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.
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 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.
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 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.
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 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 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.
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
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,
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
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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,
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 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.
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.
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 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.
Thank you and best regards,
Ani