior knowledge, and input from service providers and law enforcement. To ensure the count’s accuracy, trained survey teams conduct face-to-face interviews with individuals living on the streets or in places not meant for habitation. These teams are supervised by Glendale Police officers to guarantee both the effectiveness and safety of the process.

The survey instrument for this count is developed using ESRI's ArcGIS software and Survey123.

This tool helps capture critical demographic information, such as age, gender, race, ethnicity, housing status, and the duration of homelessness. Volunteers, staff from community organizations, and City of Glendale personnel are all trained to administer the survey. Data gathered from these interviews is processed through ArcGIS software for further analysis.

METHODOLOGY AND DATA

COLLECTION
2025 Homeless Count Report
The methodology behind the PIT Count is carefully designed to ensure that data collected is as accurate and representative as possible. The process involves two key components:

Street Outreach & Interviews: Trained volunteers and staff conduct interviews with unsheltered individuals and visually survey public areas during designated early morning and evening hours.

Shelter and Program Data: Information is also gathered from emergency shelters, transitional housing programs, and other service providers, many of which report through HMIS.

Incorporating both direct engagement and administrative data allows the city to create a more complete picture of homelessness in Glendale. The approach prioritizes data integrity, dignity, and respect for those being surveyed, while minimizing bias and ensuring demographic representation.

To ensure the accuracy of the count, a unique
identifier is assigned to each respondent based on
demographic data and a detailed description of their
situation. If duplicate surveys are detected during data entry, they are promptly removed to avoid skewing
the results. In cases where demographic data is
missing- whether from individuals who declined to
participate or were missed in the count- an
and March of 2025 alone, we have already served 672
unduplicated individuals. This disparity highlights the challenge of capturing the full extent of homelessness
in a single, one-night survey, as many individuals may
not be visible during the count or may not seek
assistance on that particular night.

It underscores the importance of using continuous
data collection methods alongside the PIT Count to
gain a more accurate understanding of the homeless
population and its evolving needs.
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2025 Homeless Count Report
The sheltered count is an important complement to the unsheltered Count, focusing on individuals residing in formal housing arrangements, such as shelters and transitional housing programs. While the unsheltered count addresses those living on the streets or in places not meant for habitation, the sheltered count captures individuals experiencing homelessness who are temporarily housed in structured settings, like emergency shelters or transitional housing programs.

The goal of the sheltered count is to identify and collect data on individuals residing in emergency shelters, transitional housing, or temporary housing provided by third-party social service agencies. Although temporarily housed, these individuals are still considered homeless under the HUD definition due to the lack of permanent, stable housing. Tracking those in shelters helps to fully capture the scope of homelessness, including individuals who may face challenges in securing long-term housing.

Data collection for the Sheltered Count is primarily managed through the HMIS system, a federally mandated system recommended by HUD for managing and reporting homeless populations, especially in shelter settings. HMIS is an integrated software platform used by agencies that provide services to individuals experiencing homelessness. It centralizes data across shelters, transitional housing programs, and other supportive housing services.

In compliance with HUD guidelines, each organization or agency managing shelter beds is required to input data into the HMIS system, including demographic information, housing status, duration of homelessness, and other relevant data points about the individuals they serve. This data is collected at various points of entry, such as when a person first arrives at a shelter or enters transitional housing and can be updated as they progress through services or move to permanent housing. HMIS data includes:

Demographic Information: Basic details such as age, gender, race, ethnicity, and family composition. This data helps identify trends across demographic groups and highlights the unique needs of different sub-populations within the homeless community.

Housing Status: Information on the current housing situation, including whether individuals are in emergency shelters, transitional housing, or another form of temporary housing.

Length of Homeless Time: Data regarding the duration of homelessness, crucial for understanding the severity and persistence of homelessness. This information can help identify individuals who may require more intensive support services.

Supportive Services Received: Many shelter programs offer additional services like case management, job training, or mental health support. These services are tracked in HMIS to evaluate their impact on outcomes for those experiencing homelessness. extrapolation tool is used to estimate the missing information. This tool employs regression analysis, a statistical method that examines relationships between variables. By analyzing correlations between collected demographic data (such as age, gender, race, and location) and data within the HMIS system, the city can project missing characteristics for individuals encountered during the street count. This method ensures that even incomplete data sets provide an accurate representation of the homeless population.
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2025 SURVEY

RESULTS
This year’s total homeless population was recorded at 197 individuals, reflecting a 13% increase compared to the 175 individuals counted in 2024. The unsheltered population, or those living in places not meant for habitation, rose by 9%, with 87 individuals identified in this category. The sheltered population, consisting of individuals in emergency shelters or transitional housing, saw a 16% increase, with 110 individuals staying in shelters. 2025 Homeless Count Report
Demographic Breakdown
Household Type: Glendale’s homeless population was composed of 61% (120 individuals) in adult- only households without children and 39% (77 individuals) in households with children, out of a total of 197 individuals. This marks a slight shift from 2024, when out of 175 individuals, 59% (103 individuals) were in adult-only households and 41% (72 individuals) were in households with children. From 2024 to 2025, adult-only households increased by 17%, while households with children saw an increase of 7 %. While both categories saw an increase in total numbers, the proportion of adult-only households rose from 59% to 61%, suggesting a growing number of single adults or adult couples experiencing homelessness.
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Racial and Ethnic Composition:

Between 2024 and 2025, the racial and ethnic composition of the sheltered population shifted notably. The most significant increase was among individuals identifying as Black, African American, or African, whose number more than tripled- from 9 to30 - representing a 233% increase. The number of individuals identifying as Hispanic/Latina/e/o grew modestly from 36 to 40, an 11% rise. Those identifying as White remained steady at 26 in both years, while the number of individuals identifying as both White and Hispanic dropped sharply from 12 to 5, a 58% decrease. New representation appeared among individuals identifying as American Indian, Alaska Native, or Indigenous (increasing from 0 to 6) and those identifying as Middle Eastern or North African (from 0 to 3). Conversely, individuals identifying as Asian and Multiracial were no longer represented, with both groups decreasing from 6 in 2024 to 0 in 2025. 2025 Homeless Count Report
The age distribution showed notable patterns among the homeless population 26% of individuls experiencing homelessness were under 18, while 4% were between the ages of 18 and 24, an age group that often faces housing challenges due to limited income or support networks. The majority, 70%, were adults aged 25 and older, including 13% who were 65 years or older.

Gender distribution revealed that 59% (116 of the 197) of the homeless population were male, 40% (79 of the 197) were female, and 1% (2 of the 197) identified as transgender and more than one gender.

Among the sheltered population, the number of males increased by 12%, from 41 in 2024 to 46 in 2025, while females rose by 15%, from 54 to 62. Individuals identifying with a different gender also appeared for the first time, increasing from 0 to 2. In the unsheltered population, males saw a significant 19% increase, rising from 59 to 70 and continuing to represent the majority. Females in this group decreased by 15%, from 20 to 17. While one unsheltered individual identified with a different gender identity in 2024, none were recorded in this category in 2025. 9 1040 of 1125

2025 Homeless Count Report
Chronic Homelessness in Glendale
In the 2025 homeless count, 26 individuals were identified as chronically homeless, an increase from 18 in 2024. Of these, 17 were unsheltered and 9 were sheltered. This 44% year-over-year increase underscores a troubling rise in chronic homelessness in the region. *Chronic homelessness refers to individuals who have been homeless for at least one year or have experienced multiple episodes of homelessness, combined with the presence of one or more disabling conditions such as mental health issues, substance use disorders, chronic physical health conditions, and severe cognitive impairments that make it difficult to maintain stable housing and employment. These individuals face deeper-rooted challenges than the general homeless population, making it extremely difficult for them to exit homelessness. Chronic homelessness is often marked by repeated cycles of homelessness, wherein individuals may transition in and out of shelters or temporary housing, but are unable to secure permanent using due to their health, economic, and social barriers.

Unsheltered Chronic Homeless Population: 17 individuals were identified as chronically homeless and unsheltered, a stark increase from just 6 individuals in 2024. This represents a 183% increase in the number of chronically homeless individuals within just one year. This significant rise is a clear indication of escalating homelessness in the region, driven by several interrelated factors, including the housing affordability crisis, rising rent costs, and insufficient mental health services.

Many of the chronically homeless individuals are entrenched in a cycle of unemployment, substance abuse, and physical and mental health challenges that prevent them from breaking free of homelessness.
* The HMIS (Homeless Management Information System) does not include a specific category for “Armenian” as a race or ethnicity. As a result, it is difficult to determine exactly how many individuals of Armenian descent are sheltered in Glendale. Some may identify as “White,” others as “Middle Eastern or North African,” or “Other.” This limitation should be considered when interpreting the racial and ethnic composition data, as it may affect the accuracy of representation for the Armenian community within the homeless population.
10 In contrast, the unsheltered population experienced a different set of demographic shifts between 2024 and 2025. Hispanic representation increased by 23%, rising from 22 to 27 individuals. The number of White individuals, including those identifying as Armenian, grew by 39%, from 31 to 43.

In contrast, the Black population declined sharply by 61%, dropping from 18 to 7, while the Asian population decreased by 20%, from 5 to 4. Those identifying as Multiracial grew by 33%, from 3 to

4. Meanwhile, representation among American Indian, Alaska Native, or Indigenous individuals remained unchanged at 1.
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2025 Homeless Count Report
Length of Residency in Glendale: A substantial number of the chronically homeless individuals surveyed have long-standing ties to Glendale. Specifically, 10 of the 17 chronically homeless individuals became homeless while living in the city. When asked about their prior living situations, many individuals indicated that they had been living in Glendale for several years, with some having resided in the city for over a decade before losing their housing. For many, Glendale is not just the place they are experiencing homelessness—it’s their home, where they grew up, worked, or raised families. This highlights the complexity of the homelessness issue in the city and the necessity for solutions that reflect the unique challenges of Glendale residents.

The causes of chronic homelessness in Glendale are multifaceted and include both individual and structural factors. According to the 2025 survey, unemployment and rising rent costs were the most frequently cited reasons for homelessness.

Disabling Conditions: Among the 17 unsheltered chronically homeless individuals, 12% reported developmental disabilities, 41% had general health issues, 18% experienced mental health conditions, 47% had physical disabilities, and 6% reported substance use disorders.

Compared to 2024, these figures reveal concerning trends: the prevalence of physical disabilities and developmental disabilities doubled, indicating a growing number of individuals facing severe functional impairments. General health issues also saw an increase of 40%, suggesting worsening overall health among this population. In contrast, rates of mental health conditions and substance use disorders remained stable, reflecting persistent challenges in these areas that continue to require focused attention. These shifts highlight the evolving and complex needs of the chronically homeless community, emphasizing the importance of integrated healthcare, accessible disability services, and targeted support programs to address both physical and cognitive impairments alongside ongoing mental health and substance use concerns.
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2025 Homeless Count Report
Rising Rent Costs: High housing costs were another major contributing factor. 3 of the 17 individuals surveyed (18%) attributed their homelessness to rising rent prices. As rent continues to increase in Glendale, individuals with limited or unstable incomes struggle to maintain housing. This reflects a broader affordability crisis across California and the nation. For chronically homeless individuals, the combination of high rents, low wages, limited affordable housing, and unstable employment opportunities creates significant barriers to securing and maintaining permanent housing. Additionally, evictions— whether due to non-payment or other reasons—remain a common pathway into homelessness.

Family Conflicts and Health Issues: Beyond economic challenges, personal and health- related issues also play a significant role. Some chronically homeless individuals reported becoming homeless due to family conflict, divorce, or serious health problems. When family support systems break down, individuals may have nowhere else to turn. Health- related issues, such as chronic illness or untreated mental health conditions, can also prevent individuals from working or maintaining stable housing. In the 2025 survey, 2 of the 17 individuals (12%) cited illness as a cause of their homelessness, while another 2 (12%) reported divorce or separation as contributing factors.

Unemployment: Of the 17 individuals surveyed, 6 (35%) reported becoming homeless due to unemployment. A lack of job opportunities, compounded by barriers such as mental health issues, substance use, and discrimination, makes it especially difficult for many to secure or maintain employment, further entrenching them in homelessness. Among those surveyed, only 2 individuals were currently employed, each earning $501 or more per month. Interestingly, income levels among the unemployed were higher overall: 1 unemployed person reported earning between $251–$500 per month, while 7 reported earning $501 or more. These findings highlight the complex and varied financial circumstances faced by homeless individuals—suggesting that employment status alone may not always align with income level, and that informal or non-traditional income sources may be at play.
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2025 Homeless Count Report
In contrast, there was a notable increase in the number of adults with HIV/AIDS. This year, 3 individuals with HIV/AIDS were identified, double the number reported in 2024.

Furthermore, the count included 24 victims of domestic violence, a 20% increase from 2024.

Domestic violence remains a leading cause of homelessness, particularly for women and children, and these individuals often require specialized care and housing options that can support their recovery from trauma.

Subpopulations
Each year, the homeless count provides an important snapshot of the prevalence of specific disabilities and health conditions within the homeless population. For many individuals and families experiencing homelessness, health issues are a significant contributing factor to the financial crises that result in the loss of stable housing. Without access to essential support services, even minor illnesses can escalate into more severe or chronic conditions. Exposure to harsh environmental elements, physical violence, inadequate nutrition, and a lack of preventive care often intensifies health issues, leading to more serious illnesses and placing an increasing financial burden on local communities.

Special Needs: This year’s count highlights a few key subpopulations of homeless individuals with specific needs. There were 15 adults identified with serious mental illness, representing a 7% increase from 14 individuals counted in 2024. Mental health disorders remain a significant challenge, and the lack of appropriate treatment or housing can worsen the instability these individuals experience. Similarly, 2 adults were reported with substance use disorder, showing no change from 2024. Substance abuse often both contributes to and results from homelessness, and the need for better access to treatment programs is evident.

Sheltered Chronic Homeless Population: While the unsheltered population saw a marked increase in chronic homelessness, the sheltered population in Glendale showed a different trend.

Of the 110 sheltered individuals counted on the night of the count, only 9 individuals (8%) were identified as chronically homeless. This represents a 25% decrease from the 12 individuals identified as chronically homeless in the 2024 sheltered count. The decrease in chronic homelessness among the sheltered population is likely due to the availability of emergency housing vouchers and more temporary housing options, which have provided a pathway out of homelessness for some individuals. These vouchers help individuals secure housing while they work through the underlying issues of chronic homelessness, such as substance abuse or mental health conditions. While this decrease is a positive development, it is clear that a comprehensive approach is needed to address the rising rates of chronic homelessness in Glendale, particularly among the unsheltered population.
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2025 Homeless Count Report
Youth: In the 2025 count, 7 individuals aged 18 to 24 were identified, marking a 17% increase from the previous year. This increase in youth homelessness is particularly troubling, as young people are at a heightened risk of long-term instability. Among these youth, 2 were unsheltered, a slight decrease from the 3 unsheltered youth reported in 2024. While this suggests some progress in sheltering youth, there is still a long way to go. The majority of the youth in this group, 5 individuals, were sheltered. Of these, 2 were unaccompanied and 3 were parenting youth with minor children, an increase from 2024, when 3 parenting youth were sheltered.

Veterans continue to represent a unique sub-population within the homeless community. In 2025, 4 unsheltered veterans were identified, consistent with the number found in 2024.

However, the number of sheltered veterans decreased by 100% from 2024. Over the past three years, coordinated efforts at the federal, state, and local levels have led to a notable decline in veteran homelessness. Key strategies included a Housing First approach, increased funding for housing and support services, and targeted outreach through veteran-led case management teams. Veterans were connected to permanent housing along with mental health care, job training, and other essential services. Public-private partnerships also played a critical role in expanding housing access and employment opportunities.
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UNSHELTERED POPULATION
2025 Homeless Count Report
Demographic Breakdown
Gender: Between 2024 and 2025, the gender composition of Glendale’s unsheltered population shifted modestly. The number of unsheltered males increased from 59 to 70, a 19% rise, maintaining their status as the majority demographic. In contrast, the number of unsheltered females declined by 15%, from 20 to 17. Individuals identifying with a gender identity other than male or female were no longer represented in 2025, decreasing from 1 individual in the previous year to none.

The unsheltered homeless population in Glendale continues to be a significant concern, with an increase of 9% from 2024. The 2025 PIT count recorded 87 unsheltered individuals, compared to 80 in the previous year. This increase highlights not only the housing affordability crisis but also the growing intersection of homelessness with mental health challenges. Many unsheltered individuals struggle with untreated or under-treated mental health conditions, which can hinder their ability to access services, maintain employment, or navigate housing systems. 15 1046 of 1125

2025 Homeless Count Report
The racial and ethnic composition of Glendale’s unsheltered population shifted notably between 2024 and 2025. The number of Hispanic individuals increased by 23%, rising from 22 to

27. White individuals grew modestly by 8%, from 26 to 28, while those identifying as Armenian experienced a sharp increase of 200%, from 5 to 15 individuals. In contrast, the number of Black individuals declined significantly by 61%, dropping from 18 to 7. Asian representation also decreased, falling by 20%, from 5 to 4 individuals. The Multiracial population saw a 33% increase, rising from 3 to 4. Notably, a new racial/ethnic category—Middle Eastern—was recorded for the first time, accounting for 1% of the population.

These demographic shifts underscore the evolving nature of homelessness in Glendale and highlight the need for culturally responsive, community-informed services that address the diverse experiences and needs of those affected.

The age distribution of the unsheltered population reveals notable and concerning trends, particularly among older adults. Between 2024 and 2025, the most significant growth occurred in two age groups. The 25-54 age group increased by 7%, rising from 44 to 47 individuals, and the number of individuals aged 55 and older grew by 16%, from 32 to 37.

By 2025, older adults made up a significant portion of the unsheltered population: 37 individuals (43%) were aged 55 or older, including 19 (22%) who were 65 and above. This aging population is particularly vulnerable, often facing greater health challenges and limited access to resources, highlighting the need for targeted support and intervention. 16 1047 of 1125

Employment Status: Economic hardship remains a contributing driver of homelessness. In 2025, 50 unsheltered individuals (57%) reported being unemployed—an increase from 35 individuals in 2024. This trend highlights the growing role of unemployment in perpetuating homelessness.

Even for those who are employed, many job opportunities in Glendale do not offer a livable wage, leaving low-income individuals unable to afford stable housing.

Among unsheltered individuals who reported having some form of income:
2025 Homeless Count Report
7 individuals (8%) reported earning more
than $1,000 per month.
6 individuals (6.9%) reported earning
between $501 and $1,000 per month.
7 individuals (8%) earned between $251
and $500 per month.
8 individuals (9%) earned between $1 and
$250 per month.
24 individuals (27.6%) reported having no
income at all, making it nearly impossible
for them to afford housing.

Barriers and Contributing Factors
Disabling Conditions Health issues remain a major barrier to overcoming homelessness. In 2025, a total of 20 individuals (23%) reported having at least one disabling condition, nearly double the 12 cases reported in 2024. Among these 20 individuals, many were living with multiple co- occurring health issues, including:
10 individuals (11%) with physical impairments
9 individuals (10%) with chronic health conditions
4 individuals (5 %) experiencing mental health issues
These overlapping conditions contribute to greater vulnerability and underscore the need for comprehensive, coordinated health and housing services.

Additionally, 3 individuals (3%) reported being diagnosed with AIDS, and 4 individuals (5%) indicated they were experiencing homelessness due to domestic violence.

These health-related challenges illustrate the complex needs of the unsheltered population, with many individuals requiring access to healthcare services, mental health counseling, and substance abuse treatment. Expanding access to these critical services is essential to helping people exit homelessness and prevent them from falling back into it. 17 1048 of 1125

SHELTERED POPULATION
Demographic Breakdown
Gender: Sheltered homelessness increased across all gender categories between 2024 and 2025.

The number of sheltered males rose by 12%, from 41 to 46, while the number of sheltered females increased by 15%, from 54 to 62, representing a larger share of the overall growth. In total, the sheltered population grew by 16%, increasing from 95 to 110 individuals. 2025 Homeless Count Report
Age: The 0–17 age group increased slightly from 47 to 51 individuals (a 9 % rise), continuing to makeup a substantial portion of the sheltered homeless population. The 18–24 group doubled from 3 to 6 individuals, marking a significant 100% increase. Adults aged 25–54 grew from 36 to 41 (a 14% increase), highlighting ongoing demand for services among working-age individuals.

Notably, the 55+ group saw a sharp increase from 9 to 12 individuals, a 33.3% rise, underscoring the growing presence of older adults in the sheltered population and the urgent need for more age-appropriate services and support for seniors.

Factors Contributing to Homelessness: Of the 87 unsheltered individuals counted, 20 (23%) reported unemployment as the primary cause of their homelessness, 17 (20%) cited high rent, 9 (10%) mentioned divorce or separation, 5 (6%) pointed to illness, and 1 (1%) attributed their homelessness to COVID-19. An additional 9 individuals (10%) identified other reasons, including family conflict, incarceration, disputes with landlords, substance abuse, and fleeing domestic violence. 32 individuals declined to answer the question. 18 1049 of 1125

HOMELESSNESS AMONG

GLENDALE RESIDENTS
2025 Homeless Count Report
Within households with children, the majority were female, with 51 individuals (66%) compared to 26 males (34%). The group was predominantly Hispanic/Latina/o, with 34 individuals (45% of the subgroup), followed by 18 Black or African American (23%), 11 White (14%), 6 American Indian or Alaska Native (8%), 5 identifying as White and Hispanic/Latina/o (6%), and 3 Middle Eastern or North African (4%).

Homelessness in Glendale has escalated in recent years, with a 28% increase in the number of residents experiencing homelessness in 2025 compared to 2024. According to the 2025 Unsheltered Homeless Count, 43%, 37 out of 87 unsheltered individuals surveyed reported that they were experiencing homelessness for the first time in Glendale. One of the most striking findings from the 2025 survey is that 62%, or 23 of the 37 individuals who became homeless for the first time in Glendale have lived in the city for more than a decade, and in some cases, for their entire lives.

These 23 individuals have deep ties to the community, having lived and worked in the city for over 10 years before experiencing homelessness.

Those identifying as White remained steady at 26 in both years, while the number of individuals identifying as both White and Hispanic dropped sharply from 12 to 5, a 58% decrease. New representation appeared among individuals identifying as American Indian, Alaska Native, or Indigenous (increasing from 0 to 6) and those identifying as Middle Eastern or North African (from 0 to 3). Conversely, individuals identifying as Asian and Multi-Racial were no longer represented, with both groups decreasing from 6 in 2024 to 0 in 2025.

Households without Children were primarily composed of adults, with no individuals under 18.

Among this group, there were 11 females (33%), 20 males (61%), 1 transgender individual (3%), and 1 person identifying with more than one gender (3%). Racially, 15 individuals (46%) identified as White, 12 (36%) as Black or African American, and 6 (18%) as Hispanic/Latina/o.

Racial and Ethnic Composition: Between 2024
and 2025, the racial and ethnic composition of
the sheltered population shifted notably. The
most significant increase was among individuals
identifying as Black, African American, or
African, rising from 9 to 30, a 233% increase.

The number of individuals identifying as
Hispanic/Latina/e/o grew modestly from 36 to
40, an 11% rise.
19 1050 of 1125

2025 Homeless Count Report
The ethnic composition of Glendale’s homeless population reflects a diverse community.

Hispanic/Latina/e/o individuals made up the largest group, accounting for 14 people, followed closely by those identifying as Armenian, with 12 individuals. White individuals represented 8 people within the homeless population, while 2 identified as Black, African American, or African.

One individual identified as Middle Eastern. This distribution highlights the presence of both long- standing and immigrant communities among those experiencing homelessness in Glendale.

Demographic Breakdown
The demographic profile of the 37 individuals who became homeless for the first time in Glendale reveals significant trends in terms of gender, age, and employment status:

Gender: An overwhelming 84% of these individuals, or 31 out of 37, were male.

Age: Among the 37 individuals, 46% (or 17 individuals) were aged 55 or older. This reflects a concerning trend of older adults increasingly facing homelessness, a group that often faces unique challenges such as limited earning capacity, health problems, and fewer resources to navigate the housing system.
20 1051 of 1125

2025 Homeless Count Report
The factors contributing to homelessness for the 37 individuals who became homeless for the first time in Glendale reflect a complex mix of personal, economic, and structural issues. When asked about the main causes of their homelessness, respondents identified several key factors:

Rent Increases (38%): A significant number of individuals cited rising rent costs as a major factor leading to their homelessness, with 38% of the respondents indicating rent hikes as the primary reason for losing their housing. This marks a 75% increase in rent-related responses compared to the 2024 survey.

Unemployment (32%): Unemployment was another significant factor contributing to homelessness, with 32% of individuals citing job loss or inability to secure employment as the cause. Compared to 2024, the percentage of people reporting unemployment as a factor actually decreased by 14%. However, unemployment remains one of the largest contributing factors, pointing to the vulnerability of low-income residents who may lack job security, particularly in low-wage or precarious employment sectors.

Unexpected Illness (11%): Health issues have consistently played a role in contributing to homelessness, and 11% of the respondents in the 2025 survey pointed to unexpected illness as a cause. This response mirrors the findings from the 2024 survey, showing that health problems—whether physical or mental—remain a major vulnerability for individuals at risk of homelessness.

Divorce or Separation (8%): Divorce or separation accounted for 8% of responses, marking a 25% decrease from the 2024 survey. While it remains a significant factor, the decrease suggests that family breakdowns might be somewhat less prominent as a cause of homelessness compared to previous years.

Barriers and Contributing Factors
Employment Status: Of the 37 individuals, a substantial 84% (or 31 individuals) reported being unemployed at the time they became homeless. Among the unsheltered individuals surveyed, 1 person was employed and earning between $251 and $500 per month, while 1 person earned between $501 and $1000, and 3 people earned more than $1000per month. These figures show that even among those employed, many still face significant financial challenges. On the other hand, 11 unemployed individuals reported earning $0 income, 6 individuals earned between $1 and $250, 2 earned between $251 and $500, 4 earned between $501 and $1000, and 5 earned over $1000. These figures highlight the extreme financial insecurity many individuals face, with the majority struggling to earn enough to secure stable housing. 21 1052 of 1125

2025 Homeless Count Report
Disabling Conditions: In 2025, 5 out of 37 individuals surveyed (14%) reported health-related issues, including general health problems (8%), physical health conditions (5%), mental health issues (3%), and substance use (3%). This represents an increase from 2024, when only 3 out of 37 individuals (8%) reported health challenges, with general health issues at 3%, physical health conditions at 5%, mental health issues at 3%, and substance use at 3%. The rise in health-related issues from 8% in 2024 to 14% in 2025 suggests that health problems are becoming an increasingly significant barrier to stability and housing among the homeless population.

COVID-19 (1%): Only 1 person reported falling into homelessness due to the COVID-19 pandemic, a figure that mirrors the response from the 2024 survey. While the pandemic certainly exacerbated homelessness for many individuals, it appears to have had a lesser impact on the 2025 cohort of homeless individuals in Glendale compared to previous years. 22 1053 of 1125

CONCLUSION AND

RECOMMENDATIONS
Conclusion: The 2025 homeless count in Glendale reveals a deepening and increasingly complex homelessness crisis, with the total population rising to 197 individuals, a 13% increase from 2024.

While both sheltered and unsheltered populations grew by 16% and 9%, respectively, the most concerning development is the 183% rise in chronic homelessness among the unsheltered population, indicating a troubling escalation in long-term, entrenched homelessness driven by systemic and personal barriers such as unemployment, rising rent costs, and disabling health conditions.

Chronic homelessness, in particular, presents urgent challenges. A majority of these individuals suffer from disabling conditions, notably physical and general health issues, and many have long- standing ties to Glendale, having lived in the city for years before becoming homeless.

Despite the overall rise in homelessness, the decrease in chronic homelessness among the sheltered population suggests that interventions like emergency housing vouchers have had a positive impact. However, this progress remains limited, as these vouchers offer only a temporary solution and are no longer available. Without additional resources or permanent housing options, sustaining this progress will be challenging.

Demographic shifts further underscore the evolving nature of Glendale’s homeless population.

Among the sheltered, there was a dramatic rise in individuals identifying as Black and Hispanic/Latina/e/o, along with new representation of American Indian/Alaska Native and Middle Eastern/North African individuals. Meanwhile, the unsheltered population showed significant increases in Armenian, White and Hispanic representation, suggesting changing patterns of visibility, outreach effectiveness, or community-specific challenges.

Subpopulation data adds further urgency: increases in mental illness, HIV/AIDS, and domestic violence-related homelessness demonstrate the interconnectedness of health, safety, and housing stability. Notably, the rise in youth homelessness, especially among parenting youth, highlights the need for tailored services that address the unique needs of this group.

Recommendation: To effectively address the rising rates of homelessness in Glendale, particularly among chronically homeless and unsheltered individuals, the city should continue the implementation of a Housing First strategy, integrated with wraparound support services. Special attention should be given to high-risk subpopulations such as veterans, parenting youth, and individuals with disabling conditions. Additionally, expanding culturally competent outreach efforts to better meet the diverse cultural needs of the community, ensuring that services are culturally responsive and accessible to all.
2025 Homeless Count Report
23 1054 of 1125

2025 Homeless Count Report
24 Moreover, targeted interventions for vulnerable groups, including older individuals and survivors of domestic violence, should be expanded. Based on the survey responses, a significant portion of Glendale’s homeless population has long-term ties to the city, meaning that community- based solutions and local partnerships will be essential in addressing the issue.

Glendale CoC shares geographic boundaries with Service Planning Areas (SPAs) 4 and 6—regions that are significantly impacted by high rates of homelessness. This geographic overlap compounds the challenges faced by the unsheltered population, placing additional pressure on local resources and systems. Therefore, regional coordination and support is essential to bring l in additional services and ensure homelessness is rare, brief and non-reoccurring. 1055 of 1125

UNSHELTERED LIVING CONDITIONS

TOTAL POPULATION
197

RACE/ETHNICITY

HOUSEHOLD TYPES
GENDER
shelteredUnsheltered
Multiracial White
Hispanic/Latina/e/o
Middle Eastern or North African
Black, African American or African
Asian or Asian American
American Indian or Alaska Native
White & Hispanic Latina/e/o01020304050
4 26
434027
31 30
7 461 5
44%56%
AGE

DISTRIBUTION
2025 POINT-IN TIME (PIT) COUNT
02/19/2025
Of the 193 individuals counted, 120 (62%) were in households without children, which is a 17% increase from 2024. The remaining 73 individuals (38%) were in households with children, representing a 1% increase from the previous year.

Outdoors
(38) 44%
vehicles
(15) 17%
abandoned
buildings
(5) 6%
bus/train
stations
(2) 2%
parks
(1) 1%
church
(1) 1%
tent
(1) 1%
+7%-36%
The majority, 70% were adults aged 25 and older, with 13% of the total population being 65 years or older.

Gender: 55% identified as
male, 44% as female, 1% as
transgender and more than
one gender.

The 2025 PIT count recorded 87 unsheltered individuals, compared to 80 in the previous year. This population includes individuals living in places not meant for human habitation, such as parks, streets, vehicles, abandoned buildings, and other makeshift shelters. Of the 87 individuals, 24 declined to disclose their specific sleeping location or conditions.

Ethnicity: Of those counted, 34% were
identified as White ( including individuals
of Armenian descent), 34% as Hispanic,
18% as Black, 4% as White & Hispanic
Latina/e/o, 4% as American Indian, 2% as
Asian, 2% as Middle Eastern, and 2% as
multiracial.

Decrease from 2024
Increase from 2024
Refused: 24 individuals
+7%
+17%
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VETERANS
SUBpOPULATION

SPECIAL NEEDS

YOUTH

UNSHELTERED CHRONIC HOMELESSNESS
A total of 17 individuals
were identified as
chronically homeless, a
significant increase from just
6 individuals in 2024.

Of these 17, 10 became
homeless in the city of
Glendale.

In the 2025 count, 7 individuals aged 18 to
24 were identified, reflecting a 17%
increase from the previous year.

Among these youth, 2 were unsheltered, a
slight decrease from the 3 unsheltered
youth reported in 2024.

Mental Illness: 15 adults identified with serious
mental illness, representing a 7% inccrease from the
14 individuals counted in 2024.

Substance Use Disorder: 2 adults were reported
with substance use disorder, showing no change from
2024.

HIV/AIDs: 3 individuals with HIV/AIDS were identified,
double the number reported in 2024.

Survivors of DV: 24 victims of domestic violence
were identified, marking a 20% increase from 2024.

The number of unsheltered veterans remained unchanged in 2025 compared to 2024, with 4 individuals. However, the number of sheltered veterans decreased by 100% from 2024. 1057 of 1125

HOMELESSNESS AMONG

GLENDALE RESIDENTS
Of those 14 , 86% (12 individuals ) were male, and 50% (7 individuals ) were aged 55 or older.

Of the 37 individuals
who became
homelss for the first
time in Glendale,
62% (23 individuals)
had lived in the city
for more than a
decade, and in some
cases, for their
entire lives.

Length of Time in the Community
Employment StatusAge and Gender
Gender: 84% ( 31
individuals) of the 37 were
male, and 16 % (6
individuals) were female.

Age: 49% (18 individuals)
of the 37 first-time
homeless individuals were
aged 55 or older.

Income was higher among those who were unemployed
38% (14 individuals ) of the 37 became homeless due to high rents.

Factors Contributing to Homelessness
Of the 87 unsheltered
individuals surveyed in
Glendale, 43% (37
individuals) reported that
this was their first time
experiencing
homelessness in the city.

First Time Homeless
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TRENDS
2023-2025
Domestic Violence
Population
Annual Unsheltered Homelessness
2023-2025
Annual Unsheltered vs PIT Count
2023-2025
Sheltered vs Unsheltered
Population
Unsheltered Population
by Age
Sheltered Population
by Age
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U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WASHINGTON, DC 20410-5000

OFFICE OF PUBLIC AND INDIAN HOUSING

www.hud.gov espanol.hud.gov

______________________________________________________________________________

Special Attention of:

Public Housing Directors;
Regional Public Housing Directors;
Public Housing Agencies

Notice PIH 2025-19

Issued: June 20, 2025

Expires: This notice remains in effect until
amended, superseded, or rescinded.

Cross References: Notice PIH 2025-07;
Notice PIH 2021-15; Notice PIH 2021-20

Subject: Guidance on Transitioning EHV Families into HCV and End of EHV Services Fee Expenditure

1. Purpose

This notice provides guidance to Public Housing Agencies (PHAs) on how to transition Emergency Housing Voucher (EHV) families into its Housing Choice Voucher (HCV) program. PHAs may elect to transition EHV families into the HCV program so that EHV families do not experience a loss or gap in housing assistance and can remain in their assisted units. Further, this notice informs PHAs that they may no longer expend services fees beginning 60 calendar days from the publication of this notice and that they must complete all remaining services fee expenditure reporting in the Voucher Management System (VMS) 120 days from the publication of this notice.

2. Background

EHVs are tenant-based rental assistance under Section 8(o) of the United States Housing Act of 1937 (42 U.S.C. 1437f(o)).1 Eligibility for EHVs is limited to individuals and families who are (1) homeless; (2) at risk of homelessness; (3) fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking; or (4) recently homeless and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability.

The ARP made EHV funds available for obligation by HUD until September 30, 2030, and those funds will be cancelled as a matter of law effective September 30, 2035.

However, due to historic increases in rental prices resulting in a higher per unit cost

1 Section 3202 of the American Rescue Plan Act of 2021 (P.L. 117-2, hereafter referred to in this notice as “the ARP”) appropriated $5 billion for new incremental EHVs as part of the response to the impact of the COVID-19 pandemic.
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2 (PUC) for EHVs, HUD estimates that the Department will only have sufficient funds to cover all EHV families through most of Calendar Year (CY) 2026.

In March 2025, HUD published Notice PIH 2025-07, which directed PHAs to stop issuing any new EHVs after 14 calendar days and reminded PHAs that any incoming EHV ports must be billed to the initial PHA. Additionally, HUD obligated all remaining EHV funding to PHAs. Through this notice, HUD is encouraging PHAs to begin planning for the wind-down of the EHV program as the funding for the program is likely to be expended by the end of CY 2026. PHAs are advised to consider planning a careful transition of families, which may include transitioning families into the PHA’s HCV program, in accordance with this notice. PHAs opting to take this action must follow the procedures described in Section 3 of this notice for adopting a preference for EHV families if the PHA has not already adopted such a preference.

When allocating EHVs to PHAs in 2021, HUD also awarded $245 million in services fees to help facilitate the leasing of EHVs as well as retain and support participating EHV owners. Eligible expenses for services fees, as described in Notice PIH 2023-23, fall into four categories: (1) housing search assistance; (2) security deposit, utility deposit, rental application, and holding fees; (3) owner-related uses; and (4) other eligible uses. HUD expanded the use of services fees in 2023 to provide more opportunities for PHAs to use the fees to support currently housed EHV families. Future guidance on returning unexpended service fees and reallocation is forthcoming.

3. Transitioning EHV Families into the HCV Program

HUD strongly encourages PHAs to transition EHV families to the HCV program so that EHV families do not lose assistance and potentially face homelessness. PHAs that choose this option should provide clear information to EHV families about the process for applying to the HCV waiting list under an EHV preference, the status of EHV funding, and why the PHA is adopting an EHV preference. PHA communication to EHV families should also clearly explain that choosing to apply and be transitioned to the HCV program is optional for the family. Further, communication to families should explain the potential consequences of remaining on EHV assistance, including the risk of termination of assistance due to lack of permanent EHV funding.

In transitioning a family into HCV, a PHA is making assistance payments with funding under its consolidated HCV Annual Contributions Contract (24 CFR 982.4(b)). In order to transition EHV families into its HCV program, the PHA must have HCV unit-months available to use for EHV families. The prohibition on HCV over-leasing as described in Section IV.F.3 of Notice PIH 2025-13 applies. Information on EHV waivers (which do not apply to HCV) and transitioning families to the HCV program follows in subsection c. below.

PHAs are reminded that EHV funding cannot be used for regular HCV Housing Assistance Payment (HAP) costs, even for former EHV families, once the EHV family has been transitioned to the regular HCV program.
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3 PHAs should consider using HUD’s Two-Year Tool (TYT) to help them determine how many EHV families may remain in their program towards the end of CY 2026. Because the amount of remaining EHV funding is known and not subject to annual appropriations, there are fewer unknown variables and PHAs can use PUC trends and attrition rates to estimate the number of families that may need to be transitioned to HCV.

a. Waiting Lists

In order to transition EHV families into the PHA’s regular HCV program, the family must be selected through the PHA’s HCV waiting list as required by 24 CFR 982.204(a).

PHAs that currently have an open waiting list should take the following steps:
 Determine if establishing a waiting list preference constitutes a significant amendment to its PHA Plan (24 CFR 903.21).
 If the PHA determines that establishing a waiting list preference constitutes a significant amendment, complete the process for updating the PHA Plan (24 CFR 903.17). PHAs must provide a public comment period, which is a statutory requirement that cannot be waived by HUD.
 Complete the process for updating the administrative plan (24 CFR 982.54). Per 24 CFR 982.54(a), revisions to the administrative plan must be formally adopted by the PHA’s Board of Commissioners or other authorized PHA officials.

PHAs with a currently closed HCV waiting list who opt to transition EHV families may choose to open their waiting list only for families that qualify for an EHV preference. In this case, the PHA must include the preference in its administrative plan (24 CFR 982.54(d)(1)).

b. Preferences

PHAs may establish a local preference based on local housing needs and priorities as determined by the PHA (24 CFR 982.207(a)(2)), and this may include families participating in EHV. PHAs that want to transition EHV families into the HCV program should structure the preference in a way that provides clarity that only current EHV participants are eligible for the preference. For example, the preference could state that it is for currently assisted EHV families whose assistance is at risk of termination due to lack of program funding.

There are multiple methods that PHAs may use to apply preferences, including lumping, aggregating, and ranking. PHAs have discretion to apply preferences through several methods, provided that the selected methods comply with fair housing and civil rights requirements. In establishing an EHV preference, PHAs will need to consider how the preference method(s) they currently employ will impact the desired goal of moving EHV families to the top of the PHA’s waiting list to expediently transition EHV families.

There are no priority preferences with lumping or aggregating methods, but PHAs can use a ranking method to weigh an EHV preference above all other existing preferences.

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4 Some PHAs may only have available HCVs to transition a portion of their EHV families.

PHAs in this situation may want to consider adopting multiple EHV preferences to first prioritize the most vulnerable households. For example, PHAs could adopt a preference for EHV families with a head of household, spouse, or co-head who is elderly or disabled, and a second preference for all other EHV families. In designing preferences, PHAs are reminded that all preferences must be consistent with fair housing and civil rights laws.

PHAs with Mainstream vouchers available may consider adopting a preference for EHV families that meet Mainstream eligibility requirements. To transition families into Mainstream, families must be Mainstream-eligible, and the family must be properly added to the waiting list consistent with statutory, regulatory, and other requirements.2 This option does not apply to Special Purpose Voucher (SPV) programs other than Mainstream. These SPV programs have statutory eligibility requirements that EHV families cannot meet and/or involve partnerships that require the PHA to receive referrals from certain sources (i.e., the Family Unification Program, Foster Youth to Independence, HUD-Veterans Affairs Supportive Housing, and Stability Vouchers). Per Section IV.E.1 of Notice PIH 2025-13, the same prohibition on over-leasing applies for Mainstream.

Once the PHA has adopted its EHV preference(s), the PHA should ensure effective communication of notice to all EHV families about the new preference and the opportunity to apply for the HCV program under the preference. PHAs should provide a reasonable amount of time to EHV families to apply for the HCV program before selecting any EHV families from their HCV waiting list. As an alternative to only accepting individual applications from EHV families, HUD is providing a streamlined submission and review process for a regulatory waiver that, if approved, would permit PHAs to place all EHV families on its HCV waiting list with the appropriate preference.

To ensure streamlined processing, PHAs must submit their waiver request in DocuSign.

PHAs must provide certain information within the waiver request document, including:
 PHA name, code, and business address
 Name and email for the PHA point of contact
 A PHA-specific justification for the waiver that shows good cause. The good cause justification must include: 1) why the PHA needs the waiver, and 2) the impact on PHA operations and applicants if the waiver is not provided.

Following submission, PIH will reply via email confirming that the request has been received. Once a final determination for approval by the Assistant Secretary has been made, PHAs will receive the signed response to the waiver request via email. No waiver requested may be implemented unless written approval from HUD has been obtained.

2 Notice PIH 2024-30, Statutory and Regulatory Waivers for Mainstream Vouchers, for mandatory and optional waivers and alternative requirements related to waiting lists in the Mainstream program. 1063 of 1125

5 c. EHV waivers and alternative requirements

PHAs are reminded that the EHV waivers and alternative requirements outlined in Notice PIH 2021-15 do not apply to their HCV program. However, as discussed below, families that were properly admitted to the EHV program and are currently receiving EHV assistance are participants under a section 8(o) tenant-based voucher program. This section discusses the requirements that apply (particularly with respect to criminal screening and income) when a PHA is transitioning a family from EHV to HCV assistance. In addition, this section reviews EHV waivers that PHAs may have opted to use and the existing flexibilities available to PHAs in lieu of those waivers to minimize disruption to EHV families.

Criminal Rescreening. Families that were properly admitted to the EHV program by PHAs in full compliance with the requirements of Notice PIH 2021-15 and are currently receiving EHV assistance are participants under a section 8(o) tenant-based voucher program. Therefore, applicant screening requirements do not apply when the PHA is transitioning a family from EHV to HCV assistance. All HCV requirements with respect to termination of assistance for participants apply to EHV families when they are transitioned to HCV assistance.

Income Eligibility and Targeting. Families that were properly admitted to the EHV program by PHAs in full compliance with the requirements of Notice PIH 2021-15 and are currently receiving EHV assistance are participants under a section 8(o) tenant-based voucher program. Therefore, the income-eligibility and targeting requirements in 24 CFR 982.201, which apply to applicants, do not apply in cases where the PHA is transitioning a family from EHV to HCV assistance. All HCV requirements with respect to participant family income and composition (particularly, 24 CFR 982.516) apply to EHV families when they are transitioned to HCV assistance.

Social Security Number and Citizenship Verification. In Section 9(i) of Notice PIH 2021-15, HUD waived the requirement to obtain and verify documentation of social security number (SSN) and eligible noncitizen status (if applicable) before admitting families to EHV. HUD established an alternative requirement that individuals must provide the required documentation within 180 days of admission to remain eligible for continued assistance, pending verification, unless the PHA provided an extension based on evidence from the family or confirmation from the CoC or other partnering agency that the family has made a good-faith effort to obtain the documentation.

A PHA may not transition a family from the EHV program to the HCV program until it verifies documentation of SSN and eligible noncitizen status. The EHV alternative requirement in this section does not apply to HCV program.

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6 Payment Standards and Rent Reasonableness. To increase housing choice for EHV families, section (9)(p) of Notice PIH 2021-15 waived 24 CFR 982.503(a)(3), allowing PHAs to set separate, higher payment standards for EHV. PHAs were permitted to establish EHV payment standards up to 120 percent of Fair Market Rent (FMR) without HUD approval.

PHAs that chose to set higher payment standards for EHV may want to consider two options to minimize harm to families: (1) If the EHV payment standards are above 110 percent and up to 120 percent of applicable FMR, the PHA could align both programs’ payment standards by using the simplified process described in Section 5B of Notice PIH 2024-34, or (2) the PHA could hold families harmless and choose not to reduce the payment standard amount used to calculate the subsidy for a family as long as they continue to reside in the same unit (see Section 10 of Notice PIH 2024-34).

PHAs should note that the requirement limiting the family share to 40 percent or less of monthly adjusted income at initial occupancy (24 CFR 982.508) does not apply if the family is leasing in place.

d. HAP Contract and Tenancy Addendum

As tenant-based assistance under section 8(o) of the United States Housing Act of 1937, EHV uses the same HAP contract (HUD-52641) and tenancy addendum as the regular HCV program. When transitioning an EHV family to HCV, PHAs are not required to execute a new HAP contract or tenancy addendum for the family provided that the family is remaining in the same unit.

e. PIC Reporting

When admitting an EHV family from the HCV waiting list, the family should be coded on line 2n of the HUD-50058 as “EHCV.” Moving to Work (MTW) PHAs should code the family on line 2p as “EHCV” on the HUD-50058 MTW and leave 2n blank. HUD will use this code to track the number of EHV families admitted to HCV but also to award the $1,000 fee per EHV family that is successfully transitioned to the regular HCV program, as described in Notice PIH 2025-13. PHAs will not receive the fee for transitioning EHV families if they fail to code the family as “EHCV” on line 2n or 2p for MTW PHAs. When a family transitions to HCV and remains in their unit, PHAs should not use action code 6 (“End Participation”) but instead use action code 3 (“Interim Reexamination”). If the family is not leasing in place, PHAs must use action code 7 (“Other change in unit”).

4. Services Fees

PHAs have 60 calendar days from the date of the publication of this notice to use services fees on eligible expenses, and an additional 60 calendar days from the date of the publication of this notice to complete services fees VMS reporting. PHAs should review

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7 Notice PIH 2023-23 that describes the eligible uses of services fees. PHAs will be required to repay any disallowed costs if services fees are used for ineligible expenses.

HUD will describe the process for recapture and reallocation of services fees in a separate, future notice.

5. Information Contact. Inquiries about this notice should be directed to [email protected].

6. Paperwork Reduction Act. The information collection requirements contained in this notice have been approved by the Office of Management and Budget (OMB) under the Paperwork Reduction Act (PRA) of 1995 (44 U.S.C 3520). In accordance with the PRA, HUD may not conduct or sponsor, and a person is not required to respond to a collection of information unless the collection displays a currently valid OMB control number. The active information collections contained in this notice have been approved under the PRA OMB Control Number 2577-0169.

_____________________________
Benjamin Hobbs
Principal Deputy Assistant Secretary
Office of Public and Indian Housing

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Previous version is obsolete Page 1 of 7 form HUD-50075-HCV (9/30/2027)

Status: Created

Streamlined Annual
PHA Plan
(HCV Only PHAs)
U.S. Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 9/30/2027

Purpose. The 5-Year and Annual PHA Plans provide a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA's operations, programs, and services. They also inform HUD, families served by the PHA, and members of the public of the PHA’s mission, goals, and objectives for serving the needs of low-, very low-, and extremely low- income families.

Applicability. The Form HUD-50075-HCV is to be completed annually by HCV-Only PHAs. PHAs that meet the definition of a Standard PHA, Troubled PHA, High Performer PHA, Small PHA, or Qualified PHA do not need to submit this form. Where applicable, separate Annual PHA Plan forms are available for each of these types of PHAs.

Definitions.

(1) High-Performer PHA - A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers (HCVs) and was designated as a high performer on both the most recent Public Housing Assessment System (PHAS) and Section Eight Management Assessment Program (SEMAP) assessments if administering both programs, SEMAP for PHAs that only administer tenant-based assistance and/or project-based assistance, or PHAS if only administering public housing.
(2) Small PHA - A PHA that is not designated as PHAS or SEMAP troubled, that owns or manages less than 250 public housing units and any number of vouchers where the total combined units exceed 550.
(3) Housing Choice Voucher (HCV) Only PHA - A PHA that administers more than 550 HCVs, was not designated as troubled in its most recent SEMAP assessment and does not own or manage public housing.
(4) Standard PHA - A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceed 550, and that was designated as a standard performer in the most recent PHAS and SEMAP assessments. (5) Troubled PHA - A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent. (6) Qualified PHA - A PHA with 550 or fewer public housing dwelling units and/or HCVs combined and is not PHAS or SEMAP troubled.

A. PHA Information.

Public Availability of Information. In addition to the items listed in this form, PHAs must have the elements listed below readily available to the public. A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. Additionally, the PHA must provide information on how the public may reasonably obtain additional information of the PHA policies contained in the standard Annual Plan but excluded from their streamlined submissions. At a minimum, PHAs must post PHA Plans, including updates, at each Asset Management Project (AMP) and main office or central office of the PHA and should make documents available electronically for public inspection upon request. PHAs are strongly encouraged to post complete PHA Plans on their official websites and to provide each resident council with a copy of their PHA Plans.

PHA Consortia: (Check box if submitting a joint Plan and complete table below) Participating PHAs PHA Code Program(s) in the
Consortia
Program(s) not in the
Consortia
No. of Units in Each
Program

B. Plan Elements.

B.1 Revision of Existing PHA Plan Elements.

a) Have the following PHA Plan elements been revised by the PHA since its last Annual Plan submission?

Y N
Statement of Housing Needs and Strategy for Addressing Housing Needs. 1067 of 1125

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Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions.

Financial Resources.

Rent Determination.

Operation and Management.

Informal Review and Hearing Procedures.

Homeownership Programs.

Self Sufficiency Programs and Treatment of Income Changes Resulting from Welfare Program Requirements.

Substantial Deviation.

Significant Amendment/Modification.

(b) If the PHA answered yes for any element, describe the revisions for each element(s):

Financial Resources:

Financial Resources Required to Fully Fund All Programs

Programs Total Vouchers Funding

Glendale HCV HAP $30,891,168
Glendale HCV Admin Fee $2,380,479
Glendale HCV Total 1,592 $33,271,647

VASH HAP $261,900
VASH Admin Fee $29,250
VASH Total 15 $291,150

Mainstream Voucher HAP (MSV) $272,160
MSV Admin Fee $27,300
MSV Total 14 $299,460

Fair Share Voucher HAP (FSV) $918,540
FSV Admin Fee $87,750
FSV Total 45 $1,006,290

Port HAP $18,696,000
Port Admin Fee $1,106,712
Port Total 950 $19,802,712

GRAND TOTAL 2,616 $54,671,259

Operation and Management:

Projected Early Depletion of Emergency Housing Voucher (EHV) Program Funding

Background of the EHV Program:

The Emergency Housing Voucher (EHV) Program was established in 2021 under the American Rescue Plan Act of 2021 in response to housing instability associated with the COVID-19 pandemic. The program was designed as a temporary initiative with funding originally projected through 2030. Through this effort, the U.S. Department of Housing and Urban Development (HUD) allocated approximately 70,000 tenant -based vouchers nationwide to assist households experiencing homelessness, those at risk of homelessness, and i ndividuals fleeing domestic 1068 of 1125

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violence. The Glendale Housing Authority (GHA) received an allocation of 225 vouchers. While the full allocation was initially leased, the program currently serves 188 households due to natural attrition.

Shift in Timeline and Current Program Status:

Despite the original funding horizon of 2030, updated national projections indicate that EHV program funds are expected to be depleted by calendar year 2026. The earlier than expected depletion of funds is largely attributable to rapid initial lease-up rates and higher-than-anticipated rent subsidies driven by rising housing costs nationwide.

EHV Program Outlook in Glendale:

Increased subsidy costs have affected both the EHV and the regular Housing Choice Voucher program. Increased expenditures have contributed to the Section 8 program entering shortfall status and temporarily suspending leasing from the waiting list. Under current financial conditions, the GHA does not have the capacity to absorb EHV participants into the regular voucher program.

Even if the Section 8 program were to return to stable funding, absorbing EHV participants into the regular program would not be recommended. Doing so would substantially reduce the availability of assistance for applicants who have remained on the waiting list since 2001, including elderly households awaiting the opportunity to receive housing support.

While the GHA has the option to place EHV households onto the regular waiting list, this approach is not recommended because it would adversely affect existing applicants by altering the order and timing of assistance for families who have been waiting since 2001.

GHA Response:

In preparation for the projected loss of EHV funding, the GHA has notified participants to support advance planning. The GHA will coordinate closely with the Homeless Continuum of Care (CoC) Program to identify and pursue alternative housing resources. At the same time, the GHA is expanding service partnerships, including collaboration with Gateways Hospital and Mental Health Center to provide targeted case management for participants with behavioral health needs.

In addition, the GHA continues to advocate for supplemental EHV funding at the state and federal levels through its participation in professional housing organizations, including National Association of Housing and Redevelopment Officials (NAHRO), California Association of Housing Authorities (CAHA), and Public Housing Authorities Directors Association (PHADA).

B.2 New Activities.

(a) Does the PHA intend to undertake any new activities related to the following in the PHA's applicable Fiscal Year?

Y N
Project-Based Vouchers

(b) If Project-Based Voucher (PBV) activities are planned for the applicable Fiscal Year, provide the projected number of PBV units and general locations, and describe how project-basing would be consistent with the PHA Plan.

B.3 Progress Report.

Provide a description of the PHA's progress in meeting its Mission and Goals described in its 5-Year PHA Plan.

1) Optimize Leasing and Subsidy Allocation: Maintain a balanced leasing rate to maximize program participation while ensuring sufficient rent subsidies are provided for Section 8 applicants and recipients to afford decent, safe, and sanitary housing.

Progress Report: Since December 2024, the GHA has operated in shortfall status due to expenditures exceeding the available budget authority. During this period, the GHA has successfully applied for and received shortfall funding from HUD to ensure continued payment of housing assistance subsidies for existing participants. However, as a condition of receiving this funding, HUD has restricted the GHA from leasing new applicants from the waiting list. As a result, leasing activity has been halted, and the GHA has been unable to fully utilize its HUD-authorized voucher allocation. (see Voucher Allocation and Utilization Summary below).

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Voucher Allocation and Utilization Summary
Voucher Program Voucher Allocation Vouchers Under Lease Unfunded Vouchers Glendale HCV 1592 1377 215
Fair Share 45 38 7
Mainstream 14 12 2

Total 1651 1427 224

2) Achieve High Performer Designation in SEMAP: Strive to achieve and maintain a “High Performer” designation in HUD’s Section Eight Management Assessment Program (SEMAP).

Progress Report: For FY2024-2025, the GHA earned a High Performer designation in HUD’s Section Eight Management Assessment Program (SEMAP), earning a perfect score of 130 out of 130 possible points.

3) Update Administrative Plan Policies: Regularly review and update policies in the Administrative Plan to implement regulatory and policy changes in a timely manner.

Progress Report: The GHA conducted a review of its Administrative Plan and updated program policies to reflect recent HUD regulatory changes and policy guidance. The revised Administrative Plan is scheduled to take effect on May 1, 2026.

4) Review and Update Payment Standards: Periodically review and update payment standards to ensure they remain within 90 to 110 percent of Small Area Fair Market Rents (SAFMRs) and are sufficient to enable Section 8 applicants and recipients to afford decent, safe, and sanitary housing.

Progress Report: In 2025, the GHA reviewed and updated its payment standards in compliance with HUD requirements to remain within 90 to 110 percent of Small Area Fair Market Rents (SAFMRs). Due to current budgetary constraints, median payment standards were established at 93 percent of SAFMRs. While set toward the lower end of the allowable range, the payment standards continue to support participant leasing activity and enable households to secure decent, safe, and sanitary housing, as demonstrated by ongo ing participant moves.

5) Maintain Housing Quality: Ensure Section 8 units meet HUD’s standards for being decent, safe, and sanitary.

Progress Report: From July 1, 2025, through January 31, 2026, the GHA conducted a total of 1,445 Housing Quality Standards (HQS) inspections to ensure Section 8 units met HUD requirements for decent, safe, and sanitary housing. In addition, supervisory Quality Control inspections were performed to verify inspection accuracy and ensure consistent application of HUD standards.

6) Maintain Internal Controls: Maintain robust internal controls to reduce errors in rent determinations.

Progress Report: The GHA implemented ongoing Quality Control reviews of Section 8 participant files to verify the accuracy and regulatory compliance of rent determinations. As part of internal controls, all rent determinations completed by newly trained staff were subject to 100 percent supervisory review during the training period. In addition, proposed rent increases were reviewed to confirm that rents were reasonable and comparable to similar units in the community.

7) Provide Training Opportunities for Section 8 Staff: Offer professional and internal training on HUD regulations, policies, and procedures to ensure program compliance and the adoption of industry best practices in administering the Section 8 program.

Progress Report: The GHA provided professional and internal training opportunities to Section 8 staff to support program compliance and the adoption of industry best practices. Management -level staff participated in the following external training courses and conferences:

• Emphasys Engage 2025, hosted by Emphasys, which included training on Small Area Fair Market Rents (SAFMRs), voucher program updates, portability, and system functionality. • PHA Operations for New Executive Leaders, offered by National Association of Housing and Redevelopment Officials (NAHRO), covering budgets and operating subsidies, capital funds, ACOPs and Administrative Plans, waiting lists, program decision-making, and human resources. • HCV Portability, offered by NAHRO, providing detailed guidance on portability eligibility, roles of initial and receiving PHAs, required documentation, and special portability considerations under VAWA, reasonable accommodations, and VASH.
• HCV Financial Management, offered by Nan McKay and Associates, Inc., focusing on budgeting, cash management, financial reporting, and HUD compliance requirements. • SEMAP Self-Assessment, offered by Nan McKay and Associates, Inc., providing guidance on conducting internal assessments of SEMAP compliance.

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In addition, senior staff provided comprehensive in-house training to newly hired Section 8 caseworkers, with 100 percent quality control review of their work conducted throughout the training period.

8) Pursue New Funding Opportunities and Additional Vouchers: Apply for new Notices of Funding Availability (NOFAs) and lobby for additional vouchers to expand affordable housing programs whenever opportunities arise.

Progress Report: During this fiscal year, no new Notices of Funding Availability (NOFAs) or voucher expansion opportunities applicable to the GHA were issued. The GHA continued to advocate for additional vouchers and expanded affordable housing resources through its partic ipation in regional, state, and national housing organizations (see Item #12).

9) Enhance Portability Processes: Maintain a streamlined portability transfer processes, enabling families to be issued vouchers, search for units, and lease up in their desired neighborhoods as quickly as possible.

Progress Report: The GHA maintained a streamlined portability process designed to facilitate timely voucher issuance, unit search, and lease-up for port-in families. A single point of contact was designated for all incoming portability cases, promoting consistent communication and efficient processing. Port-in participants received vouchers promptly, and once suitable units were identified, inspections were scheduled and completed expeditiously, allowing households to move in while lease-up documentation was finalized with property owners.

10) Perform Payment Reconciliations: Conduct periodic reconciliations of incoming portability housing assistance payments to ensure accuracy and accountability.

Progress Report: A designated staff member conducts ongoing reconciliations of incoming portability housing assistance payments for vouchers administered by the GHA to verify accuracy and maintain financial accountability.

11) Process Waiting List Updates Promptly: Ensure timely processing of applicant-reported updates for the Section 8 waiting list to facilitate quicker qualification when applicants are pulled from the list.

Progress Report: The GHA processed applicant-reported waiting list updates promptly upon receipt to ensure that current and accurate information was used when determining preference points and applicant eligibility at the time of selection.

12) Participate in Housing Organizations: Maintain membership and active participation in housing organizations to stay informed about regulatory updates, industry trends, and best practices.

Progress Report: The GHA maintained active membership and participation in professional housing organizations to remain informed of regulatory updates, industry trends, and best practices. During the reporting period, the GHA participated in the following organizations:

• National Association of Housing and Redevelopment Officials (NAHRO) • Southern California National Association of Housing and Redevelopment Officials (So -Cal NAHRO)
• California Association of Housing Authorities (CAHA)
• Public Housing Authorities Directors Association (PHADA) • Southern California Association of Nonprofit Housing (SCANPH)

13) Conduct Marketing and Outreach: Conduct program marketing and landlord outreach events to attract new property owners to the Section 8 program while maintaining strong relationships with existing landlords.

Progress Report: On May 29, 2025, the GHA hosted an Owner Appreciation and Outreach Event designed to strengthen relationships with existing property owners and promote participation in the Section 8 program among prospective landlords. The event, held at Forest Lawn Museum, included a museum tour and provided opportunities for property owners to engage directly with Housing staff and City officials regarding program participation and benefits.

14) Strengthen Partnerships with Glendale Continuum of Care (CoC) Agencies: Collaborate with the Glendale Continuum of Care (CoC) and its partner agencies to support Section 8 participants with special needs, ensuring program compliance and long-term housing stability.

Progress Report: The GHA collaborated closely with the Glendale Continuum of Care (CoC) partner agencies to support participants with complex and special needs. CoC partner staff conducted in -person wellness checks, assisted with required documentation, and provided suppor t to address sanitary and housing stability challenges, helping ensure continued program compliance and participant well -being.

In addition, the GHA is expanding its partnerships with external service providers to strengthen long -term housing stability, particularly in preparation for the Emergency Housing Voucher (EHV) program winddown.

The GHA is in the process of finalizing a contract to fund a dedicated case manager position with Gateways Hospital and Mental Health Center. The case manager will collaborate with Housing and Homeless Services staff to provide intensive mental health support, daily case management, and care coordin ation aimed at improving housing stability for participants with behavioral health needs. 1071 of 1125

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B.4 B.4 Capital Improvements. - Not Applicable
B.5 Most Recent Fiscal Year Audit.

(a) Were there any findings in the most recent FY Audit?

Y N N/A

(b) If yes, please describe:

C. Other Document and/or Certification Requirements.

C.1 Resident Advisory Board (RAB) Comments.
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(a) Did the RAB(s) have comments to the PHA Plan?

Y N

(b) If yes, comments must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the RAB recommendations and the decisions made on these recommendations.

Resident Advisory Board meeting scheduled for February 25, 2026.

C.2 Certification by State or Local Officials.

Form HUD 50077-SL, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan.

C.3 Civil Rights Certification/ Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan.

Form HUD-50077-ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations
Including PHA Plan Elements that Have Changed, must be submitted by the PHA as an electronic attachment to the PHA Plan.

C.4 Challenged Elements. If any element of the PHA Plan is challenged, a PHA must include such information as an attachment with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public.

(a) Did the public challenge any elements of the Plan?

Y N

(b) If yes, include Challenged Elements.

This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added a new section 5A to the U.S.

Housing Act of 1937, as amended, which introduced the Annual PHA Plan. The Annual PHA Plan provides a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA's operations, programs, and services, and informs HUD, families served by the PHA, and members of the public for serving the needs of low- income, very low- income, and extremely low- income families.

Public reporting burden for this information collection is estimated to average 4.52 hours per response, including the time for reviewing instructions, searching existing data sources, gathering, and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions to reduce this burden, to the Reports Management Officer, REE, Department of Housing and Urban Development, 451 7th Street, SW, Room 4176, Washington, DC 20410-5000. When providing comments, please refer to OMB Approval No. 2577-0226. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number.

Privacy Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality.

Form identification: CA114-Housing Authority of the City of Glendale Form HUD-50075-HCV (Form ID - 7323) printed by Arthur Bolbolian in HUD Secure Systems/Public Housing Portal at 02/05/2026 01:28PM EST

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Formal public challenge to elements of the draft FY 2026–2027 PHA Annual Plan #3 Pursuant to 24 CFR 903.17 and 903.23(b) Submitted by: Ani Khash Date: May 3, 2026 To: Edgar Akopyan, Housing Division, Glendale Housing Authority ([email protected])
CC: City Clerk ([email protected]); City Council ([email protected]) Re: Civil rights certification under 24 CFR 903.7(o), including its component certification of affirmatively

furthering

fair

housing

and

disparate

impact

analysis

the

EHV

Program

Outlook

Glendale

recommendations

against

absorbing

listing

EHV

households

Formal challenge and scope

Pursuant to 24 CFR 903.17 and 903.23(b), this submission constitutes a formal challenge to the following

elements

the

draft

2026–2027

PHA

Annual

Plan

currently

posted

engage.glendaleca.gov

for

the

noticed

public

review

and

comment

period

running

February

20 through

May

2026

(the

"Plan"):

(1) The civil rights certification under 24 CFR 903.7(o), including its component certification of affirmatively

furthering

fair

housing

the

basis

that

the

Plan's

affirmative

recommendation

against

absorbing

EHV

households

into

the

regular

Housing

Choice

Voucher

(HCV)

program

and

against

placing

EHV

households

the

regular

waiting

list

unaccompanied

any

disparate

impact,

Section

504,

VAWA,

Title

analysis,

despite

the

policy's

foreseeable

effect

protected

classes

who

are

systematically

represented

within

the

population

EHV-eligible

households

defined

federal

program

rules;

(2) The Statement of Housing Needs under 24 CFR 903.7(a) and the Operation and Management element

under

24 CFR

903.7(e),

the

basis

that

the

"EHV

Program

Outlook

Glendale"

section

the

HUD-50075-HCV

form

(p.

elevates

the

interests

one

applicant

population

over

another

based

solely

length

waiting

time,

without

examining

the

demographic

composition,

protected-class

status,

current

housing

instability

either

group;

(3) The Statement of Strategy for Addressing Housing Needs under 24 CFR 903.7(a)(1), on the basis

that

the

Plan

does

not

consider,

evaluate,

reference

the

streamlined

waiver

and

EHV-only

waiting

list

preference

pathways

authorized

HUD

Notice

PIH

2025-19

("Guidance

Transitioning

EHV

Families

into

HCV

and

End

EHV

Services

Fee

Expenditure,"

issued

June

20,

2025),

the

federal

regulatory

tools

HUD

has

expressly

authorized

for

transitioning

EHV

households

into

HCV,

including

the

streamlined

waiver,

the

closed-waiting-list

reopening

for

EHV-preference

families,

and

the

ranked

multiple

preference

structures

described

the

Notice.

[ 1 ]
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I request that this challenge, and the PHA's written response to each challenged element, be attached

the

Plan

upon

submission

HUD

required

HUD-50075

Section

C.4.

The Housing Authority's public notice for this plan cycle does not inform the public that plan elements

may

formally

challenged

under

24 CFR

903.23(b),

that

challenged

elements

must

attached

the

Plan

upon

submission

HUD.

exercising

this

right

regardless.

Statement of facts
The Plan currently posted on the City's noticed engage.glendaleca.gov public comment portal contains

the

following

language

the

"EHV

Program

Outlook

Glendale"

section,

3 of

the

form:

"Even if the Section 8 program were to return to stable funding, absorbing EHV participants

into

the

regular

program

would

not

recommended.

Doing

would

substantially

reduce

the

availability

assistance

for

applicants

who

have

remained

the

waiting

list

since

2001,

including

elderly

households

awaiting

the

opportunity

receive

housing

support."

"While the GHA has the option to place EHV households onto the regular waiting list,

this

approach

not

recommended

because

would

adversely

affect

existing

applicants

altering

the

order

and

timing

assistance

for

families

who

have

been

waiting

since

2001."

These two paragraphs do two distinct things. They affirmatively recommend against absorbing EHV

households

even

under

hypothetically

stable

Section

8 funding.

They

affirmatively

recommend

against

placing

EHV

households

onto

the

regular

waiting

list,

context

which

the

Plan

acknowledges

this

authorized

"option."

The

Plan

supplies

one

and

only

one

rationale

for

both

recommendations:

protecting

2001

waiting

list

applicants

from

"altered

order

and

timing

assistance."

The Plan does not contain any of the following:
● Demographic data on the 188 EHV households served by GHA. ● Demographic data on the approximately 1,000 applicants on the regular HCV waiting list

whose

interests

the

Plan

elevates.

● Any disparate impact analysis under 24 CFR 100.500. ● Any Section 504 / 24 CFR Part 8 analysis. Any VAWA / 24 CFR Part 5 Subpart L analysis.

● Any Title VI / 24 CFR Part 1 analysis. ● Any reference to or analysis of HUD Notice PIH 2025-19. Any documentation of consultation

with

disability

rights,

domestic

violence

survivor,

fair

housing

organizations

regarding

the

recommendations.

[ 2 ]
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The EHV population is, by federal program design, drawn from a population the City of Glendale's

own

data

documents

composed

substantial

part

protected-class

members

The Emergency Housing Voucher (EHV) program was established by Section 3202 of the American

Rescue

Plan

Act

2021

(P.L.

117-2).

HUD's

Notice

PIH

2025-19

(the

"Notice"),

Section

confirms

that

EHVs

are

"tenant-based

rental

assistance

under

Section

8(o)

the

United

States

Housing

Act

1937

(42

U.S.C.

1437f(o)),"

and

that

"Eligibility

for

EHVs

limited

individuals

and

families

who

are

(1)

homeless;

(2)

risk

homelessness;

(3)

fleeing,

attempting

flee,

domestic

violence,

dating

violence,

sexual

assault,

stalking,

human

trafficking;

(4)

recently

homeless

and

for

whom

providing

rental

assistance

will

prevent

the

family's

homelessness

having

high

risk

housing

instability."

Each of these four federal eligibility categories intersects multiple protected-class statuses under

federal

civil

rights

law:

● Disability under Section 504 of the Rehabilitation Act and 24 CFR Part 8. ● Survivor status under the Violence Against Women Reauthorization Act of 2013 and 24 CFR

Part

5 Subpart

L.
● Sex under the Fair Housing Act and HUD's implementing regulations. ● Race, color, and national origin under Title VI of the Civil Rights Act of 1964 and 24 CFR

Part

1. The City of Glendale's own data documents the protected-class composition of the population from

which

its

EHV

recipients

are

drawn.

The

City's

"2025

Glendale

Homeless

Count,"

conducted

the

City's

Community

Development

Department,

Homeless

Services

Division,

and

published

the

"City

Glendale

2025

Homeless

Count

Report,"

available

engage.glendaleca.gov,

identified

197

individuals

experiencing

homelessness

the

City

Glendale

the

date

the

count,

13%

increase

compared

2024.

Of those 197 individuals, the City's own published findings record:
● 26 individuals identified as chronically homeless, an increase from 18 in 2024. Under 24 CFR

91.5,

chronic

homelessness

requires

the

documented

presence

diagnosable

substance

use

disorder,

serious

mental

illness,

developmental

disability,

post-traumatic

stress

disorder,

cognitive

impairments

resulting

from

brain

injury,

chronic

physical

illness

disability."
● 15 individuals experiencing serious mental illness. ● 24 individuals identified as survivors of domestic violence. ● 3 individuals living with HIV/AIDS.

The 2026 Glendale Homeless Count was conducted on January 20, 2026. The City's published timeline

indicates

the

2026

Homeless

Count

Report

anticipated

for

publication

May

June

2026.

The

City

was

therefore

possession

of,

actively

developing,

current

local

data

the

protected-class

composition

its

homeless

and

formerly

homeless

populations

during

the

period

which

the

2026–2027

PHA

Annual

Plan

was

drafted,

finalized,

made

available

for

public

comment,

and

presented

for

adoption.

The 188 EHV households served by GHA were drawn from populations meeting the federal

EHV

eligibility

criteria

described

Section

2 of

PIH

2025-19.

Federal

eligibility

[ 3 ]
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design makes it a reasonable inference that the 188 households include individuals with disabilities,

survivors

gender-based

violence,

and

members

racial

and

ethnic

groups

overrepresented

among

populations

meeting

these

criteria,

rates

substantially

elevated

above

the

rates

general

renter

applicant

population.

Glendale's

own

PIT

data

consistent

with

that

inference.

Whether

the

188

households

fact

mirror

that

distribution

data

the

Plan

does

not

produce.

The

Plan

also

produces

analysis

comparing

the

protected-class

composition

those

188

households

the

protected-class

composition

the

approximately

1,000

applicants

the

regular

HCV

waiting

list

whose

interests

the

Plan's

recommendations

elevate.

The

absence

either

dataset,

Plan

that

recommends

course

action

with

foreseeable

civil

rights

implications,

the

basis

which

this

challenge

brought.

The Plan's recommendations are made in direct contradiction of HUD's own published guidance

this

exact

situation

HUD Notice PIH 2025-19, at p. 2, Section 3, states in its first paragraph: "HUD strongly encourages

PHAs

transition

EHV

families

the

HCV

program

that

EHV

families

not

lose

assistance

and

potentially

face

homelessness."

The Notice's stated Purpose, at p. 1, Section 1, is that "PHAs may elect to transition EHV families

into

the

HCV

program

that

EHV

families

not

experience

loss

gap

housing

assistance

and

can

remain

their

assisted

units."

The Notice provides specific procedural pathways for PHAs in GHA's circumstances. At p. 3, Section

3.a,

the

Notice

states:

"PHAs

with

currently

closed

HCV

waiting

list

who

opt

transition

EHV

families

may

choose

open

their

waiting

list

only

for

families

that

qualify

for

EHV

preference.

this

case,

the

PHA

must

include

the

preference

its

administrative

plan

(24

CFR

982.54(d)(1))."

At p. 4, Section 3.b, the Notice describes the streamlined waiver: "As an alternative to only accepting

individual

applications

from

EHV

families,

HUD

providing

streamlined

submission

and

review

process

for

regulatory

waiver

that,

approved,

would

permit

PHAs

place

all

EHV

families

its

HCV

waiting

list

with

the

appropriate

preference."

The Notice also instructs PHAs, at p. 4, Section 3.b, that "In designing preferences, PHAs are reminded

that

all

preferences

must

consistent

with

fair

housing

and

civil

rights

laws."

The Plan does not reference PIH 2025-19. The Plan does not reference the streamlined waiver.

The

Plan

does

not

reference

the

EHV-only

waiting

list

preference

pathway

available

PHAs

with

closed

waiting

lists.

The

Plan

recommends

against

using

the

regulatory

pathways

HUD

has

expressly

authorized

for

the

situation

the

Plan

describes,

without

acknowledging

that

those

pathways

exist

analyzing

why

they

have

been

declined.

The

Notice

authorizes

multiple

mechanisms,

including

targeted

waiting-list

reopening

for

EHV-preference

families

(p.

Section

3.a),

ranked

and

multiple

preferences

prioritize

the

most

vulnerable

households

(p.

Section

3.b),

the

streamlined

waiver

place

all

EHV

families

the

waiting

list

(p.

Section

3.b),

and

Mainstream-voucher

use

where

eligible

(p.

Section

3.b).

The

Plan

addresses

none

them.

[ 4 ]
1077 of 1125

The AFFH certification deficiency under 24 CFR 903.7(o) Under 24 CFR 5.151, a PHA's AFFH certification is 'sufficient if the participant takes, in the relevant

period,

any

action

that

rationally

promoting

one

attributes

fair

housing

defined

section

5.150(a).'

Section

5.150(a)

defines

fair

housing

that

'affordable,

safe,

decent,

free

unlawful

discrimination,

and

accessible

required

under

civil

rights

laws.'

Foreseeable termination of housing assistance for a population that, by federal eligibility design under

PIH

2025-19,

systematically

composed

protected-class

members

not

rationally

promoting

affordable,

safe,

accessible

housing

free

unlawful

discrimination.

The

Plan

does

identify

certain

GHA

actions

EHV

wind-down:

notice

participants,

coordination

with

the

Continuum

Care,

the

Gateways

Hospital

partnership,

and

continued

participation

NAHRO,

CAHA,

and

PHADA.

None

those

actions,

described

the

Plan,

addresses

the

central

recommendation

against

using

HUD-authorized

pathways

that

would

prevent

loss

housing

for

the

affected

households.

Whether

those

actions,

taken

together

with

the

recommendation

against

absorption

and

against

waiting

list

placement,

satisfy

the

rational-relation

standard

the

question

this

challenge

places

squarely

before

HUD.

The contradiction is sharpened by HUD's own instruction at p. 4 of PIH 2025-19, Section 3.b, that

"all

preferences

must

consistent

with

fair

housing

and

civil

rights

laws."

HUD

anticipated

that

the

design

EHV

transition

preferences

would

itself

raise

fair

housing

and

civil

rights

questions

and

instructed

PHAs

accordingly.

The

Plan's

recommendation

against

creating

any

preference

all

does

not

exempt

GHA

from

the

underlying

civil

rights

analysis.

intensifies

the

question,

because

the

recommended

course

action

results

the

foreseeable

termination

housing

assistance

for

the

affected

population.

Disparate impact under 24 CFR 100.500
HUD's disparate impact regulation at 24 CFR 100.500 codifies the Fair Housing Act standard recognized

Texas

Department

Housing

and

Community

Affairs

Inclusive

Communities

Project
,

576

U.S.

519

(2015).

facially

neutral

practice

that

produces

discriminatory

effect

protected

class

violates

the

Fair

Housing

Act

unless

the

practice

necessary

achieve

substantial,

legitimate,

nondiscriminatory

interest

and

there

less

discriminatory

alternative.

The Plan's recommendations operate against a population the federal eligibility rules at PIH 2025-19,

Section

2 establish

systematically

composed

protected-class

members.

The

Plan

offers

"fairness"

rationale

rooted

length

time

the

waiting

list.

The

Plan

does

not

analyze

whether

less

discriminatory

alternatives

exist.

The

streamlined

waiver

pathway

and

EHV-only

preference

pathway

authorized

PIH

2025-19,

the

Notice's

allowance

for

closed-waiting-list

PHA

open

the

list

only

EHV

families,

the

Notice's

allowance

for

time-limited

preferences,

the

Notice's

allowance

for

ranked

preferences

that

prioritize

the

most

vulnerable

households

(p.

Section

3.b),

and

the

Notice's

express

guidance

permitting

PHAs

"consider

adopting

multiple

EHV

preferences

first

prioritize

the

most

vulnerable

households"

[ 5 ]
1078 of 1125

(p. 4, Section 3.b) are all less discriminatory alternatives that HUD has explicitly authorized under

the

same

federal

rules.

The

Plan

does

not

analyze

any

them.

The

Plan

does

not

explain

why

GHA

cannot

achieve

any

"fairness"

interest

means

less

burdensome

population

that

includes

individuals

with

disabilities,

survivors

gender-based

violence,

and

persons

protected

racial

and

ethnic

classes.

Section 504 / 24 CFR Part 8
Under Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) and 24 CFR Part 8, GHA may

not,

the

basis

disability,

deny

qualified

individual

with

disabilities

the

opportunity

participate

benefit

from

the

federally

assisted

program,

afford

benefit

that

not

equal

that

afforded

others,

provide

benefit

that

not

effective

affording

equal

opportunity.

policy

that

recommends

against

extending

continued

HCV

assistance

population

that,

federal

eligibility

design,

includes

individuals

with

disabilities

substantially

elevated

rates,

while

preserving

the

queue

position

comparison

group

whose

disability

composition

has

not

been

examined,

raises

Part

8 question

the

Plan

does

not

address.

The Plan's reliance on the Gateways Hospital and Mental Health Center partnership ("targeted case

management

for

participants

with

behavioral

health

needs,"

HUD-50075-HCV

form,

"GHA

Response";

see

also

Item

14 of

the

Progress

Report,

form

raises

separate

Part

8 question.

Conditioning

enhanced

service

the

presence

specific

Glendale City CouncilMay 5, 2026

Glendale City Council
May 5, 2026