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SUBSTANTIAL AMENDMENT #4 TO 2020-2025 CONSOLIDATED PLAN CITY COUNCIL: NOVEMBER 12, 2024
The City of Stockton is a recipient of funding from several Federal programs from the U.S. Department of Housing and Urban Development (HUD). HUD requires jurisdictions to prepare a five-year Consolidated Plan as one of the conditions to receiving Community Development Block Grant (CDBG), Home Investment Partnerships Program (HOME), and Emergency Solutions Grant (ESG) funding. The Consolidated Plan assesses community needs related to affordable housing and community development and establish a 5-year strategic plan to address the needs. In addition to the Consolidated Plan, the City must prepare and submit Annual Action Plans and performance reports for each fiscal encompassed by the five-year Consolidated Plan. The City’s E conomic Development Department (EDD) is the lead department in administering these HUD funded programs.
Background
HUD requires that the City follows its Citizen Participation Plan when amending its Consolidated Plan if new goals, projects, or policies are to be implemented and not previously identified in the active Consolidated Plan and/or Annual Action Plan.
This document serves to comply with the City’s HUD Citizen Participation Plan requirements and inform the public of two proposed amendments to the City’s 2020- 2025 Consolidated Plan.
Present Situation
Through this item, EDD is proposing a Substantial Amendment # 4 to the 2020-2025 Consolidated Plan to impose the following updates:
1. Am
end AP-90 (part of Year 1 Annual Action Plan 2020-2021) of the Consolidated Plan to establish HOME Program Preferences for rental housing projects, in accordance with 24 CFR 92.253(d)(3) to allow the award of HOME funds to housing developers intending to develop housing for particular segments of the population.
2. Amend AP-50 (part of Year 1 Annual Action Plan 2020-2021) of the Consolidated Plan to designate a slum/blight area map for use of CDBG funds for eligible activities in Program Year 2024-2025 under the Slum Blight Area Basis National Objective for aiding in prevention or elimination of slums or blight.
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1. Amend AP-90 (part of Year 1 Annual Action Plan 2020-2021) of the Consolidated Plan to establish HOME Program Preferences for rental housing projects, in accordance with 24 CFR 92.253(d)(3) to allow the award of HOME funds to housing developers intending to develop housing for particular segments of the population.
In efforts to address the affordable housing shortage in the City of Stockton, the City partners with local or regional affordable housing developers using vital state and federal resources to assist in the development of affordable housing within the City of Stockton to in turn provide safe, decent, affordable housing opportunities for income eligible populations.
From time to time, the City of Stockton issues Notice of Funding Availability (NOFA) notices to solicit affordable project proposals to partner with housing developers by providing financial assistance for the purpose of developing affordable housing.
Depending on local housing needs, NOFA applicants/developers seek to address housing challenges within the community and in doing so, it is common that applicants may have already partnered with other funding agencies (e.g. County, state, and/or federal agencies) where funding has already been secured to develop housing for specific segments of the population including but not limited to low income individuals and families, senior citizens, veterans, homeless or at risk of homeless youth and/or individuals and families, homeless special needs, foster youth, farmworkers, domestic violence survivors, etc.
The HOME program is a key source of affordable housing funding and by way of HOME program regulations, HUD imposes stringent regulatory requirements to ensure that affordable housing projects meet HOME specific project underwriting requirements.
One of the specific HOME program requirements, codified at 24 CFR 92.253(d)(3), requires that if there is any limitation or preference given to a particular segment of the population (e.g. seniors, veterans, homeless/at risk of homelessness, farmworkers, youth, etc.) on any affordable housing project assisted with HOME program funds, the limitation or preference must be described in the City’s HUD Consolidated Plan (without violating any nondiscrimination requirements). This is a unique requirement given that most housing project proposals focus on housing one or more specific segments of the population (e.g. homeless individuals), which are inherently low-income and meet HOME program income eligibility requirements.
Staff has conducted an analysis of the HOME regulation requirements and proposes establishing a list of “preference” population types (hereafter “HOME Preferences”) for projects supported with HOME funds. The proposed HOME Preferences have been informed by project types proposed to the city in the last several years. Without the EXHIBIT 1
establishment of a list HOME Preference types, the City of Stockton would be unable to establish a housing pipeline which would impact the City’s ability partner with housing developers and spend HOME funds on addressing the affordable housing shortage.
The proposed HOME Preference Policy is included as Exhibit 1 to this document.
2. Amend AP-50 (part of Year 1 Annual Action Plan 2020-2021) of the Consolidated Plan to designate a slum/blight area map for use of CDBG funds for eligible activities in Program Year 2024-2025 under the Slum Blight Area Basis National Objective for aiding in prevention or elimination of slums or blight.
The CDBG Slum Blight Area (SBA) national objective allows the use of CDBG program funds to fund activities aimed at preventing or eliminating slums or blight. Since 1996, Stockton has used a portion of CDBG funds in addressing slum and blight through various programs, including the Commercial Façade Improvement Forgivable Loan Program. The programs have aided in revitalizing blighted commercial properties within the previous Redevelopment Project Areas, which also met the definition for HUD’s Slum Blight Area designation.
Pursuant to HUD guidelines, 24 CFR 570.208(b)(1), an activity will be considered to address prevention or elimination of slums or blight on an area basis if:
i) The area “meets a definition of a slum, blighted, deteriorated or deteriorating area under State or local law”;
ii) The area also meets the conditions in either paragraph (A) or (B):
A) At least 25 percent of properties throughout the area experience one or more of the following conditions:
1) Physical deterioration of buildings or improvements; 2) Abandonment of properties;
3) Chronic high occupancy turnover rates or chronic high vacancy rates in commercial or industrial buildings;
4) Significant declines in property values or abnormally low property values relative to other areas in the community; or
5) Known or suspected environmental contamination.
B) The public improvements throughout the area are in a general state of deterioration.
In order for SBA designation to remain eligible, the City must maintain documentation on the boundaries and conditions of the area, as well as the methodology used to EXHIBIT 1
delineate the area. Furthermore, the designated area must be redetermined every 10 years for continued qualification.
Activities assisted with CDBG funds must address one or more of the conditions that contributed to the deterioration of the area.
In 2023, RSG, Inc. completed a reevaluation of the previous Slum Blight Area as well as the current Opportunity Zones census tracts. Using available data, conducting a field study for physical assessments, and considering the City’s and Council’s goals of revitalizing downtown and the Shape Stockton initiative, the Slum Blight Area was determined to include a 5.62-square mile area located in central/south Stockton. The area is primarily composed of Downtown Stockton, the Little Manila/Gleason Park area, South Airport Way Corridor, and Cabral/East Cabral area.
The evaluation determined that 34 percent of properties within the Slum Blight Area exhibit one or more forms of HUD’s condition of blight. The area also met the slum and blight criteria established under State law (California Health and Safety Code Section 33030 and 33031(a)(1)) and local law (Stockton Municipal Code Section 8.36.040).
Therefore, the area qualifies as a slum and blighted area under the CDBG program regulations, and the SBA national objective will be used in deploying CDBG-funded activities and programs to assist in addressing slum and blight within the map area.
The proposed Slum-Blight Area Map is included as Exhibit 2 to this document.
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CITY OF STOCKTON
HOME PREFERENCE POLICY
HOME Housing Preference Policy:
1. When issuing affordable housing Notices of Funding Availability (NOFAs) the City of Stockton will consider awarding HOME funds to eligible projects that propose to serve any of the following target populations:
Housing Project
Population Definition of Population
Rationale Notes/Supporting Data
Housing for Homeless
or at Risk of Homeless
(includes
unaccompanied/foster
care youth)
Homeless or at risk of
homeless individuals or
households.
Must meet HUD/HCD
definition of
homelessness.
The need for permanent homes for homeless
residents is overwhelming and immediate.
Consistent with City/Regional plans.
The San Joaquin County 2024 Point in Time
Count reported a total of 4,732 persons
experiencing homelessness in San Joaquin
County in 2024, with 2,996 (63%) within the
City of Stockton. According to the 2022 Point
in Time Count 2,319 persons experiencing
homelessness resided within in San Joaquin
County. The fact that the homeless
population
has doubled in the past two years indicates
that more attention and resources need to be
dedicated to addressing this issue.
The San Joaquin County 2024 Point in Time
Count collected data on four subpopulations
that the federal government determined to
face particular challenges related to housing.
One of the key subpopulations identified by
the federal government was children and
youth under age 25 experiencing
homelessness. Of the 4,732 persons
experiencing homelessness in San Joaquin
County, 304 individuals were identified as
being children and transition aged youth
under 25. Compared to the other four
vulnerable subpopulations identified in the
report, children and youth under the age of
25 experienced the highest share of unsheltered
homelessness as 80% of this population
reported they were unsheltered.
The Analysis of Impediments that was
completed in correspondence with the 2020-
2025 Consolidated Plan identified homeless
persons as a special housing needs
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population. The report suggests the lead
determinate for homelessness is due to the
inability to afford housing in a particular
community. Increasing the stock of affordable
housing for this subpopulation can alleviate
some of the challenges faced by this special
housing needs subpopulation.
Housing for Homeless
with Special Needs
Homeless individuals w/
special needs including
but not limited to
individuals experiencing
or recovering from
substance abuse
disorders, mental or
physical disabilities,
chronic homelessness,
justice involved
individuals, etc.
Must meet HUD/HCD
definition of
homelessness.
The 2024 City of Stockton Housing Element
cites persons with disabilities as a key
population with special housing needs. The
report cites “14.6 percent of the total
population in Stockton five years and older
had one or more disabilities in 2020,
compared 13.3 percent countywide, and 8.0
percent in California.”
Using HMIS data, the 2024 Regional
Homeless Action Plan identified statistically
significant vulnerable populations withing the
San Joaquin Continuum of Care district.
According to HMIS data, people with serious
mental illness (SMI) and people with
substance use disorders (SUD) were a
significant population that faced housing
insecurity.
The San Joaquin County 2024 Point in Time
Count (PITC) collected data on four
subpopulations that the federal government
determined to face particular challenges
related to housing. One of the key
subpopulations identified by the federal
government was individuals with disabilities
experiencing chronic homelessness. Of the
4,732 persons experiencing homelessness in
San Joaquin County, 1,078 individuals were
identified as being chronically homeless.
According to the PITC, 72% of the chronically
homeless population are unsheltered.
The Analysis of Impediments that was
completed in correspondence with the 2020-
2025 Consolidated Plan identified persons
with disabilities as a special housing needs
population. The analysis cites that persons
with disabilities can face discrimination in the
housing market due to biases about adaptive
equipment and the need for modifications.
Property owners might be concerned about
potential damage from equipment or be
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reluctant to accommodate service animals,
even if it means violating a no-pet policy.
According to San Joaquin County Behavioral
Health Services, “there is an urgent and
increasing need for affordable housing in San
Joaquin County, particularly for justice-
involved mental health consumers. According
to the National Institute of Mental Health,
approximately 37% of individuals in the U.S.
incarcerated in state and federal prisons and
44% in local jails have been diagnosed with a
mental illness. Furthermore, justice-involved
individuals with mental health conditions are
significantly more likely to experience
homelessness, with studies indicating that
about 15% of people leaving jails and prisons
become homeless within a year of release.”
Housing for
Low/Moderate Income
Individuals and
Families (includes
families with children
and large families)
Low-income individuals
and Families.
Must meet HUD/HCD
low/moderate income
definition(s).
The updated 2024 City of Stockton Housing
Element cites large families as a key
population with special housing needs. HUD
defines a large household or family as
consisting of five or more members. Large
families are cited as a special housing needs
population because 21.2% of households in
Stockton are considered large households
compared to 19.6% in the County and 13.8%
in California.
The San Joaquin County 2024 Point in Time
Count collected data on four subpopulations
that the federal government determined to
face particular challenges related to housing.
One of the key subpopulations identified by
the federal government was families with
children experiencing homelessness. Of the
4,732 persons experiencing homelessness in
San Joaquin County, 454 individuals were
identified as being members of homeless
families with children.
The Analysis of Impediments that was
completed in correspondence with the 2020-
2025 Consolidated Plan identified large
households as a special housing needs
population. The analysis conducted cited that
lower-income large households often face
excessive housing costs due to the higher
expense of larger units and the scarcity of
such units in conventional apartment
complexes. Additionally, these families may
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experience overcrowded living conditions and
discrimination in the housing market, such as
higher rents or outright denial of rental
applications.
Housing for Veterans U.S. Military Veterans Many housing authorities have preferences for award of housing vouchers to veterans.
Rationale is that veterans are more likely to
be physically and financially vulnerable and
to
need affordable housing more than the
general population. VASH rental vouchers
from the VA are either portable or project-
based. Preference could be for VASH
holders.
The San Joaquin County 2024 Point in Time
Count collected data on four subpopulations
that the federal government determined to
face particular challenges related to housing.
One of the key subpopulations identified by
the federal government was veterans. Of the
4,732 persons experiencing homelessness in
San Joaquin County, 249 individuals were
homeless veterans. Moreover, the report
cites
that 79% of the homeless veteran population
were unsheltered.
Using HMIS data, the 2024 Regional
Homeless Action Plan identified statistically
significant vulnerable populations withing the
San Joaquin Continuum of Care district.
According to HMIS data, veterans were a
significant population that faced housing
insecurity. The plan states that “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).” The plan also
outlines that one of the four funding priorities
of HHAP round 5 involves targeted outreach
and support services for vulnerable
populations such as veterans.
Housing for Survivors
of Domestic Violence
Victims of Domestic
Violence
Many housing authority voucher programs
give priority to the Violence Against Women
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Act population. HUD recently issued new
resources for advancing housing protections
for survivors of domestic violence.
Using HMIS data, the 2024 Regional
Homeless Action Plan identified statistically
significant vulnerable populations withing the
San Joaquin Continuum of Care district.
According to HMIS data, people fleeing
domestic violence was a significant
population that faced housing insecurity. The
plan outlines that one of the four funding
priorities of HHAP round 5 involves targeted
outreach and support services for vulnerable
populations such as victims of domestic
violence.
Senior Housing • 55 years of age or older
if at least 80 percent of
its units are occupied by
at least one person of
this age.
• OR at least one person
62 or older resides in
each apartment unit
(100% of the units)
• AND the housing project
is required to
demonstrate the “intent”
to be “Housing for Older
Persons.”
• Head of Household or
spouse must meet the
age definition.
The 2024 City of Stockton Housing Element
cites seniors as a key population with special
housing needs. Senior households make up
21.6% of Stockton households and nearly
30% of senior households in Stockton have
an income of less than $25,000.
The Analysis of Impediments that was
completed in correspondence with the 2020-
2025 Consolidated Plan identified seniors as
a special housing needs population. The
analysis describes that seniors possess
special housing needs due to living on fixed
incomes, limited mobility, and physical or
mental impairments or disabilities. In order to
make housing accessible to this
subpopulation, housing must be affordable
within their fixed income budget and
designed
for individuals with limited mobility.
Farmworker Housing Farmworkers including
those that meet other
funding source
farmworker definitions.
The updated 2024 City of Stockton Housing
Element cites farmworkers as a key
population with special housing needs. The
plan states that farmworkers are an essential
component of Stockton’s economy and
according to the 2016-2020 American
Community Survey 5,010 Stockton residents
work in agriculture, forestry, fishing and
hunting, or mining. Moreover, according to the
2017 Census, 19,741 farmworkers worked in
San Joaquin County. Programs 11, 12, 16,
22, 23, and 30 of the Housing Element
commit to actions to support developing new
homes and rehabilitating existing homes for
farmworkers, along with prioritizing outreach
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and programs for farmworkers. While
farmworkers are important to the local
economy, many are low-income workers and
are often subject to substandard housing.
The Analysis of Impediments that was
completed in correspondence with the 2020-
2025 Consolidated Plan identified
farmworkers as a special housing needs
population. While farmworkers were identified
as being an essential component of the
regional agricultural system they face
challenges in obtaining adequate and
affordable housing due to high poverty rates,
large household sizes, linguistic isolation,
and
intimidation and fear due to citizenship status.
Due to limited capital in farmworker housing,
the farm-working community frequently ends
up in overcrowded, substandard housing that
is often geographically isolated and lacks
essential services, increasing their risk of
homelessness.
Workforce Housing Housing that is affordable
for those earning between
80% and 120% of the
area median income.
Households in workforce housing typically
earn too much to qualify for programs under
HUD. At the same time, they are also unable
to afford most quality market-rate apartments.
Development of workforce housing will be
subject to the availability of public or private
resources tailored to this population.
Artists’ Housing Those engaging in
defined artistic pursuits,
including visual arts,
music, dance, and other
media.
Artists are underpaid relative to housing
prices, part of the City’s priorities for
placemaking, and at high risk of
displacement. Need for flexible and
affordable live/workspace.
2. The following requirements shall apply to all HOME‐assisted housing projects that adopt any of the target populations allowable under this policy:
a. The project shall not violate of any local, state, or federal fair housing regulations.
b. The project shall comply with all applicable housing regulations at 24 CFR Part 92.
c. The project shall comply with the HOME Tenant Selection requirements at 24 CFR 92.253(d) as follows:
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i. An owner of rental housing assisted with HOME funds must comply with the affirmative marketing requirements
established by the City of Stockton pursuant to § 92.351(a). ii. The owner must adopt and follow written tenant selection policies and criteria that:
1) Limit the housing to very low‐ income and low‐income families;
2) Are reasonably related to the applicants' ability to perform the obligations of the lease (i.e., to pay the rent, not to damage the housing; not to interfere with the
rights and quiet enjoyment of other tenants);
3) Limit eligibility or give a preference to a particular segment of the population if permitted in its written
agreement with the City of Stockton (and only if the
limitation or preference is described in the City of
Stockton’s Consolidated Plan).
(i.) Any limitation or preference must not violate
nondiscrimination requirements in § 92.350. A
limitation or preference does not violate
nondiscrimination requirements if the housing
also receives funding from a Federal program that
limits eligibility to a particular segment of the
population (e.g., the Housing Opportunity for
Persons with AIDS program under 24 CFR part 574,
the Shelter Plus Care program under 24 CFR part
582, the Supportive Housing program under 24
CFR part 583, supportive housing for the elderly or
persons with disabilities under 24 CFR part 891),
and the limit or preference is tailored to serve that
segment of the population.
(ii.) If a project does not receive funding from a
Federal program that limits eligibility to a
particular segment of the population, the project
may have a limitation or preference for persons
with disabilities who need services offered at a
project only if:
(A.) The limitation or preference is limited
to the population of families (including
individuals) with disabilities that
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significantly interfere with their ability to
obtain and maintain housing;
(B.) Such families will not be able to
obtain or maintain themselves in housing
without appropriate supportive services;
and
(C.) Such services cannot be provided in a
nonsegregated setting. The families must
not be required to accept the services
offered at the project. In advertising the
project, the owner may advertise the
project as offering services for a particular
type of disability; however, the project must
be open to all otherwise eligible persons
with disabilities who may benefit from the
services provided in the project.
4) Do not exclude an applicant with a voucher under the Section 8 Tenant‐Based Assistance: Housing Choice
Voucher Program (24 CFR part 982) or an applicant
participating in a HOME tenant‐based rental assistance
program because of the status of the prospective tenant as a holder of such voucher or comparable HOME
tenant‐based assistance document.
5) Provide for the selection of tenants from a written
waiting list in the chronological order of their
application, insofar as is practicable. The Continuum of Care’s (CoC) Coordinated Entry process is not a
compliant tenant selection process therefore not
permitted;
6) Give prompt written notification to any rejected
applicant of the grounds for any rejection; and
7) Comply with the VAWA requirements prescribed in §
92.359.
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