Agenda packet — City Council and Concurrent Authorities, March 19, 2024 (part 3 of 5)

Section 12. Not
ices. Any notice or communications to be among any of the parties to this Disclosure Certificate may be given by regular, overnight, or electronic mail as follows:

To the
Developer ___________
___________
___________
Attn: ________________
Email: ________________

With a copy to: ___________
___________
___________
Attn: ________________
Email: ________________

To the City: City of Stockton
425 N. El Dorado Street
Stockton, California 95202
Attn: Chief Financial Officer
Email: ________________

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To the Participating Underwriter: Oppenheimer & Co. Inc. 135 Main Street, Suite 1700
San Francisco, California 94105
Attn: Municipal Capital Markets Group
Email: [email protected]

Any person may, by written notice to the other persons listed above, designate a different address to which subsequent notices or communications should be sent.

Section 13. B eneficiaries. This Disclosure Ce rtificate shall inure solely to the benefit of the City, the Developer (its successors and assigns), the Dissemination Agent, the Participating Underwriter and holders and beneficial owners from time to time of the Bonds, and shall create no rights in any other person or entity. All obligations of the Developer hereunder shall be assumed by any legal successor to the obligations of the Developer as a result of a sale, merger, consolidation or other reorganization.

Section 14. Count
erparts. This Disclosure Certificate may be executed in several counterparts, each of which shall be an original and all of which shall constitute but one and the same instrument.

[R
emainder of Page Intentionally Left Blank; Signature Page Follows]

IN WITNESS WHEREOF, the Developer has executed this Disclosure Certificate as of the date first above written.

DEVELOPER:

LENNAR HOMES OF CALIFORNIA, LLC

By:

Name:

Title:

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F-16

EXHIBIT A

PERIODIC REPORT

(MARCH 31, ____ / SEPTEMBER 30, ____)

$________
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

This Periodic Report is hereby submitted under Section 4 of the Continuing Disclosure Certificate (the “Disclosure Certificate”) dated April 1, 2024, executed by the undersigned (the “Developer”) in connection with the issuance of the above- captioned bonds by the City of Stockton (the “City”) with respect to its Improvement Area 3 (“Improvement Area 3”) of the City of Stockton Community Facilities District No. 2018-2 (Westlake Villages II) (the “District”).

Capitalized terms used in this Periodic Report but not otherwise defined have the meanings given to them in the Disclosure Certificate.

I. Property Ownership and Development

The information in this section is provided as of ____________________ (this date must be not more than 30 days before the date of this Periodic Report).

A. Property currently owned by the Developer in Improvement Area 3 (the “Property”):

Development name(s):

Number of lots:

B. Updated information regarding land development and home construction activities with respect to the Property described in the Official Statement for the Bonds under the caption “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3—Lennar Homes” or the Periodic Report last filed in accordance with the Disclosure Certificate:

_____________________________________________________________________

C. Status of building permits and any material changes to the description of land use or development entitlements for the Property described in the Official Statement for the Bonds under the caption “ OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3—Lennar Homes” or the Periodic Report last filed in accordance with the Disclosure Certificate:

_____________________________________________________________________ EXHIBIT 2
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F-17

_____________________________________________________________________

D. Status of any land purchase contracts (other than sales to homeowners) with regard to the Property.

_____________________________________________________________________

E. Number of Homes in Improvement Area 3 sold and closed to homeowners by the Developer to date: ___________

Number of Homes in Improvement Area 3 under contract for sale as of ___________, 20__: ___________

II. Legal and Financial Status of Developer

Unless such information has previously been included or incorporated by reference in a Periodic Report, describe any change in the legal structure of the Developer or the financial condition and financing plan of the Developer that would materially and adversely interfere with its ability to complete its development plan described in the Official Statement.

_____________________________________________________________________

III. Change in Development or Financing Plans

Unless such information has previously been included or incorporated by reference in a Periodic Report, describe any development plans or financing plans relating to the Property that are materially different from the proposed development and financing plan described in the Official Statement.
_____________________________________________________________________

_____________________________________________________________________

IV. Official Statement Updates

Unless such information has previously been included or incorporated by reference in a Periodic Report, describe any other significant changes in the information relating to the Developer or the Property contained in the Official Statement under the heading “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3 — Lennar Homes” that would materially and adversely interfere with the Developer ’s ability to develop and sell the Property as described in the Official Statement.

_____________________________________________________________________

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V. Other Material Information

In addition to any of the information expressly required above, provide such further information, if any, as may be necessary to make the specifically required statements, in the light of the circumstances under which they are made, not misleading.

_____________________________________________________________________

Certification

The undersigned Developer hereby certifies that this Periodic Report constitutes the Periodic Report required to be furnished by the Developer under the Disclosure Certificate.

ANY STATEMENTS REGARDING THE DEVELOPER, THE DEVELOPMENT OF THE PROPERTY, THE DEVELOPER’S FINANCING PLAN OR FINANCIAL CONDITION, OR THE

BONDS, OTHER THAN STATEMENTS MADE BY THE DEVELOPER IN AN OFFICIAL

RELEASE, OR FILED WITH THE MUNICIPAL SECURITIES RULEMAKING BOARD, ARE NOT AUTHORIZED BY THE DEVELOPER. THE DEVELOPER IS NOT RESPONSIBLE

FOR THE ACCURACY, COMPLETENESS OR FAIRNESS OF ANY SUCH UNAUTHORIZED STATEMENTS.

THE DEVELOPER HAS NO OBLIGATION TO UPDATE THIS PERIODIC REPORT OTHER THAN AS EXPRESSLY PROVIDED IN THE DISCLOSURE CERTIFICATE.

Dated:

DEVELOPER: __________________

By: _____________________________
_____________________________
_____________________________

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G-1

APPENDIX G

DTC AND THE BOOK-ENTRY ONLY SYSTEM

The following description of the Depository Trust Company (“DTC”), the procedures and record keeping with respect to beneficial ownership interests in the Bonds, payment of principal, interest and other payments on the Bonds (herein, the “Securities”) to DTC Participants or Beneficial Owners, confirmation and transfer of beneficial ownership interest in the Securities and other related transactions by and between DTC, the DTC Participants and the Beneficial Owners is based solely on information provided by DTC. Accordingly, no representations can be made concerning these matters and neither the DTC Participants nor the Beneficial Owners should rely on the foregoing information with respect to such matters, but should instead confirm the same with DTC or the DTC Participants, as the case may be.

Neither the issuer of the Securities (the “Issuer”) nor the trustee, fiscal agent or paying agent appointed with respect to the Securities (the “Agent”) takes any responsibility for the information contained in this Appendix.

No assurances can be given that DTC, DTC Participants or Indirect Participants will distribute to the Beneficial Owners (a) payments of interest, principal or premium, if any, with respect to the Securities, (b) certificates representing ownership interest in or other confirmation or ownership interest in the Securities, or (c) redemption or other notices sent to DTC or Cede & Co., its nominee, as the registered owner of the Securities, or that they will so do on a timely basis, or that DTC, DTC Participants or DTC Indirect Participants will act in the manner described in this Appendix. The current “Rules” applicable to DTC are on file with the Securities and Exchange Commission and the current “Procedures” of DTC to be followed in dealing with DTC Participants are on file with DTC.

1. The Depository Trust Company ( “DTC”) will act as securities depository for the securities (the “Securities”). The Securities will be issued as fully-registered securities registered in the name of Cede & Co. (DTC ’s partnership nominee) or such other name as may be requested by an authorized representative of DTC. One fully -registered Security certificate will be issued for each issue of the Securities, each in the aggregate principal amount of such issue, and will be deposited with DTC. If, however, the aggregate principal amount of any issue exceeds $500 million, one certificate will be issued with respect to each $500 million of principal amount, and an additional certificate will be issued with respect to any remaining principal amount of such issue.

2. DTC, the world ’s largest securities depository, is a limited- purpose trust company organized under the New York Banking Law, a “banking organization” within the meaning of the New York Banking Law, a member of the Federal Reserve System, a “clearing corporation” within the meaning of the New York Uniform Commercial Code, and a “ clearing agency ” registered pursuant to the provisions of Section 17A of the Securities Exchange Act of 1934.

DTC holds and provides asset servicing for over 3.5 million issues of U.S. and non-U.S. equity issues, corporate and municipal debt issues, and money market instruments (from over 100 countries) that DTC’s participants (“Direct Participants”) deposit with DTC. DTC also facilitates the post-trade settlement among Direct Participants of sales and other securities transactions in deposited securities, through electronic computerized book -entry transfers and pledges between Direct Participants ’ accounts. This eliminates the need for physical movement of securities certificates. Direct Participants include both U.S. and non-U.S. securities brokers and EXHIBIT 2
475
G- 2
dealers, banks, trust companies, clearing corporations, and certain other organizations. DTC is a wholly-owned subsidiary of The Depository Trust & Clearing Corporation ( “DTCC”). DTCC is the holding company for DTC, National Securities Clearing Corporation and Fixed Income Clearing Corporation, all of which are registered clearing agencies. DTCC is owned by the users of its regulated subsidiaries. Access to the DTC system is also available to others such as both U.S. and non- U.S. securities brokers and dealers, banks, trust companies, and clearing corporations that clear through or maintain a custodial relationship with a Direct Participant, either directly or indirectly (“Indirect Participants”). DTC has a Standard & Poor’s rating of AA+.

The DTC Rules applicable to its Participants are on file with the Securities and Exchange Commission. More information about DTC can be found at www.dtcc.com . The information contained on this Internet site is not incorporated herein by reference.

3. Pur
chases of Securities under the DTC system must be made by or through Direct Participants, which will receive a credit for the Securities on DTC’s records. The ownership interest of each actual purchaser of each Security (“ Beneficial Owner”) is in turn to be recorded on the Direct and Indirect Participants ’ records. Beneficial Owners will not receive written confirmation from DTC of their purchase. Beneficial Owners are, however, expected to receive written confirmations providing details of the transaction, as well as periodic statements of their holdings, from the Direct or Indirect Participant through which the Beneficial Owner entered into the transaction. Transfers of ownership interests in the Securities are to be accomplished by entries made on the books of Direct and Indirect Participants acting on behalf of Beneficial Owners. Beneficial Owners will not receive certificates representing their ownership interests in Securities, except in the event that use of the book -entry system for the Securities is discontinued.

4. To
facilitate subsequent transfers, all Securities deposited by Direct Participants with DTC are registered in the name of DTC’s partnership nominee, Cede & Co., or such other name as may be requested by an authorized representative of DTC. The deposit of Securities with DTC and their registration in the name of Cede & Co. or such other DTC nominee do not effect any change in beneficial ownership. DTC has no knowledge of the actual Beneficial Owners of the Securities; DTC ’s records reflect only the identity of the Direct Participants to whose accounts such Securities are credited, which may or may not be the Beneficial Owners. The Direct and Indirect Participants will remain responsible for keeping account of their holdings on behalf of their customers.

5. Conv
eyance of notices and other communications by DTC to Direct Participants, by Direct Participants to Indirect Participants, and by Direct Participants and Indirect Participants to Beneficial Owners will be governed by arrangements among them, subject to any statutory or regulatory requirements as may be in effect from time to time. Beneficial Owners of Securities may wish to take certain steps to augment the transmission to them of notices of significant events with respect to the Securities, such as redemptions, tenders, defaults, and proposed amendments to the Security documents. For example, Beneficial Owners of Securities may wish to ascertain that the nominee holding the Securities for their benefit has agreed to obtain and transmit notices to Beneficial Owners. In the alternative, Beneficial Owners may wish to provide their names and addresses to the registrar and request that copies of notices be provided directly to them.

6. Redem
ption notices shall be sent to DTC. If less than all of the Securities within an issue are being redeemed, DTC ’s practice is to determine by lot the amount of the interest of each Direct Participant in such issue to be redeemed.

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7. Neither DTC nor Cede & Co. (nor any other DTC nominee) will consent or vote with respect to Securities unless authorized by a Direct Participant in accordance with DTC ’s MMI Procedures. Under its usual procedures, DTC mails an Omnibus Proxy to Issuer as soon as possible after the record date. The Omnibus Proxy assigns Cede & Co. ’s consenting or voting rights to those Direct Participants to whose accounts Securities are credited on the record date (identified in a listing attached to the Omnibus Proxy).

8. Redemption proceeds, distributions, and dividend payments on the Securities will be made to Cede & Co., or such other nominee as may be requested by an authorized representative of DTC. DTC ’s practice is to credit Direct Participants ’ accounts upon DTC ’s receipt of funds and corresponding detail information from Issuer or Agent, on payable date in accordance with their respective holdings shown on DTC ’s records. Payments by Participants to Beneficial Owners will be governed by standing instructions and customary practices, as is the case with securities held for the accounts of customers in bearer form or registered in “street name,” and will be the responsibility of such Participant and not of DTC, Agent, or Issuer, subject to any statutory or regulatory requirements as may be in effect from time to time.

Payment of redemption proceeds, distributions, and dividend payments to Cede & Co. (or such other nominee as may be requested by an authorized representative of DTC) is the responsibility of Issuer or Agent, disbursement of such payments to Direct Participants will be the responsibility of DTC, and disbursement of such payments to the Beneficial Owners will be the responsibility of Direct and Indirect Participants.

9. DTC may discontinue providing its services as depository with respect to the Securities at any time by giving reasonable notice to Issuer or Agent. Under such circumstances, in the event that a successor depository is not obtained, Security certificates are required to be printed and delivered.

10. Issuer may decide to discontinue use of the system of book -entry-only transfers through DTC (or a successor securities depository). In that event, Security certificates will be printed and delivered to DTC.

11. The information in this section concerning DTC and DTC ’s book-entry system has been obtained from sources that Issuer believes to be reliable, but Issuer takes no responsibility for the accuracy thereof.

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1 $________
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

BOND PURCHASE AGREEMENT
__________, 2024
City of Stockton
425 North El Dorado Street
Stockton, California 95202
Ladies and Gentlemen:

The undersigned, Oppenheimer & Co. Inc., as underwriter (the “ Underwriter”), acting not as a fiduciary or agent for you, but on behalf of itself, offers to enter into this Bond Purchase Agreement (this “Purchase Agreement ”) with the City of Stockton (the “ City”) for Improvement Area 3 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) (the “Community Facilities District”), which upon acceptance will be binding upon the Underwriter and the City. The agreement of the Underwriter to purchase the Bonds (as hereinafter defined) is contingent upon the City satisfying all of the obligations imposed upon it under this Purchase Agreement. This offer is made subject to the City’s acceptance by the execution of this Purchase Agreement and its delivery to the Underwriter at or before 11:59 p.m., California time, on the date hereof, and, if not so accepted, will be subject to withdrawal by the Underwriter upon notice delivered to the City at any time prior to the acceptance hereof by the City. All capitalized terms used herein, which are not otherwise defined, shall have the meaning provided for such terms in the Fiscal Agent Agreement, dated as of April 1, 2024 (the “Fiscal Agent Agreement”), by and between the City and U.S. Bank Trust Company, National Association, as fiscal agent (the “Fiscal Agent”).

1. Purchase, Sale and Delivery of the Bonds.

A. Subject to the terms and conditions and in reliance upon the representations, warranties and agreements set forth herein: the Underwriter hereby agrees to purchase from the City and the City hereby agrees to sell to the Underwriter all (but not less than all) of the $_______ aggregate principal amount of the Improvement Area 3 of the City of Stockton Community Facilities District No. 2018-2 (Westlake Villages II), Special Tax Bonds, Series 2024 (the “Bonds”), dated the Closing Date (as hereinafter defined), bearing interest at the rates and maturing on the dates and in the principal amounts set forth in Appendix A hereto. The purchase price for the Bonds shall be $_______ (being 100% of the aggregate principal amount thereof, less a net original issue discount of $________, less an Underwriter’s discount of $________).

The Underwriter agrees to make a bona fide initial public offering of all of the Bonds in compliance with federal and state securities laws, at a price not in excess of the initial offering prices (or yields) set forth in Appendix A attached hereto and incorporated herein by reference. Subsequent to the initial public offering, the Underwriter reserves the right to change the public offering prices (or yields) as it deems necessary in connection with the offering of the Bonds, without any requirement of prior notice subject to Section 5 herein, provided that the Underwriter shall not EXHIBIT 3
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2 change the interest rates set forth in Appendix A. The Bonds may be offered and sold to certain dealers at prices lower than such initial offering prices.

The Bonds shall be substantially in the form described in, shall be issued and secured under the provisions of, and shall be payable from the Net Taxes and certain other amounts as provided in the Fiscal Agent Agreement, the Preliminary Official Statement (as hereinafter defined), and the Mello-Roos Community Facilities Act of 1982, as amended, being Chapter 2.5, Part 1, Division 2, Title 5 of the Government Code of the State of California (the “Act”). The issuance of the Bonds has been duly authorized by the City pursuant to a resolution (the “ Resolution”), adopted by its City Council (the “City Council”) on behalf of the Community Facilities District, on ________, 2024.

The proceeds of the Bonds shall be used to (i) construct and/or acquire certain public facilities authorized for the Community Facilities District, (ii) pay capitalized interest on a portion of the Bonds through September 1, 2024 , (iii) establish a debt service reserve fund for the Bonds, and (iv) pay initial administration costs and the costs of issuing the Bonds.

B. The City hereby acknowledges that the Underwriter is entering into this Purchase Agreement in reliance on the representations, warranties and agreements made by the City on behalf of itself and on behalf of the Community Facilities District herein, and the City shall take all action necessary to enforce its rights hereunder for the benefit of the Underwriter and shall immediately notify the Underwriter if it becomes aware that any representation, warranty or agreement made by the City, on behalf of itself or on behalf of the Community Facilities District, herein is incorrect in any material respect.

C. The City acknowledges and agrees that: (i) the primary role of the Underwriter, as an underwriter, is to purchase securities for resale to investors in an arm’s -length commercial transaction between the City and the Underwriter and that the Underwriter has financial and other interests that differ from those of the City and the Community Facilities District; (ii) the Underwriter is not acting as a municipal advisor, financial advisor or fiduciary to the City, the Community Facilities District, or any other person or entity and has not assumed any advisory or fiduciary responsibility to the City or the Community Facilities District with respect to the transaction contemplated hereby and the discussions, undertakings and proceedings leading thereto (irrespective of whether the Underwriter has provided other services or is currently providing other services to the City or the Community Facilities District on other matters); (iii) the only obligations the Underwriter has to the City or the Community Facilities District with respect to the transaction contemplated hereby expressly are set forth in this Purchase Agreement, except as otherwise provided by applicable rules and regulations of the Securities and Exchange Commission or the rules of the Municipal Securities Rulemaking Board (the “ MSRB”); and (iv) the City has consulted its own legal, accounting, tax, financial and other advisors, as applicable, to the extent it has deemed appropriate in connection with the transaction contemplated herein. The City acknowledges that it has previously provided the Underwriter with an acknowledgement of receipt of the required Underwriter disclosure under Rule G-17 of the MSRB and acknowledges that it has engaged Del Rio Advisors, LLC (the “ Municipal Advisor ”), as its municipal advisor (as defined in Securities and Exchange Commission Rule 15Ba1) and will rely solely on the Municipal Advisor for financial advice with respect to the Bonds.

D. Pursuant to the authorization of the City, the Underwriter has distributed copies of the Preliminary Official Statement dated _______, 2024 , relating to the Bonds, which, together with the cover page, inside cover page and appendices thereto is herein called the “Preliminary Official Statement.” By its acceptance of this Purchase Agreement, the City hereby EXHIBIT 3
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3 consents to and ratifies the use and distribution by the Underwriter of the Preliminary Official Statement, and the City agrees to execute a final official statement relating to the Bonds (the “Official Statement”) which will consist of the Preliminary Official Statement with such changes as may be made thereto, with the approval of Jones Hall, A Professional Law Corporation, San Francisco, California, Bond Counsel and Disclosure Counsel (herein called “ Bond Counsel”), and the Underwriter, and to provide copies thereof to the Underwriter as set forth in Section 2(S) hereof.

The City hereby authorizes and requires the Underwriter to use and promptly distribute, in connection with the offer and sale of the Bonds, the Preliminary Official Statement, the Official Statement and any supplement or amendment thereto. The City further authorizes the Underwriter to use and distribute, in connection with the offer and sale of the Bonds, the Fiscal Agent Agreement, this Purchase Agreement and all information contained herein, and all other documents, certificates and statements furnished by or on behalf of the City or the Community Facilities District to the Underwriter in connection with the transactions contemplated by this Purchase Agreement. The Preliminary Official Statement and/or the Official Statement may be delivered and printed in a “designated electronic format” as defined in the MSRB’s Rule G -32 and as may be agreed to by the City and the Underwriter. The City confirms that it does not object to distribution of the Preliminary Official Statement or the Official Statement in electronic form. A copy of the most recent Preliminary Official Statement sent to a potential purchaser shall be sent electronically (or other equally prompt means) by first class mail not later than the first business day following the day upon which each such request is received.

E. To assist the Underwriter in complying with Securities and Exchange Commission Rule 15c2-12(b)(5) (the “ Rule”), the City will undertake pursuant to the City Continuing Disclosure Certificate, in the form attached as an appendix to the Official Statement (the “City Continuing Disclosure Certificate”), to provide annual reports and notices of certain enumerated events. A description of this undertaking is set forth in the Preliminary Official Statement and will also be set forth in the Official Statement.

F. Except as the Underwriter and the City may otherwise agree, the City will deliver to the Underwriter, at the offices of Bond Counsel in San Francisco, California, or at such other location as may be mutually agreed upon by the Underwriter and the City, the documents hereinafter mentioned; and the City will deliver to the Underwriter through The Depository Trust Company’s (“DTC”) FAST delivery system, the Bonds, in definitive form (all Bonds bearing CUSIP
® numbers printed thereon), duly executed by the City and authenticated by the Fiscal Agent in the manner provided for in the Fiscal Agent Agreement and the Act at 8: 30 a.m. California time, on ________, 2024 (the “Closing Date”), and the Underwriter will accept such delivery and pay the purchase price of the Bonds as set forth in paragraph (A) of this Section by wire transfer, payable in federal or other immediately available funds (such delivery and payment being herein referred to as the “Closing”). The Bonds shall be in fully registered book -entry form (which may be typewritten) and shall be registered in the name of Cede & Co., as nominee of DTC, which will act as securities depository for the Bonds, and the specimen Bonds will be made available for checking by the Underwriter not less than 5 days prior to the Closing.

G. Except as the City and the Underwriter may otherwise agree, the City will deliver to the Underwriter, at the offices of Bond Counsel in San Francisco, California, or at such other location as may be mutually agreed upon by the Underwriter and the City, the documents hereinafter mentioned on the Closing Date.

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4 2. Representations, Warranties and Covenants of the Community Facilities District .

The City represents, warrants and covenants to the Underwriter, on behalf of itself and the Communities Facilities District, as the case may be, that:

A. The City is a municipal corporation and charter city duly organized and validly existing pursuant to the Constitution and laws of the State of California (the “State”), and has duly authorized the formation of the Community Facilities District pursuant to resolutions duly adopted by the City Council (the “ Community Facilities District Formation Resolution ” and, together with the Resolution, the “Community Facilities District Resolutions ”) and the Act. The City Council, as the legislative body of the Community Facilities District, has duly adopted the Community Facilities District Formation Resolution, has duly adopted the Ordinance levying the Special Tax (for all purposes herein, as such are defined in the Fiscal Agent Agreement) within Improvement Area 3 of the Community Facilities District (the “ Ordinance”), and has caused to be recorded in the real property records of San Joaquin County, a notice of special tax lien (the “ Notice of Special Tax Lien”). The Community Facilities District Formation Resolution, the Ordinance, and the Notice of Special Tax Lien are collectively referred to herein as the “ Formation Documents.” The City Council has duly adopted the Resolution. Each of the Formation Documents remains in full force and effect as of the date hereof and has not been amended. The Community Facilities District is duly organized and validly existing as a community facilities district under the laws of the State.

The City has, and at the Closing Date will have, as the case may be, full legal right, power and authority: (i) to execute, deliver and perform its obligations under this Purchase Agreement and the Fiscal Agent Agreement and to carry out all transactions contemplated by each of such agreements; (ii) to enter into the City Continuing Disclosure Certificate; and (iii) to carry out, give effect to and consummate the transactions contemplated by the Formation Documents, the Fiscal Agent Agreement, this Purchase Agreement and the Official Statement.

This Purchase Agreement, the Fiscal Agent Agreement, and the City Continuing Disclosure Certificate are collectively referred to herein as the “City Documents.” B. By all necessary official action of the City, the City has duly authorized and approved the execution and delivery by the City of, and the performance by City of, the obligations on its part contained in, the City Documents and has approved the use and distribution by the Underwriter of the Preliminary Official Statement and the execution, use and distribution by the Underwriter of the Official Statement, and, as of the date hereof, such authorizations and approvals are in full force and effect and have not been amended, modified or rescinded. When executed and delivered by the parties thereto, the City Documents will constitute the legally valid and binding obligations of the City, on its own behalf and on behalf of the Communities Facilities District, enforceable upon the City and the Community Facilities District in accordance with their respective terms, except as enforcement may be limited by bankruptcy, insolvency, reorganization, moratorium or similar laws or equitable principles relating to or affecting creditors’ rights generally. To the best of the City’s knowledge, the City has complied, and will at the Closing Date be in compliance in all respects, with the terms of the City Documents that are applicable to the City, and the Community Facilities District has complied, and will at the Closing Date be in compliance in all respects, with the terms of the City Documents that are applicable to the Community Facilities District.

C. The information in the Preliminary Official Statement (other than statements pertaining to the book-entry system and under the headings “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3,” as to which no view is expressed) as of its date was and as of the date hereof is, and in the Official Statement (other than statements pertaining to the book- entry system and under the headings “OWNERSHIP AND DEVELOPMENT OF EXHIBIT 3
481

5 PROPERTY WITHIN IMPROVEMENT AREA 3,” as to which no view is expressed) as of its date is, true and correct in all material respects and does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading; and, upon delivery and up to and including 25 days after the End of the Underwriting Period (as defined in paragraph (D) below), the Official Statement will be amended and supplemented so as to contain no misstatement of any material fact or material omission of any statement necessary to make the statements contained therein, in the light of the circumstances in which such statements were made, not misleading.

D. Up to and including 25 days after the End of the Underwriting Period (as defined below), the City will advise the Underwriter promptly of any proposal to amend or supplement the Official Statement and will not effect or consent to any such amendment or supplement without the consent of the Underwriter, which consent will not be unreasonably withheld. The City will advise the Underwriter promptly of the institution of any proceedings known to it by any governmental agency prohibiting or otherwise materially affecting the use of the Official Statement in connection with the offering, sale or distribution of the Bonds. As used herein, the term “End of the Underwriting Period ” means the later of such time as: (i) the Bonds are delivered to the Underwriter; or (ii) the Underwriter does not retain, directly or as a member of an underwriting syndicate, an unsold balance of the Bonds for sale to the public. Unless the Underwriter gives notice to the contrary, the End of the Underwriting Period shall be deemed to be the Closing Date. Any notice delivered pursuant to this provision shall be written notice delivered to the City at or prior to the Closing Date and shall specify a date (other than the Closing Date) to be deemed the “End of the Underwriting Period.” If in the opinion of the Underwriter any such event or proceedings requires the preparation and distribution of a supplement or amendment to the Official Statement, the City shall prepare and furnish to the Underwriter, at the City’s expense, such number of copies of the supplement or amendment to the Official Statement, in (i) a “designated electronic format” consistent with the requirements of the MSRB’s Rule G-32 and (ii) a printed format form in substance mutually agreed upon by the City and the Underwriter as the Underwriter may reasonably request. If such amendment or supplement to the Official Statement shall be made subsequent to the Closing Date, the City also shall furnish, or cause to be furnished, such additional legal opinions, certificates, instruments and other documents as the Underwriter may reasonably deem necessary to evidence the truth and accuracy of any such supplement or amendment to the Official Statement.

E. As of the time of acceptance hereof and as of the Closing Date, the City and the Community Facilities District, as applicable, have each complied, and will at the Closing Date be in compliance in all material respects, with the Formation Documents and the City Documents, and any immaterial noncompliance by the City or the Community Facilities District, if any, will not impair the ability of the City or the Community Facilities District, as applicable, to carry out, give effect to or consummate the transactions contemplated by the foregoing. From and after the date of issuance of its Bonds, the City will continue to comply with the covenants of the City contained in the City Documents and it shall cause the Community Facilities District to continue to comply with the covenants of the Community Facilities District contained in the City Documents.

F. Except as described in the Preliminary Official Statement, neither the City nor the Community Facilities District is, and as of the Closing Date, neither will be, in any respect material to the transactions referred to herein or contemplated hereby, in breach of or in default under, any law or administrative rule or regulation of the State, the United States of America, or of any department, division, agency or instrumentality of either thereof, or under any applicable court or administrative decree or order, or under any loan agreement, note, resolution, indenture, contract, agreement or other instrument to which the City or the Community Facilities District, as the case EXHIBIT 3
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6 may be, is a party or is otherwise subject or bound; and, to the City’s knowledge, no event has occurred and is continuing which, with the passage of time or the giving of notice, or both, would constitute a default or event of default under any such instrument which breach, default or event could have an adverse effect on the City’s ability or the Community Facilities District’s ability to perform their respective obligations under the City Documents; and as of such times, except as disclosed in the Official Statement, the authorization, execution and delivery of the City Documents and compliance with the provisions of each thereof, or the performance of the conditions precedent to be performed by the City pursuant to this Purchase Agreement, will not conflict with or constitute a breach of or default under any applicable law or administrative rule or regulation of the State, the United States of America, or of any department, division, agency or instrumentality of either thereof, or under any applicable court or administrative decree or order, or under any loan agreement, note, resolution, indenture, contract, agreement or other instrument to which the City is a party or is otherwise subject or bound, in any manner which would materially and adversely affect the performance by the City or the Community Facilities District of their respective obligations under the City Documents or the performance of the conditions precedent to be performed by the City pursuant to this Purchase Agreement. The City has received all licenses, permits or other regulatory approvals required, if any, for the pledge, collection and/or application by the Community Facilities District of the Special Taxes (as defined in the Fiscal Agent Agreement) and other moneys pledged to the payment of the principal of and interest on the Bonds under the Fiscal Agent Agreement.

G. Except as may be required under the “blue sky” or other securities laws of any jurisdiction, all approvals, consents, authorizations, elections and orders of, or filings or registrations with, any governmental authority, board, agency or commission having jurisdiction which would constitute a condition precedent to, or the absence of which would materially adversely affect, the performance by the City or the Community Facilities District of their respective obligations under the City Documents, and the performance of the conditions precedent to be performed by the City pursuant to this Purchase Agreement, have been or will be obtained at the Closing Date and are or will be in full force and effect at the Closing Date.

H. At the time of acceptance hereof there is and as of the Closing there will be no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, government agency, public board or body (collectively and individually, an “ Action”) pending (notice of which has been served on the City or the Community Facilities District) or to the best knowledge of the City or the Community Facilities District threatened, in which any such Action: (i) in any way questions the powers of the City Council or the existence of the Community Facilities District or the titles of the officers of the City and/or the Community Facilities District to their respective offices; (ii) affects, contests or seeks to prohibit, restrain or enjoin the issuance or delivery of the Bonds or the payment or collection of the Special Taxes or any amounts pledged or to be pledged to pay the principal of and interest on the Bonds, or in any way contests or affects the validity of the City Documents or the consummation of the transactions on the part of the City or the Community Facilities District contemplated thereby; (iii) contests the exclusion of interest on the Bonds from federal or State income taxation or contests the powers of the City or the Community Facilities District which may result in any material adverse change relating to the financial condition of the City or the Community Facilities District; (iv) except as disclosed in the Official Statement, wherein an unfavorable decision, ruling or finding would materially adversely affect the financial position or condition of the City or the Community Facilities District or would result in any material adverse change in the ability of the City to pledge or apply the Special Taxes or to pay debt service on the Bonds; or (v) contests the completeness or accuracy of the Preliminary Official Statement or the Official Statement or any supplement or amendment thereto or asserts that the Preliminary Official Statement or the Official Statement contained any untrue statement of a material fact or EXHIBIT 3
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7 omitted to state any material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading; and as of the time of acceptance hereof there is and, as of the Closing Date, there will be no known basis for any Action of the nature described in clauses (i) through (v) of this sentence.

I. The City will furnish such information, execute such instruments and take such other action in cooperation with the Underwriter and at the expense of the Underwriter as the Underwriter may reasonably request in order: (i) to qualify the Bonds for offer and sale under the “blue sky” or other securities laws and regulations of such states and other jurisdictions of the United States of America as the Underwriter may designate; and (ii) to determine the eligibility of the Bonds for investment under the laws of such states and other jurisdictions and will use its best efforts to continue such qualifications in effect so long as required for the distribution of the Bonds, provided; however, that the City will not be required to execute a special or general consent to service of process or qualify as a foreign corporation in connection with any such qualification in any jurisdiction.

J. The City Documents conform as to form and tenor to the descriptions thereof contained in the Preliminary Official Statement. The City represents that the Bonds, when issued, executed and delivered in accordance with the Fiscal Agent Agreement and sold to the Underwriter as provided herein, will be validly issued and outstanding special tax obligations of the City payable solely from the proceeds of the Net Taxes and amounts in certain funds and accounts established in the Fiscal Agent Agreement, and entitled to the benefits of the Fiscal Agent Agreement. The City will comply with the covenant in the Fiscal Agent Agreement to cause the Special Taxes to be levied and collected at the same time and in the same manner as ordinary ad valorem property taxes. The Fiscal Agent Agreement creates a valid pledge of, first lien upon and security interest in, the Special Taxes, and in the moneys in the Special Tax Fund established pursuant to the Fiscal Agent Agreement, on the terms and conditions set forth in the Fiscal Agent Agreement. The Fiscal Agent Agreement creates a valid pledge of the moneys in certain funds and accounts established pursuant to the Fiscal Agent Agreement, subject in all cases to the provisions of the Fiscal Agent Agreement permitting the application thereof for the purposes and on the terms and conditions set forth therein.

K. Except as disclosed in the Preliminary Official Statement, there are, to the best of the City’s knowledge, no entities with outstanding assessment liens against any of the properties within Improvement Area 3 of the Community Facilities District which are senior to or on a parity with the Special Taxes.

L. The issuance and sale of the Bonds is not subject to any transfer or other documentary stamp taxes of the State or any political subdivision thereof.

M. The City shall not knowingly take or omit to take any action that, under existing law, may adversely affect the exclusion from gross income for federal income tax purposes, or the exemption from State of California personal income tax, of the interest on the Bonds. The City has not been notified of any listing or proposed listing by the Internal Revenue Service to the effect that the City is a bond issuer whose arbitrage certifications may not be relied upon.

N. Any certificate signed on behalf of the Community Facilities District by any officer or employee of the City authorized to do so and delivered to the Underwriter in connection with the issuance and sale of the Bonds shall be deemed to be a representation and covenant by the Community Facilities District to the Underwriter as to the statements made therein.

EXHIBIT 3
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8 O. The City will apply the proceeds of the Bonds in accordance with the Fiscal Agent Agreement and as will be described in the Official Statement.

P. At or prior to the Closing, the City will have duly authorized, executed and delivered the City Continuing Disclosure Certificate. Except as otherwise disclosed in the Preliminary Official Statement and based on a review of its previous undertakings, the City has not failed to comply, in any material respects, with any of its continuing disclosure undertakings previously entered into pursuant to the provisions of the Rule within the last five years.

Q. Between the date of this Purchase Agreement and the date of Closing, the City will not offer or issue any bonds, notes or other obligations for borrowed money not previously disclosed to the Underwriter and the City shall not create, assume or guarantee any indebtedness payable from, or pledge or otherwise encumber, the Special Taxes or other assets, properties, funds or interests that will be pledged as security for the Bonds pursuant to the City Documents.

R. Until such time as moneys have been set aside in an amount sufficient to pay all then outstanding Bonds at maturity or to the date of redemption if redeemed prior to maturity, plus unpaid interest thereon and premium, if any, to maturity or to the date of redemption if redeemed prior to maturity, the City will faithfully perform and abide by all of the covenants, undertakings and provisions contained in the Fiscal Agent Agreement.

S. The Preliminary Official Statement was deemed final by a duly authorized officer of the City prior to its delivery to the Underwriter, except for the omission of such information as is permitted to be omitted in accordance with paragraph (b)(1) of the Rule. The City hereby covenants and agrees that, within seven (7) business days from the date hereof, or upon reasonable written notice from the Underwriter within sufficient time to accompany any confirmation requesting payment from any customers of the Underwriter, the City shall cause a final electronic and/or printed form of the Official Statement as set forth in Section 1 above to be delivered to the Underwriter in sufficient quantity to comply with paragraph (b)(4) of the Rule and Rules G-12, G-15, G-32 and G-36 of the Municipal Securities Rulemaking Board.

T. The City hereby approves the preparation and distribution of the Official Statement, consisting of the Preliminary Official Statement with such changes as are noted thereon and as may be made thereto, with the approval of Bond Counsel and the Underwriter from time to time prior to the Closing Date.

U. The City hereby ratifies any prior use of and authorizes the future use by the Underwriter, in connection with the offering and sale of the Bonds, of the Preliminary Official Statement, the Official Statement, this Purchase Agreement and all information contained herein, and all other documents, certificates and written statements furnished by the City to the Underwriter in connection with the transactions contemplated by this Purchase Agreement.

V. The execution and delivery of this Purchase Agreement by the City shall constitute a representation by the City to the Underwriter that the representations and warranties contained in this Section 2 with respect to the City and the Community Facilities District are true as of the date hereof.

3. Conditions to the Obligations of the Underwriter . The obligation of the Underwriter to accept delivery of and pay for the Bonds on the Closing Date shall be subject, at the option of the Underwriter, to the accuracy in all material respects of the representations and warranties on the part EXHIBIT 3
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9 of the City, on its own behalf and on behalf of the Community Facilities District, contained herein, to the accuracy in all material respects of the statements of the officers and other officials of the City and the Community Facilities District made in any certificates or other documents furnished pursuant to the provisions hereof, to the performance by the City and the Community Facilities District of their obligations to be performed hereunder at or prior to the Closing Date and, to the following additional conditions:

A. At the Closing Date, the Community Facilities District Resolutions, the Formation Documents, and the City Documents shall be in full force and effect, and shall not have been amended, modified or supplemented, except as may have been agreed to in writing by the Underwriter, and there shall have been taken in connection therewith, with the issuance of the Bonds, and with the transactions contemplated thereby, and by this Purchase Agreement, all such actions as, in the opinion of Bond Counsel, shall be necessary and appropriate.

B. At the Closing Date, except as was described in the Preliminary Official Statement, neither the City nor the Community Facilities District shall be, in any respect material to the Bonds, the City Documents or the transactions referred to herein or contemplated hereby, in breach of or in default under, any law or administrative rule or regulation of the State, the United States of America, or of any department, division, agency or instrumentality of either thereof, or under any applicable court or administrative decree or order, or under any loan agreement, note, resolution, indenture, contract, agreement or other instrument to which the City or the Community Facilities District, respectively, is a party or is otherwise subject or bound, and the performance by the City or the Community Facilities District, respectively, of its obligations under the Bonds, the City Documents, the Community Facilities District Resolutions, this Purchase Agreement and any other instruments contemplated by any of such documents, and compliance with the provisions of each thereof, will not conflict with or constitute a breach of or default under any applicable law or administrative rule or regulation of the State, the United States of America or of any department, division, agency or instrumentality of either thereof or under any applicable court or administrative decree or order or under any loan agreement, note, resolution, indenture, contract, agreement or other instrument to which the City or the Community Facilities District, respectively, is a party or is otherwise subject or bound, in any manner which would materially and adversely affect the performance by the City or the Community Facilities District, respectively, of its obligations under the City Documents, the Bonds or the Community Facilities District Resolutions.

C. The information contained in the Official Statement is, as of the Closing Date and as of the date of any supplement or amendment thereto pursuant hereto, true and correct in all material respects and does not, as of the Closing Date or as of the date of any supplement or amendment thereto, contain any untrue statement of a material fact or omit to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances under which they were made, not misleading.

D. The Underwriter shall have the right to cancel its obligation to purchase the Bonds and to terminate this Purchase Agreement by written notice to the City if, between the date of this Purchase Agreement and the Closing Date, in the Underwriter’s sole and reasonable judgment any of the following events shall occur (each a “Termination Event”):

1. Between the date hereof and the Closing Date, the market price or marketability, at the initial offering prices set forth on the cover page of the Official Statement, of the Bonds, or the ability of the Underwriter to enforce contracts for the sale of the Bonds, shall have been materially adversely affected, in the judgment of the Underwriter (evidenced by a written notice EXHIBIT 3
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10 to the City terminating the obligation of the Underwriter to accept delivery of and pay for the Bonds), by reason of any of the following:
a. Legislation introduced in or enacted (or resolution passed) by the Congress of the United States of America or the legislature of the State or recommended to the Congress by the President of the United States of America or a member of the President’s Cabinet, the Department of the Treasury, the Internal Revenue Service or any member of Congress or favorably reported for passage to either House of Congress by any committee of such House to which such legislation had been referred for consideration, or a decision rendered by a court established under Article III of the Constitution of the United States of America or by the Tax Court of the United States of America, or an order, ruling, regulation (final, temporary or proposed), press release or other form of notice issued or made by or on behalf of the Treasury Department of the United States of America, the Internal Revenue Service or other federal or State authority with appropriate jurisdiction, with the purpose or effect, directly or indirectly, of imposing federal or State income taxation upon such interest as would be received by any owners of the Bonds beyond the extent to which such interest is subject to taxation as of the date hereof; b. Legislation introduced in or enacted (or resolution passed) by the Congress, or shall have been favorably reported out of committee or be pending in committee, or shall have been recommended to the Congress for passage by the President of the United States of America or a member of the President’s Cabinet, or an order, decree, injunction or decision issued by any court of competent jurisdiction, or an order, ruling, regulation (final, temporary or proposed), press release, statement or other form of notice issued or made by or on behalf of the Securities and Exchange Commission, or any other governmental agency having jurisdiction of the subject matter, to the effect that obligations of the general character of the Bonds, the Resolution or the City Documents, are not exempt from registration under or other requirements of the Securities Act of 1933, as amended, or that the Fiscal Agent Agreement is not exempt from qualification under or other requirements of the Trust Indenture Act of 1939, as amended, or that the issuance, offering or sale of obligations of the general character of the Bonds, as contemplated hereby or by the Official Statement or otherwise, is or would be in violation of the federal securities laws as amended and then in effect;
c. A general suspension of trading on the New York Stock Exchange or other major exchange shall be in force, or minimum or maximum prices for trading shall have been fixed and be in force, or maximum ranges for prices for securities shall have been required and be in force on any such exchange, whether by virtue of determination by that exchange or by order of the SEC or any other governmental authority having jurisdiction; d. There shall have occurred (1) an outbreak or escalation of hostilities or the declaration by the United States of a national emergency or war or (2) any other calamity or crisis in the financial markets of the United States or elsewhere or the escalation of such calamity or crisis;
e. Except as disclosed in or contemplated by the Official Statement, any material adverse change in the affairs of the City or the Community Facilities District shall have occurred;

2. The introduction, proposal or enactment of any amendment to the federal or California Constitution or any action by any federal or State court, legislative body, regulatory body or other authority materially adversely affecting the tax status of the City or the EXHIBIT 3
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11 Community Facilities District, their property, income, securities (or interest thereon), the validity or enforceability of the Special Tax;

3. Any event occurring or information becoming known which, in the judgment of the Underwriter, makes untrue or incorrect in any material respect any statement or information contained in the Preliminary Official Statement or in the Official Statement or has the effect that the Preliminary Official Statement or the Official Statement contains any untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading;

4. A general banking moratorium shall have been declared by federal, State of New York or State of California officials authorized to do so or a material disruption in securities settlement, payment or clearance services affecting the Bonds shall have occurred;

5. The imposition by the New York Stock Exchange or other national Securities exchange, or any governmental authority, of any material restrictions not now in force with respect to the Bonds or obligations of the general character of the Bonds or Securities generally, or the material increase of any such restrictions now in force, including those relating to the extension of credit by, or the charge to the net capital requirements of, the Underwriter;

6. A decision by a court of the United States of America shall be rendered, or a stop order, release, regulation or no -action letter by or on behalf of the Securities and Exchange Commission or any other governmental agency having jurisdiction of the subject matter shall have been issued or made, to the effect that the issuance, offering or sale of the Bonds as contemplated by this Purchase Agreement or by the Official Statement, or any document relating to the issuance, offering or sale of the Bonds is or would be in violation of any provision of the federal securities laws at the Closing Date, including the Securities Act of 1933, the Securities Exchange Act of 1934 and the Trust Indenture Act of 1939;

7. Any amendment is made to the Official Statement that in the Underwriter’s reasonable judgment will materially adversely affect the marketability of the Bonds or the ability of the Underwriter to enforce contracts for the sale of the Bonds;

8. Any proceeding shall have been commenced or be threatened in writing by the Securities and Exchange Commission against the City or the Community Facilities District.

9. The commencement of an Action described in Section 2(H).

Upon the occurrence of a Termination Event and the termination of this Purchase Agreement by the Underwriter, all obligations of the City, the Community Facilities District, and the Underwriter under this Agreement shall terminate, without further liability, except that the City and the Underwriter shall pay their respective expenses as set forth in Section 6 below.

E. At or prior to the Closing Date, the Underwriter shall have received a counterpart original or certified copy of the following documents, in each case satisfactory in form and substance to the Underwriter:

1. Official Statement. The Official Statement and each supplement or amendment, if any thereto, executed by an authorized officer of the City; EXHIBIT 3
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12 2. Fiscal Agent Agreement . The Fiscal Agent Agreement, duly executed and delivered by the City and the Fiscal Agent;

3. Resolutions. Certifications by the City Clerk with respect to each resolution and ordinance of the City Council, for the City or as the legislative body of the Community Facilities District, relating to the City Documents, the transactions contemplated thereby, formation of the Community Facilities District and issuance of the Bonds;

4. City Continuing Disclosure Certificate . The City Continuing Disclosure Certificate executed and delivered by the City;

5. Bond Counsel Opinion . An unqualified approving opinion for the Bonds, dated the Closing Date and addressed to the City, of Bond Counsel, to the effect that the Bonds are the valid, legal and binding obligations of the City and that the interest thereon is excluded from gross income for federal income tax purposes and exempt from personal income taxes of the State, in substantially the form included as Appendix E to the Official Statement, together with a letter of Bond Counsel, dated the Closing Date and addressed to the Underwriter and Trustee, to the effect that such opinion addressed to the City may be relied upon by the Underwriter and Trustee to the same extent as if such opinion was addressed to them;

6. Supplemental Opinion. A supplemental opinion or opinions, dated the Closing Date and addressed to the Underwriter, of Bond Counsel, to the effect that:
(i) this Purchase Agreement has been duly authorized, executed and delivered by the City and, assuming due authorization, execution and delivery by the other parties thereto, constitutes the legal, valid and binding agreement of the City and is enforceable in accordance with its terms, except to the extent that enforceability may be limited by moratorium, bankruptcy, reorganization, insolvency or other similar laws affecting creditors’ rights generally or by the exercise of judicial discretion in accordance with general principles of equity or otherwise in appropriate cases and by limitations on legal remedies against public agencies in the State; (ii) the Bonds are not subject to the registration requirements of the Securities Act of 1933, as amended, and the Fiscal Agent Agreement is exempt from qualification under the Trust Indenture Act of 1939, as amended; and

(iii) the information contained in the Official Statement on the cover and under the captions “THE BONDS,” “SECURITY FOR THE BONDS,” “TAX MATTERS” and in Appendices C and E to the Official Statement (excluding any financial, statistical and economic data, forecasts, numbers, charts, graphs, estimates, projections, and assumptions and any information regarding The Depository Trust Company and the book -entry system as to which Bond Counsel need express no opinion or view, and further, excluding any material that may be treated as included under such captions by cross -reference), are accurate insofar as such statements purport to summarize certain provisions of the Bonds, the Fiscal Agent Agreement, Bond Counsel’s final approving opinion and the Act; and

7. City Attorney Opinion . An opinion, dated the Closing Date and addressed to the Underwriter, of the City Attorney to the City and counsel to the Community Facilities District, substantially in the form of Appendix B hereto; EXHIBIT 3
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13 8. Closing Certificate of the City . A certificate, dated the Closing Date, and signed by an authorized officer of the City substantially in the form of Appendix C hereto, together with such additional certifications as Bond Counsel may require;

9. Bank Incumbency Certificate . Certified copies of the general resolution of the Fiscal Agent authorizing the execution and delivery of certain documents by certain officers of the Fiscal Agent, which resolution authorizes the execution of the Fiscal Agent Agreement and the authentication of the Bonds;

10. Fiscal Agent’s Certificate. A certificate of the Fiscal Agent, dated the Closing Date, in form and substance acceptable to the Underwriter and its counsel, substantially in the form of Appendix D hereto;

11. Fiscal Agent’s Counsel Opinion. An opinion of counsel to the Fiscal Agent, dated the Closing Date, addressed to the Underwriter and the City, substantially in the form of Appendix E hereto;

12. Disclosure Counsel Opinion. A letter of Jones Hall, A Professional Law Corporation, as disclosure counsel to the City (“ Disclosure Counsel”), dated the Closing Date and addressed to the Underwriter and the City, to the effect that without passing upon or assuming any responsibility for the accuracy, completeness or fairness of the statements contained in the Preliminary Official Statement and the Final Official Statement and making no representation that they have independently verified the accuracy, completeness or fairness of any such statements, based upon the information made available to them in the course of their participation in the preparation of the Final Official Statement, nothing has come to such counsel's attention which would lead them to believe that the Preliminary Official Statement , as of its date and the date of the Purchase Agreement, and the Final Official Statement , as of its date and as of the Closing Date (but excluding therefrom the appendices thereto, financial statements and statistical data, and information regarding The Depository Trust Company and its book entry system, as to which no opinion need be expressed), contained an untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading;

13. Opinion of Underwriter’s Counsel . An opinion of Kutak Rock LLP, counsel to the Underwriter (“ Underwriter’s Counsel”), dated the date of the Closing, addressed to the Underwriter, in form and substance acceptable to the Underwriter;

14. Special Tax Consultant Certificate . A certificate, dated the Closing Date from DTA substantially in the form attached as Appendix F hereto;

15. Transcript. A transcript of all proceedings relating to the authorization, issuance, sale and delivery of the Bonds, including certified copies of the Fiscal Agent Agreement and all resolutions of the City and the Community Facilities District relating thereto;

16. Nonarbitrage Certificate. A certificate of the City, dated the Closing Date, in a form acceptable to Bond Counsel and the Underwriter, that the Bonds are not arbitrage bonds within the meaning of Section 148 of the Internal Revenue Code of 1986, as amended;

17. Specimen Bonds. Copies of the Specimen Bonds;
EXHIBIT 3
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14 18. Form 8038-G. An Information Return for Tax -Exempt Bond Issues (Internal Revenue Service Form 8038-G), in a form satisfactory to Bond Counsel for filing, executed by a duly authorized officer of the City, together with evidence that such Form 8038 -G has been mailed;

19. CDIAC Statements. Copies of filings with the California Debt and Investment Advisory Commission (“CDIAC”) relating to the issuance of the Bonds;

20. Letter of Representations . A copy of the Blanket Letter of Representations to DTC relating to the Bonds signed by the City;

21. Certificates Regarding Preliminary Official Statement. Prior to and in connection with printing and distribution of the Preliminary Official Statement, (i) an executed certificate of the City deeming the Preliminary Official Statement final within the meaning of the Rule, (ii) an executed certificate of Eight Mile Development, Inc. (the “ Master Developer ”), substantially in the form under Appendix G hereto and (iii) an executed certificate of Lennar Homes of California, LLC (“Lennar Homes”), substantially in the form under Appendix G hereto.

22. Lennar Homes Continuing Disclosure Certificate. An executed copy of the Lennar Homes Continuing Disclosure Certificate in substantially the form included as an appendix to the Official Statement.

23. Master Developer and Lennar Homes Bring-Down Certificates. An executed bring-down certificate from each of the Master Developer and Lennar Homes, each dated as of the Closing Date, in the form set forth in Appendix H hereto.

24. Master Developer Opinion . The opinions of counsel to the Master Developer substantially in the form set forth in Appendix I hereto, addressed to the City and the Underwriter.

25. Lennar Homes’ Counsel Opinion. The opinion of counsel to Lennar Homes, dated the Closing Date and addressed to the City and the Underwriter , in form and substance acceptable to the City and Underwriter.

26. Appraiser Closing Certificate. A certificate in form and substance as set forth in Appendix J hereto of Integra Realty Resources - Sacramento, the appraiser of the property within Improvement Area 3 of the Community Facilities District, dated as of the Closing Date.

27. Additional Documents . Such additional legal opinions, certificates, instruments and other documents as the Underwriter may reasonably request to evidence the truth and accuracy, as of the date hereof and as of the Closing Date, of the material representations and warranties of the City, on its own behalf and on behalf of the Community Facilities District, contained herein, and of the statements and information contained in the Official Statement and the due performance or satisfaction by the City at or prior to the Closing of all agreements then to be performed and all conditions then to be satisfied by the City and the Community Facilities District in connection with the transactions contemplated hereby and by the Fiscal Agent Agreement and the Official Statement.

If the City shall be unable to satisfy the conditions to the obligations of the Underwriter to purchase, accept delivery of and pay for the Bonds contained in this Purchase Agreement, or if the EXHIBIT 3
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15 obligations of the Underwriter to purchase, accept delivery of and pay for the Bonds shall be terminated for any reason permitted by this Purchase Agreement, this Purchase Agreement shall terminate and neither the City nor the Underwriter shall be under any further obligation hereunder, except that the respective obligations of the Underwriter and the City set forth in Section 6 hereof shall continue in full force and effect.

4. Representations and Agreements of the Underwriter. The Underwriter represents to and agrees with the City that, as of the date hereof and as of the date of the Closing:

A. The Underwriter is duly authorized to execute and deliver this Purchase Agreement and to take any action under the Purchase Agreement required to be taken by it.

B. The Underwriter is in compliance with MSRB Rule G- 37 with respect to the City and the Community Facilities District, and is not prohibited thereby from acting as underwriter with respect to securities of the City and the Community Facilities District. The Underwriter is in compliance with MSRB Rule G-17 with respect to the City and the Community Facilities District.

C. The Underwriter has, and has had, no financial advisory relationship with the City or the Community Facilities District with respect to the Bonds, and no investment firm controlling, controlled by or under common control with the Underwriter has or has had any such financial advisory relationship, within the meaning of California Government Code Section 53590, or otherwise.

D. The Underwriter has not paid or agreed to pay, nor will it pay or agree to pay, any entity, company, firm or person (including, but not limited to, the City’s financial consultants, or any officer, agent or employee thereof), other than a bona fide officer, agent or employee working for the Underwriter, any compensation, fee, gift or other consideration contingent upon or resulting from the award of or entering into this Purchase Agreement.

E. The Underwriter has reasonably determined that the City’s undertaking in the City Continuing Disclosure Certificate to provide continuing disclosure with respect to the Bonds is sufficient to effect compliance with the Rule.

5. Establishment of Issue Price.

A. The Underwriter agrees to assist the City in establishing the issue price of the Bonds and shall execute and deliver to the City at Closing an “issue price” or similar certificate, together with the supporting pricing wires or equivalent communications, substantially in the form attached hereto as Appendix K, with such modifications as may be appropriate or necessary, in the reasonable judgment of the Underwriter, the City and Bond Counsel (as defined herein), to accurately reflect, as applicable, the sales price or prices or the initial offering price or prices to the public of the Bonds.

B. Except as otherwise set forth in Appendix A attached hereto, the City will treat the first price at which 10% of each maturity of the Bonds (the “10% test ”) is sold to the public as the issue price of that maturity. At or promptly after the execution of this Purchase Agreement, the Underwriter shall report to the City the price or prices at which it has sold to the public each maturity of Bonds. If at that time the 10% test has not been satisfied as to any maturity of the Bonds, the Underwriter agrees to promptly report to the City the prices at which it sells the unsold Bonds of that maturity to the public. That reporting obligation shall continue, whether or not the Closing Date EXHIBIT 3
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16 has occurred, until either (i) the Underwriter has sold all Bonds of that maturity or (ii) the 10% test has been satisfied as to the Bonds of that maturity, provided that, the Underwriter’s reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the City or Bond Counsel. For purposes of this Section, if Bonds mature on the same date but have different interest rates, each separate CUSIP number within that maturity will be treated as a separate maturity of the Bonds.

C. The Underwriter confirms that it has offered the Bonds to the public on or before the date of this Purchase Agreement at the offering price or prices (the “ initial offering price”), or at the corresponding yield or yields, set forth in Appendix A attached hereto, except as otherwise set forth therein. Appendix A also sets forth, as of the date of this Purchase Agreement, the maturities, if any, of the Bonds for which the Underwriter represents that (i) the 10% test has been satisfied (assuming orders are confirmed by the close of the business day immediately following the date of this Purchase Agreement) and (ii) the 10% test has not been satisfied and for which the City and the Underwriter agree that the restrictions set forth in the next sentence shall apply, which will allow the City to treat the initial offering price to the public of each such maturity as of the sale date as the issue price of that maturity (the “hold-the-offering-price rule”). So long as the hold-the-offering-price rule remains applicable to any maturity of the Bonds, the Underwriter will neither offer nor sell unsold Bonds of that maturity to any person at a price that is higher than the initial offering price to the public during the period starting on the sale date and ending on the earlier of the following:
a. the close of the fifth (5th) business day after the sale date; or b. the date on which the Underwriter has sold at least 10% of that maturity of the Bonds to the public at a price that is no higher than the initial offering price to the public.

The Underwriter will advise the City promptly after the close of the fifth (5th) business day after the sale date whether it has sold 10% of that maturity of the Bonds to the public at a price that is no higher than the initial offering price to the public.

D. The Underwriter confirms that:
(i) any selling group agreement and any third-party distribution agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer who is a member of the selling group and each broker-dealer that is a party to such third-party distribution agreement, as applicable:
(A)(i) to report the prices at which it sells to the public the unsold Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Bonds of that maturity allocated to it have been sold or it is notified by the Underwriter that the 10% test has been satisfied as to the Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be reasonable periodic intervals or otherwise upon request of the Underwriter and (ii) to comply with the hold -the-offering-price rule, if applicable, if and for so long as directed by the Underwriter,
(B) to promptly notify the Underwriter of any sales of Bonds that, to its knowledge, are made to a purchaser who is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below), and EXHIBIT 3
493

17 (C) to acknowledge that, unless otherwise advised by the dealer or broker -dealer, the Underwriter shall assume that each order submitted by the dealer or broker -dealer is a sale to the public.
(ii) any selling group agreement relating to the initial sale of the Bonds to the public, together with the related pricing wires, contains or will contain language obligating each dealer that is a party to a third-party distribution agreement to be employed in connection with the initial sale of the Bonds to the public to require each broker-dealer that is a party to such third -party distribution agreement to (A) report the prices at which it sells to the public the unsold Bonds of each maturity allocated to it, whether or not the Closing Date has occurred, until either all Bonds of that maturity allocated to it have been sold or it is notified by the Underwriter or the dealer that the 10% test has been satisfied as to the Bonds of that maturity, provided that, the reporting obligation after the Closing Date may be at reasonable periodic intervals or otherwise upon request of the Underwriter or the dealer, and (B) comply with the hold -the-offering-price rule, if applicable, if and for so long as directed by the Underwriter or the dealer and as set forth in the related pricing wires.

E. The City acknowledges that, in making the representation set forth in this section, the Underwriter will rely on (i) in the event a selling group has been created in connection with the initial sale of the Bonds to the public, the agreement of each dealer who is a member of the selling group to comply with the requirements for establishing issue price of the Bonds, including, but not limited to, its agreement to comply with the hold- the-offering-price rule, if applicable to the Bonds, as set forth in a selling group agreement and the related pricing wires, and (ii) in the event that a third- party distribution agreement was employed in connection with the initial sale of the Bonds to the public, the agreement of each broker -dealer that is a party to such agreement to comply with the requirements for establishing issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the-offering-price rule, if applicable to the Bonds, as set forth in the third-party distribution agreement and the related pricing wires. The City further acknowledges that the Underwriter shall not be liable for the failure of any dealer who is a member of a selling group, or of any broker -dealer that is a party to a third -party distribution agreement, to comply with its corresponding agreement to comply with the requirements for establishing issue price of the Bonds, including, but not limited to, its agreement to comply with the hold -the-offering-price rule, if applicable to the Bonds.

F. The Underwriter acknowledges that sales of any Bonds to any person that is a related party to an underwriter participating in the initial sale of the Bonds to the public (each such term being used as defined below) shall not constitute sales to the public for purposes of this section.

Further, for purposes of this section:
a. “public” means any person other than an underwriter or a related party;
b. “underwriter” means (A) any person that agrees pursuant to a written contract with the City (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the public and (B) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (A) to participate in the initial sale of the Bonds to the public (including a member of a selling group or a party to a third -party distribution agreement participating in the initial sale of the Bonds to the public);
EXHIBIT 3
494

18 c. a purchaser of any of the Bonds is a “related party” to an underwriter if the underwriter and the purchaser are subject, directly or indirectly, to (A) more than 50% common ownership of the voting power or the total value of their stock, if both entities are corporations (including direct ownership by one corporation of another), (B) more than 50% common ownership of their capital interests or profits interests, if both entities are partnerships (including direct ownership by one partnership of another), or (C) more than 50% common ownership of the value of the outstanding stock of the corporation or the capital interests or profit interests of the partnership, as applicable, if one entity is a corporation and the other entity is a partnership (including direct ownership of the applicable stock or interests by one entity of the other); and
d. “sale date” means the date of execution of this Purchase Agreement by all parties.

6. Expenses.

A. Whether or not the Underwriter accepts delivery of and pays for the Bonds as set forth herein, it shall be under no obligation to pay, and the City shall pay out of the proceeds of the Bonds or any other legally available funds of the City, all expenses incidental to the performance of the City’s obligations hereunder, including but not limited to the cost of printing and delivering the Bonds to the Underwriter; the costs of printing and shipping the Preliminary Official Statement and the Official Statement; the fees and disbursements of the City, the Community Facilities District, the Fiscal Agent, Bond Counsel, Disclosure Counsel, accountants and any other experts or consultants retained by the City or the Community Facilities District in connection with the issuance and sale of the Bonds; and any other expenses not specifically enumerated in paragraph (B) of this Section incurred in connection with the issuance and sale of the Bonds.

B. Whether or not the Bonds are delivered to the Underwriter as set forth herein, the City shall be under no obligation to pay, and the Underwriter shall be responsible for and pay, CUSIP
® and CDIAC fees and expenses to qualify the Bonds for sale under any “blue sky” laws; the fees and disbursements of Underwriter’s Counsel; and all other expenses incurred by the Underwriter in connection with its public offering and distribution of the Bonds not specifically enumerated in paragraph (A) of this Section.

7. Notices. Any notice of other communication to be given to the City under this Purchase Agreement may be given by delivering the same in writing to the City of Stockton, 425 North El Dorado Street, Stockton, California 95202, Attention: Chief Financial Officer; any notice or other communication to be given to the Underwriter under this Purchase Agreement may be given by delivering the same in writing to Oppenheimer & Co. Inc., 135 Main Street, Suite 1700, San Francisco, California 94105, Attention: Municipal Capital Markets Group . All such notices, requests or other communications may be made by telephone, personal or courier delivery, registered or certified mail, facsimile transmission or electronic communication, provided that delivery by facsimile transmission or electronic communication must be confirmed by the sender. The City and the Underwriter may, by notice given as aforesaid, specify a different address for any such notices, requests or other communications.

8. Parties In Interest . This Purchase Agreement is made solely for the benefit of the City and the Underwriter (including any successors or assignees of the Underwriter) and no other person shall acquire or have any right hereunder or by virtue hereof. The City and the Underwriter EXHIBIT 3
495

19 may not assign this Purchase Agreement. The term “successor” shall not include any holder of any Bonds merely by virtue of such holding.

9. Survival of Representations and Warranties. The representations and warranties of the City under this Purchase Agreement shall not be deemed to have been discharged, satisfied or otherwise rendered void by reason of the Closing and regardless of any investigations made by or on behalf of the Underwriter (or statements as to the results of such investigations) concerning such representations and statements of the City or the Community Facilities District and regardless of delivery of and payment for the Bonds.

10. Severability. If any provision of this Purchase Agreement is, or is held or deemed to be, invalid, inoperative or unenforceable as applied in any particular case in any jurisdiction or jurisdictions, because it conflicts with any provisions of any constitution, statute, rule of public policy or for any other reason, such circumstances shall not make the provision in question invalid, inoperative or unenforceable in any other case or circumstance, or make any other provision or provisions of this Agreement invalid, inoperative or unenforceable to any extent whatsoever.

11. Execution in Counterparts. This Purchase Agreement may be executed by the parties hereto in separate counterparts, each of which when so executed and delivered shall be an original, but all such counterparts shall together constitute but one and the same instrument.

12. Effective. This Purchase Agreement shall become effective and binding upon the respective parties hereto upon the execution of the acceptance hereof by the City and shall be valid and enforceable as of the time of such acceptance.

13. No Prior Agreements . This Purchase Agreement supersedes and replaces all prior negotiations, agreements and understanding between the parties hereto in relation to the sale of the Bonds by the City.

14. Governing Law. This Purchase Agreement shall be governed by the laws of the State.

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

EXHIBIT 3
496

S-1

15. Effective Date. This Purchase Agreement shall become effective and binding upon the respective parties hereto upon the execution of the acceptance hereof by the City and shall be valid and enforceable as of the time of such acceptance.

Very truly yours,
OPPENHEIMER & CO. INC.

By:

Its: Authorized Officer
The foregoing is hereby agreed to and
accepted as of the date first above written:

CITY OF STOCKTON
By:

Authorized Representative

Time of Execution: _____________ p.m. California time

[EXECUTION PAGE OF BOND PURCHASE AGREEMENT – IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON COMMUNITY FACILITIES DISTRICT NO. 2018-2 (WESTLAKE VILLAGES II), SPECIAL TAX BONDS, SERIES 2024)] EXHIBIT 3
497

A-1

APPENDIX A
$________
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

MATURITY SCHEDULE
Maturity
(September 1)
Principal
Amount
Interest
Rate Yield Price
10% Test
Satisfied*
10% Test
Not
Satisfied
Subject to
Hold-The-
Offering-
Price Rule
2024
2025
2026
2027
2028
2029
2030
2031
2032
20__(T)
20__(T)
20__(T)
_________________________________
(T) Term Bond.
* At the time of execution of this Purchase Agreement and assuming orders are confirmed by the close of the business day immediately following the date of this Purchase Agreement.

EXHIBIT 3
498

B-1

APPENDIX B

OPINION OF CITY ATTORNEY
[Closing Date]
City of Stockton
425 North El Dorado Street
Stockton, California 9520
Oppenheimer & Co. Inc.
135 Main Street, Suite 1700
San Francisco, California 94105

Re: $ ________ Improvement Area 3 of the City of Stockton Community Facilities District No. 2018-2 (Westlake Villages II), Special Tax Bonds, Series 2024 Ladies and Gentlemen:

We have acted as City Attorney for the City of Stockton (the “City”) and counsel for Improvement Area 3 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) (the “Community Facilities District”), in connection with the purchase and sale of the Improvement Area 3 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II), Special Tax Bonds, Series 2024 (the “Bonds”). As such Counsel, we have reviewed the Bond Purchase Agreement, dated [BPA Date] (the “Purchase Agreement”), by and between Oppenheimer & Co. Inc. (the “Underwriter”) and the City, the Fiscal Agent Agreement, dated as of April 1, 2024 (the “Fiscal Agent Agreement”), by and between the City and U.S. Bank Trust Company, National Association, as fiscal agent (the “Fiscal Agent”), the City Continuing Disclosure Certificate, dated [Closing Date] executed by the City (the “City Continuing Disclosure Certificate”), the Preliminary Official Statement, dated [POS Date], relating to the Bonds (the “Preliminary Official Statement”), the Official Statement, dated [BPA Date], relating to the Bonds (the “Official Statement”), Resolution No. ________ adopted by the City Council of the City on _______, 2024 (“Bond Resolution”), and such other documents, certificates, records and papers as we have deemed necessary to render the below opinions.

The Bonds, Fiscal Agent Agreement, Purchase Agreement, and the City Continuing Disclosure Certificate, are collectively referred to herein as the “Bond Documents.” Capitalized terms used herein and not otherwise defined shall have the meanings assigned to them in the Purchase Agreement.

With your permission we have assumed, without undertaking to verify the same by independent investigation, the following: (a) the authenticity of original documents and the genuineness of all signatures (other than those of the City and the Community Facilities District); (b) the conformity to the originals of all documents submitted to us as copies; (c) the truth, accuracy, and completeness of the information, representations, and warranties contained in these documents, certificates, records and papers we have reviewed; and (d) compliance with all covenants and agreements contained in such documents.

Based on the foregoing, and in reliance thereon, as of the date hereof, we are of the following opinions:

EXHIBIT 3
499

B-2

1. The City is a municipal corporation and charter city duly organized and validly existing pursuant to the Constitution and laws of the State of California;

2. The Community Facilities District is duly organized and validly existing as a community facilities district under the Constitution and laws of the State;

3. The Bond Resolution was duly adopted at a meeting of the City Council, which meeting was duly called and held pursuant to law and with all public notice required by law and at which a quorum was present and acting throughout;

4. The preparation and distribution of the Preliminary Official Statement and the Official Statement have been duly approved by the City Council, acting for itself or as the Legislative Body of the Community Facilities District;

5. The execution and delivery by the City of the Bond Documents, and the Bonds and the performance of its obligations thereunder have been duly authorized by all requisite action of the City Council, acting for itself or as the Legislative Body of the Community Facilities District, and the Bonds and the Bond Documents have been duly executed and delivered by the City, and constitute legal, valid and binding obligations of the City enforceable against the City, in accordance with their respective terms, subject to bankruptcy, insolvency, reorganization, moratorium and other laws affecting the enforcement of creditors’ rights in general and to the application of equitable principles if equitable remedies are sought;

6. To the best of our knowledge, no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, regulatory agency, public board or body is pending or to the best of such counsel’s knowledge, threatened in any way affecting the existence of the City or the Community Facilities District or the titles of the officers of each to their respective offices, or seeking to restrain or to enjoin the execution and delivery of the Bond Documents, or the issuance, sale or delivery of the Bonds or the application of the proceeds thereof or the collection or application of the Special Tax, or the exclusion from gross income for State personal income taxes of interest on the Bonds, or in any way contesting or affecting the validity or enforceability of the Bonds, the Bond Documents or any action of the City or the Community Facilities District contemplated by any of said documents or in any way contesting the completeness or accuracy of the Preliminary Official Statement or the Official Statement or the powers of the City or its authority with respect to the Purchase Agreement or any other applicable agreement, or any action on the part of the City or the Community Facilities District contemplated by any of said documents;

7. To the best of our knowledge, the City and the Community Facilities District are not in breach of or in default under any court or administrative decree or order, or under any loan agreement, note, resolution, indenture, contract, agreement or other instrument to which the City or the Community Facilities District is a party or is otherwise subject or bound, including the Bond Documents, a consequence of which could be to materially and adversely affect the ability of the City or the Community Facilities District to perform their obligations under the Bonds, the Bond Documents or which, with the passage of time or the giving of notice or both, would constitute an event of default thereunder; and;

8. To the best of our knowledge, the adoption of the Bond Resolution and the execution and delivery of the Bonds and the Bond Documents, did not and will not conflict with or constitute a breach of or default under any applicable court or administrative decree or order, or under any loan EXHIBIT 3
500

B-3
agreement, note, ordinance, resolution, indenture, contract, agreement or other instrument to which the City or the Community Facilities District, as the case may be, is a party or is otherwise subject or bound, a consequence of which could be to materially and adversely affect the ability of City or the Community Facilities District to perform their obligations under the Bonds or any Bond Documents.

The opinions set forth above are subject to the following additional qualifications:

General principles of equity, regardless of whether such enforceability is considered in a proceeding in equity or at law; and limitations imposed by bankruptcy, insolvency, fraudulent conveyance, receivership, conservatorship, reorganization, arrangement, liquidation, moratorium or other similar laws affecting the enforcement of creditors’ rights in general heretofore or hereafter enacted, as such laws may be applied in the event of bankruptcy, insolvency, reorganization, arrangement, receivership, conservatorship, liquidation, readjustment of debt or other similar proceedings of, or moratorium or similar occurrence affecting municipal corporations in the State.

We express no opinion as to matters governing by laws other than the laws of the State and the federal laws of the United States of America, or the enforceability of any choice of law provision in the documents described herein.

This opinion is solely for your benefit in connection with the transactions covered by the first paragraph of this letter and may not be relied upon or used by, circulated, quoted or referred to, nor may copies hereof be delivered to, any other person or for any other purpose without our prior written approval; provided, however, copies of this opinion may be included in the closing transcripts for the transactions connected with the issuance of the Bonds. We disclaim any obligation to update this opinion letter for events occurring or coming to our attention after the date hereof.

Respectfully submitted,

EXHIBIT 3
501

C-1

APPENDIX C

IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

CLOSING CERTIFICATE OF THE CITY
I, the undersigned, hereby certify that I am the Chief Financial Officer of the City of Stockton (the “City”), the City Council (the “City Council”) of which is the Legislative Body for Improvement Area 3 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) (the “Community Facilities District”), a community facilities district duly organized and existing under the laws of the State of California (the “State”) and I am authorized to execute this Certificate on behalf of the City in connection with the issuance of the above -captioned bonds (the “Bonds”). All capitalized terms herein not otherwise defined shall have the meanings given such terms in the Bond Purchase Agreement (the “Bond Purchase Agreement”), dated [BPA Date], by and between the City and Oppenheimer & Co. Inc.

I further certify on behalf of the City that:
(i) The representations, warranties and covenants of the City contained in the Bond Purchase Agreement, made on behalf of the City and the Community Facilities District, are true and correct in all material respects on and as of the date hereof as if made on the date hereof; (ii) The Community Facilities District Resolutions, Formation Documents and the City Documents are in full force and effect and have not been amended, modified or supplemented; (iii) Except as described in the Official Statement, there is no action, suit, proceeding, inquiry or investigation at law or in equity, or by any court or regulatory agency, public board or body pending, with respect to which the City or the Community Facilities District has been served with process, or to the best knowledge of the City or the Community Facilities District, threatened wherein an unfavorable decision, ruling or finding would: (a) affect the creation, organization, existence or powers of the City or the Community Facilities District, or the titles of their officers to their respective offices, (b) enjoin or restrain the issuance, sale and delivery of the Bonds, the levy or collection of the Special Tax or any other moneys or property pledged or to be pledged under the Fiscal Agent Agreement, or the pledge thereof, (c) in any way question or affect any of the rights, powers, duties or obligations of the City or the Community Facilities District with respect to the Special Taxes or moneys and assets pledged or to be pledged to pay the principal of, premium, if any, or interest on the Bonds, (d) in any way question or affect any authority for the issuance of the Bonds, or the validity or enforceability of the Bonds or the proceedings relating to the issuance of the Bonds, or (e) in any way question or affect the Bond Purchase Agreement or the transactions contemplated thereby, the Official Statement or the City Documents; (iv) The information in the Preliminary Official Statement (other than statements pertaining to DTC and it book -entry system and under the headings “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3” and contained in APPENDIX G– DTC AND THE BOOK- ENTRY ONLY SYSTEM,” as to which no view is expressed) as of its date was and as of the date hereof is, and in the Official Statement (other than EXHIBIT 3
502

C-2
statements pertaining to DTC and its book -entry system and under the headings “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3” and contained in APPENDIX G– DTC AND THE BOOK- ENTRY ONLY SYSTEM,”” as to which no view is expressed) as of its date was and as of the date hereof is, true and correct in all material respects and does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading;
(v) The City has complied with all agreements and covenants, and satisfied all conditions, on its part to be complied with or satisfied under the Bond Purchase Agreement and under the Community Facilities District Resolutions, the Formation Documents, the City Documents and the Official Statement at or prior to the date hereof; (vi) No event has occurred since the date of the Official Statement which either makes untrue or incorrect in any material respect as of the date hereof any statement or information contained in the Preliminary Official Statement or the Official Statement (other than statements pertaining to DTC and its book -entry system and under the headings “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3” and contained in Appendix G–DTC and the Book -Entry Only System,” as to which no view is expressed) or is not reflected in the Official Statement but should be reflected therein in order to make the statements and information therein not misleading in any material respect; (vii) The use of and distribution by the Underwriter of the Preliminary Official Statement and the Official Statement in connection with the offer and sale of the Bonds is hereby ratified; and (viii) The City and the Community Facilities District are each in compliance with all covenants set forth in the Fiscal Agent Agreement.

IN WITNESS WHEREOF, the undersigned has executed this certificate as of the date set forth below.

Dated: [Closing Date] CITY OF STOCKTON
By:

Chief Financial Officer

EXHIBIT 3
503

D-1

APPENDIX D
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024
FISCAL AGENT’S CERTIFICATE
The undersigned is an authorized officer of U.S. Bank Trust Company, National Association (the “Bank”), and as such, is familiar with the facts herein certified and is authorized and qualified to state and certify the following:
(i) The Bank is duly organized and existing as a national banking association under the laws of the United States of America, having the full power and authority to accept and perform its duties under a Fiscal Agent Agreement, dated as of April 1, 2024 (the “Fiscal Agent Agreement”), by and between the City and U.S. Bank Trust Company, National Association, as fiscal agent. Capitalized terms used herein and not otherwise defined have the meanings given to such terms in the Bond Purchase Agreement, dated [BPA Date], by and between the City and Oppenheimer & Co. Inc.;
(ii) Pursuant to the Fiscal Agent Agreement, the Bank will apply the proceeds from the Bonds to the purposes specified in the Fiscal Agent Agreement; (iii) The Bank is duly authorized to accept the obligations created by the Fiscal Agent Agreement and to authenticate the Bonds pursuant to the terms of the Fiscal Agent Agreement;
(iv) The Fiscal Agent Agreement has been duly authorized, executed and delivered by the Bank and, assuming due authorization, execution and delivery thereof by the other parties thereto, constitutes a valid and binding agreement of the Bank enforceable against the Bank in accordance with its terms;
(v) The Bonds have been validly authenticated and delivered by the Bank pursuant to the Fiscal Agent Agreement;
(vi) No consent, approval, authorization or other action by any governmental or regulatory authority having jurisdiction over the Bank that has not been obtained is or will be required for the authentication of the Bonds or the consummation by the Bank of the other transactions contemplated to be performed by the Bank in connection with the authentication of the Bonds and the acceptance and performance of the obligations created by the Fiscal Agent Agreement;
(vii) There is no action, suit, proceeding, inquiry or investigation, at law or in equity, before or by any court, regulatory agency, public board or body that has been served on the Bank or, to the best of its knowledge, threatened in any way affecting the existence of the Bank, or seeking to restrain or to enjoin the execution and delivery of the Fiscal Agent Agreement or the authentication of the Bonds, by the Bank, or in any way contesting or affecting the validity or enforceability, as against the Bank, of the Fiscal Agent Agreement or any action of the Bank EXHIBIT 3
504

D-2
contemplated by any of said documents, or in which an adverse outcome would materially and adversely affect the ability of the Bank to perform its obligations under the Fiscal Agent Agreement; (viii) The Bank is not in breach of or in default under any applicable law or administrative rule or regulation of the State of California (the “State”) or the United States of America, or of any department, division, agency or instrumentality of either thereof, or under any applicable court or administrative decree or order, or under any loan agreement, note, resolution, indenture, contract, agreement or other instrument to which the Bank is a party or is otherwise subject or bound, a consequence of which could be to materially and adversely affect the ability of the Bank to perform its obligations under the Fiscal Agent Agreement ( provided, however, that the Bank does not certify as to compliance with State or federal securities laws); and (ix) The authentication of the Bonds, and the execution and delivery of the Fiscal Agent Agreement by the Bank, and compliance with the provisions of each, will not conflict with or constitute a breach of or default under any applicable law or administrative rule or regulation of the State or the United States of America, or of any department, division, agency or instrumentality of either thereof, or under any applicable court or administrative decree or order, or under any loan agreement, note, ordinance, resolution, indenture, contract, agreement or other instrument to which the Bank is a party or is otherwise subject or bound, a consequence of which could be to materially and adversely affect the ability of the Bank to perform its obligations under the Fiscal Agent Agreement.

Dated: [Closing Date] U.S. BANK TRUST COMPANY, NATIONAL

ASSOCIATION
as Fiscal Agent
By:

Authorized Officer

EXHIBIT 3
505

E-1

APPENDIX E
FISCAL AGENT’S COUNSEL OPINION
[Closing Date]

Oppenheimer & Co. Inc.
135 Main Street, Suite 1700
San Francisco, California 94105
City of Stockton
425 North El Dorado Street
Stockton, California 95202
Re: Improvement Area 3 of the City of Stockton Community Facilities District No. 2018-2 (Westlake Villages II), Special Tax Bonds, Series 2024 Ladies and Gentlemen:

We have acted as counsel for U.S. Bank Trust Company , National Association, a national banking association (the “Bank”) in connection with the execution by the Bank of a Fiscal Agent Agreement, dated as of April 1, 2024 (the “Fiscal Agent Agreement”), by and between the City and U.S. Bank Trust Company, National Association, as fiscal agent (the “Fiscal Agent”). We are generally familiar with the Articles of Association and the Bylaws of the Bank and are also familiar with the corporate proceedings of the Bank with regard to its authorization, execution and delivery of the Fiscal Agent Agreement. Capitalized terms used herein shall have the respective meanings ascribed to them in the Fiscal Agent Agreement, except as otherwise defined herein.

We have examined such documents and have reviewed such questions of law as we have considered necessary and appropriate for the purposes of this opinion. In such review, we have assumed the genuineness of all signatures, the authenticity of all documents submitted to us as originals, and the conformity with originals of all documents submitted to us as copies. Where questions of fact material to our opinions expressed below were not established independently, we have relied upon statements of officers of the Bank as contained in their certificates.

Based upon the foregoing, we are of the opinion that:

1. The Bank is a national banking association duly organized, validly existing and in good standing under the laws of the United States of America.

2. The Bank has all requisite corporate power, authority and legal right to execute and deliver the Fiscal Agent Agreement and to perform its duties and obligations under the Fiscal Agent Agreement, and has taken all necessary corporate action to authorize the execution and delivery thereof and the performance of its obligations thereunder, including the authentication and delivery of the Bonds in its capacity as fiscal agent under the Fiscal Agent Agreement.

EXHIBIT 3
506

E-2

3. The Bank has duly authorized, executed and delivered the Fiscal Agent Agreement. Assuming the due authorization, execution and delivery thereof by the other parties thereto, the Fiscal Agent Agreement is a legal, valid and binding agreement of the Bank, enforceable in accordance with its terms against the Bank.

4. To our knowledge, no authorization, approval, consent, or order of any governmental agency or regulatory authority having jurisdiction over the Bank that has not been obtained by the Bank is required for the authorization, execution and delivery by the Bank of the Fiscal Agent Agreement or the authentication and delivery of the Bonds by the Bank under the Fiscal Agent Agreement.

The opinions set forth above are subject to the following qualifications and exceptions:
(a) the opinions are subject to the effect of any applicable bankruptcy, insolvency, fraudulent transfer, reorganization, moratorium or other similar laws of general application affecting creditors' rights; and
(b) the opinions are subject to the effect of general principles of equity, including (without limitation) concepts of materiality, reasonableness, good faith and fair dealing, and other similar doctrines affecting the enforceability of agreements generally (regardless of whether considered in a proceeding in equity or at law).

Our opinions expressed above are limited to the laws of the State of California and the federal laws of the United States of America.

The foregoing opinions are being furnished to you solely for your benefit and may not be relied upon by, nor may copies be delivered to, any other person without our prior written consent.

Very truly yours,

EXHIBIT 3
507

F-1

APPENDIX F

IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

CERTIFICATE OF SPECIAL TAX CONSULTANT
The undersigned hereby states and certifies:

1. That he is an authorized officer of DTA (the “Special Tax Consultant”) and as such is familiar with the facts herein certified and is authorized and qualified to certify the same.

2. That the Special Tax Consultant has prepared the Rate and Method of Apportionment of Special Tax (the “Rate and Method”) for Improvement Area 3 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) (the “Community Facilities District”) as set forth in Appendix A to the Official Statement for the above -captioned bonds (the “Bonds”) dated [BPA Date]. Capitalized terms not otherwise defined herein shall be defined as provided in the Rate and Method or the Fiscal Agent Agreement, dated as of April 1, 2024 (the “Fiscal Agent Agreement”), by and between the City and U.S. Bank Trust Company, National Association, as fiscal agent (the “Fiscal Agent”).

3. That the Special Tax, if levied in accordance with the Rate and Method and collected will annually yield sufficient revenue to make timely payments of the annual debt service on the Bonds, and annual Administrative Expenses related to the levy and collection of the Special Tax and the expenses of the Fiscal Agent for the Bonds (no representation is made as to the actual amounts that will be collected in future years).

4. That the Maximum Annual Special Tax, if collected in the maximum amounts permitted pursuant to the Rate and Method on the Closing Date, would generate at least 110% of the Annual Debt Service payable with respect to the Bonds payable from such Special Tax plus estimated Administrative Expenses equal to a maximum of $______ for Fiscal Year 202 3-24, assuming the debt service schedule shown in the Official Statement is true and correct.

5. That all information supplied by the Special Tax Consultant for use in the Official Statement is true and correct, as of the date of the Official Statement and as of the date hereof.

6. That, as of the dates of the Preliminary Official Statement and the Official Statement and as of the date hereof, the information contained in the portion of the Official Statement entitled “SECURITY FOR THE BONDS,” and “APPENDIX A,” including all tables and maps sourced to the Special Tax Consultant, and the other data provided by the Special Tax Consultant and included in the Official Statement, do not, to our knowledge, contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made therein, in light of the circumstances under which they were made, not misleading.

EXHIBIT 3
508

F-2

7. The Community Facilities District, the City, the Underwriter, Oppenheimer & Co.

Inc., and all the professionals involved in the financing are entitled to rely on this Certificate.

Dated: [Closing Date] DTA
By:

Title:

EXHIBIT 3
509

G-1

APPENDIX G
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESSTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

CERTIFICATE OF
[EIGHT MILE DEVELOPMENT, INC.] [LENNAR HOMES OF CALIFORNIA, LLC] [POS Date]

City of Stockton
Community Facilities District No. 2018-2 (Westlake Villages II) 425 North El Dorado Street
Stockton, California 95202

Oppenheimer & Co. Inc.
135 Main Street, Suite 1700
San Francisco, California 94105
Reference is made to Improvement Area No. 3 of the City of Stockton Community Facilities District No. 2018-2 (Westlake Villages II) Special Tax Bonds, Series 202 4 (the “Bonds”) and to the Bond Purchase Agreement (the “Bond Purchase Agreement”) to be entered into by and between the City, on behalf of itself and as the legislative body of the City of Stockton Community Facilities District No. 2018 -2 1 (Westlake Villages II) (the “ Community Facilities District ”), and Oppenheimer & Co. Inc., as underwriter (the “ Underwriter”). This Certificate of [ Eight Mile Development, Inc.] [Lennar Homes of California, LLC] (the “ Certificate”) is delivered pursuant to and in satisfaction of Section 3(E)(21) of the Bond Purchase Agreement. Capitalized terms used herein and not otherwise defined have the meanings ascribed to them in the Bond Purchase Agreement.

As used in this Certificate, the phrase “Actual Knowledge of the Undersigned” means, as of the date of this Certificate, the actual knowledge (as opposed to constructive) that the undersigned currently has or has obtained through (i) interviews with such current officers and responsible employees of the Property Owner as the undersigned has reasonably determined are likely, in the ordinary course of their respective duties, to have knowledge of the matters set forth in this Certificate, and/or (ii) review of documents reasonably available to the undersigned and which the undersigned reasonably deemed necessary for the undersigned to execute this Certificate. The undersigned has not conducted any extraordinary inspection or inquiry other than such inspections or inquiries as are prudent and customary in connection with the ordinary course of the Property Owner’s current business and operations. The undersigned has not contacted individuals who are no longer employed by the Property Owner.

As used in this Certificate, the term “ Relevant Entity” means, with respect to the Property Owner , any other Person (i) who directly, or indirectly through one or more intermediaries, is currently controlling, controlled by or under common control with the Property Owner , and (ii) for whom information, including financial information or operating data, concerning such EXHIBIT 3
510

G-2
Person is material to an evaluation of the Bonds (i.e. such person or entity’s assets or funds would materially affect the Property Owner ’s ability to develop the Property (defined below) as described in the Preliminary Official Statement or to pay its Special Taxes on the Property to the extent the responsibility of the Property Owner) prior to delinquency) . As used in this Certificate, the term “Person” means an individual, a corporation, a partnership, a limited liability company, an association, a joint stock company, a trust, any unincorporated organization or a government or political subdivision thereof. For purposes hereof, the term “ control” (including the terms “controlling,” “controlled by ” or “under common control with”) means the possession, direct or indirect, of the power to direct or cause the direction of the management and policies of a Person, whether through the ownership of voting securities, by contract or otherwise.

As used in this Certificate, the term “ Property” means the real property currently owned by the Property Owner within Improvement Area 3 (the “Improvement Area”) of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) (the “ Community Facilities District”), as further described in the Preliminary Official Statement.

The undersigned certifies that he or she is familiar with the facts herein certified and is authorized and qualified to certify the same as an authorized officer or representative of [ Eight Mile Development, Inc., a California corporation] [Lennar Homes of California, LLC, a California limited liability company] (the “Property Owner”), and the undersigned, on behalf of the Property Owner, further certifies as follows:
(1) The Property Owner is duly organized and validly existing under the laws of the State of California, and has all requisite corporate right, power and authority:
(i) to execute and deliver this Certificate;
(ii) to own and develop the Property, as described in the Preliminary Official Statement;
(iii) [LENNAR ONLY: to execute and deliver the Property Owner Continuing Disclosure Certificate at Closing;
(iv) to perform its obligations under the Property Owner Continuing Disclosure Certificate]; and
(v) to carry on its business as described in the Preliminary Official Statement. (2) [LENNAR ONLY: The Property Owner agrees to execute at Closing the Property Owner Continuing Disclosure Certificate substantially in the form attached as an appendix to the Preliminary Official Statement, with such additional changes as may be agreed upon by the Underwriter, Bond Counsel and the Property Owner.] (3) [[LENNAR ONLY: Except as disclosed in the Preliminary Official Statement, to the Actual Knowledge of the Undersigned, the Property Owner is not aware of any material failures by it or any Relevant Entity to comply in all material respects with any previous continuing disclosure undertaking in a written certificate or agreement executed by it or its Relevant Entities to provide periodic continuing disclosure reports or notices of listed events with respect to community facilities districts or assessment districts in California within the past five years.]
EXHIBIT 3
511

G-3
(4) To the Actual Knowledge of the Undersigned, (a) the Property Owner and its Relevant Entities are not i n breach of or in default under any applicable judgment or decree or any loan agreement, line of credit, option agreement, development agreement, indenture, fiscal agent agreement, bond or note (collectively, the “Material Agreements”) to which the Property Owner or its Relevant Entities are a party or otherwise subject, which breach or default could reasonably be expected to materially and adversely affect the ability of the Property Owner:
(i) to own, develop and sell the Property, as described in the Preliminary Official Statement,
(ii) to pay Special Taxes on the Property (to the extent the responsibility of the Property Owner) prior to delinquency,
(iii) to carry on its business as described in the Preliminary Official Statement, or
(iv) [LENNAR ONLY: to perform its obligations under the Property Owner Continuing Disclosure Certificate.]
(5) Except as described in the Preliminary Official Statement, the Property Owner does not have any loans outstanding and unpaid and no lines of credit that are secured by the Property.
(6) Except as disclosed in the Preliminary Official Statement, to the Actual Knowledge of the Undersigned, neither the Property Owner nor any of its Relevant Entities is currently in default in, or, in the last five (5) years, has ever defaulted to any material extent in, the payment of special taxes or assessments in connection with the Community Facilities District or any other community facilities districts or assessment districts in California that resulted in a foreclosure action being commenced in a court of law against the delinquent Property Owner or Relevant Entity.
(7) Except as disclosed in the Preliminary Official Statement, to the Actual Knowledge of the Undersigned, there is no litigation, inquiry, investigation or administrative proceeding, by or before any court, regulatory agency, public board or body, pending against the Property Owner (with service of process to the Property Owner having been accomplished), or to the Actual Knowledge of the Undersigned, overtly threatened in writing against the Property Owner, or to the Actual Knowledge of the Undersigned, pending against any Relevant Entity (with service of process to such Relevant Entity having been accomplished), or to the Actual Knowledge of the Undersigned, overtly threatened in writing against any Relevant Entity, in each case which, if successful, could reasonably be expected to:
(i) materially and adversely affect the ability of the Property Owner to own, develop and sell the Property, as described in the Preliminary Official Statement, (ii) materially and adversely affect the ability of the Property Owner to pay Special Taxes on the Property (to the extent the responsibility of the Property Owner) prior to delinquency,
EXHIBIT 3
512

G-4
(iii) materially and adversely affect the ability of the Property Owner to carry on its business as described in the Preliminary Official Statement; (iv) [LENNAR ONLY: materially adversely affect the ability of the Property Owner to perform its obligations under the Property Owner Continuing Disclosure Certificate;]
(v) challenge, question the validity or enforceability of, or restrain or enjoin the performance of, the Special Taxes, the Bonds, the Resolution, the Fiscal Agent Agreement, [LENNAR ONLY: the Property Owner Continuing Disclosure Certificate] or the Bond Purchase Agreement; or
(vi) restrain or enjoin collection of Special Taxes or other sums to be pledged to pay the principal of and interest on the Bonds.
(8) Except as disclosed in the Preliminary Official Statement or in this Certificate:
(i) the Property Owner and, to the Actual Knowledge of the Undersigned, its Relevant Entities, are able to pay their respective bills as they become due; (ii) neither the Property Owner nor, to the Actual Knowledge of the Undersigned, any of its Relevant Entities, has filed for bankruptcy or been declared bankrupt in the last 10 years; and
(iii) to the Actual Knowledge of the Undersigned, there are no proceedings pending against the Property Owner (with service of process to the Property Owner having been accomplished) or overtly threatened in writing in which the Property Owner or any of its Relevant Entities may be adjudicated as bankrupt, become the debtor in a bankruptcy proceeding, be discharged from any or all of its respective debts or obligations, be granted an extension of time to pay its respective debts or obligations, or be granted a reorganization or readjustment of its respective debts or obligations.
(9) As of the date of the Preliminary Official Statement, to the Actual Knowledge of the Undersigned, the information contained therein solely with respect to the Property Owner, its Relevant Entities, the proposed development of the Property, ownership of the Property, the Property Owner’s development plan, the Property Owner’s financing plan, the Property Owner’s lenders (if any), and contractual arrangements of the Property Owner or any Relevant Entities (including, if material to the Property Owner’s development plan or the Property Owner’s financing plan, other loans of the Property Owner or such Relevant Entities) as set forth under the sections of the Preliminary Official Statement captioned [FOR MASTER DEVELOPER: “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3—Development Plan and Current Status,” “ — Development Agreement and Subdivision Agreement,” “ —The Master Developer,” and “ — Master Developer’s Financing Plan] [ LENNAR ONLY: “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3—Lennar Homes” and “CONTINUING DISCLOSURE —Lennar Homes ”] (excluding therefrom in all cases information regarding the Appraisal Report, market value ratio and annual special tax ratio, EXHIBIT 3
513

G-5
and information which is identified as having been provided by a source other than the Property Owner) is true and correct in all material respects, and did not contain any untrue statement of a material fact or omit to state any material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading.
(10) Except as disclosed in the Preliminary Official Statement, the Property Owner has not submitted an application for, nor received actual notice of, (i) the formation or authorization of any other assessment district or community facilities district that would include any portion of the Property, or (ii) the authorization or issuance of any debt secured by an assessment or another special tax to be levied on any portion of the Property, other than the Special Tax.
(11) Except as set forth in the Preliminary Official Statement, to the Actual Knowledge of the Undersigned, there are no claims, disputes, lawsuits, actions or contingent liabilities of or against the Property Owner or its Relevant Entities, or among, by or between the Property Owner and any contractors working on the development of the Property, which could reasonably be expected to materially and adversely affect:
(i) the ability of the Property Owner to own and develop the Property, as described in the Preliminary Official Statement;
(ii) the ability of the Property Owner to pay Special Taxes on the Property (to the extent the responsibility of the Property Owner) prior to delinquency; (iii) the ability of the Property Owner to carry on its business as described in the Preliminary Official Statement; or
(iv) [LENNAR ONLY: the ability of the Property Owner to perform its obligations under the Property Owner Continuing Disclosure Certificate.] (12) The Property Owner covenants that, while the Bonds or any refunding obligations related thereto are outstanding, the Property Owner will not bring any action, suit, proceeding, inquiry or investigation at law or in equity, before any court, regulatory agency, public board or body, that in any way:
(i) seeks to challenge or overturn the formation of the Community Facilities District;
(ii) seeks to challenge the adoption of the ordinance levying Special Taxes within Improvement Area 3 of the Community Facilities District; (iii) seeks to invalidate the Community Facilities District or any of the Bonds or any refunding obligations relating thereto; or
EXHIBIT 3
514

G-6
(iv) seeks to invalidate the special tax liens imposed under Section 3115.5 of the Streets and Highways Code based on recordation of the notices of special tax lien relating thereto.

The foregoing covenant shall not prevent the Property Owner in any way from bringing any other action, suit, proceeding, inquiry or investigation at law or in equity relating to the following:
(a) a claim that the Special Tax has not been levied in accordance with the Rate and Method;
(b) the application or use of the Special Taxes levied and collected; or (c) the enforcement of the obligations of the City or the Community Facilities District under the Fiscal Agent Agreement or any agreements among the Property Owner and it Relevant Entities, the City and/or the Community Facilities District or to which the Property Owner or its Relevant Entities is a party or beneficiary. (13) The Property Owner has received a copy of the Rate and Method containing the prepayment formula. The Property Owner acknowledges that any prepayment of the Special Taxes may only be made in accordance with the Rate and Method. (14) The Property Owner intends to comply with the provision of the Mello -Roos Community Facilities Act of 1982, as amended, relating to the Notice of Special Tax described in California Government Code Section 53341.5 in connection with the sale of the Property.
(15) Based upon its current development plans, including, without limitation, its current budget and subject to economic conditions and risks generally inherent in the development of real property, including, but not limited to, the risks described in the Preliminary Official Statement under the sections “SPECIAL RISK FACTORS” and “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3,” the Property Owner anticipates that it will have sufficient funds to develop and sell the Property as described in the Preliminary Official Statement and pay Special Taxes on the Property (to the extent the responsibility of the Property Owner) prior to delinquency.

However, no assurance can be given that sources of financing available to the Property Owner will be sufficient to complete the property development and home construction as currently anticipated and as described in the Preliminary Official Statement.

While the Property Owner has made such internal financing available in the past, there can be no assurance whatsoever of its willingness or ability to do so in the future. Neither the Property Owner nor any of its Relevant Entities has any legal obligation o f any kind to make any such funds available or to obtain loans. Other than pointing out the willingness of the Property Owner to provide internal financing in the past, the Property Owner has not represented in any way that it will do so in the future. If and to the extent that internal financing and home sales revenues are inadequate to pay the costs to complete the Property Owner’s planned development in the Community Facilities District and other financing by the Property Owner is not put into place, t here could be a shortfall in the funds required to EXHIBIT 3
515

G-7
complete the proposed development by the Property Owner and portions of the Property may not be developed.
(16) The Property Owner consents to the issuance of the Bonds. The Property Owner acknowledges and agrees that the proceeds of such Bonds will be used for the acquisition and construction of the improvements described in the Preliminary Official Statement. The Property Owner acknowledges that the costs to acquire and construct such improvements are estimates, and that any increase in costs in excess of the estimated costs relating to improvements will reduce the improvements which may be financed by the City, and neither the City, nor the Community Facilities District has any obligation to provide moneys to pay for any such costs.
(17) If between the date of this Certificate and the Closing Date, any event relating to or affecting such Property Owner, its Relevant Entities, or the ownership, development or sale of the Property shall occur of which the undersigned has actual knowledge and which the undersigned believes would cause the information under the sections of the Preliminary Official Statement indicated in Paragraph 9 hereof (and subject to the limitations and exclusions contained in Section 9 of this Certificate) to contain an untrue statement of a material fact or to omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, Property Owner shall notify the City and the Underwriter and if, in the opinion of counsel to the City or the Underwriter, such event requires the preparation and publication of a supplement or amendment to the Preliminary Official Statement, the Property Owner shall reasonably cooperate with the City in the preparation of an amendment or supplement to the Preliminary Official Statement in form and substance satisfactory to counsel to the City and to the Underwriter.
(18) T he Property Owner agrees to deliver a Bring-Down Certificate, dated the Closing Date, in substantially the form attached as Appendix H to the Bond Purchase Agreement. If any event related to or affecting the Property Owner, its Relevant Entities or the ownership, development or sale of the Property occurs, as a result of which it is necessary to modify the form of Bring -Down Certificate, the Property Owner agrees to deliver a t the time of issuance of the Bonds a new form of Bring -Down Certificate revised to reflect such event.
(19) The Property Owner acknowledges and agrees that:
(i) in connection with the purchase and sale of the Bonds under the Bond Purchase Agreement, and with the discussions, undertakings and procedures leading up to the consummation of the purchase and sale of the Bonds under the Bond Purchase Agreement, the Underwriter is and has been acting solely as principal and is not acting as the agent or fiduciary of the Property Owner; (ii) the Underwriter has not assumed a fiduciary responsibility in favor of the Property Owner with respect to (a) the offering of the Bonds contemplated hereby or the process leading thereto (whether or not the Underwriter, or any affiliate of the Underwriter, has advised or is currently advising the Property Owner on other matters), or (b) any other obligation to the Property Owner with respect to the offering contemplated by the Bond Purchase Agreement; and EXHIBIT 3
516

G-8
(iii) the Property Owner has consulted its own legal, financial and other advisors to the extent it has deemed appropriate in connection with the offering of the Bonds.
(20) On behalf of the Property Owner, I have reviewed the contents of this Certificate and consulted with counsel regarding the meaning of its contents. The Property Owner acknowledges and understands that a variety of state and federal laws, including but not limited to the Securities Act of 1933, as amended, and Rule 10b -5 promulgated under the Securities Exchange Act of 1934, as amended, may apply to the Property Owner, and that under some circumstances certification as to the matters set forth in this Certificate, without additional disclosures or other action, may not fully discharge all duties and obligations of the Property Owner under such laws.

[Remainder of Page Intentionally Left Blank; Signature Page Follows]

EXHIBIT 3
517

G-9
The undersigned has executed this Certificate solely in his or her capacity as an authorized officer or representative of Property Owner and he or she will have no personal liability arising from or relating to this Certificate. Any liability arising from or relating to this Certificate may only be asserted against the Property Owner.

[EIGHT MILE DEVELOPMENT, INC., a California
corporation] [LENNAR HOMES OF CALIFORNIA, LLC, a
California limited liability company]

By:___________________________________________
Name:_________________________________________
Title:_________________________________________

EXHIBIT 3
518

H-1

APPENDIX H

$________
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

BRING-DOWN CERTIFICATE OF
[EIGHT MILE DEVELOPMENT, INC.] [LENNAR HOMES OF CALIFORNIA, LLC]

[Closing Date]

City of Stockton
Community Facilities District No. 2018-2 (Westlake Villages II) 425 North El Dorado Street
Stockton, California 95202

Oppenheimer & Co. Inc.
135 Main Street, Suite 1700
San Francisco, California 94105
Reference is made to the Improvement Area No. 2 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) Special Tax Bonds, Series 202 4 (the “Bonds”) and to the Bond Purchase Agreement, dated [BPA Date] (the “Bond Purchase Agreement ”), entered in connection therewith. This Bring -Down Certificate of [ Eight Mile Development, Inc. ] [Lennar Homes of California, LLC ] (the “ Bring-Down Certificate”) is delivered by [ Eight Mile Development, Inc., a California corporation] [Lennar Homes of California, LLC, a California limited liability company ] (the “ Property Owner ”) pursuant to Section 3(E)(23) of the Bond Purchase Agreement. Capitalized terms used herein and not otherwise defined have the meanings ascribed to them in the Certificate of [Eight Mile Development, Inc.] [Lennar Homes of California, LLC] (the “Certificate”), dated [BPA Date] delivered by the Property Owner in connection with the distribution of the Preliminary Official Statement relating to the Bonds.

The undersigned certifies that he is familiar with the facts herein certified and is authorized and qualified to certify the same as an authorized officer or representative of the Property Owner, and the undersigned, on behalf of the Property Owner, further certifies as follows:
(1) The undersigned has received the final Official Statement relating to the Bonds, dated [BPA Date] (the “Final Official Statement”). Each statement made in the Certificate is affirmed and restated as if made on the date hereof; except that all references therein to the Preliminary Official Statement shall be deemed to be references to the Final Official Statement. (2) To the Actual Knowledge of the Undersigned, no event has occurred since the date of the Preliminary Official Statement that has, in any material way, adversely affected the statements and information described in Paragraph 9 of the Certificate (and subject to the limitations and exclusions contained in Paragraph 9 of the Certificate) relating to the Property Owner and its EXHIBIT 3
519

H-2
Relevant Entities, the Property, the Property Owner’s development and financing plans, and the Property Owner’s contractual arrangements (but excluding any information cited as coming from a source other than the Property Owner), which should be disclosed in the Final Official Statement for the purposes for which it is to be used in order to make such statements and information contained in the Final Official Statement not misleading in any material respect. (3) For a period of 25 days after the Closing Date, if the undersigned has actual knowledge of any event relating to or affecting the Property Owner, its Relevant Entities, or the ownership development or sale of the Property which could cause the information under the captions of the Final Official Statement indicated in Paragraph 9 of the Certificate (and subject to the limitations and exclusions contained in Paragraph 9 of the Certificate) to contain an untrue statement of a material fact or to omit to state a material fact necessary to make the statements therein, in the light of the circumstances under which they were made, not misleading, the Property Owner shall notify the City and the Underwriter and if, in the opinion of counsel to the City or the Underwriter, such event requires the preparation and publication of a supplement or amendment to the Final Official Statement, the Property Owner shall reasonably cooperate with the City in the preparation of an amendment or supplement to the Final Official Statement in form and substance satisfactory to counsel to the City and to the Underwriter.
(4) [LENNAR ONLY: The Property Owner has duly executed and delivered the Property Owner Continuing Disclosure Certificate.]

[Remainder of Page Intentionally Left Blank; Signature Page Follows]

EXHIBIT 3
520

H-3
The undersigned has executed this Bring -Down Certificate solely in his or her capacity as an authorized officer or representative of Property Owner and he or she will have no personal liability arising from or relating to this Bring -Down Certificate. Any liability arising from or relating to this Bring-Down Certificate may only be asserted against the Property Owner.

[EIGHT MILE DEVELOPMENT, INC., a _________
corporation] [LENNAR HOMES OF CALIFORNIA, LLC, a
California limited liability company]

By:___________________________________________
Name:_________________________________________
Title:_________________________________________

EXHIBIT 3
521

I-1

APPENDIX I

IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024
FORM OF PROPERTY OWNER’S COUNSEL OPINION
One or more letters of counsel to Eight Mile Development, Inc., a California corporation, (the "Property Owner"), which may be in -house counsel or an outside law firm engaged by the Property Owner in connection with the issuance of the Bonds, or both, collectively to the effect that:

No information came to the attention of the lawyers in such counsel’s firm or office rendering legal services in connection with its representation of the Property Owner that caused such counsel to believe that, as of the date of the Official Statement and as of the date of such letter, the information in the sections of the Preliminary Official Statement entitled “OWNERSHIP AND DEVELOPMENT OF PROPERTY WITHIN IMPROVEMENT AREA 3,” and “SPECIAL RISK FACTORS” concerning the Property Owner and its Relevant Entities, the Property, the Property Owner ’s development and financing plans, and the Property Owner’s contractual arrangements (but excluding any information cited as coming from a source other than the Property Owner ) (except that no belief is expressed as to (a) any financial statements and other financial, statistical, economic, or engineering data or forecasts, estimates, projections, assumptions, or expressions of opinion, or (b) any information about valuation, appraisals, market absorption, archaeological, or environmental matters), contained or contain any untrue statement of a material fact or omitted or omit to state a material fact necessary to make the statements therein, in light of the circumstances under which they were made, not misleading.

EXHIBIT 3
522

J-1

APPENDIX J

IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

CERTIFICATE OF APPRAISER
Integra Realty Resources - Sacramento (the “Appraiser”), Rocklin, California prepared an appraisal of the properties within Improvement Area 3 of the City of Stockton Community Facilities District No. 2018 -2 (Westlake Villages II) (the “Community Facilities District”) with an effective date of _________, 2023 (the “Appraisal”). The Appraisal is described and summarized in the Preliminary Official Statement dated [POS Date] (the “Preliminary Official Statement”) and the Official Statement dated [BPA Date] (the “Official Statement”), including as Appendix B thereto, relating to the bonds captioned above.

The Appraiser hereby certifies that, to the best of his knowledge and belief, all information with respect to the Appraisal in the Preliminary Official Statement and in the Official Statement was true and correct as of the date of the Appraisal and that the Appraiser is aware that acts and events may have occurred since the date of the Appraisal which could result in both positive and negative effects on market value; however, an updated Appraisal has not been completed as of this date.

The Appraiser hereby consents to the use of the Appraisal in connection with the distribution and use of the Preliminary Official Statement and Official Statement.

Dated: [Closing Date]

INTEGRA REALTY RESOURCES -

SACRAMENTO
By:

EXHIBIT 3
523

K-1

APPENDIX K

$_______
IMPROVEMENT AREA 3 OF THE CITY OF STOCKTON
COMMUNITY FACILITIES DISTRICT NO. 2018-2
(WESTLAKE VILLAGES II)
SPECIAL TAX BONDS, SERIES 2024

FORM OF ISSUE PRICE CERTIFICATE

The undersigned, on behalf of Oppenheimer & Co. Inc. (“Oppenheimer”) hereby certifies as set forth below with respect to the sale and issuance of the above -captioned obligations (the “Bonds”).

1. Sale of the Bonds.
(a) Oppenheimer offered each Maturity of the Bonds to the Public for purchase at the respective initial offering prices listed in Schedule A (the “Initial Offering Prices”) on or before the Sale Date. A copy of the pricing wire or equivalent communication for the Bonds is attached to this certificate as Schedule B.
(b) As set forth in the Bond Purchase Agreement, dated [BPA Date], between the Issuer and Oppenheimer, Oppenheimer agreed in writing that, (i) for each Maturity of the Bonds, it would neither offer nor sell any of the Bonds of such Maturity to any person at a price that is higher than the Initial Offering Price for such Maturity during the Holding Period for such Maturity (the “hold -the- offering-price rule”), and (ii) any selling group agreement shall contain the agreement of each dealer who is a member of the selling group, and any retail distribution agreement shall contain the agreement of each broker- dealer who is a party to the retail distribution agreement, to comply with the hold-the-offering-price rule. Pursuant to such agreement, no Underwriter (as defined below) has offered or sold any Maturity of the Bonds at a price that is higher than the respective Initial Offering Price for that Maturity of the Bonds during the Holding Period.

2. Defined Terms.
(a) Holding Period means, for each Maturity of the Bonds, the period starting on the Sale Date and ending on the earlier of (i) the close of the fifth business day after the Sale Date, or (ii) the date on which Oppenheimer has sold at least 10% of such Maturity of the Bonds to the Public at prices that are no higher than the Initial Offering Price for such Maturity. (b) Issuer means the City of Stockton.
(c) Maturity means Bonds with the same credit and payment terms. Bonds with different maturity dates, or Bonds with the same maturity date but different stated interest rates, are treated as separate Maturities.
(d) Public means any person (including an individual, trust, estate, partnership, association, company, or corporation) other than an Underwriter or a related party to an Underwriter.

EXHIBIT 3
524

K-2
The term “related party” for purposes of this certificate generally means any two or more persons who have greater than 50 percent common ownership, directly or indirectly. (e) Sale Date means the first day on which there is a binding contract in writing for the sale of a Maturity of the Bonds. The Sale Date of the Bonds is [BPA Date]. (f) Underwriter means (i) any person that agrees pursuant to a written contract with the Issuer (or with the lead underwriter to form an underwriting syndicate) to participate in the initial sale of the Bonds to the Public, and (ii) any person that agrees pursuant to a written contract directly or indirectly with a person described in clause (i) of this paragraph to participate in the initial sale of the Bonds to the Public (including a member of a selling group or a party to a retail distribution agreement participating in the initial sale of the Bonds to the Public).

The representations set forth in this certificate are limited to factual matters only. Nothing in this certificate represents Oppenheimer’s interpretation of any laws, including specifically Sections 103 and 148 of the Internal Revenue Code of 1986, as amended, and the Treasury Regulations thereunder. The undersigned understands that the foregoing information will be relied upon by the Issuer with respect to certain of the representations set forth in the Tax Certificate and with respect to compliance with the federal income tax rules affecting the Bonds, and by Jones Hall, A Professional Law Corporation, in connection with rendering its opinion that the interest on the Bonds is excluded from gross income for federal income tax purposes, the preparation of the Internal Revenue Service Form 8038-G, and other federal income tax advice that it may give to the Issuer from time to time relating to the Bonds.

OPPENHEIMER & CO. INC.

By:_______________________________________
Name:_____________________________________

Dated: [Closing Date]

EXHIBIT 3
525

SCHEDULE

SCHEDULE A

SALE PRICES
(Attached)
EXHIBIT 3
526

SCHEDULE

SCHEDULE B

PRICING WIRE OR EQUIVALENT COMMUNICATION

(Attached)

EXHIBIT 3
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Improvement Area 3
City of Stockton
Community Facilities District No. 2018-2
(Westlake Villages II)
Special Tax Bonds Series 2024
City Council Meeting
March 19, 2024
Agenda Item 15.2
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History of the District
 District Formation: June 2018
 Location: North Stockton, South of Eight Mile Road
and West of Highway 5
 Original Size: 580 Gross Acres
 Split off from CFD 2006-2 in 2018
 Original formation included Improvement Area 1
 Amended in February 2020 to split off a portion of
Improvement Area 1 into Improvement Area 2
 Amended in December 2021 to split off a portion of
Improvement Area 2 into Improvement Area 3 and
Improvement Area 4
 CFD 2018-2 planned for 2,163 residential units (277 units in Imp. Area 3), with a portion reserved for a 55+
retirement community
2 529
Improvement Area 3
 Special Taxes:
 Single-family residential with FY 2024-25 facilities tax rates ranging from $2,708 (<1,800 SF) to $3,747 (>3,000 SF)
annually.
 2% escalation of facilities tax
 City is able to recover administrative costs as part of the special taxes
 A services tax is also paid each year by property owners  Term of the Improvement Area 3 Facilities Tax:

Fiscal year 2071/72
 Bonds: Bonds approved up to $18.5 million for
Improvement Area 3
3 530
CFD 2018-2 Boundary Map
4 531
Special Tax Bonds, Series 2024
(Improvement Area 3)
 Maximum amount of bonds authorized $18.5 million
 Series 2024 Expected Issue Size: $13.96 million
 Series 2024: Not-To-Exceed Issue Size: $15.5 million
 Interest only on 9/1/24, 3/1/25 and 9/1/25
 Interest on 9/1/24 paid by capitalized interest
 Interest on 3/1/25 and 9/1/25 partially paid by capitalized interest  2026 debt service begins at $738k and increases at 2.00% annually to September 1, 2054
 1.10 times debt service coverage each year
 Estimated fixed costs of issuance of $275,000 plus underwriter’s compensation of $132,620 for “all-in” cost of $407,620
 Issuance planned as non-rated Public Offering
5 532
6Proposed Timeline
Timeline Item
March 19, 2024 City Council Consideration
Friday, March 22, 2024 Print and Post Preliminary Official Statement April 2 and April 3, 2024 Pre-Pricing and Pricing
April 17, 2024 Close the Transaction
533
Documents for Consideration
 Fiscal Agent Agreement: This agreement governs the
terms and conditions of the bonds and the role and
responsibilities of the Fiscal Agent.
 Preliminary Official Statement (Including Continuing
Disclosure Certificate): Will be distributed as the primary marketing document to prospective bond purchasers.
 The agenda packet includes the Preliminary Official
Statement deemed to be essentially final.
 A final version of this document, called the Final Official Statement, is estimated to be made available shortly after the bonds are sold and will reflect all the bond sale
information.
 The continuing disclosure certificate is part of the official statement and governs the terms and conditions of the City’s responsibility to disclose information to bondholders.
 Bond Purchase Agreement: Is a contract between the City and the Underwriter that provides the terms and
conditions under which the underwriter will purchase the Series 2024 Bonds.
7 534
Staff Recommendation
Adopt a Resolution authorizing
1) the issuance of special tax bonds for and on behalf
of Improvement Area 3 of the Community Facilities
District No. 2018-2 (Westlake Villages II),
2) approving and directing the execution of a fiscal
agent agreement,
3) approving the form of Preliminary Official
Statement,
4) approving sale of such bonds, and
5) approving other related documents and actions.
8 535
City of Stockton
Legislation Text
File #: 24-0163, Version: 1

ADOPT A MOTION TO ACCEPT AND APPROVE A REGIONAL HOMELESS ACTION PLAN AND

MEMORANDUM OF UNDERSTANDING FOR HOMELESS, HOUSING ASSISTANCE AND PREVENTION ROUND 5 APPLICATION

RECOMMENDATION
It is recommended that the City Council adopt a motion to:

1. Accept and approve the Regionally Coordinated Homelessness Action Plan for Round 5 of the Homeless Housing, Assistance and Prevention Grant (HHAP 5) grant program;

2. Authorize the City Manager to execute a Memorandum of Understanding with San Joaquin County and San Joaquin Continuum of Care; and

3. Authorize the City Manager, or designee, to take appropriate and necessary actions to carry out the purpose and intent of this motion.

Summary
The general purpose of Homeless Housing, Assistance and Prevention (HHAP) funding is to build regional coordination and a unified regional response to reduce and end homelessness, informed by a best-practices framework focused on moving homeless individuals and families into permanent housing and supporting the efforts of those individuals and families to maintain their permanent housing. HHAP 5 requires applicants to strategically pair HHAP 5 funds with other local, state, and federal resources toward long-term sustainability of housing and supportive services and to prioritize permanent housing solutions.

HHAP 5 differs from previous funding rounds in that it requires regions (i.e., the Continuum of Care, San Joaquin County, and the City of Stockton) to apply together and be signatory to a Regionally Coordinated Homelessness Action Plan. Funding allocations, though, may be received directly.

Applications and the Regionally Coordinated Homelessness Action Plan are due to the California Interagency Council on Homelessness (Cal ICH) on March 27, 2024.

On October 17, 2024, the City Council approved a Motion (Motion 2023-12-12-1203) authorizing staff to apply for, accept, and appropriate Round 5 of HHAP, and enter into a Standard Agreement for consulting services for a regionally coordinated homeless action plan to meet HHAP 5 application requirements.

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File #: 24-0163, Version: 1

DISCUSSION
Background
HHAP 5 is established for the purpose of organizing and deploying the full array of homelessness programs and resources comprehensively and effectively, and to sustain existing federal, state, and local investments toward long-term sustainability of housing and supportive services. To accomplish these goals, HHAP 5 requires applicants to: create and implement a Regionally Coordinated Homelessness Action Plan; develop data-driven plans which fund the state’s priorities and commit to spending funds to sustain existing investments towards long-term sustainability of housing and supportive services, with a focus on permanent housing solutions; and be a signatory to a Memorandum of Understanding (MOU) between each eligible applicant that is participating in the Regionally Coordinated Homelessness Action Plan.

On September 29, 2023, Cal ICH released the NOFA for Round 5 funding. Applications are due March 27, 2024.

The City’s funding allocation dollar amount under HHAP Round 5 was announced on January 14, 2024. The City’s allocation is $7,153,178.87 and is based on HUD certification of the 2023 Point in Time Count findings for all jurisdictions.

On October 17, 2024, the City Council approved a Motion (Attachment A - Motion 2023-12-12-1203) authorizing staff to apply for, accept, and appropriate Round 5 of HHAP. Council additionally approved findings pursuant to Stockton Municipal Code section 3.68.070, which supported an exception to the competitive bidding process, to enter into a Standard Agreement for consulting services for a Regionally Coordinated Homeless Action Plan to meet HHAP 5 application requirements.

Present Situation
The HHAP 5 regional and coordinated planning process included the following methods to garner community insight, assess needs and opportunities, and create coordinated and collaborative strategies to address homelessness:

Community Insight
· Key Stakeholder Interviews:
o 17 one-hour discussions with community and system leaders · Public Meetings
o January 11, 2024: 65 participants
o February 8, 2024: 23 participants
o March 7, 2024: 21 participants
· Focus Groups
o February 22, 2024: People with Lived Experience in Homelessness o February 23, 2024: Regional Housing Trust Fund (COG meeting) o February 26, 2024: Housing Justice Coalition
o March 5, 2024: Reinventing South Stockton Neighborhood Transformation City of Stockton Printed on 3/15/2024Page 2 of 4
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File #: 24-0163, Version: 1
· Community Survey
o Open for on-line submission: 2/21/24 through 2/28/24: 33 responses Assessment of Needs and Opportunities
· HMIS Data Dashboard, April 2021 - June 2022
· HDIS Data Review, Provided February 2024 by Cal-ICH
· PIT and HIC Data / Trend Analysis: as submitted to HUD · Homeless Revenues and Expenditure Analysis
o City of Stockton
o City of Lodi
o City of Tracy
o City of Manteca
o County of San Joaquin
o San Joaquin Continuum of Care
· Review of Written Reports and Meeting Minutes
o San Joaquin Cost of Homelessness Survey Summary Report 2023 o Unsheltered Encampment Outreach Study 2023
o City of Stockton’s Local Homeless Action Plan 2022
o San Joaquin Community Response to Homelessness 2020
o SJCoC Strategic Impact Report 2020-2021
o Point in Time Count (PIT) Trends and Analysis: Homelessness and Disparities in San Joaquin County 2022
o Various SJCoC Meeting Agendas and Minutes 2020 - 2023 Strategy Development
· Best Practices Review
o Housing and Urban Development (HUD) Establishing and Operating a Continuum of Care Program Guidelines, 2012
o Code of Federal Regulations, Continuum of Care Title 24, Chapter V Part 578, as updated 2017
o California State Housing Policy Chapter 6.5 (section 50231 - 50238) o Interview with Stanislaus County Continuum of Care: 2/27/2024 o Practice Review: Harris County CoC (Houston TX), Lane County CoC (Eugene, OR) and San Diego County CoC
· Four Funding Partner Planning Workshops
o January 30, 2024: Roles and Responsibilities
o February 12, 2024: Equity in System Performance Measures o February 20: 2024: Reducing Institutional Exits to Homelessness o February 26: 2024: Budget Planning
Review Process
· March 12, 2024: Draft Plan posted for Public Review
· March 14, 2024: Presentation to CoC Board
· March 19, 2024: Presentation to Stockton City Council · March 26, 2024: Presentation to County Board of Supervisors City of Stockton Printed on 3/15/2024Page 3 of 4
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File #: 24-0163, Version: 1
The Regionally Coordinated Homeless Action Plan (a draft including the MOU, which will be substantially similar to what is submitted to Cal ICH, has been included as Attachment A - Regionally Coordinated Homeless Action Plan and MOU) will be submitted as part of the regional application to Cal ICH on March 27, 2024.

FINANCIAL SUMMARY
There is no financial impact to the City's General Fund as a result of this action. HHAP 5 funding will be appropriated and budgeted in the Special Grant Fund in the Housing Division. The consultant contract will be supported with available HHAP 4 funds, and later reimbursed with HHAP 5 funds once received, as allowed by grant guidelines.

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ATTACHMENT A
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CONTENTS
I. Glossary of Terms ......................................................................................................... 2 II. Executive Summary ....................................................................................................... 5 III. Introduction ............................................................................................................... 12 Purpose of the Action Plan ....................................................................................................... 12 Guiding Vision .......................................................................................................................... 12 Regional Goals ......................................................................................................................... 13 Mission and Values .................................................................................................................. 13 Research Methods ................................................................................................................... 13 Limitations ............................................................................................................................... 14 Report Structure ...................................................................................................................... 14 IV. Landscape Analysis ..................................................................................................... 15 Background ............................................................................................................................. 15 Regional Homelessness ........................................................................................................... 15 The San Joaquin CoC ............................................................................................................... 16 Partnership Model .................................................................................................................... 16 Partner Roles and Responsibilities ........................................................................................... 17 Current Use of Funds ............................................................................................................... 18 Program and Service Utilization ................................................................................................ 22 V. System Performance Measures .................................................................................... 25 People Experiencing Homelessness ......................................................................................... 25 People Living Unsheltered in San Joaquin County ..................................................................... 26 Racial and Ethnic Disparities by Performance Measures .......................................................... 27 Gender Disparities by Performance Measures .......................................................................... 30 VI. Key Findings ............................................................................................................... 32 Community Service Needs ....................................................................................................... 32 Strengths .................................................................................................................................. 38 Challenges ............................................................................................................................... 40 VII. Application Tables ...................................................................................................... 45 Roles and Responsibilities (Table 2.1) ...................................................................................... 45 Key Actions to Improve Performance (Table 2.2) ....................................................................... 49

ATTACHMENT A
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Equity Improvement Plan (Table 2.3) ........................................................................................ 51 Improving Exits from Institutions (Table 2.4) ............................................................................. 52 Coordinated Use of Leveraged Resources (Table 2.5) ............................................................... 55 IX. Key Activities: Project Summaries ................................................................................. 56 Strengthen the Foundational Aspects of the SJCoC .................................................................. 56 Develop Regional Practice Expectations ................................................................................... 61 Refine Procurement, Contracting, and Monitoring .................................................................... 62 Improve Data Quality and Data Systems .................................................................................. 62 Invest in Staff, Training, and Expertise ...................................................................................... 63 Improve Coordination of Services ............................................................................................. 64 X. Funding and Implementation Plan ............................................................................... 67 Connections to Benefit Program (Table 2.6) .............................................................................. 67 Funding Priorities (Table 3.0) .................................................................................................... 67 Benchmarks of Success ........................................................................................................... 69 Declarations .............................................................................................................................. 70 XI. References ................................................................................................................. 71 XII. Appendices ................................................................................................................. 72

A. Key Stakeholder Interview Participants & Protocol
B. List of Public Meetings and Workshops
C. List of Planning Stakeholders
D. Meeting Presentations
E. Community Survey Findings
F. Memorandum of Understanding

ATTACHMENT A
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 2024 REGIONAL HOMELESS ACTION PLAN – EXECUTIVE SUMMARY

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I. GLOSSARY OF TERMS
211 211 is a three-digit phone number that provides access to a wide range of community services.

ArcGIS Geographic Information System
ARPA American Rescue Plan Act
BHS Behavioral Health Services
BIPOC Black, Indigenous, and People of Color
Block Grant Funds A type of federal grant provides state or local governments with a broad range of discretion over how the funds are allocated within a specific program area.

CAL-ICH California Interagency Council on Homelessness
CAO County Administer Office
CARE Program A homeless outreach co-response model pairing first responders with health and behavioral health professionals and people with lived experience.

CBO Community-Based Organizations
CDBG Community Development Block Grant
CDCR California Department of Corrections and Reentry
CES Coordinated Entry System
CoC Continuum of Care - Continuums of Care exist across the nation and are the designated recipients of certain federal homeless funds.

CoC Program Competition Process The competitive process through which funding is allocated to Continuum of Care (CoC) organizations by the U.S.

Department of Housing and Urban Development (HUD).

Collaborative Applicant The County of San Joaquin is defined as the Collaborative Applicant for HHAP 5, referring to the entity designated by the U.S. Department of Housing and Urban Development
(HUD) to submit a single application for Continuum of Care (CoC) funding on behalf of the entire homeless services system in a particular geographic area.

Collaborative Applicant Agreement A formal document that outlines the roles, responsibilities, and obligations of the entity designated as the Collaborative Applicant within a Continuum of Care (CoC) homeless
services system.

Congregate Housing Programs Shared living arrangements where individuals or families reside in a communal setting while having access to
supportive services.

Continuum of Care (CoC) A comprehensive approach to addressing homelessness within a community or region.

Coordinated Entry A centralized system designed to streamline and coordinate access to homeless services and resources for individuals and families experiencing homelessness.

COS City of Stockton
COVID-19 Coronavirus Disease 2019
CY Calendar Year
DCDC Delta Community Developers Corporation

ATTACHMENT A
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DV Domestic Violence
ECM Engagement, Case Management
ESG Emergency Solutions Grant
ESRI Environmental Systems Research Institute
EUCs Eligible Use Categories
FY Fiscal Year
Governance Charter A formal document that outlines the structure, responsibilities, and operating procedures of a governing body or organization.

HACSJ Housing Authority of San Joaquin County
HCS Healthcare Services
HDIS California's Homeless Data Integration System
HHAP Homeless Housing Assistance and Prevention
HHD Regional Homeless Housing Development
HIC Housing Inventory Count
High-Barrier Shelter A type of homeless shelter that imposes requirements or conditions for individuals seeking accommodation.

HIPAA Health Insurance Portability and Accountability Act HIV/AIDS Human Immunodeficiency Virus/ Acquired
Immunodeficiency Syndrome
HMIS Homeless Management Information System
HOME Funds Home Investment Partnership Program
Homekey California state grant program aimed at addressing homelessness and providing housing solutions during the COVID-19 pandemic.

Housing Density Refers to the number of housing units or people living within a given area of land.

HPSJ Health Plan of San Joaquin
HSA Human Services Agency
HUD Housing and Urban Development
Interim Housing Also known as transitional housing, providing temporary shelter and support services for individuals or families experiencing homelessness.

Landscape Analysis The process of assessing and evaluating the features, characteristics, and dynamics of a particular geographical area or system.

LGBTQIA+ Lesbian, Gay, Bisexual, Transgender, Queer/Questioning, Intersex, Asexual and other terms
Low-Barrier Shelter A type of homeless shelter that aims to provide accommodation to individuals experiencing homelessness
with minimal barriers to entry.

Lx A person from Latin American origin or descent.

Medi-Cal California's Medicaid Health Care Program
MCPs Managed Care Plans
MHSA Medical Health Services Act
MOU Memorandum of Understanding

ATTACHMENT A
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N Total number of individuals
N/A Not Applicable
NAACP National Association for the Advancement of Colored People
NOFA Notice of Funding Available
PATH Projects for Assistance in Transition from Homelessness Permanent Housing Long-term, stable housing solutions for individuals or families experiencing homelessness.

Permanent Supportive Housing (PSH) A housing intervention model designed to provide stable and affordable housing coupled with supportive services for individuals or families experiencing chronic homelessness, particularly those with disabilities or other complex needs.

PIT Point in Time - Annual PIT Counts are conducted across the nation, using a census model, to count homeless
individuals.

PLEE People with Lived Expertise and Experience
PLHA Funds Permanent Local Housing Allocation Program (state funding)
PTSD Post-Traumatic Stress Disorder
Region SJCoC’s HUD designated region is San Joaquin County RHNA Residential Housing Needs Allocation
RRH Rapid Rehousing
San Joaquin Council of Governments
(SJCOG)
San Joaquin County's regional transportation planning
agency.

SJC San Joaquin County
SJCHSA San Joaquin County Human Services Agency
SJCoC San Joaquin Continuum of Care
SMI Serious Mental Illnesses
STAND Stocktonians Taking Action to Neutralize Drugs
SUD Substance Use Disorders
TAY Transition Age Youth
Unincorporated Areas Regions within the county's jurisdiction that are not governed by any specific municipal government or
incorporated municipality.

UOP University of the Pacific
WKSHP Workshop
WPC Whole Person Care

ATTACHMENT A
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II. EXECUTIVE SUMMARY
Purpose: Through this Action Plan, the County of San Joaquin, the City of Stockton, and the San Joaquin County Continuum of Care commit to working jointly in a coordinated, regional fashion to make homelessness rare, brief, and non-recurring.

Intent: Through this Action Plan, the three partners express their intentions and the planned strategies to address homelessness through the articulation of specific roles and responsibilities, actions, and funding plans.

Invitation: The Cities of Lathrop, Lodi, Manteca, Ripon, and Tracy are hereby invited to adopt this Action Plan and join this partnership. As independent public entities, the San Joaquin County Office of Education, the Housing Authority of the County of San Joaquin, and the San Joaquin Council of Governments are also invited to join the partners in the work expressed within this Action Plan.

Key Findings: The region is well positioned to address homelessness, and significant achievements have been accomplished in the past few years, including a 40% increase in emergency shelter beds and approximately 180 new units of housing intended for homeless persons developed or in construction, with more pending. However, significant work remains in the areas of increasing transitions to housing, especially for people with specialized and acute needs such as substance use disorders and reducing duplications in services. Overcoming barriers and challenges will require a stronger emphasis on housing navigation and supportive services for people to maintain in placements successfully. Accordingly, this will require the three partners to ensure funds are allocated towards priorities, contracts are managed to ensure investments are leading to the desired results, and that contracted support, or technical assistance is available to continuum partners around operational issues, including data management, evaluation, training, and communications.

Roles and Responsibilities: The County of San Joaquin, in its role as the Collaborative Applicant, has the primary and lead agency responsibilities for operating the continuum. This means having the staff expertise and capacity to manage and coordinate the approximately $30 million in direct regional funds allocated annually to address homelessness and complete the reports, plans, evaluations, and monitoring required under federal and state regulations and in accordance with local needs and priorities. The leadership role of the Collaborative Applicant in leveraging the additional $100 million that passes through other public agencies for collaborative and assigned purposes is also essential.

The County of San Joaquin, in its role as the recipient of state and federal health, safety, and entitlement program funds, has an obligation through its Departmental Leadership to align and leverage all available funding to the purposes of this Action Plan and as permitted under regulation. The San Joaquin County Human Services Agency (HSA), Probation Department, and Behavioral Health Services (BHS) are called to participate in regular SJCoC Board of Directors Meetings, and to work with the Collaborative Applicant and other public agencies on the continued and strategic blending and braiding of efforts. Specifically, it is anticipated that:

 HSA will help ensure that homeless program partners across the region have the tools and communication pathways to link clients to eligible public assistance effectively;  Probation will help ensure that there is a coordinated and regional approach to outreach to unsheltered persons, using a co-responder model (the joint engagement of emergency services personnel, health/behavioral health professionals, and people with lived expertise and experience); and,
 BHS will help ensure that sufficient and consistent treatment support is available to sustain and maintain housing placements according to assessed needs and as necessary to obtain the highest level of self-sufficiency.

ATTACHMENT A
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The City of Stockton, in its role as the largest of the five incorporated cities, has the primary responsibility of working with municipal partners on crafting a shared approach to engaging and organizing their local communities. This includes developing a shared approach to homeless outreach and engagement, emergency sheltering, and the development of affordable housing suitable for people experiencing homelessness. It also includes developing program partner expectations around suitable competencies and ensuring local community partners, including people with lived expertise and experiences in homelessness, receive information, training, and capacity-building assistance as needed to improve the delivery of services.

The San Joaquin Continuum of Care (SJCoC), through its elected Board and broader General Membership, is responsible for the general oversight and stewardship of effort. The Board is responsible for monitoring the performance of its Collaborative Applicant in discharging its duties. Additionally, the Board is responsible for engaging and sustaining the broader General Membership of homeless service practitioners, community members, people with lived expertise and experience, and responsible professionals in informed dialogue and discussion about needs and opportunities to strengthen the homeless continuum of care.

The Collaborative Applicant looks to the guiding principles and directives of the SJCoC, applicable regulations, local priorities, and best practices in the dischargement of its operational management of required activities, including the procurement and operations of a functional Homeless Management Information System (HMIS) and Coordinated Entry System, overseeing the federal CoC Program Competition process, and the general operations of the continuum including establishing standards, monitoring sub- recipients, and conducting regular evaluations of the system as a whole to assess housing and service needs.

Performance Measures: Through this Action Plan, the County of San Joaquin, the City of Stockton, and the San Joaquin County Continuum of Care agree to the following regional and system-wide performance measures, as articulated in federal and state regulations, to assess homeless housing and service needs:

Homeless Housing
 Number of people accessing homeless services.
 Number of unsheltered homeless.
 Number of first-time homeless.

Service Needs
 Number of people successfully placed in interim or permanent housing from a street outreach or engagement program.
 Number of people exiting homelessness into permanent housing.  Average length of time homeless people experience homelessness.  Percent of people returning to homelessness after a placement.  Percent of people who make improvements in self-sufficiency, following placements, by severity of need.

And to measure and track the extent to which these measures are having equitable results across race/ethnicity, gender, age, vulnerabilities, and disability status as tracked by HUD for people with HIV/AIDS, chronic health conditions, substance use disorders, and serious mental illnesses.

Contract Management: Through this Action Plan, partners agree to embed within all contracts issued for direct program service activities provisions to track effort (work conducted), fidelity (adherence to practice standards), and outcomes (the extent to which performance measures are being achieved, including equity) by January 2025.

ATTACHMENT A
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Key Actions: Through this Action Plan, the County of San Joaquin, the City of Stockton, and the San Joaquin County Continuum of Care agree to undertake the following key actions to achieve regional and coordinated programmatic and systemic objectives.

By June 30, 2024:

1. Outsource, or otherwise assign to neutral third parties, the 2024 CoC Program Competition Process.

2. Develop a regional and coordinated list of homeless housing pipeline projects with quantifiable criteria such as units, feasibility, and funding plan, including other leveraged resources such as tax credits or supportive housing vouchers.

3. Confirm partner agreements to address key actions and assign additional tasks and activities.

Determine staff duties or procurement needs and assign the Collaborative Applicant to begin solicitations for technical assistance. Review Action Plan with County Counsel and other jurisdictions.

By September 30, 2024:

4. Revise the Collaborative Applicant Agreement to address identified deficiencies in roles and responsibilities and incorporate new local and state expectations.

5. Update the Governing Charter and Bylaws to address identified deficiencies in the Conflict-of- Interest Policies.

6. Update the Governance Charter and Bylaws to expand participation on the SJCoC Board, including fixed seats for city staff and department leaders and for more people with lived experiences in homelessness, including homeless youth and other populations overrepresented in homelessness.

7. Conduct the HUD-mandated review and updates to the SJCoC Board Nomination Process in accordance with regulations.

By December 31, 2024:

8. Update the SJCoC website. Release regular communications for community stakeholders and partners.

9. Standardize procurement process for (unobligated) HHAP-4 and HHAP-5 sub-grantee awards.  Develop a shared approach to measuring and prioritizing organizational capacity to address disparities as a component of application review.
 Develop shared contractor reporting requirements for demonstrating effort, fidelity, and outcomes, by program type.
 Develop shared contractor expectations for staff training, qualifications, and use of HMIS or CES to complete program activities.
 Release joint or aligned NOFAs and create a joint County/City review process using neutral third parties to reduce applicant burden.

10. Complete a comprehensive review of existing information systems to determine where they are working to enhance client-level coordination and collaboration, program management and monitoring, and system-wide assessments of performance measures, as well as where there are deficiencies based on regulations and Action Plan needs. Use recommendations to drive system improvements and increase validity and confidence in HMIS data.

11. Update and revise the Coordinated Entry System prioritization process. Prepare guidance and convene regional trainings to ensure consistent and effective use of the CES, including standardized assessment tools to triage needs and referrals.

ATTACHMENT A
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 Update procedures to prioritize people who have primarily been living unsheltered for the duration of their most recent episode of homelessness, regardless of occasional use of shelter services or recent linkage pending placement. (In accordance with Encampment Resolution Fund Initiative.)

12. Develop a regional CARE model. Create a regional co-response model and routine practices for coordinating activities across jurisdictions and departments. Develop regional practices and training protocols for teams.

13. Create a practice kit for housing navigators. Articulate best practices and expectations for local program partners. Create uniform expectations and protocols for housing navigators to ensure clients are document-ready and eligible for a range of public benefits and housing support services, including rapid re-housing rental assistance vouchers.

By June 30, 2025:

14. Complete a system-wide assessment of homeless housing and service needs as indicated by the selected performance measures and other key indicators. The assessment must include all relevant Federal and State initiatives, including but not limited to the CoC Program Competition, Emergency Solutions Grant (ESG), HHAP, and Homekey projects and activities.

15. Create regional screening and referral protocols to escalate case management and treatment for individuals likely to have serious mental illnesses or other disabling conditions that require specialty interventions. Disseminate model and train program partners responsible for hospital discharge, jail release, and street outreach.

16. Develop a Housing-focused shelter model. Standardize expectations for housing navigation and case management within interim housing programs. Standardize practices for other services and supports, including substance use treatment, medication monitoring, counseling services, peer support, and legal advocacy services. Embed the model into the procurement process.

17. Develop regional Rapid-Rehousing funding and practice expectations. Clarify the allocation and monitoring of funds for eligible purposes associated with short-term rental assistance and support for homeless individuals vs. people at risk of homelessness. Clarify expectations for wrap-around support services, case management and rapid re-housing. Clarify rules and policies for landlord incentives. Develop a regional tracking system for accounting and monitoring purposes. Embed model within any procurement processes.

18. Develop practice guidelines for other innovative and creative housing solutions, including master leasing and landlord incentives.

By December 31, 2025:

19. Develop shared accounting and contract monitoring protocols to prevent service duplication between the County of San Joaquin and City of Stockton-funded projects.

20. Provide routine updates to the SJCoC Board regarding the obligation and use of CoC Program Competition, Emergency Solutions Grant (ESG), HHAP, and Homekey program funds.

21. Provide routine updates to the SJCoC Board regarding unique clients served, by demographics, service utilization, and costs per client by service activity.

The Action Plan narrative contains the intent and justifications for the planned key actions in Sections V., VI., and VII.

The application includes Tables 2.2, 2.3, and 2.4, which further list key actions with timelines, funding sources, and responsibilities.

ATTACHMENT A
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Fund Allocations: Through this Action Plan, the County of San Joaquin, the City of Stockton, and the San Joaquin County Continuum of Care agree to the collective allocation of Homeless Housing Assistance and Prevention (HHAP) Round 5 funds as follows:

Proposed Eligible Uses Proposed County /
SJCoC Allocations
Proposed City of
Stockton Allocations
Permanent Housing At least 30% Up to 45%
Interim Housing – Shelter Operations At least 30% At least 30% Street Outreach and Service Coordination Up to 10% No funds allocated Systems Support Up to 20% At least 14%
Administration (7%) / HMIS (1%) 8% 8%
Total $6,914,426 $7,153,179
10% Youth Set-aside $ 691,443 $715,318

The Action Plan below includes further details articulating allocations by eligible use categories.

The partners further agree that unobligated HHAP Round 3 and Round 4 funds will also be released under the vision and spirit of this Action Plan and as promised under their respective and approved funding applications to the California Interagency Council on Homelessness (Cal-ICH).

The partners acknowledge the imperative of obligating the remainder of the County’s HHAP Round 3 funds by May 31, 2024, and through this Action Plan, state an intent to obligate funds as necessary for (a) systems support activities including Collaborative Applicant staffing and/or technical assistance needs as outlined in this Action Plan and to support the Key Actions described above; and (b) existing programs that are showing significant progress in using funds as planned to achieve goals and are at risk of stopping activities before other funds can be secured.

The Collaborative Applicant will make funding recommendations for unobligated County HHAP-3 funds and bring them to the SJCoC Board of Directors for discussion at the regularly scheduled Board meeting in April 2024 and ratification at the May 2024 SJCoC Board Meeting.

Authority for this Action Plan: This was developed under the collaborative management of the County of San Joaquin, the City of Stockton, and the San Joaquin County Continuum of Care. An independent consulting firm was contracted through a public purchase solicitation to conduct the public planning process, which included three public meetings and engaged a range of experts and subject matter professionals, including:

 People with lived experience of homelessness
 Youth with lived experience of homelessness
 Persons of populations overrepresented in homelessness  Local departmental leaders (County)
 Staff from local municipalities (other smaller jurisdictions)  Homeless service and housing providers
 Medi-Cal managed care plan partners
 Street medicine providers and other outreach partners

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The planning process also included a community survey, key informant interviews, strategy workshops, discussion groups, and analysis of expenditures and funded activities. The SJCoC Board reviewed and vetted all Planning Activities, and a shared management team of the three partners monitored them weekly.

Action Plan Term: This Action Plan will be implemented under a joint Memorandum of Understanding (MOU), entered into following plan review and approval by the SJCoC Board of Directors, the Stockton City Council, and the San Joaquin County Board of Supervisors, as of March 27, 2024, and continued until its termination on June 30, 2028, or modified or renewed.

Further evidence and details in support of this Action Plan are contained in the full Action Plan narrative.

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III. INTRODUCTION
Purpose of the Action Plan
San Joaquin County, the City of Stockton, and the San Joaquin Continuum of Care (SJCoC) work jointly to promote the coordinated and impactful delivery of homelessness supports and services across the full continuum of care. Through this Action Plan, the three partners commit to a coordinated regional approach to making homelessness rare, brief, and non-recurring.

This plan’s purpose is to lay out how the region will build, deploy, sustain, and strengthen actions across the full array of homelessness programs and resources, leveraging federal, state, and local investments. It builds upon and continues the vision and legacy of the community’s first strategic plan, A Community Response to Ending Homelessness. Five years later, it is time to update and advance our regional efforts and chart a continued path forward. We invite other local jurisdictions and community partners to join us.

Guiding Vision
Jointly, partners recognize the need for and are committed to fostering collaboration to further:

 A formal coordinated system that functions throughout the region,  A focus on solutions that can be measured and impactful, and  Significant investment in housing-focused services that increase successful transitions to long-term permanent housing.

This Action Plan is guided by the following vision statement, as developed through the 2019 community planning process:

We envision a future in which homelessness in San Joaquin County will be rare, brief, and nonrecurring, supported by a robust homeless crisis response system. People experiencing homelessness will be empowered through a responsive, nimble, housing- focused system that provides effective, supportive, and humane services and housing, efficiently leveraging public and private resources.

This plan articulates regional actions to promote this vision, which are intended to:

 Increase coordination, strengthen cross-system partnerships, and improve the quality and use of data;
 Maximize the effective use of resources to support improved implementation and outcomes at every point along the continuum of care;
 Address disparities that underlie inequitable provision of services and outcomes for Black, Native and Indigenous, Latinx, Asian, Pacific Islanders, and other sub-populations disproportionately impacted by homelessness; and
 Expand access to housing and supports delivered in a low-barrier, trauma-informed, and culturally responsive manner.

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Regional Goals
Goal 1: Establish a Coordinated and Engaged Regional System of Care.

Develop a fully coordinated and transparent system that can help obtain greater funding, identify shared priorities, and establish a formal coordinated entry system to identify, assess, and connect individuals to housing and services.

Goal 2: Increase Access and Reduce Barriers to Homeless Crisis Response Systems.

Engage unsheltered individuals, provide safe places to stay at night, and connect people to public benefits, services, and housing opportunities.

Goal 3: Ensure Households Experiencing Homelessness Have Access to Affordable and Sustainable Permanent Housing.

Invest in the creation, rehabilitation, and expansion of affordable housing options; and provide the support and tools necessary for people to maintain their housing and optimize their self-sufficiency successfully.

Mission and Values
The SJCoC provides leadership and effective stewardship of resources and facilitates community planning, design, and implementation of programs critical to preventing and ending homelessness in San Joaquin County.

 Our core values are collaboration, communication, and transparency.  We are committed to evidence-based programming and data-driven initiatives.

Research Methods
Rane Community Development led research activities for this 2024 Regional Homeless Action Plan. The mixed-method approach combined qualitative research, consisting of interviews, public meetings, focus groups, and a survey of community sentiments, with statistical analysis of various financial and programmatic data.

Key aspects of the research included:

 A thorough review of each entity’s financial resources, expenditures, and specific use of funds;  Quantitative analyses of data from the State of California’s Homeless Data Integration System (HDIS), the U.S. Housing and Urban Development’s (HUD’s) Homeless Management of Information System (HMIS), the SJCoC’s Point-in-Time (PIT) count, and local Housing Inventory Counts (HICs);  Systematic reviews of relevant reports and plans, including the 2022 San Joaquin County Cost of Homelessness Survey Summary Report (Amoroso-Pohl, 2023) and the Community Survey on Homelessness Needs & Resources Report. Shelter Health and Safety Project (Kiss, 2020), A Portrait of the Valley: San Joaquin Valley Human Development Report (Lewis, 2023), 2023 San Joaquin Continuum of Care Point in Time Count Local Report (Mendelson & Singh, 2023), The San Joaquin County Unsheltered Encampment Outreach Study (Birtwhistle, et al., 2023);

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 Collection and analysis of qualitative data obtained through interviews, focus groups, and workshops/public forums, all conducted to gather input from stakeholders, including individuals with lived experience in homelessness and people working to address homelessness and/or serve people experiencing homelessness (conducted January-February 2024 - Please see Appendix A for a comprehensive list of qualitative data collection events and participants);  Observation of PIT count interviews of ten people with lived experience (conducted on February 28, 2024, at St. Mary’s Community Services); and
 Analysis of a local community online survey regarding priorities for the elimination of disparity in homelessness across the region (conducted in February 2024, with 33 respondents, 67% of whom worked or volunteered at a homeless-serving organization or agency).

Information from the sources listed above informs the priorities and strategies described in this plan. The variety of datasets and analyses enable triangulation to ensure a comprehensive assessment of the region’s needs, strengths, and opportunities regarding homelessness.

Limitations
While every effort has been made to ensure that the analyses informing this plan are sound, the authors must acknowledge a few limitations, resulting from data that are incomplete and/or contain inaccuracies. For example, certain inconsistencies suggest that some of the HMIS data are not fully representative of activities that have taken place or the demographics of those served. The financial data was acquired from agency funders over two weeks and may include unintended revenue or expenditure inaccuracies due to the extremely brief reporting span. All expenditures were classified within Eligible Use Categories (ECUs) by financial and analytic staff and, due to the potential for overlapping uses, are subject to classification bias.

To mitigate inaccuracies, multiple team members monitored datasets and classification decisions.

Report Structure
This Introduction (Section I) is followed by a Landscape Analysis (Section II). The Regional Overview includes an overview of the region and its homeless systems, a description and demographic breakdown of the population experiencing homelessness in the region, disparities in experiences and outcomes, and an exploration of expenditures and utilization, including duplications and gaps.

Section III covers Key Findings from the various analyses, including community service needs, strengths, and challenges. Section IV details Recommendations deriving from the analyses, which center coordination and service delivery, land use and development, unsheltered outreach and encampment site coordination, interim housing, permanent housing development, performance measurement, racial and gender equity, housing linkages for people exiting institutions, and strategies to leverage resources to maximum effect.

Section V covers Implementation. Specifically, this section will lay out roles and responsibilities, system performance measures, and actions to improve performance, address equity, and reduce exits to homelessness from institutions. Section VI covers the Funding Recommendations, including suggestions for upcoming State Homeless Housing Assistance and Prevention programming allocations.

In the Appendices, readers will find a list of stakeholders involved in public discussions and workshops, copies of meeting presentations, and literature references.

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IV. LANDSCAPE ANALYSIS
Background
Located due east of the Bay Area, in the heart of California’s Central Valley, the San Joaquin region (the region) encompasses 1,426 square miles and has a population of approximately 800,000. Within the region are the City of Stockton, with a population of 320,000, and several smaller cities (Tracy, population: 89,000; Manteca, population: 77,000; Lodi, population: 65,000; Lathrop, population: 23,000; Ripon, population:
17,000; and Escalon, population: 7,200). The remaining approximately 200,000 county residents live in rural and unincorporated areas.

The California Department of Finance estimates the region will experience a 25% population explosion from 2020-2060 (State of CA Dept. of Finance, 2020). This substantial growth rate will require a corresponding expansion of infrastructure, including affordable housing and support for un-housed and under-housed populations. In recent years, the region has experienced significant population growth without a sufficient increase in housing, which has significantly driven up the cost of housing and exacerbated homelessness and housing insecurity.

Regional Homelessness
Homelessness figures for the region are available for 2016 through 2020 (HUD Exchange, 2022) and 2022 (Cheshire & Mendelson, 2022).[1] These data, displayed below in Chart 1, show that the total number of people experiencing homelessness in general, chronic homelessness, and unsheltered homelessness rose precipitously between 2018 and 2019 and have remained high. While some decreases were measured in 2022 for homelessness and unsheltered homelessness, chronic homelessness has continued to increase steadily. Furthermore, the proportion of homeless individuals who are unsheltered, which saw a peak in 2017 and 2018 at 30%, dropped to 21% in 2022.

Notably, the 2022 PIT count found that 77% of homeless in the region became homeless while living in San Joaquin County, suggesting that housing and economic conditions within the region are pushing individuals and families into a state of poverty, housing insecurity, and desperation. Indeed, vacancy rates within the multi-family housing sector are currently very low (less than 2% for affordable housing stock), and even the waiting lists for subsidized housing in San Joaquin County are closed.

[1] The 2024 PIT count had been conducted, but data were not available at the time that this plan was written.

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The San Joaquin CoC
The San Joaquin Continuum of Care (SJCoC) is tasked with providing leadership and effective resource stewardship, as well as facilitating community planning, design, and implementation of programs critical to ending homelessness in San Joaquin County. The values driving the SJCoC are collaboration, communication, and transparency, along with a commitment to evidence-based programming and data- driven initiatives.

The SJCoC includes all the services homeless people need along the full spectrum of homelessness, ranging from outreach and engagement to emergency shelter to transitional housing to permanent supportive housing or affordable housing. It is designed to ensure and coordinate support at each point along the spectrum of homelessness.

Partnership Model
The SJCoC is tasked through federal and state regulations to:

 Promote a community-wide commitment and approach to preventing and ending homelessness.  Disburse funding to rapidly re-house homeless individuals and families.  Promote access to and effective use of mainstream programs (such as Housing Choice Vouchers, Food stamps, and other public benefit programs).
 Optimize self-sufficiency among individuals and families experiencing homelessness.

The SJCoC comprises diverse partners working jointly and collaboratively to prevent and end homelessness.

Organizationally, the SJCoC is guided by a governing Board of Directors. Governing Board members are nominated through an annual “open call” to solicit interested parties to serve on the Board. The board roster is fluid and responsive to the needs of the community, but it will generally have a minimum of 11 board members and a maximum of 21. At least one, ideally more, Persons with Lived Expertise and Experience (PLEE) in homelessness serve on the Board.

The goal of the San Joaquin CoC is to improve and support a comprehensive coordinated homeless housing and services delivery system operated by the community by bringing together stakeholders. The San Joaquin CoC supports stakeholders throughout the San Joaquin County region to assist homeless persons in making the transition from homelessness to independent or supportive permanent housing, accessing education, health, and mental health services, employment training, and life skills development. We are dedicated to the development and implementation of strategies to create permanent solutions to homelessness in our community.

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Board members generally represent a rich array of professional and service interests and, at a minimum, include people who are themselves or provide services to the specialty sub-populations that comprise the homeless community. This includes but is not limited to, partners that work with or provide services to, homeless youth, veterans, people fleeing domestic violence, people with HIV/AIDS, people with mental health and substance use conditions, and those who are chronically homeless.

Additionally, the SJCoC is supported and informed by
numerous community members and professionals who
participate in twice-annual “general membership”
meetings, serve on various committees, and serve as the heart and soul of the SJCoC. Made up of retired people, business leaders, program staff, members of faith
communities, and people who have experienced
homelessness, the membership provides unflagging
support to our community during bi-annual point-in-time count activities, fundraising events, and other calls to action. During the COVID-19 pandemic shutdowns of
2020, members rallied to ensure that everyone
experiencing homelessness had adequate food, hygiene
supplies, and information about the health risks to keep themselves safe. For this planning effort, the general
membership attended public meetings, participated in
focus groups, responded to a community survey, and
provided as-needed information and ideas to the
planning team on a near-constant basis.

Anchoring the SJCoC is its partnership with San Joaquin County to serve as its Collaborative Applicant and fiscal sponsor to receive and manage federal and state entitlement grant funds, including the federal CoC Program Competition funds and State of California Homeless Housing Assistance and Prevention Funds.

Complimenting San Joaquin County’s role as the Collaborative Applicant, the four largest municipalities in the region are all deeply engaged with SJCoC, with staff either serving as Board members, heading up various committees and task forces, and participating in regular conversations through the SJCoC, and within their communities to guide and shape the narrative and opportunities to prevent and end homelessness.

Partner Roles and Responsibilities
Across the nation, CoCs are charged with developing and maintaining a continuum of programmatic services, supports, and housing opportunities necessary to prevent and end homelessness.

 Outreach, engagement, and rapid linkages to
services to prevent unsheltered homelessness,
whereby people are living in places not intended
for habitation, such as a vehicle or tent;
 Interim, temporary, and transitional housing
programs as necessary to provide immediate
sheltering for individuals and rapidly connect
them to long-term services and permanent
housing opportunities; and,
Planning and Coordination:
 Homeless Outreach
 Interim Housing
 Homeless Housing
 Land Use and Development

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 Permanent housing for those exiting homelessness or those at immediate risk of becoming homeless through rent assistance and wrap-around support services to help clients maintain housing and optimize their self-sufficiency.

In California, CoCs are also enjoined to actively plan and advocate for new affordable housing opportunities for
homeless individuals. This includes reviewing and
prioritizing potential sites and projects for new
developments and providing informed and coordinated
input to local planning departments.

The CoC is also responsible for ensuring that the system works as intended to achieve desired results, as part of coordinating and strengthening the system of care.

At a minimum, this means that programs are using
resources wisely, delivering effective and culturally
responsive services, working in a coordinated fashion,
and sharing metrics and information to enhance service
delivery and leverage additional resources.

Locally, the SJCoC is aided in these endeavors by strong partnerships and coordination with San Joaquin County and the City of Stockton, who also receive direct state and federal grant allocations to address homelessness. Jointly, these three partners have entered a regional and coordinated
compact through a Memorandum of Understanding (MOU) to
work in concert to achieve regional aims. The SJCoC, The County of San Joaquin, and the City of Stockton are joined in this partnership by the support and assistance of the City of Lodi, the City of Manteca, the City of Tracy, the Housing Authority of the County of San Joaquin, Health Plan of San Joaquin, Health Net, and the County Departments of Behavioral Health Services, Public Health, and Probation all of whom jointly and collaboratively contributed to this Action Plan.

Subsequent sections of this report include further details about all three partners' specific roles and responsibilities for implementing this Action Plan.

Current Use of Funds
This Action Plan aims to strengthen the collaborative and regional approach to ending homelessness. To this end, the Action Planning process followed State of California guidance, and considers a total approach that combines all available federal and state funds, designated for addressing homelessness, which are received and managed through local jurisdictions including the SJCoC.

The revenue and expenditure analysis below, is based upon budget information received from the Cities of Lodi, Manteca, Stockton, and Tracy and from the County of San Joaquin’s Neighborhood Preservation Unit which manages the tasks of the Collaborative Applicant and manages all other Federal and State affordable housing and homeless related program grants. Additional information was received from Managed Care Plan partners, San Joaquin County Behavioral Health, and Whole Person Care Programs.

Additional Responsibilities:
 Grant and Fiscal Management
 Data Management and Facilitating
Information Sharing
 Evaluating Performance and Equity
Measures
 Building Local Capacity (with a focus
on emerging PLEE, BIPOC, and
LGBTQIA+
 Land Use and Development
Key Partners to this Action Plan
 San Joaquin County (SJC)
 City of Stockton (CoS)
 San Joaquin Continuum of Care
(SJCoC)

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REVENUES AND EXPENDITURES: FISCAL YEAR 2022 – 2023

Across the four municipal partners, the County of San Joaquin and SJCoC, the region reportedly received over $43 million in state and federal funding to address homelessness.

Additionally, County Health and Behavioral Health programs received separate allocations to provide outreach and engagement services, street medicine, addiction, and mental health treatment services, and to provide case management and housing to people with serious mental illnesses. Hospitals and public health plans for medical care and treatment absorb an additional sum. All told, the region spends between $130,000,000 to $160,000,000 annually on addressing homelessness, according to the 2022 Cost of Homelessness Report by the University of Pacific’s Center for Business and Policy Research.

Most of the funding received, and re-distributed into the region, was through federal grants, although some cities made allocations from their general fund balance.

Of the funds received in FY 2022-2023, State HHAP funds accounted for the largest share, followed by federal CoC Program competition funds. In total, 49% of all funding was from federal sources, 44% from state Lodi $2,484,965
(6%)
SJC-NP
$22,879,637 (52%)
Stockton
$13,452,716 (31%)
Tracy $4,811,388
(11%)Revenue by Funding
Agency, FY22-23
Total reported revenue:
$43,452,739

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sources, and 7% were local allocations. Of the funds received, about $20 million can be considered “ongoing annual allocations,” primarily federal funds.

However, of the long-term ongoing funds, only HUD’s CoC Program Competition funds and Emergency Solutions Grant (ESG) funds ($6.5 million and $700,000, respectively) are specifically intended for homeless services and support. Other funds such as HOME and PLHA funds are intended for affordable housing projects which may have the benefit of increasing the housing supply. Community Development Block Grant (CDBG) program funds may be used for a range of community benefit programs, including programs that offer case management, food and nutrition, and other supportive services that may have homeless individuals and households as intended program recipients – or may not.

Of the $43 million received in FY 2022-2023, collectively, the SJCoC, the County of San Joaquin, and the Cities spent or re-allocated nearly $34 million during this same period. Notably, the City of Stockton allocated more funds than were received in 2022-23, likely due to disbursements of prior year allocations. In general, the City of Stockton is expending resources at a somewhat faster pace than the County of San Joaquin/SJCoC’s combined allocations.

Table 4: Total Revenue and Expenditures, FY22-23
Stockton SJC Tracy Lodi Healthnet Total
All Revenue $13,452,716 $22,879,63
7 $4,811,38
8 $2,484,965 Not
Reported
$43,452,739
All
Expenditures
$14,155,012 $11,171,69
3 $4,626,56
1 $2,309,454 $1,550,135 $33,812,856
Revenue Minus
Expenditures
($702,296) $11,707,94
4 $184,827 $171,511 N/A $3,501,234
Revenue
Remaining (%)
-5% 51% 4% 7% N/A 9%

Consistent with prior regional planning, the greatest proportion of funds were allocated to the construction of new permanent and interim housing projects, which jointly accounted for 57% of all homeless spending in FY 2022-2023 ($18.7 million).

Table 5: Expenditures by Strategy/Allowable Use
Strategy / Allowable Use Sum of Expenditures
Permanent Housing $17,400,746
Capital for Permanent Housing $10,845,886
Rapid Rehousing $1,592,403
Prevention and Diversion $4,404,623
Services and Subsidies for Permanent Housing $557,834
Interim Housing $11,202,981
Operating Subsidies for Interim Housing $2,342,720
Renovations and Upgrades $979,666
Delivery of New Interim Housing $7,880,595
Service Provision and System Support $3,396,365
Street Outreach $1,969,858
Service Coordination $661,041
System Support $765,467
Administration $1,812,764
Grand Total $33,812,856

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In summary, looking at all revenues and expenditures, spending in FY 2022-23 was responsive to prior regional planning with expenditures allocated as follows:

• Permanent Housing: 52%
• Interim Housing: 33%
• Services and Coordination: 10%
• Administrative Costs: 5%

Across the top ten agencies receiving funding allocations through the SJCoC, County, and local municipalities the first nine largest allocations were for the provision or development of permanent housing:

Table 6: Top Agencies Allocated Funding by SJCoC, County, and Local Municipalities Agency Total Expenditures
Housing Authority (DCDC) $7,133,136.00
Central Valley Housing $5,424,993.01
Tracy Navigation Center $4,610,802.10
Visionary Home Builders $3,109,652.73
Stockton Navigation Center $2,106,388.49
Lodi Navigation Center $2,009,725.12
Children's Home of Stockton $1,313,137.39
Lutheran Social Services $859,554.01
STAND $856,531.41
St. Mary's Community Services $767,600.06

HHAP REVENUES AND EXPENDITURES (ALL ROUNDS)
Looking forward, an additional $26 million in one-time HHAP Round 4 and Round 5 funds are coming into the region and an additional $9 million of HHAP Round 3 funds was unexpended as of December 31, 2023, suggesting that a total of $35 million in state HHAP funds needs to be expended over the next four years.

Importantly, allocations must be spent on schedule to prevent reversion to the state’s general fund.

HHAP PROGRAM SPENDING DEADLINES :
 HHAP-1: by 6/30/25
 HHAP-2: by 6/30/26
 HHAP-3: by 6/30/26
 HHAP-4: expend (50%) of initial by 5/31/25 and remainder by 6/30/2027.  HHAP-5: expend (50%) of initial by 6/30/26 and remainder by 6/30/2028.

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To date, program expenditures have been slower than anticipated due to numerous compounding challenges, including:

 Influx of One-time Funds: In addition to the State’s HHAP allocations, new one-time American Rescue Plan Act funds also required spend down along specific timeframes. In general community partners were encouraged to draw down from ARPA related contracts prior to HHAP related contracts.
 Contracting Processes: Fair and transparent public purchases take time. Other aspects of contracting, including scope refinements and approvals, also contribute to delays in getting contracts executed in a timely manner. County/SJCoC HHAP-3 contracts were just completed recently, in Fall 2023.
 Construction Delays: Supply chain logistics have been a hurdle. More critically, any capital development project comes with its own timing challenges associated with securing additional financing, approvals, and permits. In the case of the Stockton Navigation Center, permits were required from the Federal Department of Transportation to build underneath Interstate 5.

Program and Service Utilization

DATA DASHBOARD
Table 7: Utilization Data from San Joaquin CoC Data Dashboard (August 2022) Engaged by Project Type: 04/01/2021 - 06/30/2022
Individuals
(N = 11,866)
Households
(N = 8,311)
Emergency Shelters 7,730 4,956
Permanent Housing with Services 39 39
Permanent Supported Housing
(for people with disabling conditions)
732 547
Rapid Re-Housing 1,930 841
Street Outreach 4,056 3,931
Transitional Housing 535 451

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According to data from the HMIS data dashboard, nearly 12,000 individuals accessed homeless services in San Joaquin County during the 15-month period between April 2021 and June 2022. For all persons active in the HMIS system, 14,659 case management encounters were recorded, or approximately 1.2 case management sessions per person or 1.8 per household served. Despite case management sessions being the most frequent type of service, data entry was sporadic across programs. While some programs appear diligent about recording case management activities, others, particularly interim housing programs, were less inclined to report these types of activities.

Other data regarding program utilization appear more reliable. All told, 732 individuals in 547 households received permanent supportive housing. An additional 39 households benefitted from permanent housing and did not require long-term supportive services, consistent with a disabling condition. Enrollments (pre- determined eligibility) into rapid re-housing were also robust, with 1,930 individuals from 841 households qualifying for rapid rehousing (RRH) assistance and services. Typically, RRH program recipients will receive case management and housing navigation services. Those that can find housing are provided with short-term rental assistance. During the first part of the reporting period, an average of about 50 households entered a new RRH situation each month. Later data show that the figure drops to an average of 33 households entering RRH programs each month. Additional data is forthcoming and will provide information if the dip in placements was an abnormality or a sign of more concerning trends.

HOUSING INVENTORY COUNT

Table 8: Utilization Data from Housing Inventory Count (November 2023) Housing/Program Type Capacity
(# of Beds)
Occupancy Occupancy
Rate
# and % of Sites Operating
Under-Capacity
Emergency Shelters 1,311 892 68.0% 26 out of 42 = 62% Transitional Housing 326 170 52.1% 12 out of 15 = 80% Other Permanent Housing 530 408 77.0% 2 out of 3 = 67% Permanent Supportive
Housing 752 650 86.4% 5 out of 7 = 71%
Rapid Re-Housing 381 381 100.0% 0 out of 19 = 0%
Total (All Types) 3,300 2,501 75.8% 45 out of 86 = 52%

At the request of the planning team, the HMIS lead agency prepared a “proxy” housing inventory count for one night in November to provide an informal snapshot of interim and permanent housing utilization. The chart above shows overall occupancy rates for different types of interim and permanent housing. Further analysis of the HIC data revealed the following findings:
 There are eighty-five separate programs, providing 3,300 different interim, transitional, and permanent housing options.
 Occupancy rates were highest for units dedicated for short-term RRH placements (100%)  Family shelters had lower occupancy rates than non-family shelters. This is expected, as family shelters tend to have more “beds” per unit than is necessarily needed at that moment (e.g., the unit has a rated capacity of five beds, but the family size is three).  Emergency shelters designed for individuals had higher occupancy rates (83%) than when aggregated together with family-serving programs.
 Utilization rates were lowest for transitional housing (52%) and voucher-based programs (65%).  Transitional housing programs with the lowest occupancy rates typically had more barriers to entry (e.g., sobriety or faith requirements).

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FISCAL YEAR 2022-2023: EXPENDITURES BY PROGRAM UTILIZATION About one-third of the expenditures made by the contributing program partners in FY 2022-2023 were allocated to programs intended to have direct client benefit. The chart below shows the average per-person program cost/benefit:
 Engaged in a permanent housing program: $1,410.00
 Engaged in an interim housing program: $225.00
 Receiving street outreach or other case management: $84.00

Persons who receive the greatest benefit from public resources are those at risk of homelessness, who received, on average, $2,747.00 per person, likely rental assistance, or other subsidies to remain housed.

This data shows that the region’s most resource intensive intervention is in preventing new incidents of homelessness.

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V. SYSTEM PERFORMANCE MEASURES
People Experiencing Homelessness
According to the most recent report generated by the San Joaquin CoC Homeless Management Information System (HMIS) and released by the state's Homeless Data Information System (HDIS), the number of unduplicated individuals receiving homeless services is 11,722.

This figure, along with figures for the number of people experiencing homelessness for the first time and the percentage of people returning to homelessness within six months of exiting permanent housing, is down slightly from 2022 figures (See Table 1). Approximately 53% of individuals in the HMIS data report experiencing homelessness for the first time, suggesting that the problem of homelessness is continuing to grow in the San Joaquin region.

Table 1: System Performance Measures
Measure CY 2020 CY 2021 CY 2022 7/1/22-6/30/23

1.a. Number of persons experiencing homelessness
in HMIS
9,421 8,931 11,977 11,722

1.b. Estimated number of people experiencing
unsheltered homelessness on the SJCoC PIT count
1,558 - 1,355 1,355

2. Number of people accessing services who are
experiencing homelessness for the first time
4,715 4,348 6,485 6,211

3. Number of people exiting homelessness into
permanent housing
977 913 1,273 1,169

4. Average length of time (in days) that people were
enrolled in non-residential or short-term programs
without securing long-term housing
73 85 72 76

5. Percent of people who return to homelessness
within 6 months of exiting homelessness response
system to permanent housing
6% 12% 19% 11%

6. Number of people with successful placements
from street outreach (temporary or permanent)
4* 2* 3* 6*
* Low numbers likely a result of insufficient data entry practices

Table 2 lists the individuals in the HMIS system according to specific characteristics, including gender, family structure, and key vulnerabilities.

Table 2a: Individuals Served by Key Characteristics
Gender / Household Composition Number Proportion of Total Man/Boy 6,372 55%
Woman/Girl 5,316 45%

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Transgender 18 0.2%
Single adults without children 6,445 52%
People in families with at least 1 child 5,492 44%
People in households with only children 469 4%

Table 2b: Individuals Served by Vulnerabilities
Additional Vulnerabilities Number Note
Adults with SUD 1,339 Percentages are not
calculated.

The high number of children
served by the homeless
system would skew a
proportional analysis.

Adults with SMI 1,182
Veterans 463
Adults fleeing Domestic Violence (DV) 337
Parenting Youth 249

People Living Unsheltered in San Joaquin County
Point in Time (PIT) homeless count data from 2022 (HUD 2022b), which is the latest data available at the time of this plan, show sheltering variations:

 Sheltering by the presence of children in the household The majority (75%) of people living in households without children (single adults) were unsheltered, vs. all (100%) people in households with at least one adult and child (families) were in emergency shelters or transitional housing.

 Sheltering status of unaccompanied youth
Nearly the same proportion of unaccompanied youth were sheltered (54%) and unsheltered (46%) (n=72).
 Sheltering by status of people with behavioral health conditions A large majority (73%) of people with chronic substance abuse issues were unsheltered (n=602), and a very large majority (79%) of people with serious mental illness were unsheltered (n=567).  Sheltering status of other vulnerable populations
All (100%) people known to have HIV/AIDS were sheltered (n=10); most (67%) people fleeing domestic violence were sheltered (n=32); and most veterans (71%) were unsheltered (n=127).

Findings from the Unsheltered Encampment Outreach Study researched and published by the United Way of San Joaquin County provide insights into the personal situations and challenges that may have contributed to the experience of homelessness.

Data highlights from the study show that among those living unsheltered:

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 33% did not graduate from high school.
 37% reported that "job loss/income reduction" contributed to their homelessness.  64% indicated that losing employment or housing was part of what contributed to them becoming homeless.
 44% reported being prevented from working because of a disability.

Consistent with state and national trends, the vast proportion of people experiencing homelessness in San Joaquin County, sheltered or unsheltered, are from San Joaquin County.

Racial and Ethnic Disparities by Performance Measures
For the purposes of running an analysis of racial and ethnic disparities, some recoding of the traditional Census designations was conducted to construct a more consolidated set of categories that recognized Latina/o/x individuals as non-white, even if they did not select “Black.” These consolidated categories grouped all Asian-identified, Black-identified, Native American/Alaska Native-identified, and Polynesian/Pacific Islander-identified in those self-same designations, irrespective of Hispanic identification. People who indicated they were of Hispanic ethnicity were grouped into the Latina/o/x category (Lx) if they were also white, Multi-Ethnic, or Unknown. The category of White comprised people who were white-identified and not of Hispanic ethnicity.

The following analyses are based on these recorded racial and ethnic categories.

HMIS TOPLINE BY RACE/ETHNICITY:

The HMIS data report lists a series of figures and outcomes broken down by the recoded race/ethnicity categories in Table 3. Please note that the data for Measure 1.b., Unsheltered Count from PIT, was not provided in a way that enabled analysis using the race/ethnicity categories, so that measure is not listed below.

Table 3: HMIS Topline Measures
Measure 1a:

Number of
people
accessing
services who are
experiencing
homelessness
Measure 2:

Number of
people
accessing
services who are
experiencing
homelessness
for the first
time
Measure 3:

Number of
people exiting
homelessness
into permanent
housing
Measure 4:

Average length of
time (in days)
Measure 5:

Percent of people
who return to
homelessness
within 6 months
of exiting
homelessness to
permanent
housing
Asian (all) 317 205 35 59 11%
Black (all) 3,556 1,824 411 79 13%
Latinx (combo) 4,067 2,222 385 67 10%
Multi (non-Lx) 453 261 56 73 13%
Native American/
Alaska Native (all) 204 92 18 79 20%
Polynesian/Pacific
Islander (all) 116 59 *** 96 0%
Unknown (non-Lx) 96 81 *** 34 0%
White (non-Lx) 2,805 1,397 231 91 10%
COUNTY POPULATION COMPARISON:

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The HMIS data show some disproportionality between the racial and ethnic composition of county residents versus the composition of people accessing services who are experiencing homelessness. As shown in Chart 2, relative to their representation in the community, Black residents are highly over-represented in the HMIS data, Asian residents are highly under-represented and white and Latinx residents are slightly under- represented.

UNSHELTERED HOMELESSNESS:

Certain racial/ethnic groups are overrepresented among the unsheltered homeless. For this measure, because PIT count data were not provided according to the previously described racial/ethnic groups, this analysis considers data from the San Joaquin County Unsheltered Encampment Outreach Study (Birtwhistle, et al., 2023). For comparison purposes, Chart 3 shows the racial/ethnic breakdowns of people surveyed in the Unsheltered Encampment Study with both county and HMIS racial/ethnic breakdowns. As evident in the chart, among unsheltered homeless, Asian residents are substantially underrepresented, Black residents are highly overrepresented, Indigenous peoples (both American Indian/Alaska Native and Polynesian) are highly overrepresented, and Multi-Ethnic people are somewhat overrepresented. Curiously, while white residents are slightly underrepresented among people in the HMIS, they are highly overrepresented among the unsheltered vis-a-vis their representation in the county.

FIRST TIME HOMELESSNESS:

Among all individuals represented in the HMIS data, the proportion experiencing homelessness for the first time is 53%. As Chart 4 shows, when disaggregated by race/ethnicity, differential rates of first-time

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homelessness become evident. The three groups with a higher-than-average proportion experiencing homelessness for the first time were Asian and Multi-Ethnic, as well as those whose race/ethnicity was Unknown.

EXITS TO PERMANENT HOUSING:

Among all individuals in the HMIS data, the overall proportion exiting into permanent housing was 10%.

Disaggregation by race/ethnicity shows that Asian, Black, and Multi-Ethnic individuals had higher rates of obtaining permanent housing, while Native American, Latinx, and White individuals had lower-than-average rates. Data were not reported for Polynesian/Pacific Islander individuals and those of unknown race/ethnicity.

LENGTH OF TIME HOMELESS:

Overall, the average length of time that people spent enrolled in street outreach, emergency shelter, transitional housing, safe haven projects, and time prior to move-in for persons enrolled in rapid rehousing and permanent housing projects was 76. A few racial/ethnic groups had higher-than-average numbers of days in known homelessness, including Polynesian/Pacific Islander, White, Native American, and Black.

Groups with less-than-average lengths of time in known homelessness included Multi-Ethnic, Latinx, Asian, and those of Unknown race/ethnicity.

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RETURNS TO HOMELESSNESS:

The HMIS data show that overall, 11% of individuals who exit homelessness to permanent housing return to homelessness within six months. The analysis by race/ethnicity shows that people who are Native American/Alaska Native have a much higher rate than average (20%). Multi-Ethnic and Black individuals have slightly higher-than-average rates of return to homelessness, and White and Latinx people have close to average rates. The rates for people of Unknown race/ethnicity and Polynesian/Pacific Islander individuals were listed as zero.

Gender Disparities by Performance Measures
INCREASE IN FEMALE HOMELESSNESS:

The current HMIS 511 data for the San Joaquin region show that 45.6% of people in the HMIS system are female. This compares to 41% in 2015(HUD Exchange, 2015). This increase is consistent with a statewide trend measured by the U.S. Department of Housing and Urban Development (HUD). Over the past eight years (as of December 2023), there has been an increase of more than 50% in the number of women experiencing homelessness in California -- many of these women face additional vulnerabilities associated with pregnancy, parenthood, and domestic violence (McClure, 2023).

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DIFFERENTIAL OUTCOMES BY GENDER:

The HMIS data show that men/boys, comprising 54.4% of all individuals in the system, were more likely to be unsheltered and return to homelessness, and were less likely to exit to permanent housing, as compared to women/girls in the system (See Chart 8). As there were only 18 individuals listed as Transgender, most of these outcomes were not listed in the HMIS data report for Transgender individuals.

ADDITIONAL GENDER DIFFERENCES:

Males and females in the HMIS system had moderately different rates of first-time homelessness (51% and 55%, respectively), although the small number of Transgender individuals had a substantially higher rate (67%). The average length of time (in days) that people were known to be homeless, as documented within the SJCoC's HMIS, differed by gender, with men showing 84 days, women showing 66 days, and Transgender individuals showing 133 days.

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VI. KEY FINDINGS
Community Service Needs
 Accessible / Responsive / Non-Duplicative Services
 Housing Navigation
 Affordable Housing
 Housing for Vulnerable Populations
 Culturally Responsive Services

ACCESSIBLE / RESPONSIVE / NON-DUPLICATIVE SERVICES
The mixed methods analysis points to a need for a robust system to assess individual needs and place people accordingly. This will require enhanced coordination and collaboration among community partners, emphasizing the importance of honest and open conversations among service providers.

Stakeholders reported in interviews that the services for people experiencing homelessness are fragmented and not easily accessed. The Community Survey revealed coordination across agencies (criminal justice, behavioral health, hospitals, housing resources, domestic violence programs, etc.) as the top priority for addressing homelessness in the San Joaquin region. In workshops and interviews, stakeholders asserted that while the issues and challenges that homeless individuals are experiencing are interconnected, the services that could help them are disconnected. As a result, a person seeking support will need to access multiple agencies, undergo repetitive intakes, and still not be guaranteed to receive the support they need.

One direct service provider explained:

While calling 211 could theoretically be a way for homeless people to access care more seamlessly, few people experiencing homelessness can take advantage of this resource. Many do not have a phone to make the call in the first place, and if they do have a phone, it is seldom charged. Some may make the call with the assistance of an outreach worker, but in most cases, they must leave a message and wait for a callback, and without a phone, they have no ability to receive that return call.

Some of the barriers to effective communication and collaboration result from agencies and actors not being aware of one another and the array of resources that exist in the region; some arise from obstacles like restricted access to client information when entities do not have HIPAA clearance, and others still occur because funded agencies are not making optimal use of the HMIS system. With a more effective Coordinated Entry System, which makes better use of the HMIS, providers could coordinate case management efforts, reduce duplication, and capture basic intake information (reducing the need for repeat intakes). “
It’s an onion… and you’re trying to isolate each layer, but it’s not you; you can’t. For an individual to be able to be successful, you have to be able to transition to mental health treatment, substance abuse treatment, housing, health services, [and] all of these services are siloed; they are all separate. So, the individual has to go somewhere, then go somewhere else, and go through the whole process at a different physical location: one for substance abuse and another intake process at a different location. Everything is so siloed, and I get it because funding is separate, but it discourages people from accessing services.”

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More than one stakeholder indicated that there is a need for one-stop shops, where people experiencing homelessness can seamlessly access services and supports that correspond to the complex needs experienced by this population. Under one roof, or even as a mobile event, individuals and families could navigate resources and access immediate help, including medical care, legal services, mental health care, veterans' programs, substance abuse treatment, disability program enrollment, childcare, hygienic products, emergency shelter, housing applications, and more.

HOUSING NAVIGATION
The analysis points to a need for affordable permanent housing in the region. The lack of affordable housing poses a significant challenge, rendering housing vouchers ineffective if suitable properties are inaccessible.

To address housing needs sustainably, stakeholders emphasized that long-term low-income housing solutions should be prioritized over short-term temporary shelters.

Furthermore, stakeholder input raised the need for improved housing navigation to help homeless individuals and families identify the potential housing resources among the few that do exist. The region’s HMIS data show that around 90% of people in temporary shelters exit either to other temporary programs or unknown destinations, rather than permanent housing programs. Building up skilled housing navigation could help remedy this situation.

Current housing navigation services are insufficient and not guided by pre-established standards. Housing navigation should be readily available to all shelter residents and should constitute support with housing applications as well as the more nuanced work of brokering relationships among clients, engaging with landlords, putting clients on the Coordinated Entry list, and providing specialized case management plans that set people up for successful and sustained permanent housing.

Finally, stakeholder input underscored the need to increase awareness and access to housing resources for vulnerable populations to ensure equitable access to available services and support. They pointed to a need to equip the region with a continuum of low-barrier housing options to serve those with consistently less positive housing and provide creative housing options for individuals with extensive needs, beyond traditional shelters.

AFFORDABLE HOUSING
The dearth of affordable housing is a major contributing factor to homelessness in the San Joaquin region.

Stakeholders recognize that the shortage of housing leads to shelter hopping among the homeless, which further destabilizes people’s lives. They also indicate that high barriers to entry into affordable housing
frustrate efforts to find permanent housing for people
experiencing homelessness, especially those in key
vulnerable populations. Many voiced concerns that
there is insufficient support to ensure that once
engaged in affordable housing, people will not return
to homelessness.

Below are key findings from the multi-method
analysis:

RESOLVE BOTTLENECKS : Bottlenecks in the
permanent housing process, such as limited availability of affordable housing units or bureaucratic obstacles, hinder progress, exacerbate homelessness in San Joaquin County, and highlight the need for more affordable housing options and streamlined housing placement processes. “We need to remove the barriers to housing
navigation. There are too many inefficiencies
within our current programs. We must improve
coordination, implement streamlined
processes, enhance communication, and
generally act with a sense of urgency to
provide successful housing exits.”

Participant, Key Stakeholder Interviews

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HOUSING CONSTRUCTION RATE : Independent analyses of the region’s homeless issues and stakeholder input indicate that the housing construction rate has been inadequate to mitigate rising prices or meet demand. Specifically, the 2014 County’s Residential Housing Needs Allocation (RHNA) Plan called for 40,360 new units to be constructed in San Joaquin County between 2014 and 2023 (San Joaquin Council of Governments, 2014). The San Joaquin Council of Government's public data dashboard estimates a shortfall of 23,400 units on that initial promise (San Joaquin Council of Governments, 2022). The current RHNA plan adds to the total construction need, calling for 52,719 new units, including 21,637 very low and low-income housing units (San Joaquin Council of Governments, 2022a). The insufficiency was not lost on stakeholders – in nearly every interview and public input forum, the need to build additional affordable housing was specifically named. The region’s projected population growth is likely to exacerbate further the affordable housing shortage, which in turn would lead to more homelessness, shelter-hopping, disparities among vulnerable populations, and returns to homelessness after achieving permanent placement.

C
OORDINATION & ACCOUNTABILITY : Stakeholders expressed a desire to develop a unified vision and strategy for promoting self-sustainability among homeless individuals in permanent affordable housing, ensuring coordinated efforts and resources in San Joaquin County. To this end, the SJCoC must facilitate more rigorous accountability structures, enhance communication channels, and foster alignment and collaboration among stakeholders to address permanent housing needs for the homeless in San Joaquin County effectively.

P
ROMOTING SELF -S UFFICIENCY : It is difficult to equip individuals with the necessary resources and support to ensure self-sustainability and prevent returns to homelessness—most require some skill-building, education, and employment support to promote long-term independence. For higher-need populations, affordable housing must be accompanied by ongoing and comprehensive behavioral health care to maintain stability and avoid falling back into homelessness. Offering services such as counseling, skill-building workshops, employment assistance, and case management can enhance the success of individuals with mild to moderate needs.

A
DDRESSING DISPARITY : Stakeholders pointed out insufficient programs focused on specialized support for populations experiencing disparities. This lack of targeted programs perpetuates barriers to permanent housing access and promotes disparate retention rates. The HMIS data show very clearly that Black residents are highly over-represented among the homeless in the San Joaquin region, and that certain populations are less likely to move into and sustain permanent housing (e.g., men, people with serious mental illness (SMI), people with substance use disorders (SUD), youth, and people who are Transgender).

Customized outreach and support can help remedy these disparities in permanent housing outcomes.

HOUSING FOR VULNERABLE POPULATIONS
HMIS data provide outcomes for key populations experiencing specific circumstances and vulnerabilities, including:

 People with SMI (serious mental illness)
 People with SUD (substance use disorders)
 Youth facing housing challenges
 Transitional-age youth (TAY) transitioning out of foster care  People fleeing domestic violence
 Veterans
Stakeholder engagement and a review of relevant reports indicate specialized needs among individuals exiting jails and prisons, and people leaving hospitals and behavioral health facilities, although outcomes in the HMIS data analyzed for this plan were not broken down based on these characteristics.

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Chart 12 lays out the differential rates of placement in permanent housing according to key client characteristics, including the aforementioned categories available in the HMIS data, as well as gender and family structure. This chart demonstrates that some populations have higher rates of exit to permanent housing than others. The existence of specialized programming for veterans, for example, enables a higher rate for this sub-population. Parenting youth, families in general, adults fleeing domestic violence (DV), and women tend to have overall higher rates of placement in permanent housing. By contrast, being male, Transgender, young, and single are associated with lower rates of placement. Also of note are the low rates among adults with SMI and those with SUD. There was no data available for people with HIV/AIDS on this outcome.

Chart 13 below shows the differential rates of return to homelessness (within six months of placement in permanent housing) according to these same client characteristics. Once again, adults with SUD, who had the lowest rate of placement, also have the highest rate of return to homelessness. Having HIV/AIDS, being a youth, and having an SMI are also associated with higher-than-average return to homelessness rates.

Interestingly, while veterans had the highest rate for permanent housing placement, they also have a higher- than-average rate of returning to homelessness after placement, suggesting that veterans' housing programs might benefit from additional support for clients (perhaps trauma or PTSD-specific). Consistent with the permanent housing placement data above, the return to homelessness data show that people in families, parenting youth, women, and adults fleeing DV fare better than singles, men, and youth on their own. There were no data available for Transgender individuals on this outcome.

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Community survey results provide a view on what some stakeholders believe to be priorities for addressing the specific needs of individuals leaving hospitals and jails into homelessness, and those of both youth and older adults.

When prompted to consider the complexities of serving people leaving jail into homelessness, respondents identified the following as the top priorities:

 Coordination across agencies (criminal justice, behavioral health, hospitals, housing resources, domestic violence programs, etc.) (61%)
 Outreach to unsheltered and/or vulnerable people exiting hospitals or jails (58%)  Delivery of mental health treatment (30%)

Stakeholder input confirms that poor cross-agency coordination leads to gaps in service and challenges in placing individuals leaving jails, particularly those who do not qualify for limited specialized programs for individuals with disabilities or medical needs. They also indicate that the small number of low-barrier shelter beds in the region also hinders the easy placement of people leaving jail.

Improved cross-agency coordination and increased outreach also stood out in survey responses for how to support better outcomes for people leaving hospitals. Respondents felt increased permanent supportive housing with intensive case management should be prioritized for this population, as well:

 Coordination across agencies (criminal justice, behavioral health, hospitals, housing resources, domestic violence programs, etc.) (61%)
 Access to permanent supportive housing (with intensive case management) (52%)  Outreach to unsheltered and/or vulnerable people exiting hospitals or jails (45%)

Stakeholder input pointed to the lack of discharge planning and cross-agency coordination for those leaving hospitals, naming the need for direct linkages to services and shelter at the moment of release.

In response to data showing poor outcomes among youth along the homeless continuum of care, survey respondents identified a range of priorities without much consensus. The top four are provided below, and while none show a majority of responses, the array demonstrates an appreciation that when youth are experiencing homelessness, their needs are usually complex and multi-faceted.

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 Access to permanent supportive housing (with intensive case management) (48%)  Coordination across agencies (criminal justice, behavioral health, hospitals, housing resources, domestic violence programs, etc.) (36%)
 Delivery of mental health treatment (36%)
 Access to safe low-barrier shelter beds (no drug testing or other requirements for shelter) (33%)

There was more consensus among survey respondents when it came to contemplating how to best serve older adults experiencing homelessness who identified the following top three priorities, focused very clearly on permanent housing and prevention strategies:

 Access to permanent housing or rental assistance (with modest case management) (70%)  Prevention activities (emergency rent assistance, eviction protection) (61%)  Access to permanent supportive housing (with intensive case management) (52%)

Stakeholder input lent insights as to the challenges facing homeless individuals with SUD and SMI:
 People with SUD have few options, either for temporary shelter or permanent housing. A true housing-first approach requires accessible low-barrier shelter, navigation, and program options that do not pre-suppose sobriety or recovery.
 There is insufficient support for individuals exiting behavioral health facilities, including a lack of beds, alternative housing options, affordable housing, staffing, case management, medical support, and basic essentials.
 There is an overlap between people with SMI and those with SUD, as some people with SMI self- medicate in the absence of adequate psychiatric care. The exclusion of people with SUD from programs (that require drug tests) may, therefore, also affect the outcomes of people with SMI.  People with SMI need ongoing treatment irrespective of their housing situation (or lack thereof), including free medication, psychiatric care, and medication management.

CULTURALLY RESPONSIVE SERVICES
When prompted to reflect upon what the highest priorities should be in addressing homelessness among Black residents of the San Joaquin region, whose representation among the homeless and unsheltered homeless are so disproportionate relative to their representation in the county, Community Survey respondents identified the following:

 Outreach to unsheltered and/or vulnerable people exiting hospitals or jails (45.5%)  Access to permanent supportive housing (with intensive case management) (42.4%)  Coordination across agencies (criminal justice, behavioral health, hospitals, housing resources, domestic violence programs, etc.) (42.4%)

In their comments, some respondents noted that intergenerational practices excluding Black people from housing and economic opportunities have long-term repercussions. Respondents also called for cultural responsiveness and implicit bias training for staff working within the continuum of care. Approximately 76% of respondents agreed that cultural responsiveness training should be tied to funding for homeless services, to improve service delivery based on race, gender, and other vulnerable categories, and 55% of respondents felt that the allocation of funds for homeless services should prioritize organizations that are led by people of color or have a proven record of serving people of color effectively.

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When asked to identify priorities for meeting the needs of the ever-increasing number of women experiencing homelessness, survey respondents indicated the following as their top three areas:

 Delivery of mental health treatment (51.5%)
 Access to permanent supportive housing (with intensive case management) (42.4%)  Delivery of substance abuse treatment (39.39%)

In their comments, several respondents named the importance of recognizing the specialized needs of homeless women, including that they may be escaping domestic violence, may have experienced complex trauma, are vulnerable to sexual violence living on the streets, and may have children in tow.

Invited to identify priority areas for addressing homelessness among men, who are more likely to be unsheltered, less likely to transition into permanent housing from shelters, and more likely to return to homelessness within six months of obtaining permanent housing, respondents selected the following three solutions most frequently:

 Access to permanent supportive housing (with intensive case management) (54.55%)  Delivery of mental health treatment (51.52%)
 Outreach to unsheltered and/or vulnerable people exiting hospitals or jails (45.45%)

Some respondents pointed out that relative to women, men are often less connected to family members whom they can call when they find themselves without housing. Others pointed out that men are more likely to be in the criminal justice system. When they exit from these settings, there are few safety nets to catch them – stakeholder interviews confirmed this, indicating that while there are some specialized programs for people with a disability or medical need, many leave the jail unhoused and ineligible for many local shelter programs. Housing outcomes for men may also be affected by fears that homeless men will engage in fights in congregate housing programs.

The three most common priorities identified by survey respondents for addressing the needs of Transgender people experiencing homelessness, who are less likely to exit to permanent housing, were:

 Coordination across agencies (criminal justice, behavioral health, hospitals, housing resources, domestic violence programs, etc.) (51.5%)
 Delivery of mental health treatment (45.5%)
 Access to permanent supportive housing (with intensive case management) (42.4%)

Several respondents indicated the importance of recognizing the trauma that many Transgender people have endured and named the importance of supporting agencies and services that have specific competence in serving LGBTQIA+ community members. Some also indicated that Transgender people may need privacy to feel safe in shelters, which are often divided based on binary gender definitions. Some expressed concern that faith-based shelters and providers would not be sufficiently accepting of Transgender individuals seeking services and support.

Strengths
The multi-method analysis indicated that the San Joaquin region has many strengths, including a robust service sector, engaged partners who share a vision for addressing homelessness, and innovation in using resources from various sources.

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ROBUST SERVICE SECTOR
Many public agencies, community-based organizations (CBOs), and faith-based groups play roles in addressing homelessness within the region. Some providers offer specialized services (for example, County Behavioral Health, the Veterans Administration, and CBOs focused on domestic violence) to help ensure services are tailored to clients’ unique circumstances. Connection and coordination among entities often function well, with cross referrals among shelters and programs facilitating effective service delivery. The engagement of community partners is seen as a significant asset and strength in addressing homelessness, with successful programs and partnerships contributing to supportive care for individuals living on the street and advocating for realistic solutions.

ENGAGED PARTNERS WITH SHARED VISION
Agencies working on homelessness unanimously demonstrated a shared desire for an honest assessment of the current state. Stakeholders were willing to discuss and take a frank look at areas that need improvement, including the historical disinvestment in affordable housing and the current over-reliance on shelters as temporary solutions. This understanding of the historical context provides a foundation for addressing the root causes of homelessness and implementing sustainable long-term solutions. It was also clear that entities across the regional service sector were open to adopting best practices and innovative approaches to addressing homelessness, including considering the potential replication of successful models delivered in adjacent areas.

Stakeholders consistently expressed a need for a unified vision for improved cross-agency coordination, bold leadership, and measurable, outcomes-focused implementation. They demonstrated a high consensus on the goal of expanding permanent housing situations while still acknowledging that immediate shelter is essential. Importantly, there was recognition that more support for the San Joaquin Continuum of Care (SJCoC) and increased transparency and trust in financial practices could yield better results. This shared ground indicates great potential for the region to move forward.

INNOVATIVE LEVERAGING OF RESOURCES:

Another clear strength in the region is the creative and innovative use of resources, drawing from a variety of sources. For example, general funds from county and city budgets are applied toward homeless outreach initiatives, enabling more extensive and sustainable support programs. Collaboration and cross-referral among public health agencies, Whole Person Care, County Behavioral Health, and other community partners can allow a client to benefit from multiple funding streams – this is recognized as essential for effective outreach and triaging. Furthermore, the implementation of incentives within managed care plans was identified as a strength -- these incentives encourage providers to offer tailored services and support to homeless individuals, ensuring more effective outreach and comprehensive care.

POSITIVE IMPACTS:

The strengths of the region and its commitment to addressing homelessness have led to strong successes, particularly as it pertains to new developments.

 40% increase in emergency shelter capacity
 180 new affordable housing units
o Harmony Homes
o Sutter Commons
o Town Center Studios
o Turnpike Commons
o Victory Gardens
o Crossways Residence
o Sonora Square

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 Additional projects pending:
o Tracy Navigation Center expansion
o St. Mary’s Navigation Center expansion
o St. Mary’s Pathways Modular Community

Challenges

COC GOVERNANCE
While there were many strengths that stakeholders pointed to, there were also several challenges, some of which centered around CoC governance. Inefficiencies along the continuum of housing, including limitations of existing programs, gaps, and duplication of efforts, were sometimes framed as a failure of governance.

Furthermore, governance dynamics stood out as something that sometimes interferes with effective SJCoC governance. Specifically, stakeholders conveyed that different opinions about the CoC's role hamper governance, as does the influence of personal agendas and potential conflicts of interest within SJCoC governance dynamics. Addressing these challenges will require a comprehensive approach focused on improving coordination, redefining roles, enhancing transparency, and fostering collaboration among stakeholders.

Regional Coordination, Oversight, and Accountability: The challenges with regional coordination, oversight, and accountability regarding homelessness in the region are multifaceted and encompass various themes, including a need for stronger leadership that
sets clear expectations, political dynamics, and poor
transparency and trust.

Expectations vs. Reality: There is a prevailing
perception that leadership does not set clear
expectations. For example, while strategic and Homeless Housing Assistance Program (HHAP) plans emphasize
low-barrier solutions, implementation is challenging.

Additionally, there is a pressing need for the construction of permanent housing, but funded projects are not
materializing due to a shortage of developers. This discrepancy between the public narrative and the reality of what is being accomplished leads to mistrust and friction, hindering effective regional coordination.

Political Barriers and Conflicting Objectives: Political dynamics, particularly at the county level, create barriers to effective action. Conflicting objectives among CoC entities like cities and counties further complicate regional coordination and oversight. These dynamics lead to ineffective communication among critical entities, which results in fragmented services, duplication, and a lack of collective action. This breakdown in communication severely impacts regional coordination and oversight efforts.

Financial Challenges and Transparency Concern: Intense competition for resources, restrictions imposed by policymakers, and a lack of transparency contribute to perceived conflicts of interest and generalized mistrust. These issues further impede regional oversight and accountability.

Addressing these challenges will necessitate a comprehensive approach to improve coordination, redefine roles, and enhance transparency and accountability. Efforts to streamline communication, address housing needs, and strengthen partnerships with hospitals and community-based organizations are essential for improving the regional response to homelessness.
“We need a leader who will oversee
centralized efforts to address homelessness
in San Joaquin County – a leader capable of
bringing together all stakeholders to foster
collaboration and move the needle.”

Participant, Key Stakeholder Interviews

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REGIONAL DATA MANAGEMENT: HMIS / CES
The HMIS has great potential to enhance the region’s Coordinated Entry System, but current practices prevent this.

Data Consistency and Management: There appears to be a lack of consistency in data entry and management across different parts of the sector. Additionally, it seems individuals and agencies may not be operating with the same definitions and terminology when entering data into HMIS. Furthermore, some stakeholders complained about the tediousness of needing to re-enter data, suggesting that people may need additional training on how to use the system more efficiently and/or that data-sharing agreements could be revisited to ease the burden of re-entering data. This underscores the need for improved training for HMIS users, including a unified language and clarification of parameters to ensure accurate and standardized reporting.

Real-Time Use of Data: Stakeholders reported that the HMIS does not reflect real-time updates. They are not able to trust that the data in the HMIS are up to date, which hinders the system's effectiveness in informing decision-making processes. For example, without real-time bed count data, the HMIS cannot serve as an effective tool in Coordinated Entry, which weakens the system’s ability to respond promptly and effectively to the homeless population's needs and results in poor resource management.

Transparency and Conflicts of Interest: Concerns were raised regarding transparency and potential conflicts of interest in managing and utilizing data within the HMIS and Coordinated Entry System.

These challenges underscore the importance of implementing additional training in data entry and data management for providers, enhancing monitoring and coaching to promote consistent data entry practices, and fostering collaboration and transparency within regional data systems. Addressing these challenges is vital to improving the effectiveness of the Coordinated Entry System and outcomes for the homeless population.

REGIONAL MONITORING OF PERFORMANCE MEASURES
The problems with using HMIS lead to performance monitoring challenges. Without reliable data, the CoC, partner agencies, and the community cannot recognize the impact that the work is having.

COMPREHENSIVE USE OF HMIS
A review of HMIS data revealed that parts of the data system are not fully utilized. For example, there are no data entered for San Joaquin under the category of outreach resulting in shelter placement (corresponding to HHAP Measure 6), despite stakeholder input verifying that this is occurring regularly. Therefore, there is a need to investigate further if other HMIS features or fields are not being properly utilized and strategize accordingly.

CAPACITY BUILDING FOR STANDARDIZED DATA PRACTICES
The aim is to leverage the use of the HMIS toward an improved regional Coordinated Entry System. However, without standardized practices for monitoring the quality and consistency of data entry practices, measures of progress and impact are unreliable. Input from stakeholders made it clear that some organizations will require capacity building to implement sophisticated data monitoring systems. Capacity building can establish clear and common definitions, emphasize the importance of accurate data maintenance, demonstrate the ways that data can be used for reporting and program improvement, and illustrate the need for transparency.

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DATA SHARING AGREEMENTS

Encouraging collaboration and data sharing among stakeholders should also be revisited – while there are concerns about data ownership, confidentiality, and competition for funding, partners can establish agreements that conform to HIPAA while minimizing duplication and enabling providers to support individuals already in the system. An outreach worker explained the need and the feasibility of more generous and flexible data-sharing arrangements:

These challenges underscore the need for improvements in data management practices, communication strategies, resource allocation, capacity building, and collaboration efforts to enhance the effectiveness of performance monitoring in addressing homelessness. Limited financial and human resources have impeded efforts to establish robust data monitoring systems; increased investment in infrastructure, technology, and staff training may be necessary to achieve the required level of data tracking.

REGIONAL PLANNING FOR LAND USE AND HOUSING
The challenges in regional planning for land use and housing encompass managing housing density, ensuring regulatory consistency, balancing rural-urban development, protecting high-resource areas, aligning housing density with transit infrastructure, and addressing disparities among marginalized communities.

Housing Density Management: The challenge of
managing housing density is a persistent and prominent
theme in discussing regional land use. As the region’s
population continues to grow, it is important to build
infrastructure with the capacity to support an increasing populace, and the community must figure out how to
incorporate high-density housing into its plans.

Stakeholders suggest that task forces be formed to
analyze zoning regulations and infrastructure
requirements for sustainable housing density.

Consistency In Permits and Restrictions: Ensuring consistency in permit processes and regulations across different cities and unincorporated areas in the region is crucial for streamlined development regulatory consistency. This requires high collaboration among departments to minimize barriers, confusion, and needless land use and housing development delays.

Rural-Urban Development Balance: Stakeholders, particularly those supporting homeless populations outside the region's most populous city, emphasized the need to balance development efforts between rural and urban areas. Data-driven decision-making can help ensure the needs of both rural and urban communities are met effectively.

Protection of High-Resource Areas: Some stakeholders highlighted the need to identify and protect high- resource areas through land conservation and ensure that land use and housing development decisions are “We must be proactive in planning for the
projected growth of the San Joaquin Valley in
the next five years, with many people moving
from the Bay Area and the East Bay to find
more affordable Housing.”

Participant, Key Stakeholder Interviews
“For field teams to be on the release of information at the county level is key. I’ve seen it in other counties…[where] everyone was on the [HIPAA] release of information because we didn’t want barriers, even on the phone. There still had to be encryption, but it lowered the fence…It’s beneficial for our clients – if anyone has a resource, we should know about each other. It’s all connected:
substance abuse, mental health, criminal justice, homelessness…There needs to be a feedback loop among providers.”

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made sustainably and ecologically responsible. Collaboration with relevant departments and agencies is necessary to designate and protect these areas effectively.

Transit Infrastructure and Housing Density: Balancing housing density with transit infrastructure development is crucial for efficient urban planning. The Transportation Department plays a key role in coordinating these efforts.

Disproportionalities in Homelessness: Addressing the highly disproportionate rate of homelessness among Black community members is a critical challenge that arises in connection with every form of support along the continuum of care. Within regional planning for land use and housing, this theme underscores the need for targeted strategies to address systemic inequalities and provide equitable access to housing and supportive services for marginalized communities. To remedy the disparate rate at which Black residents experience homelessness in the region, their rate of achieving successful outcomes must not simply be commensurate to those of their non-Black peers – to effect equity, Black clients’ “risk” of positive outcome must be equal to their risk, relative to other residents, of experiencing homelessness in the first place.

Planning for land use and housing is one of the many critical areas where strategies may be designed with the express intent of reversing these disparities.

These challenges necessitate collaborative efforts and strategic planning involving various departments and stakeholders to achieve equitable and sustainable urban development.

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VII. APPLICATION TABLES
Roles and Responsibilities (Table 2.1)

OUTREACH
San Joaquin County, the City of Stockton, and the SJCoC will work together to ensure that outreach efforts enact and sustain a co-responder outreach model (the joint engagement of emergency services personnel, health/behavioral health professionals, and people with lived expertise and experience) wherein law enforcement agencies employ best practices in homeless outreach, focused on connecting individuals with supports (rather than arrest and other forms of enforcement). San Joaquin County, through its departments, will oversee the coordination and implementation of this model throughout the region. The City of Stockton will facilitate conversations as needed with counterparts in the City of Lodi, the City of Manteca, and the City of Tracy to educate and garner support for the implementation of this best practice. The SJCoC will ensure that people with lived experience and expertise in homelessness will remain central to the implementation of the model and that deliverables are met and measured accurately.

Participating
Jurisdictions
Role(s) and Responsibilities in Outreach and Site Coordination San Joaquin
County
• Is responsible, through Probation, for ensuring the replication of a co-responder outreach model wherein law enforcement agencies employ best practices in homeless outreach, focused on connecting individuals with supports (rather than arrest and other forms of enforcement);
• Is responsible, through BHS, for ensuring that there is sufficient staffing to ensure access to field-based (mobile) mental health assessments and that all assigned mental health /community health outreach workers have sufficient training and capacity to link homeless individuals to needed behavioral health service. • Is responsible, through Whole Person Care, for creating a regional screening and referral pathway (triage tool) to escalate case management and treatment for individuals likely to have serious mental illnesses or other disabling conditions.

SJCoC • Is responsible for centering people with lived expertise and experience as influential members of SJCoC, alongside homeless service practitioners, community members, and responsible professionals in seeking and implementing opportunities to strengthen outreach and site coordination.

City of Stockton • Is responsible for working with leaders across all San Joaquin municipalities (and unincorporated areas) to promote a co-responder outreach model (the joint engagement of emergency services personnel, health/behavioral health professionals and people with lived expertise and experience) wherein law enforcement agencies employ best practices in homeless outreach, focused on connecting individuals with supports (rather than arrest and other forms of enforcement)

LAND USE AND DEVELOPMENT
Continued coordination among jurisdictions, departments, agencies, and the community is vital to effectively use available land to combat homelessness in the region surrounding the City of Stockton.

Collaboration between the City of Stockton and neighboring cities like Tracy, alongside adherence to state and federal directives, is key for comprehensive land use planning. Priorities include pro-housing designations, homelessness mitigation, density promotion in transit corridors, and adaptive reuse of commercial spaces. In San Joaquin County, coordinated efforts among community departments are crucial for sustainable and equitable development, focusing on common issues and leveraging expertise.

Collaboration between the City of Stockton and San Joaquin County is essential, emphasizing themes like collaboration, process streamlining, density optimization, and high-resource area protection. By incorporating these recommendations and fostering collaboration among stakeholders, the region can

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create inclusive, sustainable communities that enhance residents' quality of life while supporting economic growth.

Participating
Jurisdictions
Role(s) and Responsibilities in Land Use and Development San Joaquin County
(Neighborhood
Preservation
Department and
Collaborative Applicant)
• Is responsible to align and leverage all available funding to the purposes of the Action Plan, including developing a regional list of homeless housing pipeline projects.
• Is responsible for facilitating grant and tax credit applications for eligible applicants.
• Is responsible to align federal HOME and CDBG funding opportunities towards affordable housing (particularly in high resource areas) and community improvement projects (particularly in low resource areas).

SJCoC • Is responsible to focus public awareness and education initiatives to address misconceptions and foster community support. Provide education resources to enhance understanding of homelessness issues. Provide support at public hearings regarding land use to ensure community engagement. • Is responsible for supporting and coordinating needs assessments to identify gaps and allocate resources effectively. Encourage developers to invest in the county and promote development initiatives.
• Is responsible to implement targeted services for the homeless population and work with development teams on creating service-rich and sustainable housing opportunities.

City of Stockton • Is responsible for creating a positive and receptive affordable housing landscape. Prioritize creating a pro-housing environment and offering more housing options for homeless individuals. Emphasize density-oriented development over transit considerations. Explore adaptive housing approaches tailored to the homeless population. Integrate commercial multi-family housing. • Is responsible to collaborate with municipal partners to craft a shared approach for engaging and organizing local communities, including developing strategies for homeless outreach, emergency sheltering, and affordable housing development. Collaborate with different departments and neighboring cities to identify high-resource areas for housing solutions.
• Is responsible to align federal HOME and CDBG funding opportunities towards affordable housing (particularly in high resource areas) and community improvement projects (particularly in low resource areas).

Other County and City
Departments:

Planning / Community
Development
• Is responsible to create local policies that emphasize housing density to maximize available space, identify and prioritize high-resource areas for housing solutions, explore the integration of commercial multi-family housing and adaptive solutions and remove barriers to development, particularly for affordable housing projects.
• Is responsible to facilitate opportunities for cross-jurisdictional collaboration on land use and development of projects to house homeless individuals. Ensure consistency in permits and restrictions to streamline development. • Is responsible to tailor approaches to suit the unique challenges of rural and urban areas.

DEVELOPMENT OF INTERIM AND PERMANENT HOUSING OPTIONS
Interim and permanent housing initiatives in the City of Stockton and San Joaquin County involve collaboration among city governments, service providers, faith-based organizations, and funders to address

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homelessness. Key themes such as funding, accountability, partnerships, and sustainability guide these efforts, aiming to provide holistic support to homeless individuals and families. Strategies in San Joaquin County prioritize behavioral and public health support, county coordination, neighborhood preservation, and housing sustainability.

The SJCoC focuses on standardized policies and a low-barrier approach, enhancing collaboration with local decision-makers. This coordinated effort involves various stakeholders and emphasizes sustainability, selective support, effective assessment, and reporting. Priority initiatives within this strategy area include:

 Create a housing-focus framework.
 Create uniform policies for rapid rehousing programs.  Create protocols for innovative housing solutions, including master leasing or landlord incentives.

The Interim and Permanent Housing Program relies on collaboration among property management, developers, managed care providers, and human services agencies to address housing needs effectively.

Continued coordination, advocacy, and support are essential for program success.

Participating
Jurisdictions
Role(s) and Responsibilities in Development of Interim and Permanent Housing Options
San Joaquin County • Is responsible for promoting housing focused shelters and transitional housing programs and permanent housing solutions with wrap-around case management, treatments, and other behavioral interventions.
• Is responsible for facilitating the collaboration among stakeholders and serves as the collaborative applicant.
• Is responsible for integrating county human and behavioral health services into major shelters.
• Is responsible for formulating policies, aligning, and leveraging funding, conduct comprehensive reviews of existing information systems, and allocating Homeless Housing Assistance and Prevention (HHAP) Round 5 funds according to agreed-upon categories.

SJCoC • Is responsible for promoting interim and permanent housing options, establishing best practices and guidelines, and offering technical assistance to higher barrier shelters and sober living environments.
• Is responsible for attending local council meetings to advocate for homelessness solutions and ensuring effective communication of pertinent information. • Is responsible for overseeing the general oversight and stewardship of the homeless service continuum, ensuring that all partners are developing and delivering interim and permanent housing as planned.

City of Stockton • Is responsible for allocating funding and issuing NOFAs for the development and/or operation of interim and permanent housing options to combat homelessness. • Is responsible for collaborating with shelters, law enforcement agencies, and other partners to enhance homeless outreach teams’ ability to engage with and link to emergency sheltering or other housing solutions. As well as monitoring contracts to ensure expectations are being met.
• Is responsible for addressing concerns about shelter effectiveness, shelter-hopping behavior, and high barriers to entry through contracting and performance-based evaluations.

Other County
Departments:

Behavioral Health
Services
Whole Person Care
Public Assistance
• Is responsible for ensuring housing sustainability for people with SMI/SUD through treatment, case management, and assistance with independent living skills as needed.
• Is responsible for verifying eligibility for clients enrolled in Medi-Cal to ensure continued capacity to receive benefits, supporting housing stability efforts.

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COORDINATION AND CONNECTION TO SERVICE DELIVERY
All participating jurisdictions in the region are working to establish a coordinated framework to provide a full array of services, including interim and permanent housing solutions, to people experiencing or at risk of homelessness. This effort involves creating standard operating procedures (SOPs) to ensure uniformity and efficiency in service delivery, establishing shared data and contract standards among entities like the City of Stockton and San Joaquin County, and designating positions for effective collaboration between county and city entities. By synthesizing feedback, grouping information, and standardizing procedures, data, and responsibilities, these coordinated efforts aim to enhance collaboration and improve outcomes for the community, effectively delivering quality services to those in need.

Participating
Jurisdictions
Role(s) and Responsibilities in connection to Service Delivery San Joaquin
County
• Is responsible for developing protocols and managing data sharing requirements across relevant providers and partners, to streamline collaboration. • Is responsible for revamping standard operating procedures and data sharing agreements for the Homeless Management of Information System (HMIS) among providers and partners throughout the region, including:
o Reviewing all program specific data points and ensuring that there are specific and uniform definitions for services that overlap between two or more programs.
o Developing and communicating coordinated and aligned contracting agreements and performance monitoring expectations regarding the use of HMIS by funded sub-recipients (including Invoice Specifications); o Facilitating homeless service provider access to the HMIS system, allowing them to track activities and effort by program staff and determine whether activities are leading to desired outcomes.
o Establishing programmatic rules and expectations regarding the Release of Information and the use of HMIS for case coordination; and o Supporting SJCoC in producing annual program evaluations based on the evidence of effort, impact, and timeliness of activities as measured in aggregate through HMIS, confirmed through independent monitoring and analysis Enhance.
• Is responsible for issuing and managing contract standards among the City of Stockton, San Joaquin County, and other relevant entities.

CoC • Is responsible for, in partnership with San Joaquin County and County Counsel, re- negotiating the Collaborative Applicant Agreement and updating SJCOC’s Governance Charter and HMIS/CES Lead Agency Agreements to meet new federal guidance, align with state regulations, and achieve local expectations (including capacity to use the HMIS as a component of sub-grantee performance monitoring). • Is responsible for reviewing the current Board composition and updating the nomination and selection process, specifically to ensure the voice of people with lived experience and expertise in homelessness.
• Is responsible for reviewing community input and re-examining its committee structure: The SJCoC will develop a Finance and Performance Review committee and reimage the purpose and need for the following committees: Coordinated Entry System Committee, Data and HMIS Committee, Education and Membership Committee, Resource Development Committee, and the System Performance and Evaluation Committee.

City of Stockton • Is supporting the SJCoC and San Joaquin County, in partnership with County Counsel, and with guidance from the assigned HUD CoC Technical Assistance representative, to update the Governing Charter and By-laws with new sections, consistent with federal and state regulations and best practices addressing Conflict-of Interest Policy, Committee Structure, Board Composition with fixed representative seats, and Board Member Recruitment to Engage and Sustain PLEE.

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• Is committed to working with the County to develop standardized and aligned processes for procurement, contract monitoring, and accounting to facilitate shared performance monitoring.

Managed Care
Plans
• The Health Plan of San Joaquin (HPSJ), in partnership with HealthNet, will deliver service coordination and data management initiatives.

Key Actions to Improve Performance (Table 2.2)
Measure 1a: The number of people accessing services who are experiencing homelessness.

Measure
11,722

Across the four years from 2020 to 2023, efforts were made to monitor Measure 1a: the number of people accessing services while experiencing homelessness. In 2020, this count began at 9,421 individuals.

However, the subsequent year saw a 5% decrease, bringing the countdown to 8,931 individuals in 2021.

There was a significant upsurge in 2022 with a change in how the state decided to better measure and count data, resulting in a 34% increase from the previous year, raising the count to 11,977 individuals.

Thinking of this as a “new baseline,” 2023 shows a slight decrease of 2% from 2022, resulting in a count of 11,722 individuals.

Key Actions Measuring Success of Action
Revise the Collaborative Applicant Agreement Task Complete as Scoped Standardize procurement process Task Completed as Scoped Revise the Coordinated Entry System prioritization
process
CES updated as scoped. Integrated to HMIS.

Advocate for funding and approvals to develop new
housing.

Projects are approved and funded

Measure 1b: The number of unsheltered homeless in the SJCoC’s Point-in-Time Count (on a single day) Measure
1,355

From 2020 to 2023, there has been a consistent effort to measure the number of people experiencing unsheltered homelessness in the SJCoC's Point-in-Time Count on a single day, designated as Measure 1b. In 2020, the count stood at 1,558 individuals, but unfortunately, there was no data available for the subsequent year, 2021. However, in 2022, there was a notable 13% decrease from the baseline of 2020, bringing the count down to 1,355 individuals.

Key Actions Measuring Success of Action
Develop and replicate the CARE model Program implementation.

Program adoption, officers trained, partnerships formed.

Link street medicine Teams to CARE Program Implementation Create a regional screening and referral protocols Triage tool and referral protocols established for field use, hospital discharge and jail releases.

Invest in the operations of existing low barrier and
housing focused interim housing programs, including
support services
Shelter utilization rates increase.

Shelter exits are more consistently tracked.

Measure 2: The number of people accessing services who are experiencing homelessness for the first time.

Measure
6,211

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Over the course of four years, from 2020 to 2023, efforts have been made to track the number of individuals accessing services who are experiencing homelessness for the first time. In 2020, this count began at 4,715 individuals. The following year, there was a notable decrease of 7%, bringing the count down to 4,348 individuals.

Again, with a change in methodology to better capture information, numbers jumped significantly in 2022, raising the count to 6,485 individuals and establishing a “new baseline.” In 2023, there was a 4% decrease from 2022, resulting in a count of 6,211 individuals.

Key Actions Measuring Success of Action
Develop regional Rapid Re-housing Strategy People with RRH vouchers obtain housing within 70 days.

Invest in RRH Prevention strategies People with RRH vouchers obtain housing within 70 days.

Measure 3: The number of people exiting homelessness into permanent housing.

Measure
1,169

Over the course of four years, from 2020 to 2023, significant fluctuations have occurred in the number of individuals exiting homelessness into permanent housing. In 2020, the count stood at 977 individuals. The following year saw a slight decrease of 6%, bringing the count to 913 individuals. However, in 2022, there was a 39% increase from the previous year, with the count rising to 1,273 individuals. 2023, saw an 8% decrease in placements from 2022, bringing the count down to 1,169 individuals, or about 10%. Fluctuations in housing availability are the largest contributing factor (supply) to the variation rather than changes in the need for placement (demand).

Key Actions Measuring Success of Action
Develop Housing-focused shelter model Interim Housing Programs have trained housing navigators.

Invest in the operations of existing low barrier and
housing focused interim housing progs, including housing navigation / CM staff.

Shelter placement rates increase
Invest in Permanent Housing Acquisition, Construction,
and ongoing operating subsidies and services
Additional Units approved and funded for development.

Additional $45 million leveraged.

Target goal = 100

Measure 4: The number of days people remain in homelessness.

Measure
76 Over four years, from 2020 to 2023, there have been small fluctuations in the length of time people remain homeless before receiving a placement. Annual averages range from a low of 72 days to a high of 85 days. In general, this data point is a poor measure of the length of time people remain homeless because data is only analyzed for the small proportion of people who are known to have received housing (10%) and does not calculate the length of time homeless for the remaining 90% of individuals and families who either continue to be homeless or have been “lost” to system partners with unknown outcomes. This data will become more relevant with updates to the HMIS system and a new focus on housing navigation within emergency shelter programs. These strategies will improve the validity of the data.

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Key Actions Measuring Success of Action
Develop regional CARE model Program implementation
Invest in the operations of existing low barrier and
housing focused interim housing programs including
housing navigation & support services
Shelter placement rates increase
Develop regional Rapid Re-housing Strategy People with RRH vouchers obtain housing within 70 days.

Invest in RRH Prevention strategies People with RRH vouchers obtain housing within 70 days.

Measure 5: The percent of people who return to homelessness within six months of exiting the homelessness response system to permanent housing.

Measure
11%

Over the four years from 2020 to 2023, there have been small fluctuations in the length of time people remain homeless prior to receiving a placement. Annual averages range from a low of 6% days to a high of 19% days.

Key Actions Measuring Success of Action
Increase investments in Permanent Housing Solutions
(case management services)
Sufficient services (experienced and capable staff) are available.

Return rates decrease to 6%
Develop guidance and expectations.

Monitor Contracts.

Ratio of clients to staff
Utilization: Case Management per client.

Utilization: Cost per Client.

Assess by: Mean, Mode, Quartile

Measure 6: The number of people with successful placements from street outreach projects.

Measure
6 In general, this data point is a poor measure of the work of outreach workers to successfully place individuals and families in interim and permanent housing programs. This data will become more relevant with updates to the HMIS system and enhanced coordination between outreach and shelter partners under the CARES model. These strategies will improve the validity of the data.

Key Actions Measuring Success of Action
Review of existing information systems Outreach Elements Added Update HMIS data elements and permissions Provide access to shelter bed counts / openings on an as- needed basis for field staff.

Geo-code activities.

Upload data from mobile app.

Develop regional CARE model Reduce duplication of service. Coordinate service delivery. Outreach activities entered into HMIS.

ESRI dashboard model adopted using ArcGIS
Create a regional screening and referral protocols Triage tool and referral protocols established for field use.

Equity Improvement Plan (Table 2.3)
Key Action(s) the Region Will Take to Ensure Racial and Gender Equity in Service Delivery.

Key Actions(s)
Update the Governance Charter and Bylaws

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Revise SJCoC Board Nomination Process
Update HMIS to Data Elements
Standardize Procurement Process

Key Action(s) the Region Will Take to Ensure Racial and Gender Equity in Housing Placements.

Key Actions(s)
Assess homeless housing and service needs
Update CES prioritization process
Update Rapid Re-housing Protocols

Key Action(s) the Region Will Take to Ensure Racial and Gender Equity in Housing Retention.

Key Actions(s)
Invest in housing support services
Monitor contracts for performance

Key Action(s) the Region Will Take to Change Procurement or Other Means to Affirm Equitable Access to Housing and Services for Overrepresented Groups Among People Experiencing Homelessness in the Region.

Key Actions(s)
Develop shared approach to measuring and prioritizing organizational capacity to address disparities as a component of application review
Develop shared contractor expectations for staff training, qualifications Create joint County/City review process using neutral third parties Develop shared accounting and contract monitoring protocols Regularly measure unique clients served, by demographics, service utilization, and costs per client by service activity Conduct annual system reviews to determine change over time related to overrepresentation of Black / African American individuals and families as a proportion of those experiencing homelessness and as a proportion of those experiencing homelessness for the first time.

Improving Exits from Institutions (Table 2.4)
Key Action(s) to Reduce the Number of People Experiencing Homelessness upon Exiting a Jail.

Key Actions(s)
Implementing a voluntary re-entry program within a live-in complex.

Desired Result: Diminishing recidivism and homelessness while enhancing self-sufficiency.

Designating specialized HSA Staff to address the public benefit needs of homeless individuals transitioning from jails and prisons.

Desired Result: Ensure expertise in maintaining benefits.

Initiating changes in pre-release and release practices.

Desired Result: Generating effective measures that eliminate or minimize obstacles to coordination, resulting in streamlined linkages to services and improved outcomes.

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Key Action(s) to Reduce the Number of People Experiencing Homelessness upon Exiting a Prison.

Key Actions(s)
Expanding transitional housing services inclusive of mental health support, life skills training, and housing assistance.

Desired Result: Fostering stability and ultimately facilitating the transition to permanent housing as a long-term objective.

Implementing job training initiatives complemented by supportive services and educational programs.

Desired Result: Achievement of stable employment for participants leads to a decrease in recidivism rates.

Key Action(s) to Reduce the Number of People Experiencing Homelessness upon Exiting a Hospital.

Key Action, Lead and Collaborating Entities
Update HMIS processes, data values, and permissions to create unified criteria and enhance collaboration between hospitals and shelters.

Desired Result: Facilitating a seamless transition and warm handoff process between hospitals and shelters for individuals in need.

Implementation of a uniform (shared) communication tool.

Desired Result: enables real-time access to bed availability, facilitating efficient resource management.

Key Action(s) to Reduce the Number of People Experiencing Homelessness upon Exiting Other Institutional Settings (such as Foster Care, Behavioral Health Facilities, etc. as applicable in the region).

Institutional Setting Key Action(s)
Behavioral Health Facilities Create incentives for landlords and ensure completion of coursework with tenants for application processes.

Desired result is to establish a 24/7 on-call service to support both clients and landlords effectively.

Behavioral Health Facilities Conducting regular check-ins with collaborating agencies and establishing a shared data system to better support our clients.

Desired result: Encompass expanding our workforce, providing education opportunities, and enhancing engagement and outreach with colleges and vocational studies.

Behavioral Health Facilities Invest in wrap around case management and support services for people in permanent housing.

Desired Outcomes: Streamline strategies and establish a common flow to assessment levels, ensuring referrals to and support services are centralized into a one-stop system for enhanced accessibility and efficiency.

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VIII. STRATEGIC APPROACH

To date, the regional partnership has made important and meaningful progress in addressing homelessness.

Through focused efforts, the region has accomplished the following:
 40% increase in emergency shelter utilization.
 180 new units of affordable homeless housing.
 2% decrease in people using homeless services.
 13% decrease in unsheltered homelessness.
 4% decrease in first-time homelessness.

However, significant work remains.
 There are acute disparities in who becomes homeless, with African Americans accounting for 31% of all homeless individuals despite representing 10% of the population.  Only 10% of homeless individuals are successfully placed into permanent housing.  According to the data, there are almost no linkages from outreach to placement (though questions have been raised about the validity of this data).
 There are rising numbers of people who are over 55 experiencing homelessness (20%)  Homeless individuals with substance use disorders are the least likely to become housed. People with mental illnesses are also finding greater than average difficulty in finding housing.

Further, as described in the key findings above, there are complex systems barriers that are impeding progress, including:
 Lack of effective regional planning for homeless housing.  Inefficient stewardship of resources.
 Inconsistent and invalid data.
 Stand-alone and outdated data systems do not do enough to foster collaboration and linkage between programs, make planning difficult, and limit contract monitoring.  Management and governance structure that is no longer responsive to system needs.

Systems Change Projects Program Investments
Strengthen foundational aspects of SJCoC Support targeted outreach and case management for vulnerable and underserved populations
Develop regional practice expectations Support low-barrier emergency shelters adopting housing focused approaches
Refine the procurement, contracting, and monitoring
processes Expand Rapid Rehousing program for unsheltered individuals Improve data quality, data systems, and data analysis to improve decision-making
Expand the supply of permanent housing for homeless
individuals and families.

Invest in staff, training, and expertise (including PLEE) to grow and strengthen the continuum

Improve Coordination of Services

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Coordinated Use of Leveraged Resources (Table 2.5)
Funding Program Coordinated Use of Funds Est. Budget
T.B.D.

Homeless Housing Development (Acquisition and Development) Homekey Funds are received from state and federal sources and administered by the County, the City of
Stockton, and Behavioral Health Services. To the
extent possible funds are braided together to
secure sufficient local match to apply for loans or
other financing. More regional coordination is
needed.

Pending
HOME Investment Partnership
Permanent Local Housing Allocation
HHAP
Local Governments City Grants
Other Permanent Housing Solutions – including RRH
CoC Program Competition Funds Funds are allocated to sustain people currently in permanent supportive housing and to provide new
RRH vouchers and case management services as
feasible.

Emergency Solutions Grant
MHSA
HHAP
Interim Housing
Emergency Solutions Grant Funds are allocated for low-barrier shelter operations. Moving forward, more resources will
be dedicated to housing navigators and case
management through HHAP and enhanced care
management (ECM) services under local managed
care plan partners.

HHAP
Local Governments City Grants
Managed Care Plans Billable Services

Outreach and Service Coordination
Public Safety Realignment Probation will manage the coordination of behavioral health, street medicine teams and
others for most outreach efforts in coordination
with local law enforcement agencies, and with
some reimbursements through ECM billable
services.

HHAP will fill gaps by funding targeted outreach
and service coordination for youth and other
vulnerable populations.

TBD
Local Governments Varies

MHSA / PATH
Managed Care Pans Billable Services
HHAP
Systems Support
Local Governments Local governments provide small, and one- time grants to CBOs for local capacity building
projects.

Varies
HHAP HHAP system support funds will be used to hire
staff or procure technical assistance to: develop
regional practice guidance, assess, and revamp
data systems, train program partners, create and
manage content for a website to disseminate
information and coordinate activities, and
evaluate system performance.

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IX. KEY ACTIVITIES: PROJECT SUMMARIES
Strengthen the Foundational Aspects of the SJCoC
The SJCoC incorporated as a mechanism to receive about $6.5 million annually in HUD Continuum of Care Program Competition and Planning grant funds annually. Since then, an increasing proportion of residents have been living unhoused or teetering on the brink of homelessness. However, as homelessness has worsened, (particularly in California, which accounts for 28% of all people experiencing homelessness in the nation) and more people are living unsheltered (68% of homeless in California), in conditions not humane or fit for human habitation, new funds and guidance are being directed at communities to address homelessness1.

The SJCoC’s Governance Charter was first created in 2013 and reimagined in 2018; while minor updates have occurred, the Charter is largely the same as conceived in 2018. Consistent with the discussion above, the Governance Charter should be updated to reflect broader expectations beyond the management of the CoC Program Competition, including alignment with State regulations and local priorities.

Stakeholders and community feedback suggest improving coordination and collaboration is the highest priority for the SJCoC and its partners. As a first step, it is important to reframe the SJCoC’s role as one that is actively involved in creating and implementing regional strategies and having a measurable impact on reducing homelessness as it is experienced in San Joaquin County today.

More broadly, the CoC is designed to promote community-wide planning and strategic use of resources to address homelessness; improve coordination and integration with mainstream resources and other programs targeted to people experiencing homelessness; improve data collection and performance measurement; and allow each community to tailor its program to the particular strengths and challenges within that community2.

Activities:

1. Revise the Collaborative Applicant Agreement to address identified deficiencies in roles and responsibilities and incorporate new local and state expectations.

2. Update the Governing Charter and Bylaws to address identified deficiencies in the Conflict-of- Interest Policies.

3. Update the Governance Charter and Bylaws to expand participation on the SJCoC Board, including fixed seats for city staff and department leaders and for more people with lived experiences in homelessness, including homeless youth and other populations overrepresented in homelessness.

Conduct the HUD-mandated review and updates to the SJCoC Board Nomination Process in accordance with regulations.

4. Revisit the committee structure within the Governance Charter to address purpose and conflicts.

5. Update the SJCoC Website

1 US Department of Housing and Urban Development, 2023 Annual Homelessness Assessment Report to Congress. 2 US Department of Housing and Urban Development, 2012 Program Guidance: Establishing and Operating a Continuum of Care.

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COLLABORATIVE APPLICANT AGREEMENT
As a first step, the Collaborative Applicant Agreement will be updated to clarify the roles and responsibilities of the County and articulate the appropriate responsibilities of the SJCoC Board to oversee the work of the Collaborative Applicant. Tasks and activities best completed by dedicated staff members are conducted by County personnel or their contracted agents as the Collaborative Applicant.

The Collaborative Applicant Agreement will be updated to articulate responsibility for tasks associated with clearly:
 Procuring funding from all eligible state and federal sources.  Accounting and managing the allocation of funds to sub-recipients.  Contract and performance management of sub-recipients, including a regular independent system- wide program evaluation that includes progress in achieving equity-driven performance measures.  Administering the CoC Program Competition Process with fidelity to HUD regulations and intent.  Enabling data collection and information sharing consistent with federal and state requirements and local priorities.
 Communicating needs, strategies, performance, and impact to the public.

CONFLICT OF INTEREST
HUD has released new conflict of interest guidance for review and incorporation into the Governance Charter as applicable. Pertinent to the this Action Plan is the commitment to more transparency and clarity in matters pertaining to:

 Defining actual and perceived conflicts of interest.
 Clarifying allowable benefits from gifts or gratuities.  Procedures for disclosing conflicts of interest annually and as they arise.  Recusal procedures for discussions, votes, and rank and review processes.  Policies to ensure transparency and awareness of conflict-of-interest processes.  Procedures for intentional or unintentional violations of the policies.

The SJCoC Board, in partnership with the Collaborative Applicant and other stakeholders, should review and make recommendations on updated Conflict-of-Interest policies within the Governance Charter as soon as possible and bring these back to the general membership for consideration.

BOARD COMPOSITION
HUD requires that CoCs review, update, and approve the selection process for CoC Board members at least once every five years. This action is overdue.

The SJCoC Governance Charter currently calls for a minimum of 13 board members and a maximum of 21.

Currently, 11 active Board members are listed as attending SJCoC meetings. The immediate recruitment of new members is required.

Currently, the sJCoC Governance Charter does not clearly indicate the required Board members. HUD regulations for CoC Board composition requires:

 One homeless or formerly homeless individual is to serve on the CoC board, though more are preferred. Homeless individuals are those that have been homeless within the past seven years.

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 Representatives of the relevant organizations and projects serving homeless subpopulations.

And indicates that:
 One board member may represent the interests of more than one homeless subpopulation.  HMIS lead agencies, Collaborative applicant staff, etc., are not mandated board members.  State and Federal regulations and guidance suggest that some consideration of BIPOC, LGBTQIA+, mobility limitations/disability inclusion, and Youth representation is allowable.

The SJCoC will work with community partners to review the current Board composition and update the nomination and selection process. Overall best practices suggest that there should be a balance between professionals working in systems that interact with the homeless response system and providers representing grant sub-recipients. Too many grant sub-recipients on the Board can jeopardize the capacity of the Board to have a discussion without breaking quorum through recusals.

Nearby Stanislaus County and Houston, Texas CoCs provide good examples of additional best practices for Board composition. These regions assign fixed representative seats to their CoC Boards. This helps engage high-level participation on their CoCs by local municipalities and public agencies. Local city governments and County agencies have pledged to support ongoing CoC efforts in San Joaquin County. It is recommended that fixed seats be allocated to the City Manager’s Office in each City for the designation of a CoC Board Member. Further, the Directors of the Public Agencies representing Behavioral Health Services, Human Services Agency, Probation, Public Health, and the local Housing Authority should be given discretion in appointing themselves or a high-level member of their leadership team to the CoC Board.

COMMITTEE STRUCTURE
Community stakeholders encouraged a re-conceiving of the committee structure to meet emerging community needs. Several committees currently detailed in the charter are inactive, others have outdated descriptions that no longer match needs, and others are missing, needed, or operating in a de facto fashion without formalization. Overall, stakeholders suggested fewer committees and more dedicated staff time to complete critical operational tasks.

The following changes to the committee structure are indicated:
 EXECUTIVE COMMITTEE : An executive committee meets on a de facto basis to plan CoC Board meeting agendas and other matters. There is also an ad-hoc nominating committee and a strategic planning committee dedicated to steering SJCoC’s responses to local needs and opportunities. The tasks of these three committees need to be more transparent and potentially combined. Formalized procedures for releasing and communicating the annual Open Invitation for New are ready for updates.3 Current CoC Board members and non-board members must participate in the development of processes and application review procedures, as well as ensuring PLEE, BIPOC, and LGBTQ+ representation. Finally, the Executive Committee should review agreements and contracts for services (such as the Collaborative Applicant, HMIS, and CES Lead Agency Agreements) annually and make recommendations to the Board for any updates to enhance performance or otherwise better meet the needs of the time.

 FINANCE AND PERFORMANCE COMMITTEE : Overall, one of the greatest challenges of the SJCoC is the lack of alignment between fund allocation and performance review. Most SJCoC Board members were unaware of the total amount of funds managed on their behalf through the Collaborative

3 US Department of Housing and Urban Development, FY 2023 CoC Application Detailed Instructions, See Question 1B-2 Open Invitation for New Members.

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Applicant, the status of grant awards and expenditures, or the extent to which impact is being realized through investments. While it is the Collaborative Applicant’s role to serve as the fiscal agent and accountant for the funds, that does not preclude the Board’s responsibility for monitoring and managing financial resources. In furtherance of federal and state guidance, collective stewardship is needed for major regional investments that pass through the SJCoC, the County, and the City of Stockton, which explicitly come with guidance to use in a coordinated and collaborative fashion to address homelessness. Finally, there is too little quantitative information about the impact achieved by contractors in meeting their fair share goals of state and federal performance measures.

The Finance and Performance Committee should review sub-recipient agreements and contracts on an annual basis to ensure that funds are being expended as anticipated, goals are being met, and impact is being achieved. This committee, at a minimum, should include joint City and County representation, excludes contracted sub-recipients, and consider joint review of HHAP funding allocations to ensure appropriate coordination and utilization of resources.

Additional tasks could include reviewing and updating the CoC Program Competition scoring rubric and evaluating local projects. As with all committees, participation by additional community members, including PLEE, BIPOC, and LGBTQIA+ representatives, is required.  INITIAL STANDING COMMITTEES : The SJCoC Board, jointly and with community input, will discuss and reimaging the purpose and need for the following committees:
o Coordinated Entry System Committee
o Data and HMIS Committee
o Education and Membership Committee
o Resource Development Committee
o System Performance and Evaluation Committee
Two of the committees, EDUCATION AND MEMBERSHIP and RESOURCE DEVELOPMENT , are functionally inactive. Review tasks to determine if any remain necessary and reassigned.

The SYSTEM PERFORMANCE AND EVALUATION COMMITTEE serves a HUD-required purpose of preparing the application for the CoC Program Funds. However, moving forward, and for the next CoC Program Application:
o More clarity is in the Collaborative Applicant Agreement concerning staff roles and responsibilities vs. the oversight or support roles of the (volunteer) Board members with respect to the design and implementation of the collaborative planning process, the development of funding priorities for the region, and the application itself. o Board members who are current or potential sub-recipients of CoC program competition funds should recuse themselves from any Board or Committee discussions or votes.

More work is necessary to strengthen the HMIS /D ATA COMMITTEE and the CES COMMITTEE .

Stakeholders repeatedly expressed concerns about the capacity and use of the two information systems. Specifically, stakeholders expressed concerns that after several years of implementation efforts, the CES software system still cannot pull information directly from the HMIS software system, resulting in duplication of effort and missed opportunities for improved coordination.

Additional concerns include:

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o Data Validity. The HMIS system contains too many errors or missing information to accurately inform decision-making. For example, the state HDIS data reports almost no work completed in one performance measure.
o Data Quality. The HMIS system has too many user-defined options, making data aggregation for performance monitoring challenging. Further, some organizations simply do not enter critical information without consequences.
o Access to Information. Partners need real-time access to information to improve linkage and referrals to resources, reduce duplicative case management activities, and prevent missed placement opportunities. Specific and useful data-sharing agreements (within the allowable use framework) are needed between program partners and clients who have signed a release of information.

Board members and other stakeholders have indicated that the work needed to strengthen the HMIS and CES systems is likely beyond the scope of their respective committees. The region needs a more thorough assessment and some of the work of the two committees should be combined and managed by paid staff or experienced information technology consultants. Resources for this time- limited project are available through HHAP-5 funding for systems support activities.

 OTHER COMMITTEES : There are currently regular meetings of Outreach Committees, a Housing Committee, a Shelter Committee, and the Youth Action Board. The greatest challenge of these committees is the lack of robust participation and overburdensome tasks. Despite the heroic efforts of the volunteer Board and community members of the committees, much work remains. Dedicated staff time will be assigned to committee efforts by the Collaborative Applicant or leveraged through additional county or city partners. Additional recommendations to strengthen services are in Section VI, below.

UPDATE THE SJCOC WEBSITE
The SJCoC’s website requires significant attention. A new website and communication plan are needed, along with dedicated personnel to keep content updated and stakeholders engaged. HHAP funds will be used to hire or contract a person or entity to manage the SJCoC website, social media postings, and communications to ensure ongoing transparency of activities and compliance with regulations and keep the public informed of local needs, opportunities, and resources.

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Develop Regional Practice Expectations
ACTIVITIES:

1. Outsource, or otherwise assign to neutral third parties, the 2024 CoC Program Competition Process.

2. Develop a regional and coordinated list of homeless housing pipeline projects.

3. Develop regional Rapid-Rehousing funding and practice expectations.

4. Develop protocols for landlord incentives. Provide a template for master-lease projects.

COC PROGRAM COMPETITION
There are currently insufficient Members of the SJCoC Board with the time and capacity to manage the CoC Program Competition Process who are free of any perceptions of conflict of interest. Board members have raised this concern with the Collaborative Applicant, and steps are being taken to shift responsibility to neutral parties. Guidance regarding the management of the process will be received through the HUD Technical Assistance Team and help inform processes moving forward.

REGIONAL HOMELESS HOUSING COORDINATION
The San Joaquin region needs a comprehensive and coordinated strategy for developing new homeless housing units. Clarity on the criteria for HACSJ to prioritize and assign project-based housing vouchers is also needed. Long-term agreement, understanding, and alignment on available sites and locally available funds across all jurisdictions and partners will streamline the development approach. Enhanced partnership between the County, Cities interested in promoting affordable housing, and the Housing Authority is recommended to create a Regional Homeless Housing Development (RHHD) Plan. Core elements will include:
o List of pipeline projects and/or available land
o HACSJ’s strategy for allocation of project-based housing vouchers. o Coordinated project monitoring and program oversight.

RAPID REHOUSING PRACTICES
Develop regional Rapid-Rehousing funding and practice expectations. Clarify the allocation and monitoring of funds for eligible purposes associated with short-term rental assistance and support for homeless individuals vs. people at risk of homelessness. Clarify expectations for wrap-around support services and case management. Clarify rules and policies for landlord incentives. Develop a regional tracking system for accounting and monitoring purposes. Embed model within the procurement process.

CREATIVE HOUSING SOLUTIONS
Develop practice guidelines for other innovative and creative housing solutions, including master leasing and landlord incentives. Innovative solutions are needed to rapidly scale up the housing supply without the time constraints of acquisition and construction. Landlord incentives and master leasing can be wise investments – if implemented consistently in the region. Shared criteria for considering locations and units are needed to ensure consistency across jurisdictions. More coordination would be advantageous and potentially lead to a regional leasing strategy. Landlord incentives are another place where greater transparency between partners is beneficial. The primary purpose of a landlord incentive is to encourage “new” landlords to work with housing navigators. More coordination is required to ensure landlords and property management companies are not receiving multiple incentives from different programs.

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Refine Procurement, Contracting, and Monitoring
ACTIVITIES:

1. Standardize procurement process for HHAP-4 and HHAP-5 sub-grantee awards.  Develop a shared approach to measuring and prioritizing organizational capacity to address disparities as a component of application review.
 Develop shared contractor reporting requirements for demonstrating effort, fidelity, and outcomes, by program type.
 Develop shared contractor expectations for staff training, qualifications, and use of HMIS or CES to complete program activities.
 Release joint NOFA’s and create joint County/City review process using neutral third parties to reduce applicant burden.

2. Develop shared accounting and contract monitoring protocols to prevent service duplication between the County of San Joaquin and City of Stockton-funded projects.  Make allocations contingent upon achieving desired impacts.  Invest in external evaluation and independent performance monitoring.

3. Provide routine updates to the SJCoC Board regarding the obligation and use of CoC Program Competition, Emergency Solutions Grant (ESG), HHAP, and Homekey program funds.

4. Provide routine updates to the SJCoC Board regarding unique clients served, by demographics, service utilization, and costs per client by service activity.

Improve Data Quality and Data Systems
ACTIONS:

1. Develop a Uniform Approach to Data Collection Grounded in HMIS

2. Establish Consistent Measures for Similar Programs.

Increasingly, community stakeholders are calling for an overhaul of the way in which we collect, compile, and use data to inform decision-making. While there is overall satisfaction with the HMIS software program as relates to the recording of day-to-day program activities, there is growing concern about the capacity of the data system to aggregate information across types of programs and activities; produce regular and accurate standardized reports to inform in-the-field decision making; and to provide program monitoring information that is responsive to new performance metrics. A qualified, independent assessment of system performance and opportunities is needed.

Further recommendations include:

o Reviewing all program specific data points and ensuring that there are specific and uniform definitions for services that overlap between two or more programs. o SJCoC, the County, and the City should have coordinated and aligned contracting agreements and performance monitoring expectations regarding the use of HMIS by funded sub-recipients. Invoices for services should clearly demonstrate services completed (amount of work) and impact achieved (by assigned performance measures).

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o Homeless service providers should have access to a working and functional HMIS system that allows them to track activities and efforts by program staff and determine whether activities are leading to desired outcomes.
o Programmatic rules and expectations regarding the Release of Information and the use of HMIS for case coordination should be regularly monitored through data validity checks. o Annual program evaluations should be partially based on the evidence of effort, impact, and timeliness of activities as measured in aggregate through HMIS. Independent monitoring and analysis should be able to confirm reports and validate the completeness of data for both HUD reporting and program evaluation purposes.

Invest in Staff, Training and Expertise
A focus group was held on February 26, 2024, with the Re-Invent South Stockton and the Housing Justice Coalition to explore issues, root causes, and ramifications of disproportionate rates of Black and African American people experiencing homelessness or becoming newly homeless. Focus group participants shared thoughts and experiences pertaining to finding and maintaining housing in San Joaquin County. Among the root causes raised were the historic consequences of bank-backed redlining and disinvestments in Black and African American communities.

Stakeholders provided thoughtful suggestions on how SJCoC and its funding partners can work to overcome the harms of prior generations.

Culturally competent and effective service delivery is critical. Stakeholders were clear that the demographic characteristics of service providers are less important than the demonstrated competencies of highly qualified, professional providers. That said, service provider partners need to be diligent in working with a range of individuals, especially those who are most likely to be experiencing homelessness. Echoing the sentiment of a youth focus group conducted in the prior year, discussion group members talked about experiences of feeling judged or questioned by service providers based on dress, expression, or “attitude.” One young person reminded the group: “Of course, we are late, unorganized, dressed differently, and disrespectful - we are teenagers. That is essentially the definition of being a teenager. People who choose to work with teenagers should be prepared to work with teenagers. And like them.” More evidence-based practices training is needed across the field. All training should additionally include discussions of cultural expectations and trauma-informed service delivery to help service providers recognize and overcome unintentional bias. Contracting and performance monitoring will be updated to address expectations.

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Improve Coordination of Services
The SJCoC and its regional partners are committed to preventing and ending homelessness. Locally, there is a strong will and interest in reducing the number of families, veterans, people who are ill, escaping domestic violence, or otherwise suffering from multiple hardships who are living unaided, on the streets, and in hidden alleys, freeway underpasses, and drainage basins. Following concerns about the lack of housing options, the second greatest comment heard through the planning process was a plea to improve coordination of services and reduce duplication of effort. Stakeholders discussed the need for strong leadership and staff support to coordinate efforts between program partners. Two critical areas of practice improvement are discussed below.

COORDINATE OUTREACH EFFORTS
Support and partnership are requested of the San Joaquin County Probation Department to continue creating stronger and more effective coordination between emergency responders and service providers.

Versions of police-supported homeless outreach teams exist within each municipal region. Work is needed to ensure that best practices are being followed to decrease the sudden and unplanned displacement of unsheltered homeless individuals. Encampment sweeps, while popular for “clearing an area,” have far- reaching negative consequences that worsen the problem of homelessness by the (unintentional) destruction of important documents and records necessary for program enrollment or housing, misplacement/loss of medications or other assisted mobility devices, exacerbation of trauma and grief over loss of sentimental personal possessions or removal of pets, and decreased trust and faith in homeless service partners to assist people in overcoming homelessness.

San Joaquin County has selected the CARES Program model for coordinated street outreach and encampment engagement. Adapted from Stanislaus County, the CARES Program is rooted in best practices for mobile co-responder teams. Mobile co-responder teams bring a coordinated and collaborative approach to homeless outreach activities, often involving a range of partners, including street medicine providers, behavioral health professionals, and specially trained local law enforcement officers. Officers engaged in co- responding programs typically receive intensive training in community policing strategies, which include recognizing trauma, problem resolution, and de-escalation. Rather than a “mop and sweep” model, mobile co-response teams engage in long-term case management and support to move people from the streets and into services and housing programs.

To this model, the Probation Department can bring regional leadership and coordination, reduce duplication of effort, and enhance the training and protocols used by local law enforcement agencies in responding to situations involving people who are homeless. San Joaquin County Probation Department is one of the first in the State to implement a graduated rewards approach, evidence-based programming, and assessment- guided case management. Having county-wide jurisdiction and pre-existing relationships with local municipal agencies means the Probation Department is well-situated to work with local departments on enhanced practices and protocols. The Probation Department Training Division can also provide assigned community police officers training on motivational interviewing and effective practices for encouraging and supporting behavioral change.

Ongoing staff and programmatic support work includes:

 Coordinate outreach activities to reduce duplication of effort.  Ensure case coordination through the monitoring of HMIS activities.  Create uniform co-response strategies in partnership with local municipalities and existing homeless outreach teams.
 Facilitate regional discussion.

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HOUSING NAVIGATION
Support and partnership are requested of the San Joaquin County Human Services Agency (SJCHSA) to continue creating stronger and more effective coordination between eligibility workers and housing navigation teams to create housing-focused shelter programs.

Successful housing navigation is rooted in documentation and eligibility for public benefit programs. SJCHSA public assistance workers play a pivotal role in compiling documentation and ensuring eligibility. Over the years, SJCHSA has developed streamlined procedures for ensuring benefits are processed and approved in a timely manner to address critical safety net needs.

Ongoing staff and programmatic support work includes:

 Create uniform expectations and protocols for housing navigators to ensure clients are document- ready and eligible for a range of public benefits and housing support services, including rapid re- housing rental assistance vouchers.
 Enhance coordination and communication between outreach workers, housing navigators, and public social services teams.
 Provide feedback following any assessments of the community queue to measure whether this strategy is meeting the desired result of qualifying more individuals and families for housing support services and rapidly moving them into housing.
 Facilitate regional discussions on strategies to improve eligibility and document readiness for permanent housing.

SYSTEM SUPPORT PROJECTS TO BE COMPLETED THROUGH ALL AVAILABLE HHAP FUNDING The County, SJCoC, and the City agree to the following Key Actions for improving the operational performance and impact of state and regional funds allocated to the region for preventing and addressing homelessness. These operational change activities are largely derived from key informant interviews, survey suggestions, and the strategy and planning sessions held during the four planning workshops. These sessions largely focused on the question of how we can, as a region, advance our work and meet our performance goals. Strategy sessions focused less on “what is needed” and more on “how to get there.” Overwhelmingly, responses focused on strategies to improve coordination and collaboration, reduce unnecessary duplication of services, and develop better protocols for “doing the work.” Currently, too much of the work is “everyone’s job,” meaning the collective responsibility of the SJCoC. Moving forward, and through updates to the Collaborative Applicant Agreement and Governing Charter, more responsibilities can be shifted to paid County, City, or partner staff and TA providers (such as external evaluators). Unspent HHAP-3, HHAP-4, and upcoming HHAP-5 funds will be leveraged to create a stronger and more effective foundation to manage and coordinate activities at the client and program levels.

Further details about the Workshops, including participants, presentations, and activities, are included in the Appendix.

CORE PROJECTS

1. Strengthen foundational aspects of the SJCoC, to address deficiencies in (1) Board composition and nomination process; (2) Conflict of Interest; (3) CoC Program Competition scoring, solicitation, and review process; (4) Coordination on land use and development; (5) Financial and programmatic accountability and monitoring; and (6) Transparency / public communications.

2. Complete a comprehensive review of existing information systems to determine where they are working to enhance client-level coordination and collaboration, program management and

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monitoring, and system-wide assessments of performance measures, as well as where there are deficiencies based on regulations and Action Plan needs. Use recommendations to drive HMIS system improvements.

3. Complete a system-wide assessment of homeless housing and service needs as indicated by the selected performance measures and other key indicators. The System-wide assessment must include all relevant Federal and State initiatives, including but not limited to the CoC Program Competition, Emergency Solutions Grant (ESG), HHAP, and Homekey projects and activities.

4. Update and revise the Coordinated Entry System prioritization process. Prepare guidance and convene regional trainings to ensure consistent and effective use of the CES, including standardized assessment tools to triage needs and referrals.
o Update procedures to prioritize people who have primarily been living unsheltered for the duration of their most recent episode of homelessness, regardless of occasional use of shelter services or recent linkage pending placement. (In accordance with Encampment Resolution Fund Initiative.)

5. Develop a regional CARE model. Create a regional co-response model and routine practices for coordinating activities across jurisdictions and departments. Develop regional practices and training protocols for teams.

6. Create regional screening and referral protocols to escalate case management and treatment for individuals likely to have serious mental illnesses or other disabling conditions that require specialty interventions. Disseminate model and train program partners responsible for hospital discharge, jail release, and street outreach.

7. Develop a Housing-focused shelter model. Standardize expectations for housing navigation and case management within interim housing programs. Standardize practices for other services and supports, including substance use treatment, medication monitoring, counseling services, peer support, and legal advocacy services. Embed the model into the procurement process.

8. Create a practice kit for housing navigators. Articulate best practices and expectations for local program partners. Create uniform expectations and protocols for housing navigators to ensure clients are document-ready and eligible for a range of public benefits and housing support services, including rapid re-housing rental assistance vouchers.

9. Fund program staff and experts to complete and implement work as planned.

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X. FUNDING AND IMPLEMENTATION PLAN
Regionally, strong partnerships with managed care plan partners and the County’s Human Services Agency are a pivotal component of the implementation plan. Managed Care Plan partners were deeply invested into the local planning process, with leadership attending all public meetings and workshop discussions.

Similarly, SJCHSA has committed to senior leadership support and thought partnerships with the SJCoC and other local partners to refine linkages to eligible federal, state, and local benefit programs.

Connections to Benefit Program (Table 2.6)
Connections to Benefit Programs
CalWORKS
San Joaquin County Human Services Agency
(SJCHSA) is an integral and engaged partner.

Moving forward,
o HSA will assign / designate an SJCHSA
representative to the SJCoC Board.
o Facilitate regional discussions on strategies
to improve eligibility and document readiness
for permanent housing
CalFresh

SSI / SSP
IHSS
APS
Child Welfare
Child Care
Med-Cal
Enhanced Care Management Benefits
Managed care plan partners are actively
working with homeless service providers to
expand the provider network of entities
capable of billing CalAIM for enhanced care
management and community supports.

HHAP-5 Funding Priorities (Table 3.0)
Through this Action Plan, the County of San Joaquin, the City of Stockton, and the San Joaquin County Continuum of Care agree to the collective allocation of Homeless Housing Assistance and Prevention (HHAP) Round 5 funds:

Proposed Allocations Proposed County /
SJCoC Allocations
Proposed City of
Stockton Allocations
Permanent Housing At least 30% Up to 45%
Interim Housing – Shelter Operations At least 30% At least 30% Street Outreach and Service Coordination Up to 10% No funds allocated Systems Support Up to 20% At least 14%
Administration (7%) / HMIS (1%) 8% 8%
Total $6,914,426 $7,153,179
10% Youth Set-aside $ 691,443 $715,318

Budget details to be refined prior to application submission. Following application submission, budgets may be refined with Cal-ICH approval.

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HHAP ROUND 5 FUNDING PRIORITIES
 Expand the supply of permanent housing for homeless individuals and families.  Expand the provision of treatment services and program supports for those receiving housing, including RRH vouchers and other short-term assistance to stabilize more people in their homes.  Support low-barrier, housing-focused shelter programs with housing navigation and on-site treatment and case management services for those who seek additional support.  Support targeted outreach and case management for vulnerable and underserved populations (e.g., youth, victims of domestic violence, etc.) who may not otherwise be the beneficiaries of outreach efforts, intensive case management, or other homeless supports.

SYSTEM SUPPORT AND COORDINATION PRIORITIES
 Improve HMIS data quality, data systems, and data analysis to improve decision-making.  Update CES processes to streamline Rapid Rehousing program supports for unsheltered individuals exiting encampments.
 Invest in staff, training, and expertise (including PLEE) to grow and strengthen the Continuum of Care, including updates to the Collaborative Applicant Agreement and Governance Charter.

HHAP-5 LOGIC MODEL

Objective (Mandated
Performance Measures)
Action (Recommended Areas of
Program Funding)
Action (Recommended Areas of
System Support Activities)
• Increase the number of people
exiting homelessness into
permanent housing.
• Reduce the average length of time
people experience homelessness.
• Reduce percent of people returning
to housing after placement.

Permanent Housing
Invest in Permanent Housing Solutions.

Invest in actions to increase supply of
short and long-term supportive housing,
including warp-around support services.

Strengthen Continuum of Care.
• Collaborative Applicant
Agreement
• Governance Charter
Strengthen data collection, data
validity, and monitoring.
• Assess and strengthen HMIS
system and operations.
• Develop aligned analysis and
joint contract monitoring.

Strengthen linkages to permanent
housing and other long-term supports
services.
• Update CES to align with new
state regulations.
• Develop regional practice
models, and train accordingly
and in partnership with County
systems.

Measure and work towards equitable
outcomes.
• Use trauma informed and
culturally responsive practices.
• Ensure transparency of
systems and information.
• Conduct regional assessments
and evaluation.

• Reduce the number of people
experiencing unsheltered
homelessness.
• Increase linkages to programs from
street outreach programs.

Shelter
Invest in housing focused shelter
operations, including housing navigation
services and other wrap-around services.
• Reduce the number of people
accessing homeless services.
• Reduce the number of people
experiencing first-time
homelessness.

Outreach / Prevention
Invest in early identification, prevention,
and diversion programs for vulnerable
persons and those over-represented in
the homeless population. (e.g., youth,
people fleeing domestic violence, and
Black/African American community
members).

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Benchmarks of Success
As the City and Collaborative Applicant consider releasing funds for major project activities, the following benchmarks are key measures of success in accordance with HHAP-5 application requirements and indicators discussed during planning workshops.

ADDRESSING RACIAL AND ETHNIC DISPARITIES
 Reduce rates of Black / African Americans experiencing homelessness (31%), such that rates are more consistent with their proportion of the general population (7%).  Reduce rates of Black / African Americans experiencing first-time homelessness (31%), such that rates are more consistent with their proportion of the general population (7%).  Increase the rates for Polynesians and other Pacific Islanders (2%) and Native Americans (2%) to obtain housing after being homeless, such that there is parity with others (10%).  Reduce the length of time Polynesians and other Pacific Islanders (100 days), White people (91 days), and Native Americans (88 days) experience homelessness such that there is parity with others (76 days).

INTERIM HOUSING AND HOUSING NAVIGATION
 Shelter utilization increases as a measure of % of the time the shelter is at or above 80% capacity. (For non-specialty shelter programs such as recuperative care or domestic violence shelters)  Shelter exits are more consistently tracked; an exit is recorded for at least 50% of clients.  Unique count of people using shelters and duration of use.  Utilization of on-site services by demographics.
 Shelter stays can be analyzed using variables including length of time enrolled, number of stays during enrollment, number of services during enrollment, type of exit, and location of exit (if known), and cross-tabulated by demographic characteristics.

PERMANENT HOUSING AND HOUSING STABILIZATION
 Unique count of people accepted for a rapid re-housing voucher and duration to placement in a housing unit. The benchmark of success is for average wait time drops to less than 70 days to placement following issuance of voucher. The average length of time people remain homeless prior to placement is 76 days.
 Unique count of clients in housing program by type (RRH, Supported Housing, Other Housing).

Monthly count of new admissions and exits. The ratio of clients to assigned program staff.  Utilization of services, cost per c, and services received per client. Assessed by mean, mode, and quartile, and cross-tabulated by demographic characteristics.  Unique count of clients who return to homelessness after placement. The goal is to achieve 6% or less.

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Declarations

2.7 MEMORANDUM OF UNDERSTANDING
A copy of the MOU is in the Appendix for review.

2.8 APPLICATION DEVELOPMENT PROCESS

Public Meetings convened for the HHAP-5 Planning process.

MEETING DATE PURPOSE

1. January 11, 2024 Review and launch planning process. Solicit input to strengthen community engagement.

2. February 8, 2024 Review performance measures, equity assessment, and other key findings. Solicit input
on funding priorities and additional research,
including partner engagement.

3. March 7, 2024 Review recommendations for funding and system improvements. Receive approval to
incorporate recommendations into the Plan and
Application as Actions through HHAP funding.

Public Plan Review.

MEETING DATE PUBLIC MEETING

1. March 14, 2024 SJ CoC Board Meeting

2. March 19, 2024 Stockton City Council Meeting

3. March 26, 2024 San Joaquin County Board of Supervisors Meeting

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XI. REFERENCES
Amoroso-Pohl, M., McCarty, S., & Pogue, T.E. (2023). 2022 San Joaquin County Costs of Homelessness Survey Summary Report. Stockton, CA: University of the Pacific Center for Business and Policy Research. https://drive.google.com/file/d/1KztSqrNEy2ZVuf0MHzj0uGe4_8MIH4Qb/view

Birtwhistle, K., Haynes, N., Rane, K., Balderama, A., & Waldron, S. (2023). Unsheltered Encampment Outreach Study: San Joaquin County Unsheltered Outreach Survey Findings, Results, and Recommendations. Stockton, CA: San Joaquin Community Data Co-op & United Way of San Joaquin County. https://unitedwaysjc.org/sites/unitedwaysjc/files/2023-05/Unsheltered_v8_web.pdf

Cheshire, A. & Mendelson, B. (2022). San Joaquin Continuum of Care Report on the Point in Time Count of the Sheltered and Unsheltered Homeless. Stockton, CA: San Joaquin County Homeless Initiatives & Central Valley Low Income Housing Corporation. http://www.sanjoaquincoc.org/wp-content/uploads/2022/06/PIT-Count-Report-2022-FINAL.pdf

HDIS Data Dashboard. (2023). Homeless Data Integration System. Sacramento, CA:

California Business, Consumer Services and Housing Agency, California Interagency Council on Homelessness. https://public.tableau.com/app/profile/california.business.consumer.services.and.housing.agency/viz/Overall_CAExperiencingHom elessness_V1_8-7_22_22/CAExperiencingHomelessness

HUD Exchange (2015). HUD 2015 Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations. Washington D.C.: US Department of Housing and Urban Development. https://files.hudexchange.info/reports/published/CoC_PopSub_CoC_CA-511-2015_CA_2015.pdf

HUD Exchange. (2022). CoC Performance Profile CA-511. Stockton, CA: Stockton/San Joaquin County CoC. Washington D.C.: US Department of Housing and Urban Development. https://files.hudexchange.info/reports/published/CoC_Perf_CoC_CA-511-2020_CA_2020.pdf

HUD Exchange. (2022b). CoC Dash CA-511. Stockton, CA: Stockton/San Joaquin County CoC. https://files.hudexchange.info/reports/published/CoC_Dash_CoC_CA-511-2022_CA_2022.pdf

Kiss, M.E. (2020). Community Survey on Homeless Needs & Resources. Statesboro, GA:

Resource Development Group. https://drive.google.com/file/d/124nX9jWjpPxOuLnyRH9NzMYGhJ-SFlpQ/view Lewis, K. (2023). A Portrait of the Valley: San Joaquin Valley Human Development Report 2023. New York, NY: Measure of America, Social Science Research Council. https://drive.google.com/file/d/139gtSqu6wgOx5MJssJD3QigvIBAOY-Pp/view

McClure, S. (2023). Homelessness Spikes Among California Women. The Guardian, September 21, 2023.
https://www.theguardian.com/us-news/2023/dec/21/california-women-unhoused-domestic-violence- pregnant-mothers

Mendelson, J. & Singh, S. (2023). San Joaquin Continuum of Care Report on the Point in Time Count of Sheltered Homeless. Stockton, CA: Central Valley Low Income Housing Corp. https://drive.google.com/file/d/1zIxmf18-
7q-y1NxSP8KwAM-Nm6gnR-dC/view

State of California Department of Finance. (2020). P-2: County Population Projections (2020-2060). Sacramento, CA: State of California Department of Finance. https://dof.ca.gov/forecasting/demographics/projections/

San Joaquin Council of Governments. (2014). Residential Housing Needs Allocation (RHNA) Plan 2014-2023. Stockton, CA: San Joaquin Council of Governments. https://www.sjcog.org/DocumentCenter/View/805/Regional-Housing-Needs-Plan-Adopted-8-28-14?bidId=#page=6

San Joaquin Council of Governments (2022). Housing Gap Data Dashboard. https://public.tableau.com/app/profile/joe.benapfl/viz/HousingGap_1/Dashboard1

San Joaquin Council of Governments. (2022a). Residential Housing Needs Allocation (RHNA) Plan 2023-2031. Stockton, CA: San Joaquin Council of Governments. https://www.sjcog.org/DocumentCenter/View/7407/2022-SJCOG-RHNP_Adopted-Sep-2022_Oct22

U.S. Department of Housing and Urban Development. (2012). Program guidance: Establishing and operating a continuum of care.

U.S. Department of Housing and Urban Development. (2023). Annual Homelessness Assessment Report to Congress.

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XII. APPENDICES
A. Key Stakeholder Interview Participants & Protocol
Seventeen key stakeholder interviews were conducted in the spring of 2024 to delve into the workings and shortcomings of homeless services in San Joaquin County. These interviews aimed to gather insights and recommendations from subject-matter experts to address homelessness effectively.

B. List of Public Meetings and Workshops
Three public meetings and four workshops were facilitated by Rane Community Development, engaging regional subject matter experts to explore current conditions, roles, responsibilities, and recommendations outlined in the HHAP 5 template. These sessions provided valuable input for shaping strategies to combat homelessness.

C. List of Planning Stakeholders
Appendix C compiles a roster of subject-matter experts involved in the HHAP 5 process, contributing through public meetings, workshops, or both. Their expertise and insights enriched the planning process.

D. Meeting Presentations
All presentations from the public meetings and workshops are cataloged in Appendix D. These presentations offer detailed insights and discussions on various aspects of homelessness, providing valuable context for understanding the challenges and solutions discussed during the sessions.

E. Community Survey Findings
Appendix E presents the findings from a community survey distributed in late February 2024.

Approximately 33 respondents contributed their perspectives, offering statistical insights and thematic analysis into community perceptions and needs regarding homelessness.

F. Memorandum of Understanding
The Memorandum of Understanding (MOU) outlines the agreement between the City of Stockton Economic Development Department, San Joaquin County, and the Stockton/San Joaquin Homeless Continuum of Care CA-511. This document delineates collaborative efforts and responsibilities among these entities to address homelessness comprehensively.

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Appendix A: Interview Participants & Protocol
List of Individuals Interviewed

Name Agency
Veilka Guarascio City of Manteca
John Narvaez Salvation Army Hope Harbor
Petra Linden St. Mary's Dining Room
Britton Kimball Gospel Center Rescue Mission
Jennifer Spruill SJC Behavioral Health Services
John Sisneroz SJ Health
Jessica Velez Red Rabbit Advocacy
Hector Jaimes Familiar Faces (Program of Tracy Police)
Asst. Sheriff Mike Tibon Sheriff's Office
Mirriam Lyell Public Defender's Office
Mark Yost County Office of Education
Greg Diederich Health Care Services Agency
Chris Woods Human Services Agency
Sam Kaisch Human Services Agency
Steve Jackson Probation Department
LaTosha Waldon Stanislaus County
Midori Lichtwardt City of Tracy
RC Thompson Reinvent South Stockton Coalition

Interview Protocol

1. Could you please describe your role in terms of homelessness in the region?

2. What programs and services currently exist to prevent and address homelessness in San Joaquin County?

3. What is currently working well in terms of types of service activities and coordination?

4. What is not working as well in this landscape of services? Where are the gaps, duplication of efforts, or lack of coordination?

5. What are the priority needs in terms of the full continuum of care?

6. What do you see on the horizon? Are there any specific causes for optimism?

7. What are your recommendations to strengthen the homelessness system of care?

8. What pitfalls or challenges should we be mindful of, systemically and programmatically?

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Appendix B: List of Public Meetings and Workshops

Public Meetings

1. January 11, Public Meeting #1: CoC Board Meeting via Zoom, which included a public planning discussion on HHAP 5. The goal is to review the planning requirements and proposed planning process and gather input and support from SJCoC and community members for the HHAP 5 application.

2. February 8, Public Meeting #2: CoC Board Meeting, which included a public planning discussion on HHAP 5. System Performance Measures and Improvement Plan Discussion. Held at the Cesar Chavez Central Library, 605 N El Dorado St, Stockton, CA 95202, Meeting Room.

3. March 7, Public Meeting #3: CoC General Membership Meeting, which accepted the plan detailed in this report, and commensurate By-Law and Charter changes in alignment with the HHAP-5 requirements and the Action Plan. Held at City of Tracy Council Chambers, City Hall, 333 Civic Center Plaza, Tracy, CA. 95376.

Workshops

1. January 22, Workshop #1: Table 2.1 Participating Jurisdictions’ Roles and Responsibilities. Held at the Public Health Department, 1601 E Hazelton Ave, Stockton, CA 95205, Conference Rooms 145 A&B.

2. January 30, Workshop #2: Table 2.2 System Performance Measures and Improvement Plan Discussion. Held at the Public Health Department, 1601 E Hazelton Ave, Stockton, CA 95205, Conference Rooms 145 A&B.

3. February 12, Workshop #3: Table 2.4 Plan to Reduce the Number of People Experiencing Homelessness Upon Exiting an Institutional Settings Discussion. Held at the Health Plan of San Joaquin, 7751 S Manthey Rd, French Camp, CA 9523, Conference Room.

4. February 26, Workshop #4: Coordinated Approach, Funding Plan, and Other Agreements Held at the Public Health Department, 1601 E Hazelton Ave, Stockton, CA 95205, Conference Rooms 145 A&B.

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Appendix C: List of Planning Stakeholders
Name Title Agency/Dept P. MTG
1 P.MTG
2 P.MTG
3 WKSHP 1 WKSHP 2 WKSHP 3 WKSHP 4
Alana
Moreno
Emergency Food
Bank
x
Alejandra
Navarro
Youth Program
Supervisor
Community
Partnerships for
Families
x
Alexander
Nunez
Emergency Food
Bank
x
Augustine
Navarro
Emergency Food
Bank
x x x
Ayesha
Nic-Gongora
TPD/Familiar Faces X
Betty Wilson Business Council
SJC
x
Brandi
Hopkins
Assistant County
Administrator
SJC/ CAO x x

x x
Brenda Sison Housing Navigator Catholic Charities x
Brian
McDonald
Interim Public Works
Director
City of Tracy x

Britton
Kimball
COO Gospel Center
Rescue Mission
x x
Carissa
Lucas
Public Information
Officer
City of Tracy x x

x
Carrie
Grover
Executive Director Tracy Community
Center
x
Carrie Wright Economic Development
Manager
COS x x

x
Caryn
Romero
TAY Program Director Aspiranet x
Casey
Armstrong
Turning Point
Community
Programs
x
Cheryl
Fowler
First 5 SJC – HAS x
Chris Woods HSA Director SJC x

x
Christina
Noble
Catholic Charities x
Christian
Valeros
Lodi Police
Department
x
Courtney
Wood
x
David
Tolliver
Deputy Director of
Operations
SJC/ Public Works x

Dave Madura Executive Director Gospel Center
Rescue Mission
x
Dezarae
Quilantang
First 5 SJC, HSA x
Oeun Prak Assistant Director HACSJ x

x x
Dawn
McLeish
Deputy Director HSA

x x
D’Andre
Davie
NAACP, Stockton x

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Eliana Argeta Regional Program
Manager
Health Net x

x
Flor Robles Administrative
Technician HSD
City of Tracy x x

Gina Calder Chief of Staff Board of
Supervisors
x x x
Gurman
Singh
Staffer Rep. Josh Harder’s
Office, 9th District
x
Greg
Diederich
HSC Director SJC/ HCSH x x x x x
Harlin Smith Shelter Specialist Prevail x

Hector
James
Familiar Faces
Jayson Burk SJ S/O x
Jeff Sabin Deputy Director BHS

x
Jennifer
Rhyne
Neighborhood Services
Manager
City of Lodi x x

x x
Jennifer
Spruill
Chief Mental Health
Clinician
SJC/ BHS x x x x x
Jenny
Rodriguez
Community Medical
Centers & Care Link
x
Jessica Quan Director of Occupancy &
Housing Compliance
HACSJ x x

x x
Jessica Velez CEO Red Rabbit
Advocacy
x
John Della
Monica
Community
Development
City of Lodi x

x x
John Narvaez Director, Lodi Hope
Harbor Shelter
Salvation Army x
Jory
Gwasdoff
Executive Director Family Promise of
San Joaquin County
x
Juan
Gonzales
City of Stockton x
Julisa
Villalobos
City of Stockton x
Kate
Hutchinson
Lutheran Social
Services
x
Kelly Vega Program Assistant Catholic Charities x
Kendra
Kaiserman
Gospel Center
Rescue Mission
x
Kia Phillips Insight Housing x
Kim De La
Cruz
Captain Sheriff's Office x

x x
Kimberly
Murdaugh
Interim Assistant City
Manager
City of Tracy x

Krista Fiser SJCOC Chair SJCOC/ Prevail x x x x x x x
Kristen
Birtwhistle
President & CEO United Way of San
Joaquin County
x x
Lakisha
Holton
Correctional Health
Admin
SJSO

x
Latonya
Jackson
Community
Partnerships for
Families
x
Leanna Buck Crisis/ Peer Counselor Prevail x x x x

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Lizeth
Granados
Chief Executive Officer HPSJ x x x x
Luis Ayala Salvation Army x
Ahmad Majid Concrete
Development
x
Maria
Rodriguez
West Care x
Matt Garber Assistant Director SJC/ COC x x x x

x x
Melanie
Estarziau
Homeless Strategic
Initiatives Manager
COS x x x x x x x
Michael
Tibon
Asst. Sheriff SJSO

x
Mayra Garcia Insight Housing x
Muay
Saechao
Children’s Home of
Stockton
x
Natascha
Garcia
Administrator of
Homeless Initiatives
HCS x x x x x x
Nicole
Goehring
x
Niyati Reddy Director of Special
Projects, Operations
Health Plan of San
Joaquin
x
Paul Canepa SJ County Supervisor SJC Board of
Supervisors
x x
Perry Shelta
Jr.

Service Coordination
Liaison
Health Net

x x
Peter
Ragsdale
Executive Director HACSJ x x

Petra Linden CEO St. Mary’s
Community
Services
x x
Ray Call Interim Executive
Director
SJC homeless
related n/p orgs
x x
Sam Kaisch SJCHSA x
Sandy
Regalo
Assistant County
Administrator
SJ County/ CAO x

Sasha
Jackson
Chief Mental Health
Clinician
SSC/ BNS x x x x
Shadi
Barfjani
Senior Deputy Public Health x

Shirley
O’Neill
HCSA x
Steve Ding SJ County Supervisor SJC Board of
Supervisors
x x
Tammy Shaff St. Joseph’s
Medical Center
x x
Tran Nguyen Family Resource
Center
x
Vernell Shaw
III
Regional Medi-Cal Lead Health Net x
Vielka
Guarascio
Management Analyst City of Manteca

x x
Virginia
Carney
Homeless Services
Manager
City of Tracy x x x x x x x
Wayne
Templeton
Tracy Community
Connections Center
x

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Appendix D: Meeting Presentations
January 11, Public Meeting #1

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Appendix D: Meeting Presentations
February 8, Public Meeting #2

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Appendix D: Meeting Presentations
March 7, Public Meeting #3

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Appendix D: Meeting Presentations
January 22 Workshop #1

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Appendix D: Meeting Presentations
January 30 Workshop #2

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Appendix D: Meeting Presentations
February 12 Workshop #3

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Appendix D: Meeting Presentations
February 26, Workshop #4

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Appendix D: Public Plan Review Presentation

March 14, SJCoC Board Meeting
March 19, Stockton City Council Meeting
March 26, San Joaquin Board of Supervisors Meeting

This section is deliberately left blank for the public review draft.

Presentation and Comments from the plan review meetings listed above, including any substantial corrections or updates to the Regional Homeless Action Plan, will be inserted on March 27, 2024.

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