City Council
Housing Authority
Report
City Council Meeting: April 11, 2023
Agenda Item: 11.C
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To: Housing Authority, Mayor and City Council
From: Danielle Noble, Acting Director, Community Services Department, Housing and Human Services
Subject: Introduction and First Reading of an Ordinance Forming a Client Advisory Board
Recommended Action
Staff recommends that the Housing Authority Board:
1. Review and provide direction on the proposed approach for the creation of the Client Advisory Board (CAB) to replace the current Resident Advisory Board (RAB).
2. Extend the term of the Section 8 Resident Advisory Board (RAB) member on the Housing Authority Board until two CAB members are appointed (at least one a Section 8 voucher holder) by the Housing Authority.
Staff recommends that the City Council:
1. Introduce for First Reading an Ordinance, adding Chapter 2.70 to create the CAB.
Summary
In 2022, the Housing Authority Board (HAB) gave direction that staff return to the HAB with a proposal for formation of a Client Advisory Board (CAB) to replace the current Resident Advisory Board (RAB), which is currently constituted with all the Housing Authority’s Section 8 Housing Choice Voucher holders. Staff recommends the creation of an inclusive seven-member CAB representing all voucher program participants, appointed by the Housing Authority Board, which conducts meetings following protocols used by existing City Boards and Commissions. The CAB would provide a forum for voucher participants to publicly gather to discuss voucher program issues, enhance understanding of voucher programs and policy, provide annual input to the staff during the Annual Plan process, and act as an advisory body to the Housing Authority Board. 2 of 18
Additionally, the HAB would appoint two of the seven appointed CAB members to serve as tenant representatives on the HAB, which acts as the governing body of the Santa Monica Housing Authority (SMHA). The recommended actions, if adopted, will carry out the HAB’s direction.
The CAB would serve the same function as the Resident Advisory Body (RAB) but include all federally assisted residents (including Continuum of Care, Emergency Housing, HOME, and Veteran Affairs Supportive Housing voucher holders) instead of being limited to Section 8 voucher holders. The SMHA has historically included provisions relating to its administration of all federally assisted voucher holders (versus just Section 8) and HUD has never taken exception to the approach. Therefore, given the flexibility accorded to Public Housing Authorities (PHAs) in federal law regarding the formation and governing structure of the RABs, the SMHA could include other federally assisted residents in the CAB, as long as the CAB functions equivalently to a RAB. Due to federal requirements, at least one Section 8 voucher holder must serve on the CAB and the HAB. If the CAB is formed, it would begin providing input on the PHA Plans for fiscal year 2024-2025.The input for the PHA Plans for Fiscal Year 2023-2024 has been provided by the current RAB.
Upon authorization to create a CAB, staff would conduct applicant outreach during April/May 2023, accept applications during a four-week period in May/June 2023, and prepare draft bylaws for CAB consideration at their first meeting. Appointment of the seven-member CAB by the HAB, appointment by the HAB of two CAB members to the HAB, and consideration of updates to the Housing Authority Board bylaws would occur at the first available HAB meeting after the application period closes, anticipated in July 2023. As there will be a gap between the time that CAB members are appointed to the HAB and the end date of the terms of the current tenant representatives to the HAB, staff recommends extending the terms of the current tenant representatives until the CAB members are appointed.
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Background
The SMHA administers approximately 1,675 rental assistance vouchers to extremely low-, very low-, and low-income Santa Monica households amongst five federal housing programs (Housing Choice Voucher [HCV]; Continuum of Care [CoC]; HOME Investment Partnerships Program [HOME]; Veterans Affairs Supportive Housing [VASH], and Emergency Housing Voucher [EHV]).
Each year, the SMHA must submit an Annual Plan (a streamlined, 3-page federal form), report progress made towards the goals identified in the HAB’s 5-Year Plan and present any changes to the Administrative Plan (which contains the federal regulations, discretionary policies, and some local procedures that govern the SMHA’s operations) to the U.S. Department of Housing and Urban Development (HUD), seventy-five days before the beginning of the fiscal year. Additionally, every five years the SMHA must also submit a 5-Year Plan to HUD within the same deadline. Together, the 5-year Plan, Annual Plan, and Administrative Plan represent the SMHA’s Annual Plan process. The HAB’s consideration of the SMHA’s Fiscal Year (FY) 2023-24 Annual Plan is scheduled for the April 11, 2023, Consent Calendar and is due to HUD on April 17, 2023.
In a typical year, SMHA develops an Annual Plan, captures progress made towards the goals identified in the HAB’s 5-Year Plan, and presents any changes to the Administrative Plan. All documents are posted for a 45-day public review period. Due to the highly regulated nature of the HCV program, opportunities for the SMHA to create discretionary policies are narrow in scope and generally limited to the Annual Plan process which occurs once a year. All documents included in the Annual Plan process including the 5-year Plan, the Annual Plan, and the Administrative Plan are available online year-round on the City’s website at https://www.santamonica.gov/housing-policyand-reports.
Most often, there are no proposed changes to the Annual Plan and minor proposed changes to the Administrative Plan to enhance voucher household opportunities, improve program flexibility within federal parameters, and clarify policies. Some years 4 of 18
there may be no proposed changes to the Annual and Administrative Plans. However, HUD requires an annual public review and Housing Authority Board approval process.
Prior to the submission of the Plans, the RAB, other voucher participants, and the public must have an opportunity to provide input on the proposed Plans. The RAB, which currently includes all 1,350+ participants in the HCV program, is consulted annually regarding the Annual Plan process and any time significant revisions to the Plan are proposed. Participants in the SMHA’s other voucher programs are also notified of the Annual Plan process and encouraged to provide input on the SMHA’s policy documents. This year, all 1,675+ voucher participants (including the RAB) have been invited to provide input on the Annual Plan, Administrative Plan, and progress made to the 5-Year Plan, through email, mail, public comment at the March 2 Housing Commission meeting, and at a March 13 workshop. The notification to voucher participants describes the process for submitting feedback, allowing for various formats including email, paper mail, and/or telephone, as well as public meetings of the Housing Commission and the HAB.
Legal Requirements for the RAB
As the governing body of the Public Housing Authority (PHA) for the City of Santa Monica’s Housing Authority’s Section 8 voucher program and other federally assisted programs, federal law requires the HAB to provide opportunities for public participation before the HAB approves its annual and 5-year administrative plans (referenced in federal law as “the PHA Plans”). These plans are submitted to the United States Department of Housing and Urban Development (HUD) to ensure PHA obligations under federal law, and they provide a comprehensive guide to the PHA’s policies, programs, operations, and strategies for meeting local housing needs and goals.
Federal law contemplates that participation by federally-assisted residents will occur through the PHA’s establishment of one or more Resident Advisory Boards (RABs).
The purpose of these RABs is to provide the PHA and assisted residents with a forum for providing input and assisting in the development of the PHA Plans before they are adopted. While federal law does not specify how a RAB must be formed or governed, 5 of 18
HUD has provided significant policy guidance to PHAs, recognizing that the form of the PHA should be flexible enough to ensure participation by resident stakeholders, depending upon the nature of their interests. For example, the participation for RABs that are comprised of residents of public housing owned and/or operated by a PHA are likely to be different from the participation of residents who reside in privately-owned housing with Section 8 subsidies (like in Santa Monica).
With one exception, federal law also requires that the governing board of the PHA must have not less than one eligible RAB member, who must be a Section 8 program recipient. (24 CFR § 964.415(a); § 964.420). The exception applies where the PHA does not own public housing (like Santa Monica) and where the PHA has provided annual notice and outreach for opportunities to serve on the PHA governing body, but no requests for participation have been made by any RAB member. (24 CFR § 964.425.)
For many years, and under the purview of HUD’s local office, the HAB fostered public and Section 8 recipient participation through its Housing Commission (which has historically included no less than two Section 8 voucher holders as members). While not officially named as a “RAB,” the Housing Commission served as a functional equivalent of a RAB and provided a public forum for public participation in PHA Plan development.
In 2020, SMHA staff made an inquiry to the local HUD office as to whether the HAB must have at least one RAB member since the SMHA does not own/operate public housing. HUD’s response was that once the term limits for the two resident board members on the Housing Commission end, if the HAB complies with the annual outreach provisions in federal law (24 CFR.§ 425(a)(2) to (a)(4)), and receives no interest to serving on the HAB, then no RAB member would be required to sit on the HAB.
Rather than terminating the Housing Commission, the SMHA established a separate advisory body of all Section 8 voucher holders as “the RAB”, notified RAB members of 6 of 18
an opportunity to serve in the HAB, and then conducted a lottery of interested applicants to select two members of the RAB as board members on the HAB in June 2021. These two members have been provided opportunities to serve continuously on the HAB since June 2021, however, one member (Donna Brown) resigned on March 23, 2023.
Consequently, since that date the HAB only has one sitting RAB member, which still satisfies the legal requirement under federal law that one eligible RAB member serve on the HAB.
While federal law requires the PHAs to establish RABs, federal law does not expressly dictate the governance structure or terms of RAB membership. HUD provides policy guidance in numerous publications about RAB membership, the most comprehensive of which is the Public Housing [PHA] Plan Desk Guide (Chapter 4). The Desk Guide states that a PHA has discretion “in determining the method of appointment of RABs, as long as the PHA ensures that its RAB or RABs reflect and represent all the residents assisted by the PHA.”
Because the SMHA does not own or operate any public housing, the SMHA is considered a “Section 8-only PHA”. According to the Desk Guide (p. 94), "Section 8- only PHAs have discretion in the RAB appointment process. Participation in a RAB is limited only to residents that are assisted under federally assisted public housing and the Section 8 tenant-based program.” For this reason, the RAB must be comprised of Section 8 members and only Section 8 recipients are eligible to serve on the HAB as to the single member required by federal law to be included on the HAB.
The Desk Guide (p. 95) also provides that if the PHA is not successful in establishing a RAB, it may appoint all of the agency’s assisted residents as members of the RAB. The PHA must notify all of its members that they have been appointed as members of the RAB and inform them of their role and responsibilities regarding development of the PHA Plan. The SMHA RAB is currently comprised of all Section 8 residents based upon this HUD guidance.
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City Charter section 1000 also authorizes the City Council to create by ordinance such additional advisory boards or commissions as in its judgment are required and may grant to them such powers and duties as are consistent with the provisions of the City Charter. While the City and SMHA are legally distinct bodies with different legal mandates, there does not appear to be any conflict if the City adopts an ordinance creating the CAB/RAB structure as a City board and commission.
At the September 13, 2022, Council/Housing Authority meeting, the HAB discussed alternative, more inclusive approaches to the current RAB structure to represent all of Santa Monica’s voucher participants and provide opportunities for voucher participants to meet collectively in preparation for communicating input to SMHA staff regarding voucher program policies. A summary of the RAB, its structure, purpose, role, and requirements under 24 CFR Part 903 is included in the September 13, 2022, Council staff report: Section 8 Resident Advisory Board Approaches and provided in Attachment A. At that time, the Housing Commission also presented a recommendation for the creation of a Client Advisory Board (CAB), which would include voucher participants from all of the SMHA’s voucher programs and serve as a replacement for the current RAB. Community members have suggested that workshops and multiple CAB meetings per year would improve the exchange of information amongst voucher participants as well as comprehension of HAB and voucher program policies.
The Housing Commission recommended the following structure for the CAB:
• Be comprised of seven to fifteen members.
• Include at least one representative from every federally-funded SMHA program. • Allow program participants to collectively decide for themselves how CAB members are chosen, meeting frequency, the content of bylaws. • Allow the CAB to decide who will represent them on the Housing Authority Board. • Have meetings be public and agendized, with sufficient notice provided. • Adopt a Memorandum of Understanding between the CAB and HAB Board, to be incorporated into the Housing Authority Board bylaws by reference and the Administrative Plan in its entirety.
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• Include CAB bylaws in the Administrative Plan.
• Use HAB federal funds allocated for administrative costs to pay for the CAB communications, basic administrative costs, and possible relevant educational and training opportunities.
• Pay a $50 stipend for each CAB meeting attended.
• Require staff advise all clients and the CAB about all regular timelines for the Housing Authority planning process to ensure maximum participation. • Periodically invite Housing Authority staff as needed, to provide educational presentations on the Annual, Administrative, and 5-Year Plans.
A more detailed description and full list of the Housing Commission’s recommendations is provided in Attachment B.
During the study session the Housing Authority Board discussed alternatives to the current RAB structure which included:
• How to meet the needs of voucher participants for engagement. • The Housing Commission’s recommendations.
• Approaches to RAB engagement by comparable Housing Authorities. • Initial RAB/CAB appointment.
• How to make the RAB/CAB self-determining.
• How to make the RAB/CAB Brown Act compliant.
Unlike many other Housing Authorities in its immediate vicinity and Housing Authorities in larger cities, including those referenced in the HAB’s initial discussion of the RAB, Santa Monica operates a voucher-only program. The HAB does not own or operate a Public Housing program and is therefore not subject or have access to the same requirements or funding sources as other Housing Authorities which own and operate Public Housing. At the September 13, 2022, HAB Meeting, the HAB directed staff to consider its discussion, along with the Housing Commission’s recommendations, and return with a recommendation for a CAB.
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In response to the HAB’s direction, staff turned first to researching approaches to the formation, implementation, and operation of an active, inclusive, self-determining CAB.
Staff coordinated with both the Legal Aid Foundation of Los Angeles (LAFLA) and the National Housing Law Project (NHLP) to identify an experienced and available firm with relevant expertise to assist staff in the research. LAFLA and NHLP referred staff to the National Alliance of Resident Services in Affordable and Assisted Housing (NARSAAH), which provides technical assistance to Housing Authorities regarding the creation and execution of RABs.
Independent Survey of RABs from Comparable Housing Authorities In September 2022, staff engaged the services of NAR-SAAH to conduct an independent study of RABs associated with Housing Authorities of comparable size and scope to the HAB. The study identified approaches to RABs, such as appointment process, number of members, meeting frequency, and budget/funding source.
NAR-SAAH provided a detailed report of the findings and profiles of the Housing Authorities to staff which is provided in Attachment C. The report listed the 13 Housing Authorities surveyed which are comparable to the HAB, RAB administration approaches, and the recommendations of NAR-SAAH. Below are key points from the survey results.
• RAB members at all 13 PHAs in the study cohort were appointed by agency staff and elected officials.
• RAB membership ranges from seven to twelve members.
• The average term for RAB member service is three years. • Seven of the 13 Housing Authorities have at least one RAB workshop annually.
The RAB workshop provided updates regarding the Housing Authority, the Annual Plan, the 5-Year Plan, and the Administrative Plan.
• None of the 13 Housing Authorities paid a stipend to their RAB members. • All 13 RABs have bylaws.
• All 13 Housing Authorities have executed a Memorandum of Understanding (MOU) between the RAB and the Housing Authority.
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• Although all 13 RABs have a budget, such funding is supplemented by the state, city, or another non-federal source in light of the insufficient funding provided by HUD for direct administration of voucher programs.
Discussion
The Housing Authority Board directed staff to take steps to facilitate a more inclusive RAB process and form a CAB that represents the entire HAB voucher population, rather than solely HCV participants.
Staff considered the recommendations of the HAB, the Housing Commission, NARSAAH, and community members, and the desire for expediency. The model proposed would codify a HAB-appointed CAB in the City’s Municipal Code in the same manner as other City Boards and Commissions. CAB roles and responsibilities are detailed in the attached ordinance (Attachment D). This, plus the creation of CAB bylaws, would serve the same purpose as the Memorandums of Understanding used in other jurisdictions.
Staff recommends an inclusive seven-member CAB to replace the current RAB model.
The proposed CAB would expand traditional RAB membership beyond the HCV program to include other voucher programs like the Continuum of Care (CoC) program, which serves people experiencing homelessness and living with a disability. The CAB would represent all voucher program participants, provide input to HAB staff during the Annual Plan process, and act as an advisory body to the Housing Authority Board.
Initially, the general structure of the CAB, its bylaws, rules, procedures, and meeting requirements would follow the Council-adopted template and the workings of Council’s other advisory bodies, unless certain aspects conflict with the HUD’s federal requirements for the RAB. Once established, the CAB may make recommendations directly to the HAB regarding its operation. CAB meetings would be open to the public, with the requisite public notices and agendas, and SMHA staff attendance would depend on the scope and purpose of the meeting, per the Housing Commission recommendation. All voucher program members would be eligible to apply for a seat on the CAB. The seven CAB members would be appointed by the HAB from the pool of applicants from all voucher programs.
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There are several avenues for inclusivity and self-determination, including through adhoc committees or advisory groups appointed by the CAB, which may focus on various areas of voucher program policy and initiatives within the scope of the 5-Year Plan, Annual Plan and Administrative Plan. Additionally, the CAB may establish time-limited ad hoc committees of CAB-appointed members and voucher participants to formulate reports or recommendations to the CAB on specific topics. Such meetings would not be subject to the Brown Act, but must include less than a quorum of CAB appointed members. The CAB may also form advisory groups made up of CAB-appointed members and voucher participants. Advisory groups would be subject to the Brown Act and meeting rules and procedures.
The HAB would select the two tenant representatives to serve on the Housing Authority Board from amongst the seven current CAB members. Appointments would be for twoyear terms. To meet federal requirements, one of the CAB members and one of the Housing Authority Board members must be from the Section 8 program.
The previous and existing RAB was/is not subject to the Brown Act because the RAB was appointed by SMHA staff for the purpose of providing input directly to staff during the Annual Plan process as recommended by HUD, rather than appointed by the City Council or Housing Authority Board. The creation of a CAB at the direction of the Housing Authority Board (which includes Council) would be subject to the Brown Act.
The Brown Act applies to “legislative Bodies” of local government agencies and includes: the governing body of the local agency (e.g., Council) and any commission, committee, board, or other body of the local agency, whether permanent or temporary, decision-making or advisory, that is created by formal action of a legislative body (Section 54952).The Brown Act would require any meetings of the CAB to be open and public.
The proposed model includes a $50 per meeting stipend for the seven appointed CAB members for up to four meetings a year. In accordance with City policy, City funds for Boards and Commissions are restricted to supporting Board or Commission-related 12 of 18
events, dues, memberships, conferences, trainings, and meeting materials and logistics. Staff recommends that, in recognition of their participation, the City offer $50/meeting stipends to the seven appointed CAB members for up to four meetings per year. Modifications to the City’s adopted policy regarding Boards and Commissions would be presented to the Council upon second reading and become effective thirty days thereafter. Existing departmental resources would be re-directed for CAB stipends and meeting support.
Staff corresponded with HUD about the recommended CAB and received positive feedback. HUD reaffirmed that to meet federal requirements for a RAB, the proposed CAB must always include an HCV (Section 8) participant. Additionally, HUD indicated that stipend payments which exceed $200 annually must be reported by voucher participants and would be counted as income. The current staff recommendation that $50 stipends paid to CAB members for up to four CAB meetings annually, would not exceed $200 in annual stipends ($50 x 4 meetings).
A summary of the recommended structure and operation of the proposed RAB/CAB is as follows.
Recommendation Outline for Creating a CAB
Membership
• The CAB would have seven members to represent all
voucher participants.
• Participants in all SMHA voucher programs would be
eligible for membership.
• CAB membership would prioritize having a
representative from each SMHA voucher program if
eligible applicants are available during appointments.
• CAB vacancies would not be held open if no eligible
applicants are available (except for the HCV program
which requires representation per HUD regulations)
during appointments.
• Each member would serve a four-year term.
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Recommendation Outline for Creating a CAB
Appointment Process
• Outreach for CAB membership would be solicited via
mail and email and follow Limited English Proficiency
(LEP) guidelines. Notices would also be placed on
the Housing Office website and in the Santa Monica
Daily Press.
• Application for the CAB would be modeled after the
template used for other City Boards and
Commissions.
• The Housing Authority Board would review
applications and appoint CAB members.
Meeting Model
• Meeting rules and procedures would follow adopted
guidelines for Boards and Commissions.
• Appointed members would receive a stipend of $50
per meeting for up to four meetings per year.
• SMHA staff would participate in at least one annual
meeting to receive input during the Annual Plan
process.
• Staff would host 1-2 workshops annually within the
CAB meeting structure to engage with voucher
participants and inform/educate about mandatory
federal policy versus local, discretionary policy.
• Meetings would be held in accordance with the City’s
forthcoming administrative instructions related to
access and language justice.
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Recommendation Outline for Creating a CAB
Formation and
Operational Structure
• The CAB would be created by amending the City’s
Municipal Code.
• The CAB would act as an advisory body to the
Housing Authority Board, provide input to SMHA staff
during the Annual Plan process, and represent the
SMHA’s voucher population.
• Bylaws would conform to the Council-adopted
template for City Boards and Commissions.
• Roles and responsibilities of CAB and HAB would be
incorporated into the City’s Municipal Code.
• Outreach for the CAB application period would occur
over a four-week period during April/May.
• Applications for CAB would be open in May 2023 for
a four-week period; HAB would agendize
appointments at the next available meeting date.
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Recommendation Outline for Creating a CAB
Staff Resources
& Role
• Staff would post general information (e.g., email
addresses of CAB members, active members, and
formal meeting schedule) about the CAB on the
Housing Office Website.
• Staff would encourage participation in the CAB and
Annual Plan process, via email, mail, at a briefing for new voucher participants, and during the annual
reexamination for existing voucher participants and in
accordance with LEP guidelines.
• Staff would create a designated email address for
each CAB member so voucher participants and the
public can directly correspond or connect with the
CAB.
• Staff would help identify and secure a physical
meeting space for the CAB to meet in person during
the Annual Plan process and for any staff-lead
workshops.
• Staff would conduct a mandatory orientation for CAB
members.
• Additional or redirected organizational and supportive resources would be needed to organize, implement,
attend, and document meeting(s) based on the
Division’s current staffing model. However, proposed
restructuring of the Division would create sufficient
staff resources.
Housing Commission
Role
• The CAB meeting(s) would replace the annual
Housing Commission meeting used as a forum for
voucher participants to provide input for the Annual
Plan process.
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Recommendation Outline for Creating a CAB
Opportunities
• This model provides an opportunity for the CAB to
represent the entire voucher population and convene
multiple times during the year in a forum where other
voucher holders may attend and discuss program
issues.
• The model includes the HAB appointing two of the
seven CAB members as the two tenant
representatives to the Housing Authority Board. The
only requirement is that one representative must be
from the Section 8 program per HUD regulations.
Considerations
• To meet HUD requirements the CAB must always
have at least one Section 8 representative.
• Generally, as a practical matter due to the public
review period, amendments to the Administrative
Plan and Annual Plan are feasible only once a year
during the Annual Plan process.
Housing Commission
The Housing Commission may choose to agendize a discussion about the RAB/CAB at its April 6 meeting and provide input to the HAB in writing and/or during the April 11 meeting during public comment. A draft of this report was provided to the Housing Commission on April 4, 2023.
Next Steps
If the HAB supports the recommendation for the proposed CAB modeled after other Commissions/Boards appointed by Council, staff would coordinate with the Clerk’s Office to open the application process for CAB recruitment in April/May 2023. Staff would directly notify all voucher participants twice within a four-week period and post a notice on the Housing Office website and two in the Santa Monica Daily Press. The application period would be open for four weeks to ensure adequate time for interested 17 of 18
voucher participants to apply. The application would be modeled after the applications used with other City Boards and Commissions. After the close of the application period, the HAB would consider appointments to the CAB at the Board’s next available meeting date. At that time the HAB would also select the two CAB members to serve on the HAB and consider updates to the Housing Authority’s bylaws. The current Housing Authority bylaws were last adopted in 1974. The timeline anticipates that the CAB would begin meeting in early fall.
Prior to the appointment of the initial CAB, staff would begin to coordinate with the City Attorney and City Clerk’s office to prepare draft bylaws modeled after the template City bylaws for Boards and Commissions adopted by Council. Review and adoption of bylaws would be considered at the CAB’s initial meeting(s).
Environmental Review
The actions contemplated by this report do not constitutes a “project” within the meaning of CEQA because they would not cause either a direct physical change in the environment or reasonably foreseeable change in the environment.
Financial Impacts
There is no immediate financial impact or budget action necessary because of the recommended action. Budgeted resources would be re-directed to support CAB stipends. In order to provide staff support for quarterly CAB meetings, existing HAB staff resources would need to be redirected from current voucher administration and projects. However, staff has developed a proposed restoration and enhancement of the Housing Division for Council consideration during the FY2023-25 Biennial Budget process. If the enhanced Housing Division staffing proposal is approved, the Division would have sufficient staff resources beginning in FY23/24 to support the CAB. 18 of 18
Prepared By: Patrick Komesu, Sr. Administrative Analyst Approved Forwarded to Council
Attachments:
A. RAB staff rpt 091322
B. Santa Monica Housing Commission RAB Recommendations
C. CAB Formation Ordinance
D. NAR-SAAH Independent Study
E. Written Comments
F. PowerPoint Presentation