Agenda packet, joint meeting — Glendale City Council, June 23, 2026

A G E N D A
JOINT MEETING: GLENDALE CITY COUNCIL AND GLENDALE HOUSING AUTHORITY

COUNCIL CHAMBERS
613 E. Broadway, 2nd Floor
Glendale, CA 91206
JUNE 23, 2026 - 3:00 PM

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JUNE 23, 2026 - 3:00 PM

ROLL CALL
-
3:00 PM
-
Report of the City Clerk of the City Council and Housing Authority, re: Posting of Agenda.

The Agenda for the Tuesday, June 23, 2026 joint public meeting of the City Council and Housing Authority was posted on June 17, 2026 on the Bulletin Board outside City Hall.

JOINT PUBLIC MEETING
of the City Council and Housing Authority is hereby called to meet at

3:00 PM
on
Tuesday, June 23, 2026
, in the Council Chamber, 613 E. Broadway,
2nd Floor, Glendale, CA 91206 to consider the following item(s) of business, to wit;

1. Community Development, re: Substantial Amendment to the HOME-ARP Allocation Plan – Parkview Glendale Resident Selection Preferences and Methods of Prioritization
a. City Council Motion Approving the Substantial Amendment to the HOME-ARP Allocation Plan governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue b. Housing Authority Motion Approving the Substantial Amendment to the HOME-ARP Allocation Plan governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue

2. Community Development, re:

Adoption of the FY 2026-27 Glendale Housing
Authority Budget
a. Resolution of the City Council Making Findings and Approving Expenditures of Low Moderate Income Housing Asset Funds for Administration, Planning and Expenditures Outside of Redevelopment Project Areas for the FY 2026-27 Housing Authority Budget b. Resolution of the Housing Authority Making Findings and Approving Expenditures of Low Moderate Income Housing Asset Funds for Administration, Planning and Expenditures Outside of Redevelopment Project Areas for the FY 2026-27 Housing Authority Budget and Adopting the FY 2026-27 Housing Authority Budget

ADJOURNMENT

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1 CITY OF GLENDALE, CALIFORNIA
REPORT TO THE JOINT MEETING: GLENDALE CITY COUNCIL AND

GLENDALE HOUSING AUTHORITY

AGENDA ITEM
Report: Substantial Amendment to the HOME-ARP Allocation Plan – Parkview Glendale Resident Selection Preferences and Methods of Prioritization

1. City Council Motion Approving the Substantial Amendment to the HOME-ARP Allocation Plan governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue;

2. Housing Authority Motion Approving the Substantial Amendment to the HOME-ARP Allocation Plan governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue.

COUNCIL ACTION

EXECUTIVE SUMMARY
Parkview Glendale is a 68-unit senior affordable housing development at 426 Piedmont Avenue. Eleven of the units are assisted with federal HOME-ARP funds and are subject to federal program requirements governing selection of residents. The proposed Substantial Amendment to the HOME-ARP Allocation Plan modifies the preferences and methods of prioritization governing resident selection for those eleven units.

On April 28, 2026, the City Council and Housing Authority directed staff to offer the eleven HOME-ARP units at Parkview Glendale to senior households (age 62 or older) currently assisted through the Emergency Housing Voucher (EHV) program who may face future loss of voucher assistance due to the temporary nature of EHV funding, with the selection order to be determined by randomized lottery. To implement this directive in compliance with federal HOME-ARP requirements, staff prepared a substantial amendment to the City’s HOME-ARP Allocation Plan (Exhibit 1) establishing a tiered preference structure and lottery-based method of prioritization specific to the eleven HOME-ARP-assisted units at Parkview Glendale.

Item Type: Public Hearing
Approved forJune 23, 2026 calendar
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1 The draft amendment was published for a 15-day public comment period from May 7, 2026 through May 21, 2026. Two public comments were received and are summarized in Exhibit 3.

RECOMMENDATION
That the City Council and Housing Authority approve the Substantial Amendment to the HOME-ARP Allocation Plan governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, at 426 Piedmont Avenue.

ANALYSIS
HOME-ARP and Parkview Glendale
HOME-ARP is a federal program created through the American Rescue Plan Act of 2021 to assist households experiencing homelessness, housing instability, or other qualifying hardships. The City of Glendale received a HOME-ARP allocation and, in 2023, HUD approved the City’s HOME-ARP Allocation Plan, which dedicated a portion of that allocation toward the development of affordable housing at Parkview Glendale, a 68-unit senior affordable housing development located at 426 Piedmont Avenue, owned by Piedmont Glendale L.P. and managed by EAH Housing. Eleven of the 68 units at Parkview Glendale are assisted with HOME-ARP funds and are subject to HOME-ARP program requirements. The original HOME-ARP Allocation Plan (Exhibit 4) established a preference framework for seniors facing homelessness, at risk of homelessness, and seniors at greatest risk of housing instability for those eleven units.

Emergency Housing Voucher Program and April 28 Direction The Emergency Housing Voucher (EHV) program was established under the American Rescue Plan Act of 2021 and provides temporary federal rental assistance to households experiencing or at risk of homelessness, including seniors, persons with disabilities, survivors of domestic violence, and other vulnerable populations. The Glendale Housing Authority currently assists 188 active EHV households. 70 of those households are senior households whose primary tenant is age 62 or older and are therefore eligible for Parkview Glendale under the project’s senior occupancy restrictions. These senior households are among the most vulnerable to housing instability in the event of future EHV funding expiration or termination, given fixed or limited incomes, potential health and mobility limitations, and the scarcity of affordable senior housing in Glendale and the broader region. On April 28, 2026, the City Council and Housing Authority reviewed Housing Staff’s proposed EHV Transition Plan and directed staff to offer the eleven HOME-ARP-assisted units at Parkview Glendale to senior EHV households through a randomized lottery as part of the City’s broader EHV transition planning efforts.

HUD Funding Update
In January 2026, the Housing Authority notified EHV households that federal funding was projected to run out approximately seven months later and that rental assistance would end when funding was exhausted. Congress subsequently enacted the Consolidated Appropriations Act, 2026 (P.L. 119-75), which included provisions making Tenant Protection Voucher funding available to address EHV shortfalls. HUD issued PIH Notice 2026-12 (May 5 of 61

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1 6, 2026) indicating that HUD anticipates adequate funding available to address EHV shortfalls nationally and directing PHAs facing shortfalls to request bridge HAP funding through their Financial Management Center Financial Analyst. The Housing Authority has submitted a request for bridge HAP funding and is awaiting a response from HUD. No new termination notices have been issued to Glendale EHV households at this time.

The House FY 2027 Transportation, Housing and Urban Development Appropriations Subcommittee draft bill, released May 20, 2026, does not include dedicated EHV funding beyond a significantly reduced Tenant Protection Voucher appropriation. Although early in the appropriations process and subject to change, it reflects the current federal budget environment in which dedicated EHV program funding faces significant uncertainty beyond 2026.

Proposed Amendment
The proposed Substantial Amendment updates the existing senior preference framework in the HOME-ARP Allocation Plan by adding a defined preference for eligible senior EHV households and establishing more detailed prioritization and referral procedures for the eleven HOME-ARP-assisted units at Parkview Glendale. The amendment implements the Council direction from April 28, 2026.

The amendment establishes a Primary Preference for Senior Citizen Households (head of household age 62 or older) meeting any of the four HOME-ARP Qualifying Populations.

Within that preference, a Tier 1 subpopulation priority is established for senior EHV households who have received written notice of termination of EHV rental assistance — including notices of program expiration or sunsetting — and who have not received a Tenant Protection Voucher or other replacement federal rental assistance sufficient to sustain housing.

For initial lease-up, EAH Housing will conduct a randomized lottery of Tier 1 households under procedures approved by the City of Glendale Housing Authority and documented in the project’s Resident Selection Plan. Because the number of Tier 1 households substantially exceeds the eleven available units, the lottery will determine selection order.

If the Tier 1 lottery does not produce sufficient qualified households to fill all eleven units, the Glendale Continuum of Care will be given 14 days to refer qualified Senior Citizen Households from its active caseloads. If combined Tier 1 and CoC referrals still do not fill all units, remaining units will be filled from the Tier 2 waitlist in lottery order.

The Tier 2 waitlist consists of all other senior households meeting any HOME-ARP Qualifying Population who do not fall within the Tier 1 subpopulation. It was initially populated by senior applicants who completed the HOME-ARP Supplement to Application during the March 2026 application period and self-identified as Qualifying Population-eligible, ordered by lottery numbers assigned during the March 2026 public lottery. New applicants may be added through affirmative marketing
For subsequent vacancies during the 15-year compliance period, the CoC receives a 14-day referral window before the unit is filled from the Tier 2 waitlist in lottery order. The amendment does not establish a standing Tier 1 waitlist for subsequent vacancies. 6 of 61

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1 HOME-ARP Qualifying Population Eligibility
HOME-ARP program rules require that each household admitted to a HOME-ARP-assisted unit be individually documented as meeting one of HUD’s designated Qualifying Population definitions at the time of move-in, in accordance with HUD Notice CPD-21-10.

EHV senior households may meet HOME-ARP Qualifying Population definitions by virtue of their prior homeless or housing-unstable status at the time of EHV issuance, and may further qualify as households requiring housing assistance to prevent homelessness under HUD Notice CPD-21-10. The City’s approved 2025–2030 Consolidated Plan identifies severe housing cost burden, homelessness prevention, and housing instability among low-income and elderly households as significant local housing needs, supporting the prioritization of senior EHV households under the “At Risk of Homelessness” and “At Greatest Risk of Housing Instability” definitions. All households will be individually documented as meeting applicable Qualifying Population requirements at admission, consistent with HUD Notice CPD-21-10. The amendment establishes a method of prioritization rather than a categorical exclusion; all four HOME-ARP Qualifying Populations remain eligible for the HOME-ARP- assisted units at Parkview Glendale.

Compliance and Coordination
The substantial amendment process requires public notice, public comment, public hearing, and submission to HUD through the Integrated Disbursement and Information System (IDIS), which routes to HUD’s Los Angeles Community Planning and Development (CPD) Field Office. The proposed amendment has been reviewed for compliance with applicable HOME-ARP regulations and HUD requirements and remains within the scope of the originally approved HOME-ARP eligible activity and senior preference framework for Parkview Glendale. Staff has coordinated with EAH Housing regarding the amended prioritization process and the timeline for unit selection, and has been in correspondence with HUD’s Los Angeles CPD Field Office regarding the HOME- ARP regulatory framework applicable to the Parkview Glendale units.

STAKEHOLDERS/OUTREACH
The draft Substantial Amendment was published as a legal notice in the Glendale Independent on May 7, 2026 (see Exhibit 2), and posted for public review at www.glendaleca.gov/affordablehousing. The draft amendment was also available in person at the Community Development Department – Housing Division, 141 N. Glendale Avenue, Suite 202, Glendale, CA 91206. A 15-day public comment period was held from May 7, 2026 through May 21, 2026 at 5:00 p.m. Written comments were accepted by email to [email protected] and by mail to the address above. Two public comments were received during the comment period. Both comments and the City’s responses are included in Exhibit 3. A new notice of the June 23, 2026 public hearing (previously noticed for June 2, 2026) was published in the Glendale Independent on June 4, 2026; this notice was also posted at www.glendaleca.gov/affordablehousing and posted outside of City Hall.

FISCAL IMPACT
There is no fiscal impact associated with this report.
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1 ENVIRONMENTAL REVIEW (CEQA/NEPA)
The actions described in this report to approve a Substantial Amendment to the HOME- ARP Allocation Plan governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue (an already- existing Project) is exempt from further environmental review under the California Environmental Quality Act ("CEQA") pursuant to Title 14 of the California Code of Regulations ("CEQA Guidelines") for all of the following reasons: 1) the activity will not result in a direct or reasonably foreseeable indirect physical change to the environment under CEQA Guidelines Section 15060(c)(2) because the Project is already built, the funding will go to minor rehabilitation (not subject to discretionary review, so not a project under CEQA) and/or will undergo independent CEQA review at the time when such re-habilitation work is applied for; 2) the activity is not a project under CEQA Guidelines Section 15060(c)(3) and 15378(b)(4) because it constitutes the creation of government funding mechanisms or other governmental fiscal activity that does not involve any commitment to any specific project which may result in a potentially significant physical impact on the environment; and 3) the activity is covered by the common sense exemption that CEQA applies only to projects which have the potential for causing a significant effect on the environment, and here, it can be seen with certainty that there is no possibility that the activity may have a significant effect on the environment per CEQA Guide-lines Section 15061(b)(3).

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES TO STAFF RECOMMENDATION

1. Reject the proposed Substantial Amendment and direct staff to explore alternative resident selection approaches for the eleven HOME-ARP-assisted units at Parkview Glendale.

2. The City Council and Housing Authority may consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Submitted by:

Jack Wong, Interim Community Development Director
Prepared by:

Michael Fortney, Deputy Director of Community Development/Housing Pamela Jackson, Housing Coordinator
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS
Exhibit 1: Substantial Amendment to the HOME-ARP Allocation Plan; Exhibit 2: Public Notice of Substantial Amendment and 15-Day Public Comment 8 of 61

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1 Period and Notice of new June 23, 2026 date for hearing; Exhibit 3: Summary of Public Comments and City Responses; Exhibit 4: HOME-ARP Allocation Plan (Original, HUD-Approved 2023). 9 of 61

MOTION
Moved by Council Member , seconded by Council Member , that the Council of the City of Glendale, following a public hearing on the matter, hereby approves a Substantial Amendment to the HOME-ARP Allocation Plan (“Substantial Amendment”) governing resident selection preferences and methods of prioritization for the eleven HOME-ARP- assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue, as further described in the Joint Report to the Council and Housing Authority dated June 23, 2026 from the Director of Community Development; and authorizes the City Manager or his designee, and/or Community Development Department staff to submit the Substantial Amendment to the U.S. Department of Housing and Urban Development, and to execute all application materials, agreements, amendments, certifications, and/or documents and/or take any further actions necessary per the Substantial Amendment.

Vote as Follows:

Ayes:

Noes:

Absent:

Abstain:
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MOTION
Moved by Authority Member , seconded by Authority Member , that the Housing Authority of the City of Glendale hereby approves a Substantial Amendment to the HOME-ARP Allocation Plan (“Substantial Amendment”) governing resident selection preferences and methods of prioritization for the eleven HOME-ARP-assisted senior units at Parkview Glendale, located at 426 Piedmont Avenue, as further described in the Joint Report to the Council and Housing Authority dated June 23, 2026 from the Director of Community Development; and authorizes the Executive Director or his designee, and/or Community Development Department staff to submit the Substantial Amendment to the U.S. Department of Housing and Urban Development, and to execute all application materials, agreements, amendments, certifications, and/or documents and/or take any further actions necessary per the Substantial Amendment.

Vote as Follows:

Ayes:

Noes:

Absent:

Abstain:
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CITY OF GLENDALE
Substantial Amendment to the HOME-ARP Allocation Plan
Section: Preferences, Targeting, and Methods of Prioritization

1. Preferences
For the eleven (11) HOME-ARP-assisted units at the Parkview Glendale project, located at 426 Piedmont Avenue, the City of Glendale establishes a Primary Preference for Senior Citizen Households (head of household age 62 or older) who meet any of the four HOME-ARP Qualifying Population (QP) definitions:
Homeless (QP1)
At-Risk of Homelessness (QP2)
Fleeing/Attempting to Flee Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking (QP3)
Other Populations: At Greatest Risk of Housing Instability (QP4) This Primary Preference is specific to the Parkview Glendale project and does not apply to other HOME-ARP-assisted activities established under separate amendments to this Allocation Plan.

2. Subpopulation Preference and Needs Justification
Within the Primary Preference, the City further prioritizes a defined subpopulation: Senior Citizen Households who have received written notice of termination of Emergency Housing Voucher (EHV) rental assistance (including notices of program expiration or sunsetting) administered through the Glendale Housing Authority.

This subpopulation preference is established based on the following documented need. Based on Glendale Housing Authority case file analysis conducted in the first quarter of 2026, approximately 70 Senior Citizen Households (head of household age 62 or older) currently assisted through EHVs face termination of rental assistance as the federal EHV program winds down. The specific timeline for program termination remains subject to further guidance from the U.S. Department of Housing and Urban Development. The substantial majority of these households are documented at incomes at or below 30% of Area Median Income, with the remainder at or below 50% of Area Median Income while meeting the at-risk-of-homelessness criteria established under HUD Notice CPD-21-10. They lack documented alternative resources sufficient to sustain housing upon voucher termination and face significant risk of returning to homelessness absent intervention. Existing Continuum of Care shelter and rapid rehousing capacity within the City of Glendale is insufficient to absorb these households.

Prioritizing this subpopulation for the eleven HOME-ARP units at Parkview Glendale prevents avoidable returns to homelessness for a defined, documentable population at a known point in time, consistent with the City's HOME-ARP needs assessment and the priorities identified through the consultation process.

In addition to this subpopulation, the City has identified additional senior households meeting HOME-ARP Qualifying Populations through the affirmatively marketed application process for the 12 of 61

Parkview Glendale project. During the application period of March 2 through March 20, 2026, applicants for Parkview Glendale's affordable units were provided with a HOME-ARP Supplement to Application that described the eleven HOME-ARP units, their eligibility criteria, and the option to self-identify as meeting one or more HOME-ARP Qualifying Populations. Senior applicants who completed this supplement and self-identified as QP-eligible will form the initial Tier 2 waitlist described in Section 3 below.

This subpopulation preference is established within the City's existing preference framework for senior households at risk of homelessness and at greatest risk of housing instability, and operates as a method of prioritization within those existing preferences rather than as a new preference category.

3. Method of Prioritization
The eleven HOME-ARP units at the Parkview Glendale project will be filled at initial lease-up through a randomized lottery of qualified Tier 1 households, with subsequent vacancies during the project's affordability period filled through Continuum of Care referral and the project waitlist as described below.

Initial Lease-Up — Randomized Lottery of Tier 1 Households: For initial lease-up of the eleven HOME-ARP units, the City of Glendale Housing Authority and the project owner will conduct a randomized lottery of Tier 1 households. Tier 1 consists of Senior Citizen Households (age 62 or older) who have received written notice of termination of Emergency Housing Voucher rental assistance administered through the Glendale Housing Authority (including notices of program expiration or sunsetting), who have not received a Tenant Protection Voucher or other replacement federal rental assistance sufficient to sustain housing, and who meet one or more applicable HOME-ARP Qualifying Populations, including but not limited to QP2 (At Risk of Homelessness) and QP4 (Other Populations).

The applicable QP and the absence of replacement rental assistance will be documented at admission for each household in accordance with the documentation standards set forth in HUD Notice CPD-21-10. Because the number of Tier 1 households substantially exceeds the available units, the lottery will determine the order of selection.

If the Tier 1 lottery does not produce sufficient qualified households to fill all eleven units, the Glendale Continuum of Care will be given a period of fourteen (14) days to identify and refer qualified Senior Citizen Households meeting a HOME-ARP Qualifying Population from the active caseloads of CoC member agencies. If the combined Tier 1 lottery and CoC referrals do not produce sufficient qualified households to fill all eleven units, remaining units will be filled from the Tier 2 waitlist in lottery order.

The fourteen-day CoC referral window is consistent with and within the maximum window authorized by the HOME-ARP Regulatory Agreement at Section 4.a.iii.

Tier 2 Waitlist: The Tier 2 waitlist will consist of all other Senior Citizen Households meeting any of the four HOME-ARP Qualifying Populations (QP1, QP2, QP3, or QP4) who do not fall within the Tier 1 subpopulation. The Tier 2 waitlist will be initially populated by senior applicants who completed the HOME-ARP Supplement to Application during the March 2026 application period and self-identified as QP-eligible. Order within Tier 2 will be established using the lottery numbers assigned to these applicants during the March 2026 affordable housing lottery for Parkview Glendale, which was conducted as a public, affirmatively-marketed process. New applicants meeting QP criteria added to the Tier 2 waitlist on an ongoing basis through affirmative marketing channels will be ordered 13 of 61

chronologically by application date following the March 2026 cohort.

Subsequent Vacancies — Continuum of Care Referral and Project Waitlist: Following initial lease-up, subsequent vacancies during the project's affordability period will be filled through a two-step process. First, the Glendale Continuum of Care will be given a period of fourteen (14) days from the date of vacancy notification to identify a qualified Senior Citizen Household meeting a HOME-ARP Qualifying Population from within the active caseloads of CoC member agencies and refer that household to the project owner. If no qualified referral is received from the CoC within this window, the project owner will fill the vacancy from the Tier 2 waitlist in lottery order.

The randomized lottery for initial lease-up of Tier 1 households will be conducted by the project owner, EAH Housing, under procedures approved by the City of Glendale Housing Authority and documented in the project's Resident Selection Plan.

4. Limitations
The eleven HOME-ARP units at Parkview Glendale are subject to a Senior Citizen Household occupancy limitation. In accordance with the project's Affordable Housing Agreement and HOME-ARP Regulatory Agreement, occupancy is limited to households where at least one member is age 62 or older. No other limitations apply; the units remain accessible to all four HOME-ARP Qualifying Populations subject to the senior age requirement.

5. Referral Methods
The City utilizes three coordinated channels to identify qualified applicants for HOME-ARP units at Parkview Glendale: (1) Continuum of Care referral, through which CoC member agencies refer qualified Senior Citizen Households from their active caseloads; (2) the project-specific Tier 2 waitlist, populated initially through the March 2026 HOME-ARP Supplement to Application and updated on an ongoing basis through affirmative marketing channels; and (3) for initial lease-up only, the Tier 1 randomized lottery of Senior Citizen Households facing termination of EHV rental assistance administered through the Glendale Housing Authority. Procedures for each channel are described in Section 3.
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HLR MEDIA, LLC LEGAL QUOTES
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CITY OF GLENDALE — NOTICE OF CONTINUED PUBLIC HEARING
Substantial Amendment to the HOME-ARP Allocation Plan
The City of Glendale hereby provides notice that the public hearing previously scheduled for June 2, 2026 regarding the proposed Substantial Amendment to the HOME-ARP Allocation Plan for Parkview Glendale (426 Piedmont Avenue) will not be held on June 2, 2026.

The public hearing will now be held at the Joint Meeting of the Glendale City Council and Glendale Housing Authority on:

Monday, June 23, 2026
613 E. Broadway, 2nd Floor, Glendale, CA 91206
The time the public hearing will be held is on or after 1pm, with a more specific time to be specified in the published agenda at
www.glendaleca.gov at least 72 hours prior to the meeting.

The proposed Substantial Amendment and all related materials remain available for public review at:
• Online: www.glendaleca.gov/affordablehousing
• In person: Community Development Department – Housing Division, 141 N. Glendale Avenue, Suite 202, Glendale, CA 91206
The public comment period for this amendment closed on May 21, 2026. No additional public comment period will be held in connection with this continuance.

Contact: Pamela Jackson, Housing Coordinator | [email protected] | 818-548- 3705
The City of Glendale does not discriminate on the basis of disability and will provide rea - sonable accommodations and alternative formats upon request.

Publish June 4, 2026

GLENDALE INDEPENDENT
Inches 3.05
1 x Run= $14.64
Total Cost $14.64
EXHIBIT 2
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EXHIBIT 3

CITY OF GLENDALE, CALIFORNIA
HOME-ARP ALLOCATION PLAN — SUBSTANTIAL AMENDMENT
PARKVIEW GLENDALE, 426 PIEDMONT AVENUE

SUMMARY OF PUBLIC COMMENTS AND CITY RESPONSES
Public Comment Period: May 7, 2026 – May 21, 2026
Public Hearing: June 23, 2026 (continued from June 2, 2026 due to lack of quorum) Two public comments were received during the public comment period. Both are addressed below.

COMMENT 1
Summary
The first comment was received by phone during the public comment period from a member of the public whose family member had applied to Parkview Glendale through the March 2026 general lottery. The caller expressed concern that all 68 units at Parkview Glendale would be offered exclusively to Emergency Housing Voucher (EHV) households, and that this would affect her family member’s placement opportunity.

City Response
Staff clarified by phone that the Substantial Amendment applies only to the eleven HOME-ARP- assisted units at Parkview Glendale and does not affect the resident selection process for the remaining 57 units, which were filled through the March 2026 public lottery. The caller indicated satisfaction with the clarification and expressed no further objection. No contemporaneous notes were taken of the call. The caller did not identify herself nor did she want to identify her family member.

COMMENT 2
Commenter Information
Commenter: Ani Khash
Date: May 20, 2026
Method: Email to [email protected]
Full Text of Comment
This is a public comment on the Substantial Amendment to the HOME-ARP Allocation Plan, posted to GlendaleCA.gov/AffordableHousing on May 7, 2026, comment period May 7 to May 21, 2026, hearing June 2, 2026.
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Please confirm receipt of this email.

I support housing for residents. I also believe the City of Glendale has obligations to explain to the public, on the record, why this preference structure is appropriate for the eleven HOME-ARP units at Parkview Glendale but inappropriate when applied to the Housing Choice Voucher program for the same population of 188 currently-assisted EHV households.

The two preferences are the same structure.

The preference language in the May 7 amendment reads: “First priority will be given to Senior Citizen Households (age 62 or older) currently assisted through the Emergency Housing Voucher (EHV) program administered by the Glendale Housing Authority who have received written notice of termination of that assistance.”
The preference language in HUD Notice PIH 2025-19, Section 3(b), reads: “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.” (PIH 2025-19, “Guidance on Transitioning EHV Families into HCV and End of EHV Services Fee Expenditure,” available at https://www.hud.gov/sites/dfiles/OCHCO/documents/PIH_2025-19.pdf.) These are the same preference. Both target the currently assisted EHV households, both are triggered by the termination of assistance due to a funding shortfall, and both operate as a local preference within an existing federal framework. The only difference is where the City is willing to apply it. The first is being adopted by the City of Glendale on June 2, 2026 for eleven units.

The second was declined by the Glendale Housing Authority on January 28, 2026 in a written email from Principal Housing Supervisor Arthur Bolbolian.

The same notice provides a streamlined waiver. PIH 2025-19, Section 3(b), establishes a streamlined DocuSign submission process under which HUD’s Assistant Secretary for Public and Indian Housing may authorize a PHA to place all EHV families on its HCV waiting list with the appropriate preference. The Glendale Housing Authority could have used that waiver to place all 188 households on its closed HCV waitlist with priority. It declined to do so.

The senior subpopulation figure of approximately 70 households was computable from the City’s own April 28, 2026 agenda materials, yet the public was never shown it. In Attachment 6 to the April 28 joint meeting staff report (Item 26-89993, pages 62 through 64), the City presented two tiering frameworks for the 188-household EHV class. For Option 1 (Balanced Approach), the City published the household count for every tier: 24, 47, 80, and 37. For Option 2 (Senior-First Prioritization), prepared by the same staff and approved by the same City Manager for the same agenda packet, the City published the tier definitions but omitted the household counts. Option 2 Tier 1 uses Option 1’s 24-household criteria verbatim, and Option 2 Tier 2 is defined as “ANY household age 62 or older who did not qualify for the specific Tier 1 criteria.” Applied to the 188-household EHV class, those two tiers sum to approximately 70 households. The figure was therefore derivable from the City’s own document on April 28, 2026.

The public did not see it stated until the May 7, 2026 HOME-ARP amendment notice, nine days later, and two days after the May 5, 2026 PHA Plan public hearing at which the City certified it 17 of 61

had no other path forward for the 188 households and waived the decision to enact PIH 2025- 19 with preference language.

The senior-EHV-termination preference maps to a HOME-ARP Qualifying Population. The households the City proposes to prioritize are currently housed under temporary EHV assistance and need additional assistance to avoid a return to homelessness, which places them within Qualifying Population 4(a), “Other Families Requiring Services or Housing Assistance to Prevent Homelessness,” under HUD Notice CPD-21-10, and within Qualifying Population 1 for any household whose EHV assistance has already terminated and who has become homeless. The amendment should anchor the preference explicitly in that framework rather than treating EHV status as a freestanding preference category.

I am asking the City of Glendale to do one of the following two things before the June 2 hearing.

One. Extend the May 7 preference structure to the 24 CFR Part 982 Housing Choice Voucher program through the PIH 2025-19 streamlined waiver, and submit that waiver to HUD’s Office of Public and Indian Housing under the procedure described in the same notice. This action does not cost the city. It does not commit the city to issuing vouchers it cannot fund. It places the broader 188-household class on the closed HCV waitlist with priority position. Peer California housing authorities that have publicly adopted an EHV-to-HCV transition preference or used the PIH 2025-19 streamlined waiver include the Los Angeles County Development Authority (LACDA, FY 2026-2027 Proposed Agency Plan), the Orange County Housing Authority (OCHA, Board of Supervisors action November 18, 2025), and the Housing Authority of the City of Long Beach (HACLB, HUD-approved waiver placing all EHV households on the HCV waitlist with a preference for participants displaced due to government action). The San Diego Housing Commission has adopted a parallel preference on its Project-Based Voucher waitlist for current SDHC EHV participants. The Housing Authority of the City of Los Angeles, by contrast, has formally declined to absorb EHV households into its HCV program, citing its own funding shortfall, which illustrates that adoption is a deliberate policy choice rather than an automatic step.

Two. Articulate, on the public record before the June 2 hearing, why the same preference structure is appropriate at Parkview for approximately 70 senior EHV households but inappropriate at the Housing Authority for 188.

I also have five procedural concerns under HUD CPD Notice 21-10 (issued September 13, 2021, available at https://www.hud.gov/sites/dfiles/OCHCO/documents/2021-10cpdn.pdf).

The notice text as posted does not disclose whether the City of Glendale has met the following procedural requirements that govern HOME-ARP substantial amendments under CPD-21-10:

1. On consultation with required agencies under CPD-21-10 Section V.A, including the Continuum of Care, public housing agencies, homeless and domestic violence service providers, veterans’ groups, and fair housing, civil rights, and disability organizations: The Glendale CoC is administered jointly with the city’s homeless services division within the Community Development Department. Documentation of which of these required parties were consulted on the senior-EHV-termination preference should be made publicly available. 18 of 61

2. On the needs and gaps analysis for all four Qualifying Populations under CPD-21-10 Section V.C.1: The amendment notice does not display the needs analysis or gap analysis supporting why senior EHV households with termination notices were prioritized over the other three Qualifying Populations (homeless, fleeing domestic violence, at greatest risk of housing instability).

3. On coordinated Entry as the referral method under CPD-21-10 Section IV.C.2, including the expanded Coordinated Entry provision at Section IV.C.2.i: If the city is bypassing Coordinated Entry in favor of direct selection by the Housing Authority based on EHV program participation status, the substantial amendment must document the regulatory basis for that decision.

4. On functional limitation analysis: With eleven HOME-ARP units at Parkview and approximately 70 eligible senior EHV households competing under the first-priority preference, the other three Qualifying Populations are unlikely to receive any of the eleven units. A preference administered so as to exclude in practice other Qualifying Populations from a HOME-ARP project operates as a limitation under HUD’s HOME-ARP Policy Brief, “Preferences, Methods of Prioritization, and Limitations” (May 17, 2022). That guidance provides that a limitation should not be imposed “unless it is necessary to address a greater gap in effective housing, aid, benefit, or services in the PJ’s geographic area and the HOME-ARP project or activity cannot address the gap through the use of a preference,” that any limitation must be justified in the allocation plan based on the needs assessment and gaps analysis, and that HUD “strongly recommends that PJs consult with the FHEO Division in their local HUD Field Office before establishing a limitation that may have fair housing or civil rights implications.” The policy brief is available through HUD Exchange at https://www.hudexchange.info/resource/6640/homearp-policy-brief-preferences-methods-of- prioritization-and-limitations/.

5. Compliance with the City of Glendale’s own Citizen Participation Plan under 24 CFR 91.105 (available at https://www.ecfr.gov/current/title-24/section-91.105). The 15-day comment period meets the floor in CPD-21-10 Section V.C.6 governing substantial amendments to the HOME- ARP allocation plan. However, CPD-21-10 Section V.B separately requires the City to follow its adopted requirements for reasonable notice and an opportunity to comment for plan amendments in its current Citizen Participation Plan. Glendale’s Citizen Participation Plan, like 24 CFR 91.105(c)(2), requires a period of not less than 30 calendar days for substantial amendments. The City’s own treatment of the companion FY 2025-2026 Annual Action Plan substantial amendment, open for public comment April 27 through May 29, 2026, a period of approximately 33 days, confirms that the longer period applies. The 15-day window on this amendment is inconsistent with the City’s own concurrent practice and with its Citizen Participation Plan. The Citizen Participation Plan should be posted alongside the amendment notice, and the comment period should be re-opened to satisfy the longer-of requirement.

Further, I have three additional concerns about the public participation record.

1. The companion FY 2025-26 Annual Action Plan Substantial Amendment, also moving to the June 2 hearing, allocates $683,361 in prior-year HOME funds to Verdugo Housing Corporation for the rehabilitation and expansion of an existing affordable housing facility into permanent supportive housing. The city is making three discrete federal housing financial decisions on the 19 of 61

same June 2 agenda. The 188-household EHV question that has been pending since at least December 2025 is not on that agenda.

2. The 15-day public comment period for this amendment is a striking compression compared to the FY 2026-27 PHA Plan, which received a substantially longer review window for documents addressing the broader 188-household class. The asymmetry should be explained.

3. I object to the City’s use of the same preference architecture selectively while declining to articulate the basis for that selectivity, and to the fact that the senior subpopulation count was computable from the April 28 agenda yet not displayed to the public until May 7, after the May 5 hearing had already certified no path forward for the 188. The 188 households did not become 70 households on May 7. They remain 188.

If the City closes the comment period at 15 days and proceeds to adoption on June 2, 2026 without re-opening for the 30-day period required by its own Citizen Participation Plan, I intend to pursue other forms of recourse.

City Response to Comment 2
The City provided a written response to Comment 2, addressing each of the commenter’s concerns. The full text of the City’s response is set forth below.

RESPONSE TO PUBLIC COMMENT
Substantial Amendment to the HOME-ARP Allocation Plan
Parkview Glendale – 426 Piedmont Avenue
The City received a public comment regarding the proposed Substantial Amendment to the HOME-ARP Allocation Plan for Parkview Glendale. The comment raised issues related to the proposed prioritization structure, Emergency Housing Voucher (EHV) households, public participation procedures, qualifying populations, Coordinated Entry, and Housing Choice Voucher (HCV) program policy considerations. The City appreciates the commenter’s detailed review and provides the following responses.

1. Relationship Between the Proposed HOME-ARP Prioritization and Housing Choice Voucher Program Policies
The proposed substantial amendment concerns the administration of eleven (11) HOME-ARP- assisted units at Parkview Glendale within an already approved HOME-ARP eligible activity.

The amendment establishes a method of prioritization for those units within the framework of HOME-ARP requirements and qualifying populations.

The Housing Choice Voucher (HCV) program and Emergency Housing Voucher (EHV) transition policies referenced in the comment are separate federal programs administered under different statutory, regulatory, operational, and funding frameworks. Decisions regarding potential HCV waitlist preferences or EHV transition strategies involve broader Housing Authority program capacity, funding availability, and long-term voucher assistance obligations beyond the scope of the HOME-ARP amendment currently under consideration. 20 of 61

HUD Notice PIH 2025-19 provides discretionary tools that public housing agencies may consider in connection with EHV transition planning. Adoption of such tools is not mandatory, and public housing agencies may reach different policy determinations based on local operational and financial conditions. The City Council and Housing Authority considered EHV transition strategies, including HCV waitlist options, at the April 28, 2026 Joint Meeting and directed staff to continue monitoring federal and state funding opportunities while pursuing available local solutions including Parkview Glendale placement.

The HOME-ARP amendment and the PHA Plan are separate regulatory actions proceeding on separate timelines under separate federal requirements. The HOME-ARP amendment was developed in response to the April 28, 2026 Council direction to address Parkview Glendale lease-up, which is governed by HOME-ARP program deadlines independent of the PHA Plan public participation calendar. The broader question of assistance for all 188 EHV households remains active through the EHV Transition Plan framework approved by the Council and Housing Authority on April 28, 2026.

2. HOME-ARP Qualifying Populations and Prioritization
The proposed prioritization is intended to address senior households currently assisted through the EHV program who may require additional housing assistance to avoid a return to homelessness or housing instability upon expiration or termination of EHV assistance. The City has determined that this prioritization is consistent with HOME-ARP qualifying populations, including households requiring housing assistance to prevent homelessness as described in HUD Notice CPD-21-10.

The amendment does not create a new HOME-ARP qualifying population and does not exclude other HOME-ARP qualifying populations from eligibility. All four HOME-ARP qualifying populations remain eligible for the HOME-ARP-assisted units at Parkview Glendale.

3. Preferences, Prioritization, and Limitations
The City has structured the amendment as a method of prioritization rather than a categorical limitation or exclusion, consistent with HUD’s guidance on preferences, methods of prioritization, and limitations for HOME-ARP activities. The amendment does not reserve the units exclusively for EHV households and does not prohibit access by other HOME-ARP qualifying populations. Given the limited number of HOME-ARP-assisted units available at Parkview Glendale, the City determined that prioritization of households facing imminent loss of rental assistance was an appropriate homelessness prevention strategy within the existing HOME-ARP framework.

The City is aware of HUD’s May 2022 Policy Brief on Preferences, Methods of Prioritization, and Limitations, which provides that a preference administered so as to exclude other qualifying populations in practice may operate as a limitation subject to a higher justification standard. The City does not believe the proposed prioritization structure rises to that level for the following reasons. First, the amendment explicitly preserves Tier 2 eligibility for all other HOME-ARP qualifying populations referred through the Continuum of Care or other approved channels.

Second, the vacancy-filling process described in the amendment provides the Continuum of Care with a 14-day referral window each time a HOME-ARP unit becomes available, ensuring 21 of 61

ongoing access for other qualifying populations over the 15-year compliance period. Third, the prioritization of senior EHV households is grounded in the documented housing instability risks affecting this population, as described further in Section 4 below.

To the extent HUD determines upon review that additional justification is warranted, the City is prepared to provide supplemental documentation of the needs and gaps analysis supporting the proposed prioritization.

4. Consultation, Needs Assessment, and Gaps Analysis
The proposed amendment remains within the framework of the previously approved HOME- ARP Allocation Plan, including the original eligible activity, qualifying populations, and needs assessment framework previously reviewed by HUD.

The City’s 2023 HOME-ARP Allocation Plan, which forms the basis for this amendment, includes a needs assessment and gaps analysis that specifically identified seniors facing homelessness, at risk of homelessness, and at greatest risk of housing instability as the population with the greatest unmet need in Glendale’s affordable housing inventory. That analysis found that 95% of senior survey respondents had income at or below 50% of Area Median Income and that over 90% paid more than half of their income toward rent. The proposed amendment’s prioritization of senior EHV households is a refinement of that already- documented senior preference, targeting the subset of that population facing the most acute and imminent risk: households currently reliant on a temporary federal subsidy with no dedicated long-term replacement.

The City consulted with required agencies and organizations in connection with the HOME-ARP allocation plan process, including the Continuum of Care, public housing authority staff, and homeless service providers. Documentation of that consultation is available in the administrative record.

5. Coordinated Entry and Referral Methods
The amendment does not eliminate Coordinated Entry or Continuum of Care referral participation. The amendment explicitly provides that each time a HOME-ARP unit becomes available — at initial lease-up for Tier 2 and upon any subsequent vacancy — the Continuum of Care is notified and given a 14-day window to refer a qualified senior household from its active caseloads before the unit is filled from the Tier 2 waitlist. This referral process is consistent with HOME-ARP requirements under CPD-21-10 Section IV.C.2 and preserves Coordinated Entry participation throughout the compliance period.

The Tier 1 EHV senior lottery constitutes a preference within the HOME-ARP framework, not a bypass of Coordinated Entry. HOME-ARP allows participating jurisdictions to establish preferences and methods of prioritization within their allocation plans, which is the regulatory basis for the Tier 1 structure.

6. Public Participation Requirements
The City provided public notice and a public comment period for the proposed substantial amendment consistent with the HOME-ARP public participation framework established under 22 of 61

HUD Notice CPD-21-10 and associated HOME-ARP waiver and alternative requirements issued by HUD. The City also consulted HUD regarding applicable HOME-ARP substantial amendment procedures.

The City’s Citizen Participation Plan does not specifically address HOME-ARP Allocation Plan amendments, which were established through subsequent federal HOME-ARP waiver and alternative requirements issued by HUD. The City determined that the 15-day public comment period was consistent with applicable HOME-ARP public participation requirements established under CPD-21-10 and associated waiver and alternative requirements issued by HUD. The Annual Action Plan amendment referenced in the comment is governed by a different regulatory framework with different comment period requirements; the differing comment periods reflect those distinct regulatory standards rather than an inconsistency in the City’s practice.

All comments received during the public comment period will be included in the administrative record and considered prior to any action by the City Council and Housing Authority. 23 of 61

Dear Ani,

Thank you for your detailed comment on the proposed Substantial Amendment to the HOME-ARP Allocation Plan for Parkview Glendale. The City has carefully reviewed each of your concerns and provides the following responses. A full written response is also included as part of the administrative record for the June 2, 2026 public hearing.

1. RELATIONSHIP BETWEEN HOME-ARP PRIORITIZATION AND HCV PROGRAM

POLICIES

The HOME-ARP amendment and the Housing Choice Voucher program are separate federal programs governed by different statutory, regulatory, and funding frameworks. HUD Notice PIH 2025-19 provides discretionary tools that public housing agencies may consider in connection with EHV transition planning. Adoption is not mandatory. The City Council and Housing Authority considered HCV waitlist options at the April 28, 2026 Joint Meeting and directed staff to pursue available local solutions, including Parkview Glendale placement, while continuing to monitor federal funding opportunities. The broader EHV transition question for all 188 households remains active under the April 28 framework.

2. HOME-ARP QUALIFYING POPULATIONS

The prioritization is consistent with HOME-ARP Qualifying Population definitions, including households requiring housing assistance to prevent homelessness under HUD Notice CPD-21-10. All four Qualifying Populations remain eligible for the HOME-ARP-assisted units at Parkview Glendale.

3. PREFERENCES, PRIORITIZATION, AND LIMITATIONS

The amendment establishes a method of prioritization, not a categorical exclusion. Tier 2 preserves access for all other Qualifying Populations, and the Continuum of Care receives a 14-day referral window for each vacancy throughout the 15-year compliance period.

Given the limited number of units available, the City determined that prioritizing households facing potential loss of rental assistance is an appropriate homelessness prevention strategy within the existing HOME-ARP framework.

From: Jackson, Pamela
To: "Ani"; CityClerk; City Council
Subject: RE: Public comment on Substantial Amendment to HOME-ARP Allocation Plan (Parkview Glendale) · comment period length and Tier 2 waitlist methodology
Date: Thursday, May 28, 2026 1:49:00 PM
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4. CONSULTATION, NEEDS ASSESSMENT, AND GAP ANALYSIS

The City conducted the required consultation with agencies and organizations in connection with the development of the original HOME-ARP Allocation Plan in 2022, as documented in the 2023 HUD-approved plan. The City is not changing the Qualifying Populations served — it is adding a defined subpopulation priority within the existing senior preference framework already approved. HUD’s Los Angeles Community Planning and Development Field Office has confirmed that CPD-21-10 does not require a new consultation, needs assessment, or gap analysis for this amendment.

5. COORDINATED ENTRY

The amendment does not bypass Coordinated Entry. The Continuum of Care receives a 14-day referral window at initial lease-up and for each subsequent vacancy. The Tier 1 lottery is a preference within the HOME-ARP framework, consistent with CPD-21-10 Section IV.C.2.

6. PUBLIC COMMENT PERIOD

Staff consulted with HUD’s Los Angeles Community Planning and Development Field Office both prior to and following the public comment period regarding the applicable public participation requirements, including the comment period length. HUD confirmed that the 15-day comment period is consistent with applicable HOME-ARP requirements.

The HOME-ARP Notice Appendix waives the citizen participation plan requirements at 24 CFR 91.105, 91.115, and 91.401 and substitutes alternative requirements, including a 15- day public comment period for HOME-ARP allocation plan amendments. Where a PJ’s Citizen Participation Plan conflicts with the Appendix’s alternative requirements, the Appendix controls. A PJ is not required to amend its Citizen Participation Plan to use the reduced comment period. This is confirmed in HUD’s HOME-ARP Frequently Asked Questions and HUD-sponsored training materials on the HOME-ARP program.

Your comment has been included in the administrative record and will be considered as part of the June 2, 2026 public hearing process. The full City response is included as Exhibit 3 to the staff report.

Sincerely,

25 of 61

You don't often get email from [email protected]. Learn why this is important

From: Jackson, Pamela
Sent: Thursday, May 21, 2026 12:36 PM
To: Ani <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: RE: Public comment on Substantial Amendment to HOME-ARP Allocation Plan (Parkview Glendale) — comment period length and Tier 2 waitlist methodology

Dear Ani,

This email confirms receipt of your comment submitted regarding the proposed Substantial Amendment to the HOME-ARP Allocation Plan for Parkview Glendale.

Your comment will be included in the administrative record and considered as part of the June 2, 2026 public hearing process.

From: Ani <[email protected]>
Sent: Thursday, May 21, 2026 12:16 PM
To: Jackson, Pamela <[email protected]>; CityClerk <[email protected]>; City Council <[email protected]>
Subject: Re: Public comment on Substantial Amendment to HOME-ARP Allocation Plan (Parkview Glendale) — comment period length and Tier 2 waitlist methodology

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

Click this button to update this activity's associations.

Dear Ms. Jackson,
Could you please confirm receipt of this email from yesterday? My records show the email has been opened over a dozen times.

Thank you,
Ani

On Wed, May 20, 2026 at 3:28 PM Ani <[email protected] > wrote:

Dear Ms. Jackson,
26 of 61

This is a public comment on the Substantial Amendment to the HOME-ARP Allocation Plan, posted to GlendaleCA.gov/AffordableHousing on May 7, 2026, comment period May 7 to May 21, 2026, hearing June 2, 2026.

Please confirm receipt of this email.

I support housing for residents. I also believe the City of Glendale has obligations to explain to the public, on the record, why this preference structure is appropriate for the eleven HOME- ARP units at Parkview Glendale but inappropriate when applied to the Housing Choice Voucher program for the same population of 188 currently-assisted EHV households.

The two preferences are the same structure.

The preference language in the May 7 amendment reads: "First priority will be given to Senior Citizen Households (age 62 or older) currently assisted through the Emergency Housing Voucher (EHV) program administered by the Glendale Housing Authority who have received written notice of termination of that assistance."
The preference language in HUD Notice PIH 2025-19, Section 3(b), reads: "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." (PIH 2025-19, "Guidance on Transitioning EHV Families into HCV and End of EHV Services Fee Expenditure," available at https://www.hud.gov/sites/dfiles/OCHCO/documents/PIH_2025-19.pdf .)
These are the same preference. Both target the currently assisted EHV households, both are triggered by the termination of assistance due to a funding shortfall, and both operate as a local preference within an existing federal framework. The only difference is where the City is willing to apply it. The first is being adopted by the City of Glendale on June 2, 2026 for eleven units. The second was declined by the Glendale Housing Authority on January 28, 2026 in a written email from Principal Housing Supervisor Arthur Bolbolian.

The same notice provides a streamlined waiver. PIH 2025-19, Section 3(b), establishes a streamlined DocuSign submission process under which HUD's Assistant Secretary for Public and Indian Housing may authorize a PHA to place all EHV families on its HCV waiting list with the appropriate preference. The Glendale Housing Authority could have used that waiver to place all 188 households on its closed HCV waitlist with priority. It declined to do so.

The senior subpopulation figure of approximately 70 households was computable from the City's own April 28, 2026 agenda materials, yet the public was never shown it. In Attachment 6 to the April 28 joint meeting staff report (Item 26-89993, pages 62 through 64), the City presented two tiering frameworks for the 188-household EHV class. For Option 1 (Balanced Approach), the City published the household count for every tier: 24, 47, 80, and 37. For Option 2 (Senior-First Prioritization), prepared by the same staff and approved by the same City Manager for the same agenda packet, the City published the tier definitions but omitted the household counts. Option 2 Tier 1 uses Option 1's 24-household criteria verbatim, and Option 2 Tier 2 is defined as "ANY household age 62 or older who did not qualify for the specific Tier 1 criteria." Applied to the 188-household EHV class, those two tiers sum to approximately 70 households. The figure was therefore derivable from the City's own document on April 28, 2026. The public did not see it stated until the May 7, 2026 HOME-ARP amendment notice, nine days later, and two days after the May 5, 2026 27 of 61

PHA Plan public hearing at which the City certified it had no other path forward for the 188 households and waived the decision to enact PIH 2025-19 with preference language.

The senior-EHV-termination preference maps to a HOME-ARP Qualifying Population. The households the City proposes to prioritize are currently housed under temporary EHV assistance and need additional assistance to avoid a return to homelessness, which places them within Qualifying Population 4(a), "Other Families Requiring Services or Housing Assistance to Prevent Homelessness," under HUD Notice CPD-21-10, and within Qualifying Population 1 for any household whose EHV assistance has already terminated and who has become homeless. The amendment should anchor the preference explicitly in that framework rather than treating EHV status as a freestanding preference category.

I am asking the City of Glendale to do one of the following two things before the June 2 hearing.

One. Extend the May 7 preference structure to the 24 CFR Part 982 Housing Choice Voucher program through the PIH 2025-19 streamlined waiver, and submit that waiver to HUD's Office of Public and Indian Housing under the procedure described in the same notice. This action does not cost the city. It does not commit the city to issuing vouchers it cannot fund. It places the broader 188-household class on the closed HCV waitlist with priority position. Peer California housing authorities that have publicly adopted an EHV-to-HCV transition preference or used the PIH 2025-19 streamlined waiver include the Los Angeles County Development Authority (LACDA, FY 2026-2027 Proposed Agency Plan), the Orange County Housing Authority (OCHA, Board of Supervisors action November 18, 2025), and the Housing Authority of the City of Long Beach (HACLB, HUD-approved waiver placing all EHV households on the HCV waitlist with a preference for participants displaced due to government action). The San Diego Housing Commission has adopted a parallel preference on its Project-Based Voucher waitlist for current SDHC EHV participants. The Housing Authority of the City of Los Angeles, by contrast, has formally declined to absorb EHV households into its HCV program, citing its own funding shortfall, which illustrates that adoption is a deliberate policy choice rather than an automatic step.

I also have five procedural concerns under HUD CPD Notice 21-10 (issued September 13, 2021, available at https://www.hud.gov/sites/dfiles/OCHCO/documents/2021- 10cpdn.pdf).

The notice text as posted does not disclose whether the City of Glendale has met the following procedural requirements that govern HOME-ARP substantial amendments under CPD-21-10:

1. On consultation with required agencies under CPD-21-10 Section V.A, including the Continuum of Care, public housing agencies, homeless and domestic violence service providers, veterans' groups, and fair housing, civil rights, and disability organizations: The Glendale CoC is administered jointly with the city's homeless services division within the Community Development Department.

Documentation of which of these required parties were consulted on the senior-EHV- 28 of 61

termination preference should be made publicly available.

2. On the needs and gaps analysis for all four Qualifying Populations under CPD- 21-10 Section V.C.1: The amendment notice does not display the needs analysis or gap analysis supporting why senior EHV households with termination notices were prioritized over the other three Qualifying Populations (homeless, fleeing domestic violence, at greatest risk of housing instability).

4. On functional limitation analysis: With eleven HOME-ARP units at Parkview and approximately 70 eligible senior EHV households competing under the first-priority preference, the other three Qualifying Populations are unlikely to receive any of the eleven units. A preference administered so as to exclude in practice other Qualifying Populations from a HOME-ARP project operates as a limitation under HUD's HOME- ARP Policy Brief, "Preferences, Methods of Prioritization, and Limitations" (May 17, 2022). That guidance provides that a limitation should not be imposed "unless it is necessary to address a greater gap in effective housing, aid, benefit, or services in the PJ's geographic area and the HOME-ARP project or activity cannot address the gap through the use of a preference," that any limitation must be justified in the allocation plan based on the needs assessment and gaps analysis, and that HUD "strongly recommends that PJs consult with the FHEO Division in their local HUD Field Office before establishing a limitation that may have fair housing or civil rights implications." The policy brief is available through HUD Exchange at
https://www.hudexchange.info/resource/6640/homearp-policy-brief-preferences- methods-of-prioritization-and-limitations/.

5. Compliance with the City of Glendale's own Citizen Participation Plan under 24 CFR

91.105 (available at https://www.ecfr.gov/current/title-24/section-91.105). The 15-day comment period meets the floor in CPD-21-10 Section V.C.6 governing substantial amendments to the HOME-ARP allocation plan. However, CPD-21-10 Section V.B separately requires the City to follow its adopted requirements for reasonable notice and an opportunity to comment for plan amendments in its current Citizen Participation Plan. Glendale's Citizen Participation Plan, like 24 CFR 91.105(c)(2), requires a period of not less than 30 calendar days for substantial amendments. The City's own treatment of the companion FY 2025-2026 Annual Action Plan substantial amendment, open for public comment April 27 through May 29, 2026, a period of approximately 33 days, confirms that the longer period applies. The 15-day window on this amendment is inconsistent with the City's own concurrent practice and with its Citizen Participation 29 of 61

Plan. The Citizen Participation Plan should be posted alongside the amendment notice, and the comment period should be re-opened to satisfy the longer-of requirement.

Further, I have three additional concerns about the public participation record.

3. I object to the City's use of the same preference architecture selectively while declining to articulate the basis for that selectivity, and to the fact that the senior subpopulation count was computable from the April 28 agenda yet not displayed to the public until May 7, after the May 5 hearing had already certified no path forward for the 188. The 188 households did not become 70 households on May 7. They remain 188.

Thank you and best regards,
Ani
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CITY OF GLENDALE

HOME-ARP ALLOCATION PLAN

March 30, 2023

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2 TABLE OF CONTENTS

Introduction………………………………………………………………….……3

Consultation…………………………………………………………………….…4

Public Participation…………………………………………………………...…13

Needs Assessment and Gap Analysis ………………………………………..…14

HOME-ARP Activities and Production Goals…………………………………20

Preferences and Limitations………………….…………………………………22

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3 Introduction

In 2021, President Biden signed the American Rescue Plan (ARP) into law, which provides over $1.9 trillion in relief to address the continued impact of the COVID -19 pandemic on the economy, public health, State and local governments, individuals, and businesses.

To address the need for homelessness assistance and supportive services, Congress appropriated $5 billion in ARP funds to be administered through the Home Investment Partnerships Program (HOME) to perform eligible activities. Those activities include:

(1) Development and support of affordable housing – including acquisition, rehabilitation or construction of affordable rental housing,

(2) Tenant-based rental assistance (TBRA),

(3) Provision of supportive services,

(4) Acquisition and development of non-congregate shelter units,

(5) Nonprofit Operating and Capacity Building Assistance; and

(6) Administration and Planning (15% Cap)

The above eligible activities must primarily benefit individuals and families in the following specified “qualifying populations:”

1. Homeless, as defined in section 103(a) of the McKinney-Vento Homeless Assistance Act, as amended (42 U.S.C. 22304(s)) (“McKinney-Vento”);

2. At risk of homelessness, as defined in section 401 of McKinney-Vento;

3. Fleeing, or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking;

4. Part of other populations where providing supportive services or assistance would prevent a family’s homelessness or would serve those with the greatest risk of housing instability.

This population includes one or more of the following:

• families requiring services or housing assistance to prevent homelessness

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4 • households at greatest risk of housing instability, including

(a) those with an annual income less than or equal to 30% of the Area Median Income (AMI), and

(b) households with an annual income less than or equal to 50% of AMI AND meet the McKinney-Vento definition of At Risk of Homelessness; or

5. Veterans and families that include a veteran family member that meet the criteria in one of (1)-(4) above.

The United States Department of Housing and Urban Development (HUD) allocated $5,109,346 in HOME -ARP funding to the City of Glendale. The City engaged in consultation with organizations within its Continuum of Care, as well as other public and private organizations who work with the above qualifying populations, and sought public participation to determine how to best allocate its HOME-ARP funding.

This allocation plan details the results of the consultation and public participation process and describes how the City of Glendale intends to serve qualifying populations with HOME-ARP funds.

Consultation

The City of Glendale consulted with organizations within its Continuum of Care, developers, Housing Authority staff, and City Homeless Programs staff to determine the size and demographics of each qualifying population. Consultation was primarily accomplished through use of a survey. Staff also contacted organizations and city staff by phone and email to obtain data. Consultation dates were from February 13, 2022 to March 20, 2022.

The following table summarizes the organizations consulted and feedback given.

Agency/Org
Consulted
Type of
Agency/Org
Method of
Consultation Feedback
Glendale Tenant
Union
Public or private
organizations that
address fair
housing. QPs
served: At risk of
homelessness,
other populations
Stakeholder
Survey
• Need more affordable
housing.
• Need more funds to aid
the current homeless
population.
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5 Agency/Org
Consulted
Type of
Agency/Org
Method of
Consultation Feedback
City of Glendale:

Glendale Library,
Arts & Culture
Public agencies
that address the
needs of all
qualifying
populations.

Stakeholder
Survey
• At our branches, we
have all levels of
homeless services
needs.
• We use Ascencia to
connect homeless
patrons and we also
service resistant to
services patrons.
• We could use more
people in the library to
help connect people to
services.

City of Glendale:

Glendale Police
Department
Public agencies
that address the
needs of all
qualifying
populations
Stakeholder
Survey
• Outreach services are
not available during non-
working hours such as
evening and weekend
hours
Armenian Relief
Society of Western
USA, Social
Services
Homeless Service
Provider. QPs
served:

Homeless, At risk
of homelessness,
Other populations
Stakeholder
Survey
• At the present time, we
are encountering
insufficient services for
homelessness
prevention. Specifically,
for single older adults
with limited income.
• Our organization would
benefit from additional
funding for
homelessness
prevention, rapid re-
housing, and supportive
services for the target
population.

Adventist Health Homeless Service
Provider. Serves
all QPs.

Stakeholder
Survey
• Not enough housing
capacity within Glendale
• No organization of
existing programs and
resource collaboration

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6 Agency/Org
Consulted
Type of
Agency/Org
Method of
Consultation

Feedback
Glendale
Community
Services, Parks &
Recreation
Commission

Homeless Service
Provider. Serves
all QPs.

Stakeholder
Survey
• Need more Homeless
outreach personnel.
• Need a second
organization similar to
Ascencia to help with
finding housing.
• Major need for more
affordable housing!
• Need a shelter for
homeless during
extreme hot or cold
spells.

Community
Resource Center
for Aging
USC Verdugo Hills
Hospital
Public or private
organizations that
address the needs
of all qualifying
populations.

Serves the needs
of persons with
disabilities.

Stakeholder
Survey
• Need for low-
income/affordable
housing for seniors and
the disabled
• Need to improve access
to Section 8 housing -
waiting list
Community
Resource Center
for Aging
USC Verdugo Hills
Hospital
Public or private
organizations that
address the needs
of all qualifying
populations.

Serves the needs
of persons with
disabilities.

Stakeholder
Survey
• Need for low-
income/affordable
housing for seniors and
the disabled
• Need to improve access
to Section 8 housing -
waiting list
Glendale Unified
School District
Public agencies
that address the
needs of all
qualifying
populations.

Stakeholder
Survey
• Need short-term hotel
vouchers for
emergencies.
• Need short-term housing
for undocumented
• Linkage with several
housing agencies to
provide homeless
prevention
• Need low-
income/affordable
housing for seniors and
the disabled
• Need fresh food
distributions
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7 Agency/Org
Consulted

Type of
Agency/Org

Method of
Consultation

Feedback
USC Verdugo Hills
Hospital -
Community
Resource Center for
Aging

Public or private
organizations that
address the needs
of the qualifying
populations. QPs
served: At risk of
homelessness,
Other populations.

Serves the needs
of persons with
disabilities.

Stakeholder
Survey
• Housing navigator
needed to help older
adults find apartments
and senior housing.

Navigator who can help
transport seniors to look
at apartments - some do
not have transportation
and limited mobility.
• Assistance with moving
and moving costs.
• Need for affordable
senior housing with
supportive services.
• Educate older adults re
section 8 housing
projects and vouchers
and research/apply for
wait lists even outside of
Glendale - do some
longer range planning to
prevent housing
insecurity.

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8 Agency/Org
Consulted

Type of
Agency/Org

Method of
Consultation

Feedback

Glendale Memorial
Hospital and
Health Center
Public or private
organizations that
address the needs
of the qualifying
populations. QPs
served: At risk of
homelessness,
Fleeing or
attempting to flee
domestic violence,
sexual assault,
stalking or human
trafficking. Serves
the needs of
persons with
disabilities.

Stakeholder
Survey
• Need for shelters that
can accommodate
individuals who are
independent with no
medical needs requiring
a place to stay and
linkage to services to
establish more
permanent housing.

• We only have 1 shelter
that is not even a walk
in. We do not have any
options for immediate
temporary or emergency
housing/shelter for
individuals who leave
our hospital and are
seeking assistance.

Door of Hope Organization that
serves the needs
of the following
QPs: Homeless, At
risk of
homelessness,
fleeing or
attempting to flee
domestic violence,
dating violence,
sexual assault,
stalking or human
trafficking.

Stakeholder
Survey
• Lack of affordable
housing.

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9 Agency/Org
Consulted

Type of
Agency/Org

Method of
Consultation

Feedback
YWCA Glendale
and Pasadena
Public or private
organizations that
address the needs
of the qualifying
populations.

Domestic Violence
Service Provider.

Stakeholder
Survey
• Personal Safety: having
faced discrimination
because of being a
Domestic Violence
survivor, being denied
services from local Taxi
Service companies,
being refused
completion of services.

Feeling unwelcomed
and a sense of not
belonging. Staff at
Domestic Violence
service provider have to
perform additional duties
to ensure clients can
have external services
and respond to the
following:
• - Changing
pickup/destination
location, changing to
Uber services vs local
Taxi companies. For
one Armenian client,
when visiting another
city, felt discriminated
against for Armenian
identity.
• Public Safety: Feeling at
a higher likelihood of
being
stopped/cited/arrested
by the Glendale Police
Department. DV Service
Provider staff need to
provide specific
directions and shortcuts
to get in and out of City
quickly.

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10 Agency/Org
Consulted

Type of
Agency/Org

Method of
Consultation
Feedback
YWCA Glendale
and Pasadena
(continued)
Public or private
organizations that
address the needs
of the qualifying
populations.

Domestic Violence
Service Provider.

Stakeholder
Survey
• One client was arrested
and sent to jail over
outstanding car tax. One
client questioned and
made to cry over a
different type of car seat
for one of her children
(in front of her child)
• Housing Access: Being
discriminated against by
local landlords and
property managers once
they identify client as DV
survivor. DV Service
Provider staff need to
create and maintain
relationships with
landlords. Not enough
City programs to
educate, correct, and
intervene with property
owners.
• Public Schools: Some
students will tease
children from shelters.

On some occasions,
children from shelters
are the only ones NOT
invited to kid’s parties.

Students and families
need education from
City programs to not
alienate, or somewhat
facilitate the othering of
children from DV
survivor families.

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11 Agency/Org
Consulted

Type of
Agency/Org

Method of
Consultation

Feedback
Home Again L.A. Public or private
organizations that
address the needs
of all qualifying
populations.

Stakeholder
Survey
• We do not have Crisis
Housing available.

Should someone/family
contact an agency in
Glendale who needs
shelter it's not possible
to get them into shelter
immediately. Some of
our agencies are at
maximum capacity.
• We are in need of
Security Deposit
Assistance, Case
Management (Staffing),
Landlord Incentives.
• Need for mental health
services.

USC Verdugo Hills
Hospital -
Community
Resource Center for
Aging

Public or private
organizations that
address the needs
of the qualifying
populations. QPs
served: At risk of
homelessness,
Other populations.

Serves the needs
of persons with
disabilities.

Stakeholder
Survey
• Housing navigator
needed to help older
adults find apartments
and senior housing.

Consultation Results – Unmet Needs and Gaps Identified for Homeless Population

1. Insufficient services for homelessness prevention.

2. Need for crisis housing.

3. Need for more outreach services, including during non-working hours.

4. Need for a 2nd organization within the city to provide homeless services.

5. Need for short term hotel vouchers for emergencies.

6. Need for shelters that accommodate individuals who are independent with no medical needs.

7. City of Glendale Homeless Programs staff also noted a rise in senior 41 of 61

12 homelessness, with some seniors facing homelessness for the first time.

Consultation Results – Unmet Needs and Gaps Identified for those At Risk of Homelessness, and Other Populations

1. There is a need for more affordable housing units.

2. Few opportunities for residents of Glendale to participate in low-income housing due to limited number of units available in the City.

3. Services needed to help seniors find apartments and senior housing, including transportation services and assistance with moving.

4. Education needed for seniors to help them research housing opportunities, and to help them apply for wait lists.

Consultation Results – Unmet Needs and Gaps Identified for those Fleeing or Attempting to Flee Domestic Violence, Dating Violence, Sexual Assault, Stalking or Human Trafficking

1. Population has the feeling that they are more at risk of being stopped/cited/arrested by police.

2. Need for staff to provide specific directions and shortcuts to get in and out of City quickly.

3. Experiencing discrimination from landlords and companies (like taxi services) once the client is identified as a DV survivor.

Stakeholder organizations were asked the to rank HOME-ARP eligible activities, identifying which activity would be most beneficial to the qualifying population it serves.

Following are the results of the ranking:

0 0.5
1 1.5
2 2.5
3 3.5
4 4.5
Non-Congregate
Shelter
Supportive Services Tenant Based Rental
Assistance
Development of
Affordable Housing
Ranking of HOME-ARP Activity most needed
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13 As the chart shows, a majority of stakeholder organizations ranked Tenant Based Rental Assistance and Development of Affordable Housing as the most beneficial activities for the qualifying populations they serve.

Public Participation

The City of Glendale posted a public notice in the Glendale Independent newspaper on the following dates:

March 6, 2023
March 9, 2023
March 13, 2023
March 16, 2023
March 20, 2023

The notice invited stakeholder organizations and the public to a public hearing to be conducted during a Joint Meeting of the Glendale City Council and Glendale Housing Authority on Tuesday, March 28, 2023 at 3:00 PM. The notice also indicated that the city anticipated receiving $5,109,346 in HOME-ARP funding and intended to spend the funds on the development of rental housing to serve the needs of one or more of the qualifying populations.

A website address was listed in the notice where stakeholder organizations could complete a survey created to gauge the housing and supportive service needs of qualifying populations within the City and region. The survey was also distributed to organizations within the City’s Continuum of Care.

A website address was also listed in the notice where citizens could complete a survey created to help quantify the number of residents in Glendale and the region who fall within the Qualifying Populations. The citizen survey was also emailed to 16,378 people on the City’s affordable housing interest/notification list.

HOME-ARP funding was discussed at a community meeting designed to obtain input from the community on its housing needs, and participants at the meeting were encouraged to complete the survey.

Organizations and citizens were encouraged to submit feedback and comments to the City during a 15 day comment period.

Public comment period start date: March 6, 2023
Public comment period end date: March 20, 2023

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14 In addition to the public notice and survey distribution, City of Glendale staff contacted developers and community organizations to seek data on the size and needs of qualifying populations.

While the City of Glendale did not receive specific comments during the public participation period, it did receive 834 responses to a survey sent out to over 16,000 individuals on the City’s affordable housing interest/notification list.

There were no comments or questions from the public during the Public Hearing conducted by the Joint Meeting of the Glendale City Council and Glendale Housing Authority on March 28, 2023.

Needs Assessment and Gaps Analysis

HOMELESS POPULATION

According to the City of Glendale 2022 Homeless Count Comprehensive Report, 225 persons were homeless (122 sheltered and 103 unsheltered). This represented a 33% increase from 2020 (a count was not conducted in 2021 due to the Covid-19 pandemic).

Highlights of the 2022 Sheltered Point-In-Time Count

Of the 122 total persons counted as sheltered homeless in 2022:

Gender
• 48% Men
• 51% Women
• 1% Transgender

Household Breakdown
• 43% Single adults without children
• 57% Family with at least 2 child and adult

Subpopulations
• 3% Veteran status
• 21% Adult survivors of domestic violence

Age
• 37% 0-17 Years Old
• 1% 18-25 Years Old
• 48% 25-64 Years Old
• 14% 65 and older
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15 Highlights of the 2022 Unsheltered Point-In-Time Count

Of the 103 total persons counted as unsheltered homeless in 2022:

Gender
• 65% Men
• 24% Women

Age
• 4% 18-24 Years Old
• 17% 25-34 Years Old
• 41% 35-54 Years Old
• 17% 55-61 Years Old
• 21% 62 and older

Subpopulations
• 2.9% Veteran status

16 of 834 respondents in the HOME-ARP Citizen survey created by the city indicated that they were homeless. Of this group, 87.5% were Glendale residents. All respondents lived in Los Angeles County.

Resources
The City of Glendale has 3 affordable housing projects (a total of 34 units) within its portfolio designated for individuals and families experiencing homelessness. Vacancies in these projects are filled in the following manner:

1. By the homeless services nonprofit operating the project

2. If the project is not operated by a homeless services nonprofit, organizations within Glendale’s Continuum of Care are notified of the vacancy and given a time frame to fill the vacancy with a household experiencing homelessness.

The Glendale Homeless Continuum of Care (CoC) is one of thirteen CoCs officially recognized by HUD for participation in local and regional efforts to prevent and end homelessness in Southern California. It has established a Coordinated Entry System to streamline homeless services and quick re-housing of the homeless population.

Within the CoC, the City collaborates with Ascencia, a homeless services nonprofit organization, to provide one stop social services for individuals and families experiencing homelessness. At Ascencia, clients receive help with housing, case 45 of 61

16 management, health and mental health services, and emergency shelter intake.

Ascencia operates a 45-bed shelter for single adults and families. Clients go through an assessment process to determine what services are needed.

A mobile street outreach team is based at Ascencia and provides assessment and services to homeless persons on the streets of Glendale Monday-Friday from 7 am to 4 pm.

The following table summarizes the existing inventory of beds and units available to the homeless population in Glendale, and shows the current gap in resources.

Homeless Needs Inventory and Gap Analysis Table

Homeless
Current Inventory Homeless Population Gap Analysis
Family Adults Only Vets Famil
y HH
(at
least
1 child)
Adult
HH
(w/o
child)
Vets
Victim
s of
DV
Family Adults Only
# of
Beds
# of
Units
# of
Beds
# of
Units
# of
Beds
# of
Beds
# of
Units
# of
Beds
# of
Units
Emergency
Shelter 35 0 54 0 0
Transitional
Housing 49 0 1 0 0
Permanent
Supportive
Housing
68 0 101 0 12
Other
Permanent
Housing
0 0 5 0 0
Sheltered
Homeless 22 52 4 16
Unsheltered
Homeless 0 103 3 2
Current Gap 0 22 0 155
Data Sources: 1. City of Glendale: 2022 Glendale Homeless Count Comprehensive Report; 2. City of Glendale Affordable Housing Portfolio. 3. City of Glendale 2022 Housing Inventory Count.

The table reflects numbers reported in the Housing Inventory County in 2022. It shows a gap of 22 units for homeless families and 155 units for homeless adult only households. Organizations within the CoC expressed the need for non-congregate shelter units and crisis housing to immediately shelter individuals and families experiencing homelessness.

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17 The table does not account for occupied units at Glen Grove apartments, a family affordable housing development with 23 affordable units where vacancies are made available to the Continuum of Care first before opening units up to an existing waitlist.

AT RISK OF HOMELESSNESS AND OTHER POPULATIONS

Based on data from the American Community Survey (ACS) 2015-2019 and the most recent Comprehensive Housing Affordability Strategy (CHAS), 14,595 Glendale households are at risk of homelessness in the City of Glendale. Another 7,205 households fall within the qualifying population of “other populations requiring services or housing assistance to prevent homelessness,” and “other populations at greatest risk of housing instability” as defined by HUD.

The City has developed 195 units of affordable housing for households at or below 30% of AMI.

The units are currently occupied. That leaves a gap of at least 14,400 households at risk of homelessness that would not have access to affordable units when they become available.

The City has also developed 627 units of affordable housing for households between 30% and 50% of AMI. That leaves a gap of at least 6,578 households within the “other populations” category that would not have access to affordable units when they become available.

Following is a table that illustrates the level of housing needs and the gap in affordable housing for households within these qualifying populations.

Housing Needs Inventory and Gap Analysis Table

Non-Homeless
Current
Inventory Level of Need Gap Analysis
# of Units # of Households # of Households
Total Rental Units 50,179
Rental Units Affordable to HH at 30%
AMI (At-Risk of Homelessness) 195
Rental Units Affordable to HH at 50%
AMI (Other Populations) 627
0%-30% AMI Renter HH w/ 1 or more
severe housing problems
(At-Risk of Homelessness)
14,595
30%-50% AMI Renter HH w/ 1 or more
severe housing problems
(Other Populations)
7,205
Current Gaps 20,978
Data Sources: 1. US Census American Community Survey (ACS) 2015-2019; 2. Comprehensive Housing Affordability Strategy (CHAS), Glendale Housing Authority Affordable Housing Portfolio

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18 30.8% of respondents in the HOME-ARP Citizen survey created by the city indicated that they were at risk of homelessness. 66.7% of respondents reported spending more than half of their income toward rent.

81.8% of respondents indicated that they had an income at either 30% or below of AMI, or an income between 30%-50% of AMI.

Following are additional details on the responses received.

At Risk of Homelessness
Of 834 respondents, 54.6% reported an income at or below 30% of AMI, and 89% of the respondents in this income category reported paying more than half of their income toward rent. Of this group:

• 88% were Glendale residents
• 36% reported being at risk of homelessness
• .02% (11 respondents) reported being homeless
• .005% (2 respondents) reported being veterans
• .005% (2 respondents) reported being domestic violence survivors

Other Populations
Of 834 respondents, 27.2% of survey respondents reported an income between 30% and 50% of AMI, and 90% of the respondents in this income category reported paying more than half of their income toward rent. Of this group:

• 77% were Glendale residents
• 20.8% reported being at risk of homelessness
• .009% (2 respondents) reported being homeless
• .024% (5 respondents) reported being domestic violence survivors

Seniors

Of 834 respondents in the Glendale Citizen survey, 36% reported being over the age of 62. Of this group, 95% reported an income at either 30% or below of AMI, or an income between 30%-50% of AMI. Following are additional details on the responses received from seniors in these income categories:

76% of seniors reported an income at or below 30% of AMI, and 93% of the senior respondents in this income category reported paying more than half of their income toward rent. Of this group:

• 81 % were Glendale residents
• 35 % reported being at risk of homelessness
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19 • 2 % (4 respondents) reported being homeless
• 1 % (2 respondents) reported being veterans

24% of seniors reported an income between 30% and 50% of AMI, and 82% of the senior respondents in this income category reported paying more than half of their income toward rent. Of this group:

• 53% were Glendale residents
• 21% reported being at risk of homelessness

The results of the survey suggest a large gap in affordable housing available for households at risk of homelessness and other populations.

POPULATION FLEEING, OR ATTEMPTING TO FLEE, DOMESTIC VIOLENCE,

DATING VIOLENCE, SEXUAL ASSAULT, STALKING, OR HUMAN TRAFFICKING

12 of 834 respondents in the HOME-ARP Citizen survey created by the city indicated that they were victims of domestic violence. Of this group, 58.3% were Glendale residents. All respondents lived in Los Angeles County.

Following is additional demographical data on the 12 respondents who reported being within this qualifying population:

Gender
• 33% Men
• 67% Women

Age
• 92% 25-61 Years Old
• 8 % 62 and older

Household Composition
• 17% More than 1 Adult
• 25% More than 1 Adult with at least 1 Child
• 25% Single Adult
• 33% Single Adult with at least 1 Child

21% of sheltered homeless in the City of Glendale’s 2022 Point in Time Count indicated that they were fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking or human trafficking.

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20 The City works with the YWCA of Glendale and Pasadena to provide domestic violence services and referrals to confidential shelters. Data collected by the YWCA showed that as of March 2023, there were 24 families (with a total of 74 individuals) fleeing domestic violence in the City of Glendale.

While consultation with organizations within Glendale’s CoC did not reveal any gaps in providing shelter for victims and survivors of domestic violence, some feedback received indicated a need for better treatment of domestic violence survivors by police departments and companies providing services to this qualifying population.

Priority needs for qualifying populations
Based on results of data analysis and consultation, and evaluating gaps and unmet needs as described in this plan, the City of Glendale has identified that those at risk of homelessness and those at the greatest risk of housing instability face the largest gap in access to affordable housing units to prevent them from experiencing homelessness.

Results of a citizen survey created by the city show that a majority of respondents that fit within this qualifying population are paying more than half of their income toward rent, and are therefore facing severe cost burden.

Within this population, seniors face a particularly heavy cost burden. The city’s HOME- ARP citizen survey revealed that 93% of respondents over the age of 62, and with an income at or below 30% of AMI, paid more than half of their income toward rent. A majority of seniors in Glendale are on fixed income, receiving Social Security or SSI.

The homeless population also faces a gap in the number of non-congregate shelter and crisis housing units available for immediate shelter.

HOME-ARP Activities and Production Goals

The Glendale City Council and Glendale Housing Authority have made production of affordable housing units its top priority. It uses a variety of funding, including local Measure S funds to accomplish this goal. HOME-ARP funds will enable the City to meet its goal of addressing the demand for affordable housing among qualifying populations.

Through the HOME-ARP consultation process, needs assessment and gap analysis, the City of Glendale has determined that this highest priority for use of HOME-ARP funds is the development of affordable rental housing. To that end, the city has identified a recently acquired property as a site to utilize HOME-ARP funding for the development of affordable housing to benefit qualifying populations.

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21 The site at 426 Piedmont Avenue may be converted to a total of 58-67 units of affordable housing. HOME -ARP funds may help develop 25- 30 units on the site for qualifying populations.

The City will solicit proposals to develop the project using either a Request for Qualifications (RFQ) or a Request for Proposals (RFP). The RFQ or RFP will be issued to over 100 organizations and over 250 individuals who have expressed an interest in developing affordable housing projects in Glendale. These organizations are spread out throughout Southern California. City staff from Housing, Planning, Building and Safety, and others will form a review committee and review each proposal and make a recommendation to the Housing Authority Board based on criteria outlined in the RFQ or RFP. The Housing Authority can accept staff’s recommendation or select another developer team to partner with to develop the affordable housing project. The developer team will be provided an Exclusive Negotiating Agreement upon selection. Staff will then works with the developer team to further plan the project, entitle the project, secure additional financing, and ultimately enter into an Affordable Housing Agreement (AHA).

After the AHA is executed and financing is in place, the project begins construction per the AHA, which details the scope of work, schedule of performance, method of financing, and many more details.

All administrative tasks related to administering and monitoring HOME-ARP funded activities at 426 Piedmont Avenue will be directly carried out directly by City of Glendale staff.

Following is a breakdown of how the City of Glendale will allocate HOME-ARP funding.

Use of HOME-ARP Funding
Funding Amount Percent of
the Grant
Statutory
Limit
Supportive Services $ 0
Acquisition and Development of Non-
Congregate Shelters $ 0
Tenant Based Rental Assistance
(TBRA) $ 0
Development of Affordable Rental
Housing $ 4,342,944.10
Non-Profit Operating $ 0 0 % 0%
Non-Profit Capacity Building $ 0 0 % 0%
Administration and Planning $ 766,401.90 15 % 15%
Total HOME ARP Allocation $ 5,109,346

The City compared the number of available affordable housing units and services for each qualifying population to the size of the population and found that the largest gap 51 of 61

22 was for affordable units for households at risk of homelessness, and other populations at greatest risk of housing instability, specifically households that are at or below 30% of AMI and who are cost burdened.

HOME-ARP funds will be used to develop approximately 25-30 affordable housing units for qualifying populations at 426 Piedmont Avenue, with a preference for seniors facing homelessness, at risk of homelessness and other senior populations at greatest risk of housing instability. Once a developer is approved by the City Council and Housing Authority, and the Authority has entered into an Affordable Housing Agreement with the developer, funds will be distributed to the developer upon progress of construction of affordable housing units.

Preferences

The City of Glendale may give a preference to seniors who are facing homelessness, at risk of homelessness, and seniors who are at greatest risk of housing instability. The city may work with the Glendale CoC to identify and refer seniors who fall within these qualifying populations for HOME-ARP funded units.

This preference will help relieve the cost burden of vulnerable seniors who are on fixed incomes and facing homelessness, or at risk of homelessness, as their fixed incomes are not able to keep up with the rise in housing costs. That cost burden was reflected in the citizen survey that the city created. 95% of senior respondents indicated that their income was at or below 30% of AMI, or between 30% and 50% of AMI, and over 90% of senior respondents indicated that they paid more than half of their income toward rent.

Limitations

Development of HOME-ARP funded units at 426 Piedmont may be restricted for occupancy by seniors over the age of 62. HOME-ARP funded units may be offered to seniors through the Glendale CoC who meet the criteria of HOME-ARP qualifying populations. A preference will be given to seniors facing homelessness, at risk of homelessness, and seniors at greatest risk of housing instability. However, units may also be offered to seniors fleeing domestic violence, and senior veterans who also meet the criteria of one or more HOME-ARP qualifying populations.

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2 CITY OF GLENDALE, CALIFORNIA
REPORT TO THE JOINT MEETING: GLENDALE CITY COUNCIL AND GLENDALE

HOUSING AUTHORITY

AGENDA ITEM
Report: Adoption of the FY 2026-27 Glendale Housing Authority Budget 1) Resolution of the City Council Making Findings and Approving Expenditures of Low Moderate Income Housing Asset Funds for Administration, Planning and Expenditures Outside of Redevelopment Project Areas for the FY 2026-27 Housing Authority Budget. 2) Resolution of the Housing Authority Making Findings and Approving Expenditures of Low Moderate Income Housing Asset Funds for Administration, Planning and Expenditures Outside of Redevelopment Project Areas for the FY 2026-27 Housing Authority Budget and Adopting the FY 2026-27 Housing Authority Budget.

COUNCIL ACTION
Item Type: Action Item
Approved for June 23, 2026 Calendar

EXECUTIVE SUMMARY
The Community Development Department, Housing Division presents the Fiscal Year 2026-27 budget of all Housing funds for consideration and budget adoption. 53 of 61

22 6
9 1
2 RECOMMENDATION
Staff recommends the Council and Housing Authority adopt the FY 2026-27 budget as presented and make the required findings to utilize the funds outside of the Redevelopment Project Areas.

ANALYSIS
For FY 2026-27, the proposed budget for the Glendale Housing Authority is $64,735,709.

The Housing Authority Budget is primarily a grant funded / special revenue specific budget with funding from:
- Federal sources that are received on an annual basis; - Encumbered assets/program income from previous investments of Redevelopment 20% Housing Set Aside funds;
- Development related affordable housing fees including the Affordable Housing Density Bonus fee, City-Wide Inclusionary Housing In-Lieu fee, and the Commercial Development Impact fee; and
- One-time State grant awards.

The Housing Authority has the responsibility for administering the following programs:
-The Housing Assistance Fund (2020) – federal Section 8 Housing Choice Vouchers (HCV), VASH, Mainstream Vouchers for rental assistance to low income households;
-HOME Grant Fund (2030) – federal funds for housing development and preservation activities for low income households;
-Continuum of Care Grant Fund (2040) –federal funds for Supportive Services, Rapid Re-Housing, Permanent Supportive Housing, and Rental Assistance Program, to assist unhoused individuals and families to regain housing stability and work towards self-sufficiency;
-Emergency Solutions Grant Fund (2050) – Federal funding for homeless prevention, outreach, emergency shelter essential services, and rapid re- housing, to support those who are at-risk of homelessness currently experiencing homelessness.
-Affordable Housing Trust Fund (2090) – funds received from inclusionary housing fees, affordable housing density bonus fees, and miscellaneous program income to be expended on affordable housing purposes not covered by other restricted state and federal housing funds;
-BEGIN Affordable Homeownership Fund (2120) – State funds for down payment assistance to first time home buyers who are Moderate Income households (currently invested in the Doran Gardens project); -Low & Mod Income Housing Asset Fund (2130) – funds from previous 20% Redevelopment Set Aside funds for housing development and preservation activities (including administration and program delivery) for Low and Moderate Income households, in accordance with State law;
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32 6
9 1
2 -Miscellaneous Grant Funds (2160) – State grant funds for the Homeless Housing Assistance and Prevention Program (HHAP-6);
-Measure H Fund (2240) – County sales tax measure revenue used to assist with ending homelessness focusing on three key areas: Homeless Prevention, Time- Limited Subsidies, and Housing Navigation & Location;
-Permanent Local Housing Allocation Fund (2280) – State funds for housing- related projects and programs to address the unmet housing needs in the community;
-Measure A Affordable Housing Fund (2290) – County sales tax measure revenue to fund programs that reduce and prevent homelessness within three categories: production, preservation, and ownership (PPO), renter protection and homelessness prevention (RPHP), and technical assistance (TA); -Measure A Homeless Services Fund (2291) – County sales tax measure to fund programs that reduce and prevent homelessness, specifically for homeless programming; and
-Housing Mitigation Fee Fund (4110) – deposits from the Commercial Development Impact Fee.

Requirement for Findings Related to Former Redevelopment Areas:

Despite substantial changes to the sections of the California Law that apply to Redevelopment (including the dissolution of Redevelopment agencies), some elements of Redevelopment law remain. Redevelopment Project Areas were not eliminated and the requirement remains to approve proposed expenditures of the Redevelopment 20% Set Aside program income (LMIHAF) funds outside the project area as being necessary in order to increase, improve and preserve the supply of affordable housing within the City. Also, the requirement to approve the necessity and appropriateness of the expenditure of LMIHAF funds for administration and planning purposes remains as well.

This has been approved annually in previous years’ budgets, and new City Council and Housing Authority resolutions are included in this report to meet those State requirements.

Information Regarding Section 8 HCV, VASH, and Mainstream Program Expenditures Review:

In preparing the Section 8 federal fund expenditures included in the FY 2026-27 proposed Housing Authority Budget, expenditures have been reviewed for conformance with HUD’s requirements under the Uniform Administrative requirements, Cost Principles, and Audit requirement for Federal Awards.

STAKEHOLDERS/OUTREACH
Not applicable.
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42 6
9 1
2 FISCAL IMPACT
This report presents the annual proposed FY 2026-27 Housing Budget of $64,735,709 to the Glendale Housing Authority for adoption. In addition to the special revenue funds, Homeless Services also includes $582,318 in General Fund dollars (under the Homeless Services cost center 2527) which will be included in the Citywide Budget Adoption process.

ENVIRONMENTAL REVIEW (CEQA/NEPA)
Not applicable.

CAMPAIGN DISCLOSURE
Not applicable.

ALTERNATIVES
Alternative 1: Disapprove the proposed findings and expenditures of the funds from LMIHAF for administration and planning and expenditures outside Redevelopment Project Areas for the FY 2026-27 proposed Housing Authority Budget and may disapprove the FY 2026-27 proposed Housing Authority Budget, which will terminate the Housing programs. Although this is an available option, it is not a recommended alternative.

ADMINISTRATIVE ACTION
Submitted by:

Jack Wong, Interim Director of Community Development
Prepared by:

Michael Fortney, Acting Assistant Director of Community Development Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
Exhibit 1: FY 2026-27 Glendale Housing Authority Budget Summary 56 of 61

RESOLUTION No. ___________

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA

MAKING FINDINGS WITH RESPECT TO ADMINISTRATIVE EXPENSES

AND EXPENDITURES OUTSIDE THE REDEVELOPMENT PROJECT AREAS FOR THE 2026-27 HOUSING AUTHORITY BUDGET
WHEREAS, the Housing Authority of the City of Glendale (“Housing Authority”) administers the Low Moderate Income Housing Asset Fund (LMIHAF) pursuant to Health and Safety Code Section 33334.3 for the purpose of increasing, improving and preserving the City’s affordable housing stock; and
WHEREAS, the Housing Authority must incur certain administrative expenses in connection with its programs to increase, improve and preserve the supply of affordable housing within the City; and
WHEREAS, the Housing Authority finds that the expenditure of LMIHAF outside the Central Glendale and the San Fernando Road Corridor Redevelopment Project areas (the “Project Areas”) will be of benefit to the Project Areas as the completion of project implementation within the Project Areas and will continue to generate jobs within the Project Areas, thereby creating the need for programs throughout the City to increase the supply of affordable housing and improve and preserve the City’s existing affordable housing stock; and

NOW THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA AS FOLLOWS:

SECTION 1.The Council finds and determines that the planning and administrative expenses provided for in the Housing Authority’s Fiscal Year 2026-27 Budget to be made from the LMIHAF are necessary for the production, improvement and preservation of low- and moderate- income housing and directly relate to the projects and programs funded by the LMIHAF.

SECTION 2.The Council finds that the expenditure of LMIHAF outside the Redevelopment Project areas (Central and San Fernando) will be of benefit to the Redevelopment Project areas as the implementation of the Redevelopment Projects has and will continue to generate jobs in the Redevelopment Projects, thereby creating the need for programs throughout the City to increase the supply of affordable housing and improve and preserve the City’s existing affordable housing stock.

Adopted this _____ day of June, 2026.
______________________________
Mayor
ATTEST:
__________________________________
City Clerk
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STATE OF CALIFORNIA )
) SS

COUNTY OF LOS ANGELES )
I, Suzie Abajian, Ph.D., City Clerk of the City of Glendale, certify that the foregoing Resolution No. was adopted by the Council of the City of Glendale, California, at a regular meeting held on the day of , 2026, by the following vote:

Ayes:

Noes:

Absent:

Abstain:
___________________
City Clerk
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RESOLUTION No. ___________

RESOLUTION OF THE HOUSING AUTHORITY OF THE CITY OF GLENDALE

MAKING FINDINGS WITH RESPECT TO ADMINISTRATIVE EXPENSES

AND EXPENDITURES OUTSIDE THE REDEVELOPMENT PROJECT AREAS FOR THE 2026-27 HOUSING AUTHORITY BUDGET AND ADOPTING
THE 2026-27 HOUSING AUTHORITY BUDGET
WHEREAS, the Housing Authority of the City of Glendale (“Housing Authority”) administers the Low Moderate Income Housing Asset Fund (LMIHAF) pursuant to Health and Safety Code Section 33334.3 for the purpose of increasing, improving and preserving the City’s affordable housing stock; and
WHEREAS, the Housing Authority must incur certain administrative expenses in connection with its programs to increase, improve and preserve the supply of affordable housing within the City; and
WHEREAS, the Housing Authority finds that the expenditure of LMIHAF monies outside the Central Glendale and the San Fernando Road Corridor Redevelopment Project areas (the “Project Areas”) will be of benefit to the Project Areas as the completion of project implementation within the Project Areas and will continue to generate jobs within the Project Areas, thereby creating the need for programs throughout the City to increase the supply of affordable housing and improve and preserve the City’s existing affordable housing stock; and

NOW THEREFORE, BE IT RESOLVED BY THE HOUSING AUTHORITY OF THE CITY OF GLENDALE AS FOLLOWS:

SECTION 1.The Housing Authority finds and determines that the planning and administrative expenses provided for in the Fiscal Year 2026-27 Housing Authority Budget to be made from the LMIHAF are necessary for the production, improvement and preservation of low- and moderate-income housing and directly relate to the projects and programs funded by the LMIHAF.

SECTION 2.The Housing Authority finds that the expenditure of LMIHAF monies outside the Redevelopment Project areas (Central and San Fernando) will be of benefit to the Redevelopment Project areas as the implementation of the Redevelopment Projects has and will continue to generate jobs in the Redevelopment Projects, thereby creating the need for programs throughout the City to increase the supply of affordable housing and improve and preserve the City’s existing affordable housing stock.

SECTION 3. The Housing Authority hereby adopts the Fiscal Year 2026-27 Housing Authority Budget as set forth and described in the Joint Report to the Housing Authority and City Council dated June 23, 2026.
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Adopted this _____ day of June, 2026.
______________________________
Chair
ATTEST:
__________________________________
Authority Clerk

STATE OF CALIFORNIA )
) SS

COUNTY OF LOS ANGELES )
I, Suzie Abajian, Ph.D., Clerk of the Housing Authority of the City of Glendale, do hereby certify that the foregoing Resolution No.______________was duly adopted by the Housing Authority of the City of Glendale, at a Joint Meeting of the Housing Authority and the Council of the City of Glendale held on the _______ day of ________________________, 2026, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
___________________________________________
Clerk of the Housing Authority of the City of Glendale
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Exhibit 1
FY 2026-27 Glendale Housing Authority Budget Summary
Fund Proposed
FY 2026-27
Revenues
Proposed
FY 2026-27
Appropriations
Net Surplus/
(Use of Fund
Balance)
2020 - Housing Assistance Fund 55,691,266 56,344,716 653,450 2030 - Home Grant Fund 1,326,822 1,326,822 - 2040 - Continuum of Care Grant Fund 3,374,022 3,374,022 - 2050 - Emergency Solutions Grant Fund 152,823 152,823 - 2090 - Affordable Housing Trust Fund 42,344 155,725 113,381 2120 - BEGIN Homeownership Fund 13,000 13,000 - 2130 - Low&Mod Inc Housing Asset Fund 1,239,000 1,943,535 704,535 2160 - Grant Fund 658,330 658,330 - 2240 - Measure H 300,000 300,000 - 2280 - Perm Local Hsg Allocation Fund* - - - 2290 - Measure A Affordable Housing* - - - 2291 - Measure A Homeless Services 466,736 466,736 - 4110 - Housing Development Impact Fee 10,000 - (10,000) Special Revenue Total 63,274,343 64,735,709 1,461,366 * Fund 2280, Fund 2290: FY 2025-26 appropriation will carry over to FY 2026-27 61 of 61

Glendale City CouncilJune 23, 2026

Glendale City Council
June 23, 2026