Public comments and input from the Resident Advisory Board, voucher participants, the Housing Commission, the public and the Housing Authority Responses to the comments
Public/RAB Member Comments: The Administrative Plan should recognize children placed with a household under court-ordered temporary guardianship as a category distinct from foster children and state clearly that they count as household members for voucher size. It should also specify that Reasonable Accommodation requests may be made on behalf of a disabled child under court-ordered temporary guardianship, and that these requests must be treated the same as for a biological child and should be reviewed on a case by case basis.
Response: The Administrative Plan specifies which individuals are excluded from the definition of “family members.” Foster children, foster adults, and live-in aides are not considered family members, though they are counted as household members. Children under court-ordered temporary guardianship are included as family members.
For voucher size, this distinction does not change how individuals are counted. HUD’s HQS occupancy standards apply uniformly: two people are issued a one-bedroom voucher regardless of whether they are classified as family or household members, with the exception of a live-in aide.
Because a child under court-ordered temporary guardianship is considered a family member, their guardian may request a Reasonable Accommodation on the child’s behalf as long as the child has a disability that requires a reasonable accommodation. All Reasonable Accommodation requests are reviewed individually based on the specific circumstances and supporting documentation from a qualified professional.
Public/RAB Member Comments: The comment asserts that the PHA Annual Plan overlooks significant structural issues in the administration of Continuum of Care (CoC) housing assistance. It emphasizes that CoC assistance is non-portable across jurisdictions, which restricts the mobility of participants—especially individuals with disabilities who may need to relocate for safety, medical care, or family support. The Plan also fails to address the lack of any homeownership or long-term stability pathways, leaving participants dependent on rental assistance within a single jurisdiction.
Additionally, individuals who wish to move must relinquish CoC assistance and convert to another voucher program, resulting in the loss of CoC-specific protections. The commenter argues that these impacts are foreseeable, documented, and unaddressed, and that the City has previously reviewed but declined to implement available alternatives.
The comment further notes that the jurisdiction lacks a meaningful, program-specific oversight or feedback mechanism for CoC participants. Existing public comment opportunities, advisory seats, and outreach efforts are described as inaccessible, episodic, and insufficient for monitoring program outcomes or ensuring compliance with fair housing and disability access obligations. The discontinuation of livestreamed Housing Commission meetings and reliance on digital-only notices are cited as additional barriers.
The commenter concludes that these combined issues represent a planning deficiency and urges the City to analyze disparate impacts, restore accessible public meeting practices, establish structured oversight for CoC participants, and consider homeownership or other long-term stability options within the Administrative Plan.
Response: Under federal HUD regulations, portability is not a feature of the Continuum of Care (CoC) program. This is a federal requirement, established by HUD and cannot be altered locally, and the City of Santa Monica must administer the program as HUD designed it. However, when HUD updated CoC rules in 2012 to allow limited moves outside the issuing jurisdiction, the City incorporated those changes into its Administrative Plan.
Santa Monica does allow CoC participants to move to nearby communities when the City can still perform required inspections (to facilitate farther moves the City is allowing for virtual inspections), recertifications, and ensure access to supportive services. Several CoC participants already live outside Santa Monica under this policy. Moves to distant locations or other states are not feasible because the City cannot administer the voucher there, but move requests due to Domestic Violence or other safety-related requests are reviewed individually on a case by case basis. Participants who wish to move out of state may choose to graduate into the Housing Choice Voucher (HCV/Section 8) program, which is the only federal program that offers full portability. This process is not intended to reduce protections or create barriers but simply to provide the only federally available pathway for long-distance moves. Finally, the CoC participants can request to move within the City of Santa Monica with their CoC voucher on an annual basis if needed as long as they remain in good standing with their current landlord and with the City by paying their rent, passing inspections, and not violating any lease or program regulations. The City does not offer a homeownership program for any voucher type at this time, so no participants have access to a homeownership pathway. CoC participants are not being excluded from a benefit available to others; the option simply does not exist for any voucher program.
The City is committed to improving communication, accessibility, and engagement for all voucher program participants including CoC participants. For future PHA Plan cycles, the Housing Authority will work to provide more robust presentations explaining policy changes and offering opportunities for questions. Furthermore, the City staff will make sure to better coordinate scheduling and the communications that go out to the public to avoid any date/time discrepancies. Staff recently met with the City’s Disability Commission and plans to continue attending future meetings to share program information and receive feedback on how to better support participants with disabilities. While mailing notices to all 1,700 plus voucher households may not be feasible, the City will explore additional outreach methods—such as notifying service providers, offering flyers in the Housing Authority lobby, including reminders in email signature lines, and potentially adding information about PHA Plan Cycle process in other correspondence being mailed to tenants —to ensure broader awareness of the PHA Plan process.
The Santa Monica Housing Authority has not at any time made a decision to no longer stream Housing Commission meetings, that was done on a higher management level and the Housing Authority can attempt to find out the reasons and determine if the streaming can be possibly resumed or if there are other ways to share the meetings with the public who can’t attend in person that are more timely.
Participants are always welcome to share concerns at City Council meetings, Housing Commission meetings, Disability Commission meetings and by writing to [email protected] or dropping off a comment or a question in writing in the Housing Authority office.
Public/RAB Member Comments: Participants should be able to get an extra bedroom for a rotating aide needed due to disability which is currently not allowed by the Administrative Plan.
Response: As of the FY 25–26 Administrative Plan, the policy has been updated to allow a separate bedroom for a live-in aide when the aide has been approved by the Santa Monica Housing Authority through the Reasonable Accommodation process. In all other circumstances, participants with disabilities may still request a Reasonable Accommodation. If a participant demonstrates a clear nexus between the need for a rotating aide and the need for that aide to have a separate bedroom within the unit, the request will be reviewed and considered on a case-by-case basis.
Public/RAB Member Comments: A participant expressed concern that some disabled residents feel discouraged or unwelcome by building management, including situations where individuals who use wheelchairs feel they are not wanted in management offices.
The participant wanted the Housing Authority to be aware of these experiences.
Response: While the City is concerned about ensuring that disabled participants are treated fairly by landlords and property management, these matters fall within the realm of legal rights and obligations and cannot be regulated through PHA policies. We expect and encourage landlords to treat all applicants and participants appropriately; however, when issues arise, the City strongly advises tenants or prospective tenants to contact Legal Aid Foundation of Los Angeles, which is contracted to assist low-income tenants with legal matters, and/or the City Attorney’s Consumer Affairs Division for support.
Public/RAB Member Comments: A participant, speaking for herself and other disabled community members, requested that future PHA Plan communications and documents be made available offline, not only online or by email. She explained that many individuals with disabilities were unable to review the materials or participate in the public comment process because they lacked access to technology or were unable to use it.
Response: The Santa Monica Housing Authority will look into better ways to provide materials for review in a way that better accommodates individuals with disabilities. One of the ideas is to have a copy of the redlined Administrative Plan and Annual Plan and Progress report available in the Housing Authority office for review. While it is not feasible to distribute a copy to each participant since it is a very lengthy document one copy will be placed in the office for anyone who is interested to review. Other copies might be made available in the service agency offices and offices of some of the PBV properties or larger properties who house a number of voucher holders. There is also a consideration to hold an in person meeting next year prior to the public comment period opening to go over some of the major changes coming up in the Administrative Plan and respond to some of the questions.
From:
To: Housing Comments
Subject: Public Comment - Santa Monica PHA Administrative Plan 2026–2027 Date: Friday, March 6, 2026 6:50:40 PM
EXTERNAL
I respectfully submit this comment to request clearer language in the Administrative Plan regarding minors who live in a household under court-ordered guardianship, including temporary and general guardianship arrangements.
The current plan addresses foster children, but it does not clearly explain how minors living with a relative or caregiver under guardianship are classified for occupancy purposes. Because this situation is not specifically addressed, minors under guardianship may be treated the same as foster youth in practice, which creates uncertainty and inconsistent interpretation.
Guardianship arrangements are distinct from foster placements. In a court-ordered guardianship, the guardian assumes legal responsibility for the minor through a court order.
For that reason, the Administrative Plan should clearly explain how these minors are counted in the household and how their presence affects occupancy and voucher size determinations.
I also ask for the PHA to clarify that reasonable accommodations remain available when a minor with a disability requires a separate bedroom, regardless of whether the minor is a biological child, foster child, or living in the household under guardianship. The current subsidy standards allow two persons per sleeping room and may treat the living room as a potential sleeping room. In practice, this can make it difficult for a household to obtain a separate bedroom even when a medical provider documents that the minor’s disability requires their own sleeping space.
To avoid confusion, the Administrative Plan should clarify or expressly state that disabilityrelated accommodation requests must be evaluated on an individualized basis and are not automatically denied based on general occupancy standards or on the classification of the minor within the household.
I respectfully suggest adding language along the following lines:
“Minors residing in the household under court-ordered guardianship, including temporary or general guardianship, shall be addressed separately from foster care placements for purposes of household composition and occupancy determinations.” “Nothing in the classification of a minor as a foster child or as a child residing under guardianship shall prevent the family from requesting a reasonable accommodation when a disability-related need requires a separate bedroom or other adjustment to standard subsidy or occupancy rules.”
Adding this clarification would help ensure consistent interpretation of the policy and better protect families who are caring for minors under legal guardianship while also addressing disability-related housing needs fairly and appropriately.
Thank you for considering this comment.
From: HHS.Commissions
To: [email protected]
Cc: Housing Comments; ADACoordinator; Attorney Mailbox
Subject: RE: Agenda Item 3B – PHA Annual Plan – Continuum of Care (CoC) Program: Disparate Impact, Program Oversight, and Federal Compliance Issues
Date: Thursday, February 5, 2026 10:45:40 AM
Thank you for submitting your written public comment for Housing Commission Agenda Item 3B – PHA Annual Plan. This comment will be posted at Noon today on the Housing Commission webpage and will be shared with commissioners.
The February 11 Disabilities Commission agenda has just been posted to the DC webpage. Written public comment to the Disabilities Commission may be sent to [email protected].
From: [email protected] <[email protected]> Sent: Thursday, February 5, 2026 10:31 AM
To: HHS.Commissions <[email protected]>
Cc: Housing Comments
<[email protected]>; ADACoordinator <[email protected]>; Attorney Mailbox <[email protected]>
Subject: Agenda Item 3B – PHA Annual Plan – Continuum of Care (CoC) Program: Disparate Impact, Program Oversight, and Federal Compliance Issues
EXTERNAL
This written comment is submitted for inclusion in the official administrative record for the Public Housing Agency (PHA) Annual Plan. It is submitted to the Housing Commission and copied to other City entities with statutory, oversight, and compliance responsibilities; a current public contact address for the Disabilities Commission was not available on the City’s website at the time of submission.
The comment addresses the design, implementation, oversight, and long-term planning implications of the administration of Continuum of Care (CoC) housing assistance within the jurisdiction, as reflected in the PHA Annual Plan.
While the Annual Plan addresses general housing stability objectives, it does not meaningfully account for the structural effects of CoC program design on participants with disabilities, particularly with respect to geographic mobility, long-term exit pathways, and program-level oversight.
Where the jurisdiction administers or implements CoC assistance locally, the Annual Plan necessarily reflects the planning, oversight, and governance implications of those implementation decisions.
Even where program parameters are set at the federal or regional level, local jurisdictions retain responsibility and accountability for how those parameters are implemented, mitigated, and addressed through planning, governance, and access to lawful alternatives consistent with fair housing and disability access obligations.
1. Non-portability as a structural constraint
As administered locally, CoC assistance is categorically non-portable across jurisdictions. In practice, this operates as a structural constraint rather than a neutral program characteristic, particularly for participants with disabilities who require geographic mobility for safety, medical access, family support, or long-term stability.
The Annual Plan does not analyze or acknowledge the cumulative impact of nonportability on protected classes, nor does it identify mitigation strategies within the planning horizon. The absence of analysis itself constitutes a planning deficiency, where foreseeable disparate impacts are known or should be known at the time of plan adoption.
2. Absence of housing stability exit pathways, including homeownership The Plan does not address the absence of any administered Housing Choice Voucher Homeownership option, or equivalent stability-transition framework accessible to CoC participants without relinquishing CoC assistance. In jurisdictions where CoC assistance is non-portable and no homeownership pathway exists, participants with disabilities are effectively confined to long-term rental dependency within a single jurisdiction, without access to federally contemplated mechanisms for permanent housing stability and asset formation.
Generalized assertions related to local housing costs or administrative capacity do not substitute for program analysis. High-cost markets heighten, rather than diminish, the need for structured exit pathways from long-term assistance. Assertions of administrative burden are particularly unpersuasive where the affected participant population is limited in size and where the absence of any administered pathway reflects a policy choice rather than a demonstrated operational impossibility.
Where the City relies on assertions of administrative burden to justify nonimplementation of legally available housing stability pathways, such claims must be supported by contemporaneous documented analysis—including estimated implementation costs, ongoing administrative requirements, staffing models, and timelines. The absence of any such quantified analysis in the Annual Plan constitutes a planning deficiency rather than a policy justification.
3. Forced program conversion as a condition of mobility In practice, individuals seeking to relocate outside the jurisdiction while receiving CoC assistance are required to relinquish CoC participation and convert to a different voucher program, most commonly Housing Choice Voucher (Section 8), as a precondition to mobility. This conversion entails the loss of CoC-specific protections designed for individuals with disabilities and introduces additional administrative barriers. Conditioning access to mobility on the surrender of a more protective assistance framework raises civil rights and program-integrity concerns that are not addressed in the Plan.
4. Governance and oversight gap for CoC participants
Although general advisory bodies, designated commission seats, public comment opportunities, and written input mechanisms exist within the jurisdiction, these do not constitute a program-specific, institutionalized feedback and oversight framework for Continuum of Care (CoC) participants, nor do they provide a mechanism for continuous monitoring, issue escalation, or corrective action tied to CoC program administration.
As a result, the jurisdiction lacks a structured local feedback loop capable of systematically monitoring CoC implementation, identifying emerging barriers or disparate impacts, and informing timely program adjustments within the annual planning and oversight cycle.
The City has previously considered governance and advisory structures that would have provided program-specific participant representation beyond generalized or nominal advisory models, including structures that would have encompassed Continuum of Care (CoC) participants. Those options were formally discussed but were not implemented, and no operative advisory or oversight mechanism was subsequently established to represent CoC participants or to provide structured, localized program feedback. The absence of any implemented mechanism following those deliberations reflects a knowing governance gap rather than an inadvertent omission.
While regional or system-level CoC governance structures exist, they do not substitute for localized oversight of jurisdiction-specific administrative practices that directly affect participants’ housing stability, geographic mobility, and access to federally contemplated exit pathways. Regional bodies are structurally removed from day-to-day program administration and lack the authority, visibility, and procedural mechanisms necessary to monitor local implementation choices, identify emerging disparate impacts, or require timely corrective action. Reliance on regional or nominal advisory structures therefore does not satisfy obligations of meaningful access or effective nondiscriminatory program administration at the local level.
Mechanisms frequently cited as sufficient—such as a single designated commission seat, generalized public comment at City Council, Housing Commission, or PHA board meetings, written submissions to annual planning documents, email or fax correspondence, or ad hoc testimony—are episodic and non-programmatic by design.
They do not provide a continuous, structured process for collecting, synthesizing, and evaluating CoC participant experiences, nor do they support early detection of structural impacts related to mobility constraints, forced program conversion, or the absence of stability-transition pathways. These mechanisms also place a disproportionate burden on highly vulnerable participants to self-advocate within forums not designed to capture program-specific operational outcomes.
In addition, Housing Commission proceedings are not live-streamed and are not made available through timely public video recordings, unlike other City commissions. While audio recordings may be posted after meetings, the absence of live access and visual recordings significantly limits the ability of CoC participants with disabilities to observe deliberations, assess decision-making context, or meaningfully monitor program oversight. Reliance on delayed audio-only access—particularly where no real-time participation is possible—renders existing advisory and feedback structures functionally inaccessible for purposes of meaningful participation, transparency, and compliance monitoring.
Notably, Housing Commission meetings were previously live-streamed and made available through recorded video during the COVID-19 period, demonstrating that such accessibility is administratively feasible; the subsequent withdrawal of those practices, without explanation or mitigation, further compounds the accessibility and oversight concerns described above. This prior practice establishes both feasibility and institutional knowledge regarding such access measures.
Where existing access mechanisms are functionally ineffective for the affected participant population, their formal availability does not satisfy obligations of meaningful access, program oversight, or nondiscriminatory administration.
Recent participant outreach characterized as an online PHA Plan workshop did not include any substantive presentation, program overview, or structured opportunity for informed engagement. Instead, the session was limited to a brief, perfunctory solicitation of comments following access barriers reported by participants and observed in real time, including real-time participation obstacles and authentication requirements inconsistent with the notice provided.
Further, reliance on electronic-only notification for such engagement—without parallel written notice—fails to account for known digital access barriers among highly vulnerable voucher populations, thereby undermining meaningful access, effective participation, and the integrity of the feedback and oversight process.
5. Planning implications
Taken together, the interaction of CoC non-portability, absence of stability-transition pathways (including homeownership), forced program downgrades, and lack of localized oversight constitutes a foreseeable and durable policy outcome rather than an incidental effect. The Plan does not analyze these elements in combination, nor does it address their interacting effects on protected classes.
The Plan and related City materials expressly reference the City’s Continuum of Care program administration and goals; however, they do not include a commensurate analysis of the combined, foreseeable disparate impacts of non-portability, forced program conversion, and the absence of durable exit pathways on participants with disabilities. The City’s own public record reflects that affordable homeownership and administrative implementation options—including HUD-authorized Housing Choice Voucher (Section 8) homeownership pathways, which currently require CoC participants to relinquish CoC assistance as a condition of access—were formally analyzed and presented to City governing bodies in recent years. The Annual Plan’s failure to acknowledge those materials, or to articulate a documented rationale for declining to pursue legally available homeownership-related stability pathways for highly vulnerable populations, underscores the planning deficiency and the City’s documented awareness of the resulting disparate impacts.
The Annual Plan should explicitly analyze these interactions and identify corrective strategies consistent with fair housing obligations, disability access requirements, and principles of sound program governance.
Requested consideration:
As part of the Annual Plan process, the Housing Commission and PHA governing body should:
• Acknowledge and analyze the disparate impact risks associated with CoC nonportability; • Address the absence of homeownership or equivalent exit pathways for CoC participants;
• Examine the civil rights implications of requiring voucher conversion as a condition of mobility;
• Evaluate and restore reasonable public access measures for Housing Commission proceedings—including live-streaming and timely publication of video or audio recordings—where necessary to ensure meaningful participation, program transparency, and effective oversight for CoC participants and other protected classes; • Evaluate the need for a structured, local feedback and oversight mechanism for CoC participants, including through a Resident Advisory Board (RAB) that operates as an active oversight and feedback body (rather than a nominal or paper-based compliance structure), with representation accessible to CoC participants.
This comment is submitted to ensure that these issues are considered within the formal planning and oversight record.
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