Jim Light, Mayor
REDONDO 415 Diamond Street
BEACH Redondo Beach CA 90277
9 Apr 20
The Honorable Catherine Blakespear
California State Senate
1021 O Street, Room 7720
Sacramento, CA 95814
RE: SB 866 (Blakespear) Homeless Housing, Assistance, and Prevention program:
housing element.
Notice of OPPOSE UNLESS AMENDED
Dear Senator Blakespear,
The City of Redondo Beach must respectfully oppose your SB 866 (Blakespear) unless amended. SB 866 would require all but 14 cities to add extensive homelessness reporting requirements to their housing elements, targeting cities that do not receive state fund- ing to address homelessness.
The state's flagship homelessness grant program, the Homeless Housing, Assistance, and Prevention (HHAP) Grant program, allocates funding to all 58 counties, 44 continuums of care, and cities with populations over 300,000. This means that only 14 cities in Califor- nia are receiving direct state homelessness funding through HHAP.
To receive HHAP funding, grantees must submit a regionally coordinated homelessness action plan to the Housing and Community Development Department that includes specific system performance measures. SB 866 would copy these system performance measures from the HAP regional plans and impose them as a separate reporting re- quirement only on cities not receiving state funding - forcing them to track these met- rics in their housing elements.
Specifically, SB 866 would require all but 14 cities to provide detailed reports on availa- ble homelessness resources, actions taken to connect individuals to those resources, and various data points. For example, SB 866 requires cities to share information about the number of people who become homeless after exiting institutional settings, includ- ing jails, prisons, and hospitals, and the number of people who become unhoused after moving into permanent housing.
SB 866 also requires cities to describe how they are coordinating services under the Be- havioral Health Services Act and identify any available mental and behavioral health funding. Counties, not cities, provide behavioral health services in California and re- ceive all the funding to do so. SB 866 does not currently apply to counties because it only applies to local governments that do not receive HHAP. As a result, SB 866 places the burden on cities to report on and plan for services beyond their control, requiring significant reporting on county-led functions within a city's housing planning document - requirements that cities are not well-positioned to fulfill. 1 Jim Light, Mayor
REDONDO
415 Diamond Street
BEACH
Redondo Beach CA 90277
There is a reason these system performance metrics are currently in the HHAP regional planning process - because gathering this data requires collaboration with counties, prisons, hospitals, VAs, and other stakeholders. These requirements create significant ad- ministrative burdens for communities that already do not receive state financial support to address homelessness. Nearly all cities lack the infrastructure to collect the data re- quired by SB 866, making compliance nearly impossible.
Additionally, while HHAP regional plans are updated each year that funding is availa- ble, most communities update their housing elements every eight years. The City of Re- dondo Beach fails to see how collecting this data every eight years, when much of this information is collected annually through Continuums of Care point-in-time counts, would help address the evolving needs of unhoused residents in our community.
The City of Redondo Beach understands the goal of increasing transparency around the efforts of smaller cities to address the state's homelessness crisis. Currently, cities that do not receive HHAP funding are encouraged to participate in HHAP regional planning but are not required to do so. The City of Redondo Beach is requesting amendments that require smaller cities to have a seat at the table for the regional planning process.
This will accomplish the same goal, providing transparency into the same system metrics that SB 866 includes, but through the same regional process already used by Califor- nia's largest cities.
Redondo Beach specific facts that drive the City's opposition to the bill as currently drafted:
• The City of Redondo Beach does not have direct access to HHAP funding • Los Angeles County receives HHAP funding and distributes it to the cities, so theo- retically, Los Angeles should be reporting this data as it pertains to the funding that Redondo receives. Forcing us to report some of this data would be redun- dant. Additionally, LA County receives $100 million in administrative funding for reporting and does not allocate that to the cities within its jurisdiction. • Most cities, like ours, do not have a case management system to document all the data this bill is requiring. Unless the state provides access to a case manage- ment system, this would be an unfunded mandate.
• The language describing the data is vague and would make cities vulnerable to legal challenges if someone does not believe the city is reporting accurately, potentially subjecting a city to Builder's Remedy.
Each year, the Legislature introduces bills that change the rules mid-stream, significantly complicating cities' efforts to secure housing element certification. These multiyear planning efforts are already complex, time-consuming, and expensive. SB 866 would add yet another layer of reporting requirements — through a non-reimbursable state 2 Jim Light, Mayor Tel: 310.697.3653
REDONDO
415 Diamond Street
BEACH Redondo Beach CA 90277 Redondo.org
mandate - placing a disproportionate burden on smaller cities. For many, the chat- lenge of collecting and reporting this data could further jeopardize their ability to achieve a compliant housing element.
The City of Redondo Beach urges amendments to SB 866 that ensure consistency with the existing HHAP regional planning process and do not unfairly target California's small cities, which continue to be left out of direct state homelessness funding.
For these reasons, as Mayor of the City of Redondo Beach, I respectfully oppose your SB 866 (Blakespear) unless amended.
Sincerely,
James A Light
Mayor
City of Redondo Beach
cc. Senator Ben Allen & Assembly Member Al Muratsuchi
Jeff Kiernan, Regional Public Affairs Manager, LA County Div., League of CA Cities League of California Cities, [email protected]
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