EXHIBIT 2
CIT
Y OF STOCKTON
HOME PREFERENCE POLICY
HO
ME 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
eac
h 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 def
inition.
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 CF
R Part 92.
c. The project shall comply with the HOME Tenant Selection requirements at 24 CFR 92.253(d) as follows:
EXHIBIT 2
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, n
ot to damage the housing; not to interfere with the
r
ights 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 th
e
l
imitation or preference is described in the City of
Stockton’s Consolidated Plan).
(i.) Any limitation or preference must not violate
no
ndiscrimination 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 a
s 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 no
t
p
ermitted;
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.