Public comments 6 9 2026 — Glendale City Council, June 9, 2026

Ani <[email protected]>
Question following cancellation of June 2nd meeting re this - Re: Public comment on Substantial Amendment to FY 2025-2026 Annual Action Plan ($683,361 HOME CHDO allocation) — notice sufficiency, CHDO eligibility, and conflict of interest 2 messages
Ani <[email protected]> Thu, May 28, 2026 at 10:35 AM
To: "Brownell, Aaron" <[email protected]>
Cc: "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]>, "Fortney, Mike" <[email protected]> Bcc: [email protected]
Mr. Brownell,
Thank you for confirming on May 26 that my comment would be attached to the June 2 staff report.

I see the June 2 hearing on the FY 2025-2026 Annual Action Plan substantial amendment has since been cancelled, with Phases 1 and 2 of the HOME CHDO activity moving into the FY 2026-2027 Annual Action Plan effective July 1, 2026, and Phase 3 set for a separate Joint Housing Authority and City Council hearing on June 30, 2026.

So the public record stays complete across this change, please confirm in writing:

1. Will the FY 2026-2027 Annual Action Plan carrying this activity have its own public comment period and public hearing under 24 CFR

91.105, and on what dates?

2. Will my May 20 comment, including the points on notice sufficiency, CHDO eligibility under 24 CFR 92.2, and conflict of interest under 24 CFR 92.356, be carried forward in full into both the FY 2026-2027 Annual Action Plan record and the June 30 Phase 3 item, and attached to each corresponding staff report?

3. What is the total HOME funding for the full project, and the amount allocated to each of Phases 1, 2, and 3?

4. What is the current CHDO designation status of Verdugo Housing Corporation, and the date of any conflict-of-interest determination or disclosure made under 24 CFR 92.356?
Thank you,
Ani
On Tue, May 26, 2026 at 7:56 AM Brownell, Aaron <[email protected]> wrote:

Ms. Khash,

Your comments have been received and will be attached to the Staff Report for the Public Hearing on June 2nd, 2026.

Thanks,

You don't often get email from [email protected]. Learn why this is important Aaron Brownell | Senior Housing Project Manager
Community Development
141 N. Glendale Avenue, 2nd Level, Room 202, Glendale, CA 91206 P: +1 (818) 550-4530
[email protected] | GlendaleCA.gov | Follow us! 120 Years of Service to Our Community
From: Ani <[email protected]>
Sent: Thursday, May 21, 2026 12:18 PM
To: Brownell, Aaron <[email protected]>
Cc: 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: Re: Public comment on Substantial Amendment to FY 2025-2026 Annual Action Plan ($683,361 HOME CHDO allocation) — notice sufﬁciency, CHDO eligibility, and conﬂict of interest

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. Brownell,
Could you please conﬁrm receipt of this email from yesterday? My records show the email has been opened multiple times as well.

Thank you,
Ani

On Wed, May 20, 2026 at 1:22 PM Ani <[email protected]> wrote:

Dear Mr. Brownell,
This is a public comment on the Substantial Amendment to the FY 2025-2026 Annual Action Plan, which adds the activity "HOME CHDO Affordable Housing Rehabilitation" and proposes a HOME CHDO loan of $683,361 to Verdugo Housing Corporation to rehabilitate and expand an existing affordable housing facility in Glendale into 21 units of permanent supportive housing. Please conﬁrm receipt of this email, and please enter this comment into the administrative record so that it is addressed in the City's written summary of comments prior to the June 2, 2026 joint hearing.

The amendment names Verdugo Housing Corporation as the CHDO, describes it as "a HUD-designated Community Housing Development Organization," states that the project will create 21 units of permanent supportive housing, and provides that funds are to be committed by September 30, 2026. The amendment does not, however, identify the facility, its location beyond "City of Glendale, California," its current conﬁguration or residents, or the basis for the City's CHDO determination. So that the public and the Council can evaluate the proposal before the June 2 hearing, I respectfully request the following.

The recipient organization

1. The amendment identiﬁes the CHDO as Verdugo Housing Corporation. The California Secretary of State's records show two nonproﬁt public beneﬁt corporations of that exact name: entity 1788831 (formed 1996, active, registered agent James J. Howe, 221 E. Walnut Street, Suite 112, Pasadena) and entity 2449916 (formed 2002, suspended). Please conﬁrm which entity number is the borrower, and provide the organization's federal Employer Identiﬁcation Number, IRS tax-exempt status, and most recent IRS Form 990.

2. The current roster of Verdugo Housing Corporation's board of directors and ofﬁcers.

CHDO designation and certiﬁcation

3. The amendment describes Verdugo Housing Corporation as "a HUD-designated CHDO." CHDO status is certiﬁed by the participating jurisdiction, not by HUD directly. Please provide the City's CHDO certiﬁcation documentation for Verdugo Housing Corporation under 24 CFR 92.2, including how the City determined that the organization meets the board-composition requirement (at least one-third of the governing board representing low-income residents or community organizations), the requirement that the organization not be controlled by entities seeking proﬁt or gain, the demonstrated-capacity requirement, and the requirement of a history of serving the community within which the housing is located.

Contracts and agreements

5. Any contracts, memoranda of understanding, letters of intent, loan documents, or other agreements between the City of Glendale and Verdugo Housing Corporation related to this $683,361 allocation.

Conﬂict of interest disclosure

6. Disclosure of any conﬂicts of interest under 24 CFR 92.356 involving Verdugo Housing Corporation, its directors, ofﬁcers, employees, agents, contractors, or consultants, including any relationship between Verdugo Housing Corporation and Door of Hope. Public records indicate that Verdugo Housing Corporation and Door of Hope share a business address at 221 E. Walnut Street, Suite 112, Pasadena, and that James J. Howe, the registered agent of Verdugo Housing Corporation, holds an ofﬁcer position at Door of Hope. Door of Hope is listed in the City's own Continuum of Care social service agency directory and is understood to be a current City subrecipient. I request disclosure of the nature of this relationship and conﬁrmation of whether the disclosure and exception process required under 24 CFR 92.356(d) has been or will be followed.

The facility

7. The amendment does not name the facility being rehabilitated or its address. The City's own application to the California Department of Housing and Community Development for Homeless Housing, Assistance and Prevention (HHAP) funds describes Door of Hope as "the lead operator of the Glendale Access Center for Domestic Violence Survivors, Emergency, Interim and Permanent Housing Programs." Given the documented relationship between Verdugo Housing Corporation and Door of Hope, please conﬁrm whether the facility to be rehabilitated and expanded into 21 units of permanent supportive housing is a Door of Hope-operated site, and if so, which one. I recognize that the precise street address of a facility serving survivors of domestic violence may be subject to conﬁdentiality protections, and I am not requesting disclosure of any information that would compromise resident safety; I am requesting conﬁrmation of the operator and the nature of the facility.

9. Whether the facility is the same Parkview Glendale property at 426 Piedmont Avenue and 507 Naranja Drive that is the subject of the companion HOME-ARP Substantial Amendment moving to the same June 2 hearing, or a different facility at a different address. The amendment states this project creates 21 units of permanent supportive housing, while the companion HOME-ARP amendment concerns 11 HOME-ARP units at the 68-unit Parkview Glendale senior project developed by EAH Housing. Please clarify whether these are the same property, co-located, or distinct.

Notice and the September 30 deadline

92.356 conﬂict review will be completed and made public before any commitment of funds.

11. The amendment, as published for comment, names the CHDO and the dollar amount but does not identify the facility, its address, or its current residents. I request that the City post supplemental detail responsive to the questions above to GlendaleCA.gov/ AffordableHousing during the comment period. If that information cannot be made available with sufﬁcient time for public review before June 2, I request in the alternative that the public comment period be extended to permit informed comment after the information is posted.

I appreciate the City's attention to these questions and request a written response. I would prefer that these matters be clariﬁed on the record before the hearing rather than after adoption.

Sincerely,
Ani Khash
Brownell, Aaron <[email protected]> Fri, May 29, 2026 at 8:36 AM To: Ani <[email protected]>
You don't often get email from [email protected]. Learn why this is important Cc: "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]>, "Fortney, Mike" <[email protected]> Ms. Khash,

Thank you for your comments. City staff is no longer moving forward with the Substantial Amendment regarding the HOME-CHDO funds. Therefore, any further comments regarding this amendment are considered moot. All initial comments have been reviewed, and staff responses are provided directly below in red font. These responses will be formally attached as an exhibit to the June 30th agenda item.

Sincerely,

Aaron Brownell | Senior Housing Project Manager
Community Development
141 N. Glendale Avenue, 2nd Level, Room 202, Glendale, CA 91206 P: +1 (818) 550-4530
[email protected] | GlendaleCA.gov | Follow us! 120 Years of Service to Our Community
From: Ani <[email protected]>
Sent: Thursday, May 28, 2026 10:36 AM
To: Brownell, Aaron <[email protected]>
Cc: 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]>; Fortney, Mike <[email protected]>
Subject: Question following cancellation of June 2nd meeting re this - Re: Public comment on Substantial Amendment to FY 2025-2026 Annual Action Plan ($683,361 HOME CHDO allocation) — notice sufﬁciency, CHDO eligibility, and conﬂict of interest

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

Mr. Brownell,
Thank you for conﬁrming on May 26 that my comment would be attached to the June 2 staff report.

So the public record stays complete across this change, please conﬁrm in writing:

1. Will the FY 2026-2027 Annual Action Plan carrying this activity have its own public comment period and public hearing under 24 CFR

91.105, and on what dates?

- The item will appear on the June 2nd agenda and will be presented by the Community Services and Parks department. The public comment information can be found on their department’s subpage.

2. Will my May 20 comment, including the points on notice sufﬁciency, CHDO eligibility under 24 CFR 92.2, and conﬂict of interest under 24 CFR 92.356, be carried forward in full into both the FY 2026-2027 Annual Action Plan record and the June 30 Phase 3 item, and attached to each corresponding staff report?
- Staff will include your comments on the June 30th item and will be attached as an exhibit. However, I cannot confirm its inclusion on the June 2nd agenda as the item is being presented by the Community Services and Parks department. The public comment information can be found on the Community Services and Parks department’s subpage.

3. What is the total HOME funding for the full project, and the amount allocated to each of Phases 1, 2, and 3?

- HOME funding was appropriated for Phases 1 and 2 only, totaling $3,140,861. This information can be found in the December 2nd, 2025, staff report.

4. What is the current CHDO designation status of Verdugo Housing Corporation, and the date of any conﬂict-of-interest determination or disclosure made under 24 CFR 92.356?

- City Council officially designated the Verdugo Housing Corporation as a CHDO on December 2nd, 2025. The disclosures were attached as Exhibit 1 with the December 2nd, 2025, staff report.

Thank you,
Ani
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· This information was incorporated into the staff report dated December 2, 2025, attached as Exhibit 2.

2. The current roster of Verdugo Housing Corporation's board of directors and ofﬁcers. · This information was incorporated into the staff report dated December 2, 2025, attached as Exhibit 2.

CHDO designation and certiﬁcation

4. Whether Verdugo Housing Corporation has previously been designated as a CHDO by the City of Glendale or any other participating jurisdiction, and for which projects, and the date of the certiﬁcation the City is relying on for this allocation. · As previously mentioned, City Council officially designated the Verdugo Housing Corporation as a CHDO on December 2nd, 2025.

Contracts and agreements

5. Any contracts, memoranda of understanding, letters of intent, loan documents, or other agreements between the City of Glendale and Verdugo Housing Corporation related to this $683,361 allocation. · To date, no agreement has been executed or recorded related to the $683,361. The draft of the Affordable Housing Agreement was incorporated into the staff report dated December 2, 2025, attached as Exhibit 4.

Conﬂict of interest disclosure

1. The facility

8. The number of units before and after rehabilitation, the current resident population and the source of any existing subsidies, any affordability covenants currently recorded on the property, and the projected resident population after conversion to permanent supportive housing.
· The existing unit count is 14 units. Phases 1 & 2 will expand the facility to 21 units(The Staff Report incorrectly states 19 but was addressed in the hearing) and Phase 3 will expand the facility to 25 units. The total resident population varies depending on the household sizes.

Notice and the September 30 deadline

10. The amendment states that funds are to be committed by September 30, 2026, and that the recorded Affordable Housing Covenants will run for "a speciﬁed period of time." Please state the affordability period and conﬁrm that the certiﬁcation, underwriting, and 24 CFR 92.356 conﬂict review will be completed and made public before any commitment of funds. · The affordability term will run for 20 years from the date the Affordable Housing Agreement is recorded.

I appreciate the City's attention to these questions and request a written response. I would prefer that these matters be clariﬁed on the record before the hearing rather than after adoption.

Sincerely,
Ani Khash

Public Comment Regarding Emergency Housing
Voucher (EHV) Transition Planning and Continuity of
Assistance
Dear City Council,
You have been misinformed on several key points regarding the Emergency Housing V oucher (EHV) program.

1. Putting current EHV participants into a priority position on the Housing Choice V oucher waiting list is not “unfair to other participants in the program who have been waiting for 25 years.”
People on the waiting list are not participants in the program. They do not currently hold vouchers and are not receiving housing assistance. They only have the possibility of becoming participants in the future if and when a voucher is issued to them.

Current EHV households, by contrast, have already received vouchers and are active participants in the program.

HUD regulations define an “Applicant” as “a family that has applied for admission to the HCV program but is not yet a program participant.” 24 C.F.R. § 982.4. The same regulation defines “Participant” as “a family that has been admitted to the PHA program and is currently assisted in the program.” 24 C.F.R. § 982.4. HUD also provides that waiting lists are maintained for admission to the program. 24 C.F.R. § 982.204.

Therefore, individuals on a Housing Choice V oucher waiting list are applicants awaiting admission, not participants. Current EHV households, by contrast, have already been admitted to the program, are receiving housing assistance, and are participants.

Accordingly, it is factually incorrect to describe priority protection for current EHV households as “unfair to other participants” if the reference is to individuals who remain of 138
on a waiting list, because HUD regulations do not classify waiting-list applicants as participants.

These are two fundamentally different groups. Nevertheless, Housing Authority staff has repeatedly presented them to the City Council as equivalent categories. As a result, Council members continue to repeat the misleading claim that protecting current EHV households would be “unfair to other participants,” even though individuals on the waiting list are not participants at all.

I request that this critical distinction be clearly acknowledged and reflected in all further discussions and decisions.

Glendale Housing Authority already gives priority to homeless families and victims of domestic violence in the regular Housing Choice V oucher program. My family falls squarely within those categories. Therefore, Glendale cannot credibly claim that providing priority to current EHV participants would be “unfair,” as its own Administrative Plan expressly recognizes such priority treatment as lawful and appropriate.

2. The repeated characterization of EHV assistance as strictly “temporary” and therefore something that “must simply end” is misleading and inaccurate.

While the EHV program was created in response to the COVID-19 emergency, the housing assistance provided to participating households was never designed as temporary aid that automatically terminates without continuity. The very existence of detailed HUD guidance on transition mechanisms for EHV households directly contradicts this claim.

From the outset, HUD established formal pathways for transitioning EHV participants into the Housing Choice V oucher program and other permanent housing assistance. The presence of these explicit federal transition mechanisms demonstrates that abrupt termination without continuity was never the intended outcome of the program. (See Exhibit A.)
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3. This issue is urgent.

Independent analysis published in 2025 by the University of California identified the impending loss of EHV assistance as requiring immediate action. Failure to implement available transition mechanisms places current participants at real and imminent risk of losing housing. (See Exhibit B.)
The urgency of this issue was publicly acknowledged long before the recent hearing.

The 2025 University of California analysis was posted on HACLA’s website, demonstrating that major housing authorities were already taking the matter seriously.

Glendale Housing Authority was fully aware — or should have been fully aware — of the need for immediate transition planning.

Nevertheless, Glendale Housing Authority continues to minimize the urgency of the situation, resist priority placement for current EHV participants, and treat available transition mechanisms as unrealistic or unavailable.

Glendale Housing Authority has argued that priority placement for current EHV participants would be merely “symbolic” because of the projected Housing Choice V oucher program shortfall. However, Glendale Housing Authority has also acknowledged that HUD has provided mechanisms to address that shortfall. If the shortfall is reduced or resolved through HUD-authorized mechanisms, priority placement is no longer merely symbolic. Under those circumstances, priority placement becomes a meaningful pathway for current EHV participants to obtain continued housing assistance. Accordingly, Glendale Housing Authority cannot simultaneously rely on HUD mechanisms to address the shortfall while claiming that priority placement has no practical value because it is merely “symbolic.”
In addition, the Housing Authority has publicly minimized and devalued HUD- authorized transition mechanisms by characterizing them as merely “symbolic.” This characterization is misleading and dismissive. These mechanisms were expressly created of 338
and authorized by HUD to preserve housing assistance and prevent homelessness among current EHV participants. They are not symbolic — they are concrete federal tools designed to provide real and meaningful protection, including priority placement on the Housing Choice V oucher waiting list, Tenant Protection V ouchers, and other bridge mechanisms. By portraying these federally authorized protections as merely symbolic, the Housing Authority undermines the very solutions HUD has established to ensure continuity of assistance and prevent homelessness and displacement.

4. During the hearing, the Housing Authority repeatedly blurred and misrepresented the connection between the Administrative Plan and the transition of current EHV participants.

Although the City Council was told the Administrative Plan required immediate approval due to a May 7 deadline, the plan itself contains no meaningful strategy for transitioning current EHV participants. It includes no policy for priority placement on the Housing Choice V oucher waiting list, no absorption strategy, no commitment to request Tenant Protection V ouchers, and no specific measures to prevent displacement.

Staff claimed that EHV funding was “separate” from the plan, while deliberately failing to address critical transition measures. Instead, they offered only vague references to an undefined “EHV wind down plan” without explaining its content or protections for families facing displacement. This steered the discussion toward the simplistic narrative that the program is purely “temporary” and must end — ignoring HUD transition mechanisms successfully used by other housing authorities.

By contrast, the Los Angeles County Development Authority (LACDA) adopted a formal EHV Limited Preference specifically addressing the transition of current EHV participants facing the loss of EHV funding. LACDA’s Administrative Plan includes a defined policy for priority admission into the Housing Choice V oucher program and establishes a specific transition pathway for affected families. This demonstrates what a of 438
meaningful transition strategy looks like when a housing authority intends to utilize available HUD-authorized mechanisms. Glendale’s Administrative Plan contains no comparable transition policy despite acknowledging the projected loss of EHV funding and the impact on 188 current participant households. (See Exhibit D.)

5. Despite explicit requests from City Council members, including the Mayor, that affected EHV households receive clear written information about temporary local funding to extend assistance for approximately one additional year, the Housing Authority issued a grossly inadequate notice. The May 12, 2026 letter failed to disclose this critical fact. It stated only that staff is “monitoring guidance,” “evaluating potential local assistance options,” and is “not yet able to provide final determinations or timelines.” The letter omitted any mention of the City Council-approved local reserve funds, the expected duration of that funding, and available transition mechanisms. (See Exhibit C.)

6. Current EHV participants bear no responsibility for the Housing Authority’s long- standing administrative failures, chronic funding shortfalls, or the 25-year waiting list.

These issues, including any agreements between the Housing Authority and HUD regarding shortfalls, must be resolved separately and must not come at the expense of current EHV participants.

EHV households are a protected category under federal housing law. They should not be penalized or threatened with termination because of Housing Authority funding and administrative challenges or the failure to utilize available HUD-provided solutions.

Participants must not pay the price for mismanagement that was entirely outside their control.
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7. I strongly urge the City Council to immediately review the official HUD guidance on EHV transitions and take the following actions:
- Place all current EHV participants into a priority position on the Housing Choice V oucher waiting list.
- Require the Housing Authority to utilize every available HUD mechanism, including protected vouchers and bridge programs, to ensure uninterrupted housing assistance until each participant receives a Housing Choice V oucher.

The Housing Authority’s internal problems must be solved without displacing protected families who are currently in the program.

Sincerely,
Elena Razina
Emergency Housing V oucher Participant
Former Domestic Violence Shelter Resident
Glendale, California
06/08/2026
Exhibit list
Exhibit A
HUD and Related Guidance Regarding EHV Transition Planning and Continuity of Assistance
Contents:
• HUD EHV FAQ (Updated January 29, 2025)
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• LAHSA EHV FAQ (July 28, 2021)
• HUD Notice PIH 2025-19
Exhibit B
University of California Analysis Regarding EHV Funding Depletion and Urgency of Transition Planning
Contents:
• University of California publication regarding EHV funding depletion and homelessness risk
Exhibit C
Glendale Housing Authority Letter Dated May 12, 2026
Contents:
• Notice sent to EHV participants regarding EHV funding and future assistance Exhibit D
Los Angeles County Development Authority (LACDA) EHV Limited Preference Policy Contents:
• LACDA Board Memorandum (PDF page 4)
• LACDA Administrative Plan EHV Limited Preference (PDF page 138) of 738
Exhibit A
HUD and Related Guidance Regarding EHV
Transition Planning and Continuity of
Assistance
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Los Angeles Homeless Services Authority | Emergency Housing Vouchers Emergency Housing Vouchers (EHV)
Frequently Asked Ques�ons
Updated July 28, 2021
1How many vouchers are there in total?
There are approximately 6,800 vouchers across all
Public Housing Authori�es (PHAs) across Los Angeles
City and County.
2How long do EHVs last?
While EHVs are currently set to expire in 2030, EHVs
should be considered a permanent housing resource. It
is an�cipated that other funding or resources will
become available for persons housed with EHVs before
the expira�on date.
3When do vouchers need to be leased?
Vouchers need to be leased up by September 2023.

Any vouchers that have been issued but are not yet
leased by September 2023 will no longer be valid or
usable for housing.
6Do EHVs come with suppor�ve services?
No. Suppor�ve services were not included with these
vouchers, so any suppor�ve services needed to support
the applica�on and housing search and placement
process will need to be provided or leveraged.

Un�l addi�onal service slots can be guaranteed,
par�cipants who do not require ongoing suppor�ve
services are ideal for this opportunity.
4Who are the target popula�ons eligible for
these vouchers?
Priority Groups A-1 and A-2 will be priori�zed ﬁrst. In the absence of par�cipants from Priority Groups A-1
and A-2, Priority Groups B and C will be considered for referral and will be no�ﬁed via email.

For a detailed breakdown of the priority groups, please see the EVH PPT here.
5Can an EHV be used by any popula�on?
Yes, vouchers can be used by adults (18+), families
(households with a child under 18), and youth (16-24)
7Will there be addi�onal services added to
these vouchers?
System funders are working to increase and align
resources to provide addi�onal services for EHVs.

However, service commitments are limited at this �me.
8Is equity being considered when matching
these resources throughout the County?
Yes, LAHSA is working with partners and providers on
equity strategies to ensure equitable alloca�ons of
EHVs.
9How do I refer par�cipants to EHV?
HMIS-par�cipa�ng agencies should complete a
“Housing Voucher Interest Assessment” (found under
the par�cipant’s “Assessments” tab on their Clarity
proﬁles). Paper assessment forms are no longer
accepted as of July 21, 2021.
10If a case manager already completed the
PDF/paper Interest Survey for Housing
Choice Vouchers (HCV), do they need to
complete and submit another form?
No.
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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. of 1538

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

Exhibit B
University of California Analysis Regarding
EHV Funding Depletion and Urgency of
Transition Planning
of 1738
of 1838
Copyright 2025 Terner Center for Housing Innovation
www.ternercenter.berkeley.edu
BRIEF ! DECEMBER 2025
The Potential End of Emergency
Housing Voucher Funding:

Public Housing Agencies’ Search for Solutions
AUTHORS:

CHRISTI ECONOMY, RESEARCH ASSOCIATE, TERNER CENTER

RYAN FINNIGAN, DEPUTY DIRECTOR OF RESEARCH, TERNER CENTER

CLAUDIA AIKEN, DIRECTOR OF NEW RESEARCH PARTNERSHIPS,

NYU FURMAN CENTER

ELLIE LOCHHEAD, DOCTORAL FELLOW, NYU FURMAN CENTER

of 1938
BRIEF ! DECEMBER 2025
2 programs; many do not have available
slots, and those that can accommodate
EHV households may see increased pres-
sure on waitlists and their affordable hous-
ing pipelines.5 To conclude, we highlight
creative ways that PHAs are exploring to
sustain support to EHV households. We
also present evidence that addressing the
funding gap would only take a small in-
crease in funding: a 3.3 percent increase in
the 2025 annual HCV budget for housing
assistance payments would allow the pro-
gram to absorb all currently leased EHVs
in a way that accounts for rising rents, sig-
nificantly reducing the risk of returns to
homelessness for EHV recipients.

Background: Success of the
EHV Program
Launched with a $5 billion appropriation
through the American Rescue Plan Act
in 2021, the EHV program was designed
to rapidly house people during the Covid
pandemic, a time marked by heightened
health risks and the urgent need for safe
shelter. Like HCVs, EHVs are a type of
tenant-based assistance where partici-
pants contribute 30 percent of their ad-
justed monthly income to rent and utili-
ties, and the voucher covers the rest. EHVs
are specifically targeted to people current-
ly experiencing or at risk of homelessness
and people fleeing domestic violence, sex-
ual assault, or human trafficking.

EHVs differ from the HCV program in a
few ways, including: 1) referrals are made
through Continuums of Care (CoCs),
rather than through PHA waitlists, 2) the
program provides additional service fees
($3,500 per allocated voucher) to pay for
security deposits, housing search assis-
tance, landlord engagement, and other
move-in needs, and 3) payment standards
Introduction
The U.S. Department of Housing and Ur-
ban Development (HUD) announced in
March 2025 that funding for Emergency
Housing Vouchers (EHVs) will run out
before the end of 2026.1 At the program’s
peak, EHVs helped house almost 70,000
households experiencing or at risk of
homelessness. Analysts and practitioners
have highlighted the need for additional
federal funding to ensure that these indi-
viduals and families remain stably housed,
but the federal government has not yet
appropriated new funding.2 The lack of
ongoing funding for EHVs places signifi-
cant pressure on public housing agencies
(PHAs) to maintain support for participat-
ing families.

HUD has issued guidance to PHAs that
recommends transferring EHV house-
holds to assistance under their Housing
Choice Voucher (HCV) programs.3 How-
ever, many PHAs are already operating
at or above capacity (without any room
in their budgets to issue additional HCV
vouchers).4 Against this backdrop, PHAs
are urgently seeking ways to continue sup-
porting EHV households and prevent in-
creases in housing insecurity and returns
to homelessness.

This brief begins by highlighting the suc-
cesses of the EHV program, which scaled
rapidly to help reduce homelessness during
the Covid pandemic. It then presents find-
ings on implications of the program’s
wind-down: the end of EHV funding will
create steep challenges for voucher hold-
ers, place additional administrative bur-
dens on already capacity-strapped PHAs,
and may disrupt established partnerships
with landlords. In addition, PHAs will
face challenges absorbing EHV holders
into their Housing Choice Voucher (HCV)
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BRIEF ! DECEMBER 2025
3 can be set at 120 percent of HUD’s Fair
Market Rents (FMR) rather than the max-
imum 110 percent for most PHAs in the
HCV program.

Supplemental service fees have
been a key ingredient to getting
vulnerable people housed quickly.

PHA staff have emphasized the impor-
tance of the service fees for helping EHV
holders—many of whom were experienc-
ing homelessness and faced significant
barriers—to successfully lease homes.

PHAs have used service fees in a variety
of evidence-based ways to support rap-
id placements, including by providing
voucher holders with housing navigation
services and/or one-time cash assistance
to cover furniture, security deposits, or
application fees.6
One PHA leader said they used the service
fee to hire a third-party housing naviga-
tor, which “cut down search times consid-
erably” by giving families “a resource to
negotiate with landlords, identify more
choices by searching the market, and get
applications for units completed quickly.”
PHAs have also used the service fees to
strengthen efforts shown to improve land-
lord participation in the program: ramp-
ing up outreach efforts, offering incen-
tives for renting to voucher holders, or
creating damage mitigation funds to re-
duce perceived risks.7 As one PHA leader
explained, “For a landlord to have a face
to talk to, someone who’s not a [HUD] in-
spector… that landlord feels a lot better
about getting into this relationship if they
have something like that.”8
About 90 percent of PHAs have used the
service fees to help EHV holders success-
fully lease homes, and PHAs have spent
their service fees differently depending on
their local contexts (Figure 1). For exam-
ple, the Housing Authority of Santa Bar-
bara County—where the median rent is
about $2,200—has spent about $3,100 of
the $3,500 service fees per EHV on land-
lord incentives. In contrast, many PHAs in
the least expensive markets have primar-
ily used the service fees for other kinds
of expenses, such as furniture or other
move-in-related costs.

Some interviewees noted that EHV house-
holds would benefit from ongoing case
management or other support to maintain
stable housing. The service fees have not
been sufficient to provide ongoing support
in many places, however, and HUD has
begun reclaiming PHAs’ remaining ser-
vice fees.9 Nevertheless, interviewees also
provided examples of EHV service fees
enabling enduring improvements to their
operations, like adding in-house housing
navigation services that were sustained
through alternative funding and strength-
ening coordination with the homelessness
services system. Some PHAs have already
provided these services using adminis-
trative funding for the HCV program, but
that funding is often insufficient for cover-
ing the full cost of program implementa-
tion.10 PHA staff emphasized that dedicat-
ed funding for these services in the HCV
program would be a cost-effective way to
help all voucher holders successfully lease
homes. As one PHA director put it, “I sit
here and think, ‘HUD, when were you
going to realize how successful that was?’”
The EHV program supported nearly 70,000 households at its peak, helping to reduce homelessness across the country. of 2138
BRIEF ! DECEMBER 2025
4 The EHV program supported
nearly 70,000 households at its
peak, helping to reduce homeless-
ness across the country.

In the first two years of the program—much
of which overlapped with the height of the
Covid pandemic—the number of leased
EHVs grew to approximately 58,000 (Fig-
ure 2). The program peaked at 67,466
leased EHVs—which equated to roughly
12 percent of people in nightly counts of
homelessness in early 2022.11 At the end
of September 2025, 55,916 EHVs were still
being used to lease homes.

Previous research has demonstrated how
PHAs have strategically used EHVs to pre-
vent and end homelessness in their com-
munities.12 In Chicago, IL, the PHA has
dedicated portions of its EHV allocation
to support youth, families, and survivors
of gender-based violence.13 In Santa Clara
County, CA, EHVs have been a central part
of the County’s ‘Heading Home’ campaign
to end family homelessness.14 In Allegheny
County, PA, EHVs have been used to im-
prove flow through the local homelessness
service system by housing individuals who
have been in shelters for six months or
longer, as well as those ready to transition
out of permanent supportive housing to a
lower level of care.15
In March 2025, HUD announced that
funding for EHVs would be exhausted by
the end of 2026.16 The funding was ini-
tially meant to sustain the program for
10 years, but large rent increases across
much of the country accelerated the rate
at which the program’s funding has been
expended. The specific date at which cur-
rent funding will run out differs between
PHAs, depending on their per-unit costs.

HUD has strongly recommended that
PHAs absorb all leased EHVs into their
HCV programs when the current fund-
ing is exhausted.17 Interviewees said they
expected the initial 10-year period would
be long enough that they could absorb
Source: Voucher Management System data, U.S. Department of Housing and Urban Development; American Commu- nity Survey (2018–2022), U.S. Census Bureau
Note: The data are limited to 607 PHAs in the 50 states and District of Columbia. “Deposits” include security deposits, utility deposits, and rental application fees.

Figure 1: EHV service fee spending by eligible use category and local median rent

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BRIEF ! DECEMBER 2025
5 EHV households into the HCV program
gradually, and there would be fewer
households to absorb after that length of
time. However, if the program does end in
2026 (after only five years), they are in a
much more challenging position to ensure
housing stability for EHV households.

Findings
The end of the EHV program
will likely have detrimental
effects on voucher holders and
pose challenges for PHAs and
landlords.

EHV households will face steep
challenges in the absence of their
subsidies.

EHV households would be unable to
afford market rents without their vouch-
ers. Many communities have targeted the
program toward people experiencing un-
sheltered homelessness and/or chronic
patterns of homelessness—people who
typically face significant barriers to navi-
gating the private housing market.18 Half
of EHV households are single adults,19 and
data from 2024 showed that the average
EHV household had an annual income of
about $14,277.20 Most EHV households—
about 31,800—live in communities with
median rents of at least $1,500, and me-
dian rents are at least $2,000 for about
8,100 EHV households (Figure 3).21
Ending support to EHV households will
likely cause widespread harm. Many of
the supported households were experi-
encing homelessness when the program
launched in 2021, and stopping rental as-
sistance could push them back into pre-
carious housing situations. Research has
found that families who have exited home-
lessness with a time-limited subsidy have
often experienced the end of their rental
assistance as a “cliff,” and that long-term
Figure 2: Trend in the number of leased Emergency Housing Vouchers nationally, 2021–2025
Source: EHV Dashboard (September 2025) and Voucher Management System (September 2021 – March 2025) data, U.S. Department of Housing and Urban Development
Note: A small number of PHAs did not report data to the Voucher Management System in some months, which understates the total number of leased EVHs in a given month.

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BRIEF ! DECEMBER 2025
6 subsidies like vouchers are more effective
for preventing returns to homelessness.22
If all EHV households lost their homes, it
could significantly increase rates of home-
lessness in many places: for example, by
up to 15 percent in Texas and up to 31 per-
cent in Mississippi.23
In addition to the direct harms borne by
those losing their homes, widescale re-
turns to homelessness would also increase
burdens on public services that are already
thinly stretched. One PHA leader pointed
out that people currently served by their
EHV program represent approximately 30
percent of the county’s unsheltered home-
less population. An increase of that scale
would be a significant burden on local
nonprofit service providers, shelters, and
emergency response services.

Managing the transition of EHV
households amid continuing uncer-
tainty places significant adminis-
trative burdens on PHAs.

PHAs are devoting significant time and
energy to planning for the possible end
of the EHV program, and will need to
dedicate additional capacity to commu-
nicating with households and landlords
and processing households’ transitions to
other supports, if available. PHA leaders
described the difficulty of deciding when
and how to communicate the program’s
end to families and landlords. Giving early
notification may allow more time to pre-
pare, but may also increase families’ fears
and landlords’ motivation to evict, espe-
cially if the PHA is not prepared to share
a clear path for the continued support of
EHV households beyond 2026. One inter-
viewee, whose PHA opted for early notice,
reported experiencing “a very heavy call
volume and lots of pressure on staff as a
result.”
Figure 3: Share of Emergency Housing Voucher households by local median rent Source: EHV Dashboard data, U.S. Department of Housing and Urban Development; American Community Survey (2018–2022), U.S. Census Bureau
Note: The data are limited to 607 PHAs in the 50 states and District of Columbia.

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BRIEF ! DECEMBER 2025
7 PHAs must also balance the staff time it
will take to process households’ transi-
tion to other supports with the need to
expend as much EHV funding as possible.

One PHA leader explained, “Staffing-wise,
we have no capacity to move people [to
other voucher types] in June through Oc-
tober of 2026; it needs to happen now.”
However, any remaining EHV funding
cannot be shifted into the HCV program,
meaning that the PHA will have to begin
spending HCV program funds as soon as
EHV households are absorbed. As a result,
“We will leave some EHV money on the
table so that we can get everyone moved
in time.”
Whether and how to absorb EHVs into the
HCV program will be further complicated
for PHAs with large numbers of EHVs that
were originally issued in other jurisdic-
tions. When voucher holders move from
one PHA’s service area to another, called
“porting,” the receiving PHA must either
pay for the voucher from their own bud-
get or complete a billing process to receive
funds from the originating PHA. As a re-
sult, PHAs with a large number of ported-
in EHVs must coordinate with all originat-
ing PHAs to understand when their EHV
funding will be exhausted and whether the
EHVs will be absorbed into the originating
PHAs’ HCV programs.

The EHV program wind-down
could disrupt relationships with
landlord partners.

The end of the EHV program may also
have negative, unintended consequenc-
es on landlord partnerships. Landlord
participation is crucial to the voucher
program; however, they can be reluctant
to participate due to stereotypes about
voucher holders, such as fears about prop-
erty damage, or concerns about working
with the PHA, like potential administra-
tive burdens.24 In previous research, PHA
staff emphasized that the EHV’s program
design, which allows the service fee, was
critical to overcoming these barriers to
participation.25
An unexpected end to the EHV program
may undo the progress that PHA staff have
made in developing landlord relation-
ships. Landlords could lose trust that fed-
eral rental assistance programs or PHAs
are reliable if tenants lose their vouchers
or are forced to move to access another
program; the EHV program was initial-
ly advertised as lasting for 10 years, and
landlords expected long-term tenants with
guaranteed rent. For EHVs absorbed into
the HCV program, differences in allowed
payment standards between the EHV and
HCV programs may also negatively impact
landlords.

EHVs allowed for payment standards up to
120 percent of the Fair Market Rent (FMR)
without needing HUD approval, whereas
under the HCV program, PHAs typically
set payment standards within 90–110 per-
cent of FMR, or request an exception from
HUD to go higher. One PHA leader noted
that they are reconciling these program
differences to minimize the impact on ten-
ants and landlords by allowing the higher
payment standard to remain as long as the
tenant remains in the current unit (and re-
verting back to the typical payment stan-
dard if the tenant moves).

In addition to the direct harms
borne by those losing their
homes, widescale returns to
homelessness would also
increase burdens on public
services that are already
thinly stretched.
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BRIEF ! DECEMBER 2025
8 PHAs face many constraints to
absorbing EHV households
into their HCV programs.

Most PHAs do not have room in
their HCV programs to absorb EHV
households.

PHAs, policy experts, and advocates have
emphasized that most PHAs likely do not
have the resources to absorb all EHVs into
their HCV programs.26 The HCV program
has long been oversubscribed, and most
EHVs are administered by PHAs that al-
ready fully utilize their HCV resources.

About 39,300 EHVs—70 percent of all
EHVs—are administered by PHAs that
spent all of their HCV budgets in 2024.

About 8,900 more EHV vouchers are ad-
ministered by PHAs that used between 95
and 100 percent of their HCV resources
(Figure 4). Many of these PHAs lack the
resources to continue their current level of
assistance even within the HCV program,
let alone absorb additional EHVs.

This analysis illustrates the financial con-
straints facing PHAs, but several factors
beyond their voucher utilization rate will
determine their ability to absorb EHVs.

First, the HCV utilization rate does not
fully reflect expended/available resources
for Moving to Work (MTW) PHAs, which
have the flexibility to shift funds between
programs. Among EHVs administered by
PHAs with utilization rates below 95 per-
cent, almost all (87 percent) are admin-
istered by MTW PHAs. However, even
MTW agencies will have to make difficult
resource allocation decisions. For exam-
ple, one PHA leader described a tradeoff
between using flexible funds to absorb
EHVs or continuing to provide job search
and training resources to tenants. Anoth-
er PHA leader said that absorbing EHVs
would limit resources for their home-
lessness programs, including permanent
Figure 4: Number of Emergency Housing Vouchers by the PHAs’ HCV utilization rates in 2024 and Moving to Work status
Source: EHV Dashboard and Voucher Management System data, U.S. Department of Housing and Urban Development Notes: MTW = Moving to Work. HCV utilization is the greater of: 1) the share of a PHA’s authorized vouchers that were leased in January–December 2024, or 2) the share of a PHA’s budget for rental assistance payments that was spent in January–December 2024.

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BRIEF ! DECEMBER 2025
9 supportive housing and services for young
adults exiting the foster care system.

PHAs using 100 percent of their HCV re-
sources could still absorb EHVs as other
households gradually leave the HCV pro-
gram over time. However, many PHAs
are in a budget shortfall due to large rent
increases—meaning their costs for hous-
ing assistance payments exceed their bud-
gets—and they rely on attrition to bring
their program expenses back within their
budgets. Several of the PHA leaders we
spoke with faced a shortfall and were un-
sure when they might regain the ability to
issue vouchers.

PHAs can also maintain small reserves
of unspent budget authority that could
be used to absorb EHVs. However, those
reserves are often crucial for avoiding a
budget shortfall when program costs rise,
and HUD sometimes reclaims unspent re-
serves through an “offset.” In 2024, HUD
conducted two rounds of offsets, which is
rare and contributed to the share of PHAs
with a budget shortfall spiking to about
one in four.27
Absorbing EHV holders will re-
sult in longer wait times for other
households in need of rental assis-
tance.

Vouchers are scarce relative to need, and
households applying to the program often
wait many years before receiving a voucher
or never receive one at all. Among house-
holds that do eventually lease homes with
a voucher, the average wait time is about

2.5 years nationally, and in many commu-
nities, households wait for over five years
on average.28 Absorbing EHV households
into the HCV program will likely make
these wait times even longer. As one lead-
er from a small PHA shared, “Putting 96
EHV households on the HCV list means
putting them in front of 96 already on
the waitlist.” One leader from a large PHA
estimated that if they were to absorb all
of the EHV vouchers into their HCV pro-
gram, it would be about eight years before
they could serve anyone new.

Many households on voucher waitlists
lack stable housing or are experiencing
homelessness. Those who do rent hous-
ing while waiting for a voucher often have
little income remaining for essentials like
food, health care, and transportation.

These high housing cost burdens leave
households vulnerable to material hard-
ships, like the inability to afford food or
utilities,29 and poor physical and mental
health outcomes.30 Relatedly, households
waiting for a voucher often face risks of
housing instability, eviction, and home-
lessness.31 As one leader of a large PHA re-
flected, “Many of the folks on our waitlist
are at risk of homelessness. Having them
wait even longer will mean costs to our
community.”
Pressure on the HCV program to
absorb more families will stall
affordable housing developments
that include project-based vouch-
ers.

Some PHA leaders described how absorb-
ing EHVs would put pressure on the proj-
ect-based vouchers (PBVs) that they were
planning to use for affordable housing
developments. Typically, PHAs can “proj-
ect-base” up to 20 percent of their Housing
Choice Vouchers, where the voucher is tied
to a unit instead of a tenant. These PBVs
are often used to support new construc-
tion or rehabilitation projects by providing
a predictable revenue stream that reduces
financial risk for developers and lenders
and enables deep affordability. PBVs often
enable development that would not have
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BRIEF ! DECEMBER 2025
10 happened otherwise.32 The supply of PBVs
is particularly critical against the backdrop
of a nationwide shortfall of millions of af-
fordable units required to meet the hous-
ing needs of low-income households.33
If funding for the EHV program comes to
an end, some PHA leaders may be pushed
to choose between developing new afford-
able housing units with PBVs, or repurpos-
ing these resources to provide continuing
support to EHV holders. A PHA leader said
they have approximately 300 PBVs com-
mitted through 2028, but they may have
to pull back some of these commitments to
continue to assist EHV households. Oth-
ers are in a similar situation. A PHA leader
said they have already informed their de-
velopment community that they will not be
issuing any PBVs in the near future to ac-
commodate absorption of their remaining
EHV families. Another PHA leader reflect-
ed, “We don’t have philanthropy or bonds
to fall back on for affordable housing pro-
duction, so we’ve had to start thinking,
‘Are we going to cancel PBV contracts
and ruin that financing? Are we going to
not house EHV households?’ There’s no
good choice.” One PHA leader suggested
that if multiple EHV households are con-
centrated in a single, subsidized building,
the PHA might prioritize them for PBVs in
order to prevent a large shock to the land-
lord and forestall losses to the affordable
housing stock. However, these PBVs might
otherwise have been leveraged to spur ad-
ditional affordable housing developments.

Looking Forward
PHAs are exploring a range of part-
nerships and creative solutions
to sustain support to EHV house-
holds, but these efforts will likely be
insufficient.

PHAs without capacity to absorb EHVs
into their HCV programs are having to
think creatively about other ways to ex-
tend support to their EHV households.

For example, some PHA leaders described
plans to try and move EHV households to
public housing or PBV units as they be-
come vacant. One PHA leader described
a scenario in which the PHA might offer
public housing units to some EHV house-
holds. However, PHA leaders anticipate
challenges matching families with avail-
able units—for example, because the units
may be large, but half of EHV households
are a single adult. They also anticipate
challenges convincing families to move,
particularly without access to the support
services many had when they entered the
EHV program. As one PHA leader reflect-
ed, “Families are now disconnected from
services, and we’re having to explain
something that is stressful. We have to
think about that extra layer of supporting
families to make decisions for themselves
to stay housed.”
Some PHA leaders described working with
their local Continuums of Care (CoC), re-
gional bodies that coordinate homeless-
ness services, to navigate federal policy
and funding developments. When the
EHV program launched, CoCs played a
critical role by referring households who
were experiencing or at risk of homeless-
ness to receive a voucher. As the program
ends, turning to these CoC partnerships
can help ensure continued support for
EHV households. For example, eligible
One leader from a large public
housing agency estimated that
if they were to absorb all of the
Emergency Housing Vouchers
into their Housing Choice
Voucher program, it would be
about eight years before they
could serve anyone new.
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BRIEF ! DECEMBER 2025
11 EHV households could be prioritized for
placement in other CoC housing programs
as vacancies come up. One PHA leader
described how their CoC partners have
jumped right back in to help with the tran-
sition and collectively identify other pro-
grams for which EHV households might
be eligible. However, HUD has taken steps
to make changes to the CoC program34 (in-
cluding capping the amount of funding for
permanent supportive housing and other
homeless services), adding further uncer-
tainty and making it harder for PHAs (and
CoCs) to make decisions in an already un-
stable policy environment.

Many PHAs are still in the planning phase,
and staff are exploring a range of other
strategies to support EHV households as
the program ends. One PHA leader shared
that they are considering incentives to help
households who are doing well voluntarily
transition off the voucher program, in order
to open up slots for others in need. Others
discussed efforts to provide a “softer land-
ing”—such as covering security deposits or
moving costs—or to identify time-limited
rental assistance programs as a way to ex-
tend support to EHV families, albeit tem-
porarily. For example, one PHA is explor-
ing using Home Investment Partnerships
program (HOME) funds to offer two years
of tenant-based rental assistance to EHV
holders. (However, these HOME funds
may also be reduced or eliminated in next
year’s federal budget. Even if not, the PHA
will then divert the HOME funds from ef-
forts to expand affordable housing supply.)
A few communities may also have state or
local resources that could help bridge the
gap for EHV households. For example,
one PHA leader said they may explore
expanding their state rental assistance
program (modeled after HCV) to absorb
households they aren’t able to transition.

Another PHA leader described a rental
assistance continuity program they cre-
ated locally, which could be adapted to
support some of their community’s EHV
households.

Modest increases to the voucher
program’s budget could sustain
the EHV program and support the
implementation of other improve-
ments.

EHVs provide critical housing stability
to thousands of vulnerable households,
but as the current funding is exhausted,
many PHAs may be unable to sustain this
support. In deliberations on the voucher
program’s budget, Congress has an op-
portunity to preserve the EHV program
and build on what works. Based on recent
program costs and trends, we estimate
that modest increases to the 2025 budget
for Housing Assistance Payments (HAP)
would let the HCV program absorb cur-
rently leased EHVs, keep pace with ris-
ing costs (which exceed HUD’s inflation
factors), and expand tenant and landlord
supports in 2026 (Figure 5).

First, we estimate that a 3.3 percent in-
crease in the HAP budget would be
sufficient to absorb all currently leased
EHVs. This estimate does not account for
Another PHA leader reflected,
“We don’t have philanthropy
or bonds to fall back on for
affordable housing production,
so we’ve had to start thinking,
‘Are we going to cancel PBV
contracts and ruin that
financing? Are we going to
not house EHV households?’
There’s no good choice.”
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BRIEF ! DECEMBER 2025
12 remaining EHV funding, so the true cost
would be lower. Second, we estimate that
expanding the successes of the service
fees that came with EHVs to all newly is-
sued vouchers in the HCV program would
amount to only a 2.2 percent increase in
the HAP budget. Third, adjusting the allo-
cated budget for existing vouchers to bet-
ter reflect rising rents, which is necessary
to sustain all currently leased vouchers,
would amount to a 7.1 percent increase
over the 2025 HAP budget. The current
HUD budget has largely carried over
previous funding levels, which effectively
decreases the number of vouchers that can
be supported when combined with rising
costs.35 These modifications could help
the voucher program work better and help
more people stay housed for a relatively
modest cost.36
To complement federal efforts, strength-
ening state and local programs can help
build a more comprehensive system of
support and reach a larger share of house-
holds in need.37 A continuum of options
for rental assistance, with varying levels of
intensity, can enable communities to stra-
tegically target their resources and allow
households with different circumstances
to achieve housing stability. With this in
mind, tracking outcomes for EHV holders
and continuing to learn from the creative
approaches that PHAs are using to sustain
housing support can help to inform future
program design.

Figure 5: Estimated modiﬁcations to the 2025 Housing Assistance Payment budget Sources: EHV Dashboard (numbers of EHVs), HCV Dashboard (HAP 2025 budget, new admissions to the HCV program), and Voucher Management System data (EHV per-unit costs); U.S. Department of Housing and Urban Development Amount
(billions)
Percent Increase over
2025 HAP Budget
Current Total HAP Budget in 2025 $31.95 __
Absorb Current EHVs
Based on 55,916 currently leased EHVs for 12 months,
at current per-unit cost + the 6.1% increase observed
in March 2024 – March 2025
$1.05 3.3%
Add Service Fees for Newly Issued Vouchers
Based on $3,500/voucher for 199,941 new admissions
to HCV program in August 2024 – July 2025

$0.70 2.2%
Account for Cost Increase for Existing Vouchers
Based on 7.1% increase in per-unit costs observed in
2024–2025
$2.26 7.1%
Total Additions over the 2025 HAP Budget $4.02 12.6%
We estimate that a 3.3 percent
increase in the 2025 annual
HCV budget for housing
assistance payments would
allow the program to absorb
all currently leased Emergency
Housing Vouchers.
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ENDNOTES

1. HUD. (2025, March 6). “Emergency Housing Voucher Program Renewal Funding Allocation.” Retrieved from: https://www.nahro.org/wp-content/ uploads/2025/03/HUD-EHV-letter-3-6-2025.pdf

2. Acosta, S., and Akel, M. (2025, June 23). “Unless Congress Acts, 59,000 Additional Households at Risk of Homelessness.” Center on Budget and Policy Priorities. Retrieved from: https://www.cbpp.org/blog/unless-congress-acts-59000-addition- al-households-at-risk-of-homelessness; CLPHA. (2025, June 26). “Solutions Needed to Mitigate Devastating Effects of the Termination of the Emergency Housing Voucher Program.” Retrieved from: https://clpha.org/news/2025/clpha-out- lines-solutions-mitigate-devastating-effects-termination-emergen- cy-housing

3. HUD. (2025, June 20). “Guidance on Transitioning EHV Families into HCV and End of EHV Services Fee Expenditure.” Retrieved from: https://www.hud.gov/sites/ dfiles/OCHCO/documents/PIH_2025-19.pdf

4. Economy, C., et al. (2025). “Improving Utilization in the Housing Choice Voucher Program.” RAND Corporation. Retrieved from: https://www.rand.org/pubs/ research_reports/RRA3913-1.html

5. These qualitative insights come from interviews of PHA staff conducted by the Terner Center for Housing Innovation at UC Berkeley, the PHA Community of Practice run by the NYU Furman Center’s Housing Solutions Lab, and public presentations by PHAs and their partners.

6. Bergman, P., et al. (2023). “Creating Moves to Opportunity: Experimental Evidence on Barriers to Neighborhood Choice.” American Economic Review, 114, no. 5: 1281–1337.

DOI: 10.1257/aer.20200407

7. Garboden, P., Rosen, E., & Fleming-Klink, I. (2024). “Landlords and Housing Vouchers:
50 Years of Feedback.” Cityscape, 26, no. 2: 107–122. Retrieved from: https://www. huduser.gov/portal/periodicals/cityscape/vol26num2/article5.html

8. Economy, C., Finnigan, R., & Espinoza, M. (2023). “Using Emergency Housing Vouchers to Address Homelessness.” Terner Center for Housing Innovation, University of Cali- fornia, Berkeley. Retrieved from: https://ternercenter.berkeley.edu/research- and-policy/emergency-housing-vouchers-lessons/

9. HUD. (2025, June 20). Notice PIH 2025-19: Guidance on Transitioning EHV Families into HCV and End of EHV Services Fee Expenditure. Retrieved from: https://www. hud.gov/sites/dfiles/OCHCO/documents/PIH_2025-19.pdf

10. Economy, C., et al. (2025). “Improving Utilization in the Housing Choice Voucher Program.” RAND Corporation. Retrieved from: https://www.rand.org/pubs/ research_reports/RRA3913-1.html

11. To calculate this peak number, we first found the maximum number of EHVs leased at one time for each PHA between September 2021 and September 2025. We then added the maximum numbers from all PHAs.
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ENDNOTES

12. Urban Institute. (2025). “How Have Communities Used Emergency Housing Vouchers to Prevent and End Homelessness?” Retrieved from: https://www.urban.org/ projects/how-have-communities-used-emergency-housing-vouch- ers-prevent-and-end-homelessness

13. Moraras, P. & Doñate, A. (2025, May). How Chicago Used Emergency Housing Vouchers to Prevent and End Homelessness.” Urban Institute. Retrieved from: https://www. urban.org/sites/default/files/2025-05/How_Chicago_Used_EHVs_to_ Prevent_and_End_Homelessness.pdf

14. Heading Home. (2024). “The Santa Clara County Community Plan To End Homeless- ness.” Retrieved from: https://headinghomesv.org/

15. Moraras, P. & Doñate, A. (2025, May). How Pittsburgh and Allegheny County Used Emergency Housing Vouchers to Prevent and End Homelessness.” Urban Institute.

Retrieved from: https://www.urban.org/sites/default/files/2025-04/How_ Pittsburgh_Allegheny_County_Used_EHVs_to_Prevent_and_End_ Homelessness.pdf

16. HUD. (2025, March 6). Emergency Housing Voucher Program Renewal Funding Alloca- tion. Retrieved from: https://www.nahro.org/wp-content/uploads/2025/03/ HUD-EHV-letter-3-6-2025.pdf

17. HUD. (2025, June 20).

18. Moses, J. (2021). “What Happened After Congress Invested in Emergency Housing Vouchers: A Survey of Homeless Services Providers.” National Alliance to End Home- lessness. Retrieved from: https://endhomelessness.org/resources/research- and-analysis/what-happened-after-congress-invested-in-emergency- housing-vouchers-a-survey-of-homeless-services-providers/

19. Authors’ analysis of HUD administrative data.

20. Authors’ analysis of HUD administrative data.

21. For comparison, the average HCV household lives in a place with 2.0 million people, and 39 percent live in places with median rents of $1,500 or more.

22. Nápoles, T., Economy, C., & Reid, C. (2025). “Navigating the Post-Subsidy Cliff:

Considerations for Families Approaching the End of Rapid Rehousing.” Terner Center for Housing Innovation. Retrieved from: https://ternercenter.berkeley.edu/blog/ navigating-the-post-subsidy-cliff-considerations-for-families-approaching-the-end- of-rapid-rehousing/; Gubits, D., et al. (2016.) “Family Options Study: 3-Year Impacts of Housing and Services Interventions for Homeless Families.” U.S. Department of Housing and Urban Development. Retrieved from: https://www.huduser.gov/ portal/family_options_study.html

23. Acosta & Akel. (2025).

24. Cunningham, M. et al. (2018).; Garboden, Rosen, & Fleming-Klink. (2024). of 3238

ENDNOTES

25. Economy, C., Finnigan, R., & Espinoza, M. (2023).

26. Zaterman, S., Wills, R., & Oliva, A. (2025, August 11.) “CLPHA, NAEH, NLIHC Urge HUD to Rescind EHV Services Fees Spending Deadline.” Council of Large Public Housing Authorities. Retrieved from: https://clpha.org/news/2025/clpha- naeh-nlihc-urge-hud-rescind-ehv-services-fees-spending-deadline

27. Economy, et al. (2025).

28. Acosta, S., & Gartland, E. (2021, July 22). “Families Wait Years for Housing Vouchers Due to Inadequate Funding.” Center on Budget and Policy Priorities. Retrieved from:
https://www.cbpp.org/research/housing/families-wait-years-for-hous- ing-vouchers-due-to-inadequate-funding

29. Shamsuddin, S., & Campbell, C. (2021). “Housing Cost Burden, Material Hardship, and Well-Being.” Housing Policy Debate, 32 (3), 413–432. https://doi.org/10.108 0/10511482.2021.1882532

30. Grewal A., et al. (2024). “The impact of housing prices on residents’ health: a system- atic review.” BMC Public Health, 24 (1):931 https://pmc.ncbi.nlm.nih.gov/arti- cles/PMC10983630/

31. Acosta, S., & Gartland, E. (2021, July 22).

32. Emmanuel, D. & Aurand, A. (2024). “The Role of Vouchers in the Low-Income Housing Tax Credit Program.” Cityscape, 26, no. 2: 209–221. Retrieved from:
https://www.huduser.gov/portal/periodicals/cityscape/vol26num2/ article11.html

33. Up for Growth. (2023). “2023 Housing Underproduction™ in the U.S.” Retrieved from: https://upforgrowth.org/apply-the-vision/2023-housing-under- production/

34. Finnigan, R. (2025). “Changes to Federal Homelessness Funding Could Put More than 32,000 People in California at Risk of Losing Their Homes.” Terner Center for Housing Innovation, UC Berkeley. Retrieved from: https://ternercenter. berkeley.edu/blog/changes-to-federal-homelessness-funding-could-un- do-years-of-progress-in-california/

35. Acosta, S., and Gartland, E. (2025, February 27). “To Better Meet Record Levels of Need, Keep Families Housed, Congress Must Increase 2025 Funding for Housing Assistance.” Center on Budget and Policy Priorities. Retrieved from: https://www. cbpp.org/research/housing/to-better-meet-record-levels-of-need-keep- families-housed-congress-must-increase

36. We also note that the budget estimates in Figure 5 do not include funding for newly authorized vouchers. There have been several types of new vouchers authorized for 2025, including but not limited to vouchers for foster youth, veterans, and public housing conversions.

37. Castaldi, M. & Patel, U. (2025, August 6). “State and Local Policymakers Should Invest in Rental Assistance to Reduce Homelessness and Increase Economic Security.” Center on Budget and Policy Priorities. Retrieved from: https://www.cbpp.org/ of 3338

ACKNOWLEDGMENTS
We greatly appreciate the public housing agency staff who generously shared their time and insights with us, particularly while navigating difficult circumstances.

Special thanks to Sonya Acosta, Ophelia Basgal, Tushar Gurjal, Madeline Morris, Preston Prince, and Patricia Wells, whose expertise and input helped to make this paper better. We’d also like to thank the Terner Center team, includ- ing Carolina Reid and Ben Metcalf, for their thoughtful feedback and support through the development of this paper.

This work was made possible by the generous support of the Wells Fargo Foundation.

This research does not represent the institutional views of the University of California, Berkeley or of the Terner Center’s funders. Funders do not determine research findings or recommendations in the Terner Center’s research and policy reports.

ABOUT THE TERNER CENTER FOR HOUSING INNOVATION
The Terner Center formulates bold strategies to house families from all walks of life in vibrant, sustainable, and affordable homes and communities.

The Terner Center is housed within the University of California, Berkeley’s College of Environmental Design.
ternercenter.berkeley.edu

ABOUT THE HOUSING SOLUTIONS LAB AT THE NYU FURMAN CENTER The Housing Solutions Lab at the NYU Furman Center helps small and midsize cities plan, launch, and evaluate evidence-based local housing policies that advance racial equity; increase access to opportunity; and improve long-term health and wellbeing for residents.
localhousingsolutions.org/lab/
Exhibit C
Glendale Housing Authority Letter Dated May
12, 2026
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Exhibit D
Los Angeles County Development Authority
(LACDA) EHV Limited Preference Policy
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Glendale City CouncilJune 9, 2026

Glendale City Council
June 9, 2026