From: Marc L. Verville
To: Santa Monica City Council Members
Date: 8 May 2023
Re: SM City Council 9 May 2023 Agenda Item 11.A.
Annual Interdepartmental Update on Addressing Homelessness Summary
In reviewing this update (the “Report”) within the context of other City-issued background information, the report describes the nature of Santa Monica’s homeless crisis as deriving from a highly transient homeless demographic driven by in-migration from other parts of Los Angeles city and Los Angeles County. The report makes the case that the City has very few policy options at its disposal to manage either the in-migration or the consequences of the behavioral issues that define this expanding demographic.
Meanwhile, the Point-In-Time (PIT) count data we do have shows the sheltered total and share of the homeless population declining to 26.5% in 2023 from a high of 58.9% in 2012. The unsheltered total and share are increasing to 73.5% in 2023 from 41.1% in 2012. The total number of unsheltered is 2.16x the level it was in 2012.
Combined with the facts that there have been no families and children in the unsheltered counts and that the behavioral issues noted below affect the unsheltered population and the scenario that is evolving is highly destabilizing. Yet, there is no analysis of why this hugely impactful change is occurring.
Data Issues
The Report also highlights the difficulties in effectively addressing the issues in this crisis that result from the lack of complete or reliable data. This critical data issue was the noted in the November 2022 Moss Adams’ Homeless Study [17] and drove at least 5 (26%) of the 19 observations in the Report.
Homeless Counts and Scope of Outreach – Quantifying the Issue The Point in time (PIT) counts appear to understate the number of homeless individuals that flow through the city when compared to the City’s own Homeless Management Information System (HMIS). The PIT counts could be as low as 20% of the total number of individuals that flow through the city in a year when compared to the years in which the City’s HMIS (aka the Wellsky Community Services system ) was fully functional.
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The scope of outreach is confusing since the Report notes that City policy is focused on a small subset of the migratory total of persons experiencing homelessness through its Santa Monica Priority Population (SMPP) register. The City does not state what the number of SMPP-qualified persons being managed are within the context of the PIT count totals.
Unsheltered Behavioral Challenges
The Report inexplicably omits any discussion of the behavioral profile of the unsheltered homeless population even though that profile is fundamental to understanding the challenges this crisis presents. The City does outline the unsheltered behavioral issues in its homeless emergency proclamation as “…84% of unsheltered people had physical health conditions, 78% had mental health conditions, and 75% had substance abuse conditions.”. [16] The unsheltered demographic continues to dominate the overall growth in the homeless PIT counts going back to 2009.
Housing and Homelessness
While the Report boldly states that “Homelessness is fundamentally a housing problem” [21], the Report fails to demonstrate any linkage between the highly migratory nature of the Santa Monica-specific homeless population, and its behavioral and financial profiles, as against the City’s stated core initiatives that revolve around affordable housing production. The assertion is a simple axiomatic statement. Affordable housing production is already a state mandate (with its own serious issues).
Homelessness Prevention
As regards to “homelessness prevention”, the Report fails to define the specific risk factors being addressed in the “prevention”. In addition, the Report does not address the affordable unit allocation framework and issues that contradicts the stated link between affordable housing production and “homelessness prevention”. Rent burdening has been a previously defined risk factor for preventing homelessness. Yet, the City has stated that “It is not possible to estimate the number of rent-burdened people who may become unhoused.” [4] That is precisely because the risk of a housed individual becoming unhoused is very low since becoming unhoused is not the first alternative that housed individuals and households look to. [22]
In attempting to force a link between Santa Monica’s homelessness crisis, concepts of “preventing homelessness” and affordable housing production, the Report follows the Moss Adams’ study methodology of simply applying a generic solution based on conventional
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wisdom to a completely unrelated situation. The use of this inappropriate methodology was one of the key reasons that I voted “No” to the acceptance of the Moss Adams Report as the Vice Chair of the City’s Audit Subcommittee on November 28, 2022.
Funding and Resource Allocations
In dealing with resource allocations, the Report focuses on initiatives to secure additional funding but does not discuss the effectiveness of existing funding or how much of the additional funding will reach the street-level issues. In its discussion of expenditures (as detailed below), the Report continues to conflate housing-related expenditures with the homeless programs.
Critical street level resources appear to be declining despite the discussion of new funding. For example, the Report discusses the effectiveness of the SM Fire Department’s Crisis Response Unit (CRU) [18] and then notes that funding is not available to fully staff the unit. The existing funding is proposed to be reallocated to administrative roles, taking the resource off the streets. This conclusion is reached even though another critical crisis transport-related initiative from LA County, the Therapeutic Transport Program, has had deployment to Santa Monica endlessly delayed since first approved in 2020. [19] The Report mentions but does not address the fact that while (a corrected) $8.7 million is the total direct funding of homeless initiatives, $29.6 million of scarce Fire, Police and Public Works resourcing is being siphoned off to manage the effects of the unrestrained in-migration of a behaviorally challenged population. [20] Without a focus on controlling in-migration, the allocation of these critical resources to the growing homeless crisis will only expand, reducing their effectiveness in all other areas of the city.
Conclusions
The Report describes a complete disconnect between the origins, nature and trends of the homeless crisis and the initiatives it is pursuing. A continuing focus on irrelevant solutions within a context of deficient or non-existent data distracts City staff from identifying and targeting the core issues driving our ongoing (and growing) crisis. It also contributes to a misdirected sense of action with the heightened risk of significant misallocation of very scarce resources.
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Without any significant and substantial attempts to control in-migration, and with declining data available to assess the evolving situation, there is no ability to assess the resources required to manage the situation.
Moreover, the Report provides no definition of success and therefore success criteria against which to measure, and therefore design, relevant programs.
As such, this Report paints a picture of a focus on policies designed for other purposes such as meeting the arbitrary RHNA allocations and is therefore unrelated to managing the on-the-ground homeless crisis. The Report also describes the emphasis on increasing funding receipts but does not translate that into expanded street-level initiatives. Instead, the existing directly-applicable street-level point policies have substantial administrative burdens that render the expenditures less than effective, in an underfunded environment. Estimating the actual share of each program dollar that gets to the street would be a very worthwhile exercise for the city to conduct.
This Report indicates that the trajectory of the City’s homeless crisis will only get much worse without a fundamental change in focus.
Review of the annual Interdepartmental Update on Addressing Homelessness The update addresses the following areas:
A. Review of the City’s Four Pillar Approach
B. The Regional Context
C. The Local Homeless Service System
D. Roadmap to Permanent Housing
E. Homeless Point in Time Count Results 2023
F. Four Pillars Update (p24)
G. Declaring a Local Emergency on Homelessness (p46)
H. Next Steps
A. Review of the City’s Four Pillar Approach
See Item F
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B. The Regional Context
The Regional Context summarizes the situation in Santa Monica as a jurisdiction that is unable to exert any control over the in-migration of the highly mobile homeless demographic as a result of its being an enclave within LA City Council District 11 (CD11) which includes Venice.
The situation is then amplified by unilateral LA County transit and services policies that concentrate in-migration of homeless demographic into the city and then incentivize the duration of the stay in the city by concentrating in Santa Monica the provision of substance abuse service centers (the Harm Reduction Syringe Services Program (SSP)) [14] in Santa Monica’s few high-community-value open park areas.
Acknowledging the essentially highly mobile nature of the demographic, the City prioritizes people experiencing homelessness who have a history of living or working in Santa Monica, rather than “passing through” or “recently arrived to” Santa Monica (the Santa Monica Priority Population [SMPP] criteria).
As such, City policy is being acknowledged to address a very small subset of the migratory total of persons experiencing homelessness. The City does not state what the number is of SMPP-qualified persons that are being actively managed.
The missing items in this “Context” section are:
1. The City has not indicated how many of the 2023 PIT homeless count’s 926 individuals qualify as SMPP participants.
2. There is no discussion of what happens to those (likely the vast majority) that are NOT SMPP participants.
3. There is no quantification of the impact of LA Metro’s unilateral End of Line policy decision to convert its rail and bus vehicles into a mobile shelter system. Separate sources indicate that almost 60 homeless individuals are disembarked into SM each evening from the train alone. [13] An additional unknown number are disembarked from the four Metro Bus Lines (4, 20, 33, and 720). All End of Line disembarkations occur in downtown Santa Monica. [9]
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There is no mention of the City delegating it’s responsibility to effectively manage its relationship with LA Metro to the SM neighborhood groups by asking a neighborhood group leader to help by “sending a letter to Metro” objecting to this End of Line practice.
4. While State law prohibits cities from controlling these County Syringe Services Programs (SSP) within city limits, there is no discussion of options for the city to regain leverage over of these operations through some other negotiated means.
C. The Local Homeless Service System
This section starts off by enumerating the factors that limit the City’s agency and includes an unrelated reference to preventing homelessness. Again, there is no discussion of the reach of these initiatives. Do they apply only to those that meet SMPP criteria or is it the entire demographic?
This entire discussion creates complete confusion as to the City’s ability to quantify the problem and direct solutions.
1. The City notes that “Preventing someone from becoming homeless is much less expensive and resource intensive than housing someone once that person is homeless.” Yet, the City has also stated that “It is not possible to estimate the number of rent-burdened people who may become unhoused.” [4] Therefore, the city has no idea what risk (if any) it is addressing.
2. In discussing the processes of Interventions, Engagement, Assessment, Stabilization, Verification, Applications, there is no discussion of the capacity of the process to handle the total number of homeless or the share of those qualifying under SMPP. It is not clear that there are even enough resources to manage the SMPP-qualified individuals.
There is also no reference to the PIT count totals in relation to these processes.
3. In the assessment discussion, the City notes that individuals are “…entered into the HMIS and, if so, whether they are currently connected to a service provider.” Moss Adams has noted that “…there is no integration of data across the HMIS, Police, and Fire, (and) the data that can be reported is likely to be duplicated, which in turn impacts the accuracy of performance reporting and monitoring.” [6]
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Even if the data is entered, Moss Adams’ noted in their Report that the City had not restored 3 critical homeless-related data analyst and management positions were eliminated in budget cuts. [7]
Even if the positions are restored, the usefulness of the data is highly questionable since the City has noted that “…in 2021, a major regional nonprofit provider that is not required by federal or local funding to use HMIS moved off of HMIS and onto their own system.” [5] Without integration, this fragmentation of the information has compromised any remaining usefulness of this database.
4. The City notes that it is severely limited in enforcement options due to recently decided case law, District Attorney discretion and Sherriff Department discretion, all of which are beyond the City’s control. No mention is made of alternate strategies to address the issues facing the residents and visitors.
D. Roadmap to Permanent Housing
This section starts with a reference to the Moss Adams’ report asserting that “adequate levels of affordable housing and permanent supportive housing are the most critical components to homelessness prevention and resolution.” It goes on to list the city sites targeted for affordable housing development.
This statement was treated by Moss Adams as axiomatic, without any linkage to the specific issues facing Santa Monica. In discussions with Moss Adams, it was clarified that the statement was based on generic “Best Practices.” [7] This generic policy statement was not otherwise related or linked to the specific issues driving the homeless crisis in the city of Santa Monica.
There is no definition of what the risk factors are for “preventing homelessness” nor is there any linkage as to how affordable housing (which is income-based) is relevant to the existing migratory homeless population in the city.
With only very rare exceptions does the city’s homelessness crisis have anything to do with the city’s housing situation, despite strenuous attempts to link the two.
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1. While the Report notes that the Los Angeles Homeless Services Authority (LAHSA) estimates approximately 207 people a day are rehoused at the same time as 227 become homeless, there is no indication of what these statistics represent (e.g., previously housed homeless losing shelter) or any linkage to what is happening in Santa Monica.
2. While not defined in this Report, other City pronouncements have defined a key risk metric of potential homelessness as rent burdening, defined as a household paying more than 50% of income on rent.[6] There is no mention of such households accessing more affordable rental accommodations in locales other than Santa Monica, as would be the normal course. Thus, the actual correlation of rent burdening, as defined, to actual homelessness is therefore entirely speculative and unsupported.
In response to a direct question, the City noted that “It is not possible to estimate the number of rent-burdened people who may become unhoused.” [4]
3. The City has no idea how many residents may even be “rent burdened” by its own definition [11] and therefore has no idea what the linkage there is, if any, between a “rent burdened condition” and the city’s homeless demographic.
4. The actual scale of “rent burdened” households among the city’s 46,700 households appears to be incredibly small and therefore manageable with targeted City financial programs. The City notes in the Report that “The HOME Program alleviates the rent burden of 30 participants who may otherwise have ended up homeless.” [14] A program specifically tailored to provide rent supplements to those with rent burdens greater than 50% of income generated approximately 531 qualified applicants. [11]
5. Rent burdening is not specifically included in the City’s enumerated Affordable Housing access priority levels. Given the 8,931 applicants to the City’s Below Market Housing (BMH) program at 06-30-2022 [8], the City has effectively eliminated affordable housing as an option to the very “rent burdened” demographic it identifies as facing the worst possible housing outcome – homelessness.
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6. Even if the City wanted to include residents that are “rent burdened” as the top priority in its BMH program prioritization, it could be legally precluded from doing so since it could be construed as a form of indirect discrimination based on race (depending on the interpretation of the city’s demographics). This issue has also gone unaddressed.
7. There is no mention of how many (if any) of the existing affordable housing applicants are homeless individuals living in interim housing. As of 06-30-2022, there were 8,931 active applications for openings in the city’s 4,578 affordable units. [23]
8. The $42.5 million in “Costs Related to Addressing Homelessness” includes $33.9 million in indirect costs, housing subsidies and staff administrative costs. Actual direct expenditures on homelessness initiatives are $8.6 million [12]
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E. Homeless Point in Time Count Results 2023
The Point-in-Time count discussion paints a picture of very high transiency. The city has noted that “a significant portion of the people experiencing homelessness are here temporarily”…reflecting “the transient nature of homelessness.” [4] The demographic profile described by the statistics and the issues raised by the data are at compete odds with the assumptions of an essentially static population that the city’s housing and service initiatives require to be effective on an individual city level.
While there is no mention in the Report about the spike in homeless counts that accompanied the opening of the Metro rail line in 2016, there is a clear step change (+27%) in the counts pre (2016) and post (2017) the start of the Metro Line in May 2016. The 2023 PIT homeless count increased by 119 (15%) individuals since 2022. [2] The chart below summarizes the 2022 count within the context of the last 14 years.
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1. The Report describes a highly transient demographic and admits that it has no idea how many (if any) are just passing through or are long term. The City notes that:
“As stated before, Santa Monica’s boundaries are porous, and the city is the “end of the line” for Metro’s bus and rail lines. There is a daily influx and outflow of people. Some people who were counted in January were likely passing through Santa Monica or recently arrived. Others may have been here for years or decades.” [24]
2. Given the very high levels of transiency in this homeless demographic, using only PIT counts significantly masks actual number of homeless individuals that flow through the city in any given year. As an indicative measure for years 2018, 2019 and 2020, where the City’s HMIS was fully operational [5], the PIT counts represented between 14% and 19% of total unique homeless individuals interacting with City services (see chart below).
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3. Even with a maintained HMIS system during those years, the City notes that the numbers are not entirely reliable since there were significant deficiencies in the data (see C.3. above). That said, the magnitudes are indicative of the underlying trends.
4. Current visibility into the level of transiency has been further obscured by the decision of a major regional nonprofit provider moved off of HMIS and onto their own system.
This has prevented the City from supplying relevant HMIS-sourced statistics for 2021 and 2022. [5]
5. The Report does not address the distinct underlying trends in the PIT counts between the sheltered and unsheltered components that can be used as directional indicators:
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5. Unhoused individuals increased by 73 (12%). These increases occurred despite a county-wide eviction moratorium being in place since 2020 (and ending on 04-23-2023), eliminating loss of housing as a causal factor.
6. The 11% decrease in overall homelessness in 2022 as compared to 2020 was noted as being driven by “the significant reduction in the local shelter capacity”. [3] This rational does not align with the fact that the unhoused population count was flat during those periods, at 601 in 2020 and 608 in 2022. If the demographic was not preponderantly transient, the lack of shelter would have driven up the unhoused counts. There is no discussion of shelter capacity, despite the dramatic declines in the sheltered population (see chart below)
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7. The Report does not address why the share of unsheltered individuals has been steadily climbing since 2010.
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8. The Report does not address why the total number and share of Sheltered of individuals has been declining since 2012.
a. Are the number of shelter beds declining?
b. Are other jurisdictions taking a greater share of the shelter beds available? c. Is the number of homeless families and children declining?
9. The Report notes that “as in previous years, no families or unaccompanied youth experiencing homelessness were observed during the street count” [1] This observation is made without reference to the fact that the sheltered count has been in general decline since 2012, indicating that the homeless demographic is trending towards individuals, with anecdotal evidence indicating that it is almost exclusively male.
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10. The Report notes that the 11% decrease in overall homelessness in 2022 as compared to 2020 was noted as being driven by “the significant reduction in the local shelter capacity”. [3]
It’s not clear that is a causal factor since there has been an ongoing decline in the sheltered homeless population since 2009 (see chart above). The Report is silent on both this trend and its cause. Have shelter/institution beds been in overall decline during the entire period?
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F. Four Pillars Update
In this section, the City covers the “Four Pillars” listed as:
• Preventing housed Santa Monicans from becoming homeless and increasing affordable housing opportunities;
• Addressing the behavioral health needs of vulnerable residents; • Maintaining equitable access to safe, fun, and healthy open spaces; and • Strengthening regional capacity to address homelessness.
The entire discussion surrounding preventing homelessness and increasing affordable housing continues to revolve around an axiomatic assumption of housing initiative applicability to this city’s homeless crisis. As described above, no demonstrable link has been established by the City related to the Santa Monica-specific homeless crisis. Even the discussion around the Legal Aid Foundation of Los Angeles’ (LAFLA) Emergency Eviction Prevention Services simply assumes a link to preventing homelessness. It does not contemplate tenant relocation to other, less expensive locales as a personal tenant solution option.
The Report, and the external data cites above, supports the opposite conclusion – that there is no link. Therefore, this constant refrain by the City linking the housing policies to the homeless crisis appears to be entirely opportunistic, in support of a completely separate agenda.
In the section dealing with “Addressing the behavioral health needs of vulnerable residents”, the story is of under-funding and ineffective programs. Consequently, the discussion is focused on process rather than outcomes.
Multi-Disciplinary Teams (MDTs) section: We learn that The People Concern (TPC) made 10,454 contacts in 2022 of homeless individuals. We have no idea what the number of unique individuals contacted was or if they are all from SM. Of these contacts, only 59 individuals obtained interim or permanent housing.
Community Response Unit: This a pilot program of 2 SMFD individuals who have direct contact with the homeless population to expedite movement off the street. This unit was supposed to lead to a fully staffed 6-8 person team. Instead, the unit looks to be disbanded for lack of funds with the existing funding being reallocated to administrative uses.
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Therapeutic Transport Program: This is a promised mental health van from LA County that has been promised since October of 2020 but has yet to materialize. [15] In the section titled “Strengthening regional capacity to address homelessness”, the regional agencies are discussed but there is no discussion of their policy risks to SM or of any SM strategy to more effectively deal with the issues.
In the section “Costs Related to Addressing Homelessness”, the City notes direct expenditures of $12.9 million [12] which is, in reality, only $8.7 million with the difference being inclusion of more housing-related expenditures that are unrelated to direct homeless initiatives. This is in a city with a budget of around $600 million. Even then, there is no discussion of how much of the $8.7 million actually gets to the streets and how much is absorbed in program administration.
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References
[1] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.22
[2] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.21
Santa Monica Housing Element 2022, Appendix I Table 11 (Page 147) https://www.santamonica.gov/media/Housing-Element-Update-2021-to-2029/Final%20Draft%20Appendix%20I%20Final%20AFH%20Clean.pdf [3] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.21
[4] Responses to Questions Regarding the Homelessness Study Brought Forth by Audit Subcommittee Member Verville at the November 28, 2022 Audit Subcommittee Meeting https://www.smgov.net/uploadedFiles/Responses%20to%20Questions%20Regarding%20the%20Homelessness%20Study.pdf [5] Public Records Request of January 13, 2023., Reference # R020564-011323 [6] City of SM Homelessness Study – Final (Moss Adams) – Updated 11-30-2022 p67 https://www.smgov.net/uploadedFiles/Departments/Council/Audit_Comm/City%20of%20Santa%20Monica%20Homelessness %20Study%20FINAL_Update%2011.30.22.pdf
[7] City of SM Homelessness Study – Final (Moss Adams) – Updated 11-30-2022 p58 https://www.smgov.net/uploadedFiles/Departments/Council/Audit_Comm/City%20of%20Santa%20Monica%20Homelessness %20Study%20FINAL_Update%2011.30.22.pdf
[8] City of SM Homelessness Study – Final (Moss Adams) – Updated 11-30-2022 pgs 65 & 66 https://www.smgov.net/uploadedFiles/Departments/Council/Audit_Comm/City%20of%20Santa%20Monica%20Homelessness %20Study%20FINAL_Update%2011.30.22.pdf
[9] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.42
[10] Not used.
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[11] No Reliable Data to Support Key Housing Number – SM Lookout 02-14-2023 https://www.surfsantamonica.com/ssm_site/the_lookout/news/News-2023/February-2023/02_14_2023_No_Reliable_Data_to_Support_Key_Housing_Number.html [12] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.45
City of Santa Monica Homelessness Study – Final (Moss Adams) – Updated 11-30-2022 Appendix D
[13] LA Metro survey: About 600 homeless riders exit nightly when train service ends | LA Daily News 04-29-2023
https://www.dailynews.com/2023/04/28/la-metro-survey-about-600-homeless-riders-exit-nightly-when-train-service-ends/ [14] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.35
[15] SMCC 2021-02-08 - Item 8.A. - Efforts to Address Homelessness - CRU & DMH - Staff Report 4430 (Snapshot-32313)
Santa Monica City Council Meeting: February 23, 2021 Agenda Item: 8.A. http://santamonicacityca.iqm2.com/Citizens/Detail_LegiFile.aspx?Frame=None&MeetingID=1261&MediaPosition =&ID=4430&CssClass=
[16] Proclamation of the City Council of the City of Santa Monica Declaring a Local Emergency on Homelessness issued on February 14, 2023
https://santamonicacityca.iqm2.com/Citizens/Detail_LegiFile.aspx?Frame=&MeetingID=1353&MediaPosition=&ID =5596&CssClass=
[17] City of SM Homelessness Study – Final (Moss Adams) – Updated 11-30-2022 Observations #2, #3, #6, #12, #19 pgs 7-11
https://www.smgov.net/uploadedFiles/Departments/Council/Audit_Comm/City%20of%2 0Santa%20Monica%20Homelessness%20Study%20FINAL_Update%2011.30.22.pdf [18] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.32
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[19] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.34
[20] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.45
[21] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.6
[22] Predicting and Preventing Homelessness in Los Angeles - CalPolicyLab SEP 2019 p.5 https://www.capolicylab.org/wp-content/uploads/2019/12/Predicting_and_Preventing_Homelessness_in_Los_Angeles.pdf [23] City of SM Homelessness Study – Final (Moss Adams) – Updated 11-30-2022 p.66 https://www.smgov.net/uploadedFiles/Departments/Council/Audit_Comm/City%20of%2 0Santa%20Monica%20Homelessness%20Study%20FINAL_Update%2011.30.22.pdf [24] Annual Interdepartmental Update on Addressing Homelessness SMCC 05-09-2023 Item 11.A. (Snapshot-41059) p.22
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