Draft HCD Response to Comments Matrix (April 2024)
HCD Comment, by Chapter City Response to Comment Chapter/Section Appendix C: Assessment of Fair Housing
Racially Concentrated Areas of Affluence (RCAA): As mentioned in HCDs previous letter, the element provided a limited analysis of factors contributing to RCAA’s. While the element was revised to include a few general statements, the analysis should be revised to include local data and knowledge, and other relevant factors. For example, the element could examine past land use practices, investments, and quality of life relative to the rest of the City and region and then formulate appropriate programs to promote more inclusive communities and equitable quality of life. For example, the City should consider additional actions (not limited to the Regional Housing Needs Allocation (RHNA)) to promote housing mobility and improve new housing opportunities throughout the City.
Additional analysis was added detailing the
historical past discriminatory practices that likely
contributed to RCAAs in the city. Information was
added to the local history subsection. Discussion
was added the city's trends of RCAA and how the
City is taking initiative initiatives that promote
affordable housing and a more inclusive
community, and working to overcome past
patterns that contribute to RCAAs.
C.4 RCAAs/ Local Trends,
C.7 Local Knowledge/ Local History,
C.8 Other Relevant Factors/ City-Driven
Initiatives,
C.9 Site Inventory/ Sites by Areas of
Integration and Segregation
Disparities in Access to Opportunity:
While the element was revised to include Table (C-6) on (P.C-48) the element must analyze these data points for trends and patterns throughout the City, and any concentrations or coincidences with other components of the fair housing analysis.
A complete analysis should revise and or provide additional policies and programs that meet the need of each of the components mentioned above.
The Assessment of Fair Housing topics related to
disparities in access to opportunities include
further analysis on the data provided in Table C-6.
Patterns in opportunity access by race/ethnicity
and poverty in the city and within the region are
discussed in further detail for each of the identified
fair housing topic.
C.5 Disparities in Access to Opportunity/
Transit/ Education/Economic and
Employment/ Healthy Indicators
Disproportionate Housing Needs Including Displacement:
While the element was revised to
include additional analysis on displacement risk for areas defined as sensitive communities, the element must provide additional analysis on local and regional patterns for overcrowding, overpayment, and substandard housing including any identified trends and coincidence with other components of the fair housing assessment. In addition, the element briefly mentions persons experiencing homelessness, but should provide additional information on the need, including, impacts and patterns within the City. For instance, the element should examine disproportionate impacts on protected characteristics (e.g., race, disability) and patterns of need, including access to transportation and services. HCD will provide additional guidance under a separate cover.
Additional discussion on the local trends, patterns,
and overlap of fair housing issues, including
displacement has been added throughout
Appendix C. A new table with homeless counts
within the City of Palo Alto and additional
discussion has been added to the Homelessness,
Local Trends subsection. Analysis on
disproportionate impact on certain groups and the
overlap with special housing needs (including race
and disability) has been added where applicable
and specifically to Housing Cost Burden,
Homelessness, and Displacement sections.
C.6 Disproportionate Housing Needs,
Including Displacement/ Housing Cost
Burden/ Substandard Housing/
Homelessness/ Overcrowding/ Displacement
Risk/ Housing Tenure
Identified Sites and Affirmatively Furthering Fair Housing (AFFH):
While the element was revised
to include an analysis on site location and isolation by income group, the element must still relate site selection to all components of the fair housing assessment. In addition, the element should include additional information on how sites will improve fair housing conditions. For example, the element mentions the isolation of lower-income units in the Research; Office and Limited Manufacturing (ROLM) zone; however, the element provides minimal information on how this zone improves fair housing.
Discussion was added on how the site selection
contributes to improved housing conditions,
including number of units allocated, and the
components of fair housing. Discussion was added
regarding sites located in the GM and ROLM zone.
C.9 Site Inventory, Total Units by Resource
Area/ Sites by Area of Integration and
Segregation/ Sites by Disproportionate
Housing Needs/ Sites by CalEnviroScreen
Score
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
HCD Comment, by Chapter City Response to Comment Chapter/Section Local Data and Knowledge and Other Relevant Factors: As noted in the prior findings, the element must supplement the analysis and complement state and federal data with local data and knowledge to capture emerging trends and issues, including utilizing knowledge from local and regional advocates, public comments, and service providers.
Analysis and history about Palo Alto provided by
the City has been added into the Local Knowledge
section, including local history, recent housing
production, and discussion on the emerging trends
and issues in the city, and recent initiatives the City is implementing in order to overcome past
patterns.
C.7 Local Area Knowledge, Local History/
Community Engagement,
C.8 Other Relevant Factors, City Driven
Initiatives
Contributing Factors:
The element identifies many contributing factors to fair housing issues but must prioritize these factors to better formulate policies and programs and carry out meaningful actions to AFFH.
Contributing factors are categorized and prioritized
with corresponding programs in Table C-11. The
table has been updated as needed following
revisions to the Housing Plan as pertains to AFFH.
Appendix C: Assessment of Fair Housing;
Contributing Factors
Ch. 3: Housing Resources and Opportunities
Progress Towards the RHNA:
As you know, the City’s RHNA may be reduced by the number of new units built since June 30, 2022; however, the element must demonstrate the affordability of units in the planning period is based on actual sales price, rent level, or other mechanisms ensuring affordability (e.g., deed restrictions). Table 3-2 on (P.3-5) was revised to include the anticipated affordability of entitled and proposed developments and the element provides some information about past trends to demonstrate the likelihood these units will move from entitlement to building permits. In order to demonstrate the likelihood that the units will be built in the planning period the analysis must consider any barriers to development, phasing, anticipated build-out horizons, market conditions, and other relevant factors to demonstrate their availability in the planning period. For example, the element could apply past success rates to the projects listed on Table 3-2.
The project status and affordability level for the
entitled and proposed development projects listed
in Table 3-2 have been updated. Additional
analysis on building permit history and success
rates was included.
Chapter 3: Housing Resources;
3.3 RHNA Credits, Entitled Developments/
Table 3-2
2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
HCD Comment, by Chapter City Response to Comment Chapter/Section Realistic Capacity: As mentioned in HCDs previous letter, realistic capacity assumptions are generally conservative and based on existing or recently approved residential development within the City and the surrounding region. While development trends can be used to support realistic capacity assumptions, the element must still include an analysis that accounts for existing land use and site improvements. Based on a complete analysis, the element may need to revise current realistic capacity assumptions. In addition, while the element provides some analysis on the likelihood of residential development in zones where 100 percent nonresidential uses are allowed (P. 3-25), the analysis is unclear as to how and if existing policies incentivize residential development in nonresidential zones. Finally, the element should commit to a mid- cycle assessment of residential development in zones that allow 100 percent nonresidential uses. Based on the results of this assessment, the City may need to identify additional sites to meet the RHNA.
Additional analysis has been added to the Realistic
Capacity section to further discuss representative
sites. The representative sites analysis now
includes a list of sites from each area of the city
and an explanation as to the realistic capacity of
the sites and how development would be
supported in these zones. Additionally, sites were
removed/adjusted per public comments. The
realistic density was based on pipeline and regional
trends. Land use controls were analyzed for each
zoning district where the 5th cycle Sites Inventory
was developed; 11 of 16 were developed with
residential uses. Rationale was included for the
strategy applied, along with programs created to
facilitate residential development in these zones.
Chapter 3: Housing Resources;
3.6 Suitability of Residential Opportunity
Sites, Vacant/ Developer Interest, Surface
Parking, Vacant Buildings, Faith Based
Institutions/ Single-Story Buildings/
Improvement-to-Land Value Ratio/ Age of
Structure/ Increased Unit Potential/ Existing
Uses// Sites Used in Previous Planning Period,
3.7 Site Inventory Strategy,
3.8 Adequacy of Residential Site Inventory in
Meeting RHNA
Nonvacant Sites:
As mentioned in HCDs previous letter, the element provides several factors that demonstrate the redevelopment potential of nonvacant sites, including, current and past development trends, improvement to land value ratios, existing use vs zone use, age of structure, floor area ratio (FAR), proximity to transit, TCAC/HCD designations, and community interest. While the element now includes some information on current market demand, the element must still include an analysis addressing HCDs previous finding on the suitability of nonvacant sites. The analysis must address nonvacant sites related to existing uses that may constitute an impediment to additional residential development, past experiences converting existing uses to higher-density residential development, existing leases or contracts that would perpetuate the existing use or prevent additional residential development or other relevant information to demonstrate the potential for redevelopment such as expressed owner and developer interest. Based on a complete analysis, the element may need to add or revise programs to facilitate redevelopment. In addition, please refer to Palo Alto Moving Forward’s July 14, 2023, (P.12) letter for additional information on several data errors identified in the element related to nonvacant sites.
Finally, if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the housing element must demonstrate that the existing use is not an impediment to additional residential development in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). This can be demonstrated by providing substantial evidence that the existing use is likely to be discontinued during the planning period (Gov. Code, § 65583.2, subd. (g)(2).
Additional site selection criteria was added and
discussed, giving more reasoning as to how non-
vacant sites were selected, including criteria that
must be met for non-vacant sites to be included in
the sites inventory. Additional analysis on existing
use of nonvacant sites has been added.
Chapter 3: Housing Resources and
Opportunities; 3.6 Suitability of Residential
Opportunities, Site Selection Criteria/ Existing
Uses/ Table 3-11 Existing Uses on
Opportunity Sites, 3.7 Site Inventory
Strategies
HCD Comment, by Chapter City Response to Comment Chapter/Section Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the County must submit an electronic sites inventory with its adopted housing element. The County must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/communitydevelopment/housing- element/index.shtml#element for a copy of the form and instructions. The County can reach out to HCD at [email protected] for technical assistance.
Sites inventory will be submitted electronically with
subsequent submissions of the Housing Element.
N/A
Zoning for a Variety of Housing Types (Emergency Shelters): While the element was revised to include an analysis on the suitability of the City’s ROLM(E) zone to meet the City’s unsheltered need, the element must be revised to include an analysis of potential reuse and redevelopment opportunities in this zone.
Discussion on redevelopment trends in the GM and
ROLM zones was substantially expanded. Site
criteria and representative sites were included to
provide justification for sites in the Site Inventory.
Chapter 3: Housing Resources and
Opportunities; Amendments to the
Comprehensive Plan and Zoning Code/ROLM/
Table 3-6 Previous VS. New Development
Standards for Opportunity Sites, by
Residential and Mixed-Use New
Districts/Table 3-7 Existing vs. Proposed
Development Standards for Opportunity Sites
and Focus Areas (GM and ROLM Districts);
Chapter 4: Housing Constraints;
4.2 Governmental Constraints, Zoning for a
Variety of Housing Types - Analysis of Land
Use Controls
Ch. 4: Housing Constraints
Land Use Controls:
As mentioned in HCDs prior review, the element must identify and analyze the impact of all relevant land use controls as potential constraints on a variety of housing types in all zones that allow residential uses. While the element now analyzes most zones, the City’s CC, CS, and CD-N zones must still be analyzed.
In addition, the element must also provide an analysis that addresses any impacts on cost, supply, housing choice, feasibility, timing, approval certainty, and ability to achieve maximum densities and includes programs to address any identified constraints. Currently, the element seems to rely on several factors such as the City’s Housing Incentive Program (HIP) and Senate Bill 478 to reach maximum densities. While the HIP can be a great tool for development, the City must demonstrate that current land use controls facilitate housing without the use of this tool.
Finally, the element should link development standards used in recent projects (P.3-13-19) to current land-use controls.
Additional discussion was added on the City’s
Housing Incentive Program, Workforce Housing
Overlay and State Density Bonus Law. Additional
analysis of City's land use controls for the CD-N, CC,
CS zones was added, including figures for model
residential development and an analysis on
potential constraints. Discussion on the
implementation of Programs 3.1 and Programs 3.7
was added to address potential impacts on housing
costs, feasibility, timing, and approval certainty.
Chapter 4: Housing Constraints; 4.2
Governmental Constraints, Zoning for a
Variety of Housing Types - Analysis of Land
Use Controls
3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).) HCD Comment, by Chapter City Response to Comment Chapter/Section Local Processing and Permit Procedures: The element was revised to include a discussion on the City’s processing and permit procedures for potential constraints on approval certainty and timing. However, as mentioned in HCDs prior review, an analysis of cost and financial feasibility is required. Finally, the City relies on processes such as the City’s expedited review process to mitigate timing constraints on approval certainty. While this process can be useful, only projects that adhere to base development standards qualify. As mentioned above, the City should analyze development standards used in recent projects to better understand the effectiveness of the City’s expedited review process. Based on a complete analysis, the City may need to add or revise programs to address constraints on local processing and permit procedures.
Added additional analysis into the fee discussion
including a fee comparison table of neighboring
jurisdictions. An example feasibility case study on
the 850 W. Bayshore Rd. Project was included to
further the conclusion that permit processing costs
and impact fees to address infrastructure
improvements can be absorbed by development
projects.
Chapter 4: Housing Constraints; 4.2
Governmental Constraints, Zoning for a
Variety of Housing Types - Analysis of Land
Use Controls
On/Off-Site Improvements
: As mentioned in HCDs previous letter, the element must identify subdivision-level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.
Expanded the analysis of on/off site improvement
standards including discussions regarding the
following: HUD's study of Subdivision
Requirements, City regulations in accordance with
Title 16 (Building Code) and Title 18 (Zoning Code),
and Title 18 (Zoning Code) examples of on-site and
off-site improvements, when on and off site
improvements are typically implemented in the
City, Street improvements and regulations under
Subdivision Ordinance, Section 21.20.240, and
public improvement standards and how these
standards typically compare to nearby jurisdictions.
Chapter 4: Housing Constraints; 4.2
Governmental Constraints, On/Off-Site
Improvement Standards
Local Ordinances:
The element now analyzes the City’s Inclusionary Housing ordinance, Tree ordinance, Short Term Rental ordinance, and Retail Perseveration ordinance (RPO). However, the element must provide additional analysis on the City’s RPO and Tree ordinance. Specifically, how units that are not exempt from the RPO (along California Avenue) will develop. In addition, the element mentions the Tree ordinance has been identified as a potential constraint on Accessory Dwelling Units (ADUs). Given this finding, the element must analyze this ordinance as a potential
constraint on a variety of housing types. Finally, the element mentions the City’s Tree ordinance will not apply to state mandated ADUs. The element should be revised to include this language in a program with a specific date of completion early in the planning period.
Discussion regarding Program 3.4 (HIP), which
requires the retail preservation requirement be
further refined to waive its applicability to sites
listed in the Site Inventory except for 21 sites
located within the strategic retails/pedestrian
nodes along El Camino Real. Additionally, Program
3.4 requires a reduction to the amount of retail or
retail-like floor area that must be replaced.
Added discussion on the Tree Protection Ordinance
including recent changes the City made in June
2023 to codify the Tree Protection Ordinance to be
exempt State-mandated ADUs from the ordinance.
Furthermore, the City is preparing amendments to
the Ordinance to provide more flexibility in how
tree protection requirements can be mitigated.
Chapter 4: Housing Constraints; 4.2
Governmental Constraints, Design Guidelines
and Objective Design Standards
HCD Comment, by Chapter City Response to Comment Chapter/Section Ch. 5: Housing Plan
1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element... (Gov. Code,§ 65583, subd. (c).) As mentioned in HCDs previous letter, programs must have a specific commitment to housing outcomes and deliverables. While the element revised several programs, many programs include conducting a “study” prior to additional program commitment. HCD recognizes that program implementation may require a study; however, the element must make firm commitment to program outcomes upon the completion of the study or identify additional programmatic goals or actions that lead to housing outcomes. Programs to revise may include but are not limited to the following: Program 1.6 (Lot Consolidation) Program 2.1 (Affordable Housing Development) Program 3.1 (Fee Waivers and Adjustments) Program 3.4 (Housing Incentive Program (HIP)) Program 3.5 (Accessory Dwelling Unit (ADU) Facilitation) Program 3.6 (Expedited Project Review) 4.2 (Housing and Neighborhood Preservations) Program 6.2 (Family Housing and Large Units) Program 6.5 (Alternative Housing) Program 6.6 (Fair Housing) Finally, Programs (1.3), (1.5), (1.6), (2.1), (3.3), (3.4), (3.5), (3.6), (6.3), (6.5) and (6.6) will need to be revised with either refined commitment or timing. HCD will provide additional guidance under a separate cover.
Actions were expanded out across all programs
including revising timelines so that implementation
phases were more defined and finalization dates
were included. Dates are focused on the first half
of the planning period where feasible.
Verbiage in programs have been adjected to be
more actionable, for example, language such as
"study" or "consider" were changed to be definitive
commitments with more precise timelines. All
programs listed in this comment were revised to
establish more definitive action items, further
explain commitments where needed, and
timeframes were revised to be earlier in the
planning process with very concise timeframes.
Chapter 5: Housing Plan;
Program 2.1 (Affordable Housing
Development)
Program 3.1 (Fee Waivers and Adjustments),
Program 3.2 (Monitor Constraints to
Housing),
Program 3.4 (Housing Incentive Program
(HIP)),
Program 3.5 (Accessory Dwelling Unit (ADU)
Facilitation)
Program 3.6 (Expedited Project Review),
Program 6.3 (Middle Housing Program),
Program 6.5 (Alternative Housing), Program
6.6 (Fair Housing)
HCD Comment, by Chapter City Response to Comment Chapter/Section
2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobile homes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding A2, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.
In addition, Program 1.4: (City-Owned Land Lots) should clarify that all City-Owned sites will comply with Surplus Land Act (SLA). In addition, and as mentioned in HCDs previous letter, the element will need to commit to numerical objectives, including affordability, aligned with assumptions in the inventory, and a schedule of actions to facilitate development. A schedule of actions may include coordination with appropriate entities, including potential developers, disposition of the land, zoning, funding, facilitating other entitlements, and issuing permits.
Finally, this program should identify and make alternative sites with zoning of equivalent capacity and density by a specified date if sites are not made available by a date early in the planning period.
Additional action items were added where
applicable to identify the availability of sites with
appropriate zoning and development standards as
well as access to services and facilities. An example
of this includes Program 1.1 where a discussion of
the El Camino Real focus area was included to
showcase available sites with access to services
and facilities while also accommodating affordable
housing. Upon completion of the site inventory,
programs were refined where applicable to reflect
any new updates to unit numbers, zone changes
etc.
Verbiage was added to comply with the Surplus
Land Act by using the streamlined provisions for
affordable housing dispositions under Government
Code Section 37364.
Chapter 5: Housing Plan;
Program 1.1 Adequate Sites Program,
Program 1.4 City-Owned Land Lots,
Program 6.2: Family Housing and Large Units
3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding A3, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:
• Program 3.4 (Program 3.1 Fee Waivers and Adjustments): The Program should specifically commit to reducing impact fees comprehensively and not limit the scope of the program to park fees.
• Program 6.5 (Alternative housing): The Program should commit to actively mitigating costs related to impact fees on alternative housing.
Programs were revised to comprehensively reduce
impact fees by completing and implementing
economic studies to convert existing development
impact fees that are applied on a per unit basis to a
per square foot basis for all types of housing
including housing for persons with special needs.
Program 2.1 was revised to commit to reducing
impact fees and promote affordable housing.
Additional constraints such as processing timelines
and streamlining were revised to expedite project
application processes with an emphasis on
affordable housing.
Chapter 5: Housing Plan;
Program 3.1 (Fee Waivers and Adjustments),
Program 2.1 (Affordable Housing)
HCD Comment, by Chapter City Response to Comment Chapter/Section
4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov.
Code, § 65583, subd. (c)(5).)
As noted in Finding A1, the element must include a complete analysis of AFFH. The element must be revised to add goals and actions based on the outcomes of a complete analysis. Actions must have specific commitment, milestones, geographic targeting and metrics or numeric objectives and, as appropriate; must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place based strategies for community preservation and revitalization, and displacement
protection.
Programs requiring revisions include but are not limited to the following, Program 1.4 (City- Owned Land Lots) Program 1.6 (Lot Consolidation) Program 2.1 (Affordable Housing Development) Program 3.5 (Accessory Dwelling Unit Facilitation) Program 3.7 (Conversion of Commercial Uses to Mixed Use Development) Program 4.1 (Replacement Housing) Program 4.2 (Housing and Neighborhood Preservation) Program 5.1 (Preservation of At-Risk Housing) Program 5.2 (Funding Opportunities) Program 6.1 (Housing for Person with Special Needs) Program 6.2 (Family Housing and Large Units) Program 6.3 (Missing Middle) Program 6.4 (Homeless Program) Program 6.5 (Alternative Housing) and Program 6.6 (Fair Housing). Finally, based on a
complete analysis, additional program and policy action may need to be included.
Timelines were revised to focus the
implementation of program objectives within the
first half of the planning period in order for
programs to be more effective for identified target
audiences. Furthermore, Program 6, Fair Housing
was revised to contain firmer commitments with
the objective of being more effective for targeted
communities identified in the Assessment of Fair
Housing.
Chapter 5: Housing Plan; Program 1.4 (City-
Owned Land Lots), Program 1.6 (Lot
Consolidation), Program 2.1 (Affordable
Housing Development), Program 3.5
(Accessory Dwelling Unit Facilitation),
Program 3.7 (Conversion of Commercial Uses
to Mixed Use Development), Program 4.1
(Replacement Housing), Program 4.2
(Housing and Neighborhood Preservation),
Program 5.1 (Preservation of At-Risk
Housing), Program 5.2 (Funding
Opportunities), Program 6.1 (Housing for
Person with Special Needs), Program 6.2
(Family Housing and Large Units), Program
6.3 (Middle Housing Program), Program 6.4
(Homeless Program), Program 6.5
(Alternative Housing) and Program 6.6 (Fair
Housing).