1 City of Sunnyvale
HOME-ARP Al
location Plan
Participating Jurisdiction (PJ): City of Sunnyvale Date: January 20, 2023 Des
cribe the consultation proce ss including methods used and dates of consultation:
The consultation process was initiated by working with the Santa Cl ara County’s Office of Supportive Housing, and other local jurisdictions, to gather and analyze C ity s pecific data rel ated to homelessness. The data was harvested from the County’s Coordinated Assessment system (in addition to 2021 Point in Time Count data), and included information, specific to the unhoused population in Sunnyvale, such as: demographics (including household size), veteran and dis
ability status, length of homelessness episodes and existing subpopulations. The raw data offered the City and its partners a snapshot, emphasizing the extent and impacts of the homelessness crisis in the region.
In regard to consultation as it relates to engaging stakeholders – the City attended a loca l Continuum of Care (CoC) meeting on Ma rch 28, 2022. City staff facilitated a presentation on the HOME ARP funds (i.e., background, eligible uses, etc.) – then opened the floor for the CoC Board to provide feedback on how the City can maximize the funding source. In addition to meeting with the CoC, the City released a survey to loc al s takeholders on December 8, 2022 – then followed up with two stakeholder meetings on January 10th and 11th. The organizations that attended the Consultation meetings serve a broad range of clients as cited in the table below – from individuals with disabilities and the unhoused to veterans and victims of domestic violence.
Stakeholders who did not attend the workshops or respond to surveys were contacted directly for phone interviews throughout January 2023.
Attachment 2
2 List the organizations consulted:
Agency/Org Consulted Type of
Agency/Org
Method of
Consultation Feedback
Sunnyvale Community Services Emergency
Assistance
Network
Agency –
Services:
Unhoused,
Veterans,
etc.
Survey Respondent
and Attended
Community
Meeting on January
10, 2023 and
January 11, 2023.
Cited inadequate supportive services
for the unhoused, compared to the
need. Additionally, rental
assistance/prevention should be a
priority given escalations in evictions
and affordability.
Downtown Streets Team Homeless
Service
Provider
Survey Respondent
and Attended
Community
Meeting on January
10, 2023
Cited inadequate supportive services
and linkages to rental assistance
programs for clients of the Sunnyvale
Shelter.
Project Sentinel Fair
Housing
Service
Provider
Survey Respondent
and Attended
Community
Meeting on January
10, 2023
Cited concerns around increases in
evictions.
Silicon Valley Independent Living
Center
Serves
Individuals
with
Disabilities
Survey Respondent
and Attended
Community
Meeting on January
10, 2023
Cited a need to develop permanent
housing as a solution – as opposed to
funding rental assistance, which is
subject to the high-cost rental market.
Santa Clara County Housing Authority Local Public
Housing
Agency
City met with
SCCHA Policy
Team on January 4,
2023
Cited a need for supportive services for
at-risk of homelessness populations to
stabilize households who are not
defined as chronically homeless
(concerns around at-risk populations
being deprioritized).
Next Door Solutions to Domestic
Violence
Serves
Victims of
Domestic
Violence
Survey Respondent
and Attended
Community
Meeting on January
10, 2023
Cited inadequate supportive services
for the unhoused, compared to the
need. Additionally, rental
assistance/prevention should be a
priority given escalations in evictions
and affordability.
Continuum of Care – Santa Clara
County
Continuum
of Care
Lead
Agency
Attended a CoC
meeting on March
28, 2022
Cited inadequate supportive services
for formerly homeless who need
additional support to achieve higher
levels of housing stability.
Bill Wilson Center Service
Provider:
Mental
Health,
Unhoused,
Veterans,
Transition
Aged Youth,
etc.
Survey Respondent
and Attended
Community
Meeting on January
10, 2023
Cited rental assistance and supportive
services – which would make an impact
sooner, when compared to development
of PSH.
Attachment 2
3 Su
mmarize feedback received and results of upfront consultation with these entities:
The City consulted with local service-providers that serve a broad range of eligible populations – and a common feedback trend was support for supportive services and rental assistance. As cited in the table – one agency messaged support for the development of Permanent Supportive Housing (PSH) as a more sustainable option for the long-term. However, the majority of agencies, when looking at the total sum of money available were focused on rental assistance and supportive services, while acknowledging PSH is needed, because those efforts can help people sooner, and prevent households from experiencing an episode of homelessness OR housing families currently experiencing homelessness.
Public Participation
In
accordance with Section V.B of the Notice (page 13), PJs must provide for and encourage citizen participation in the development of the HOME-ARP allocation plan. Before submission of the plan, PJs must provide residents with reasonable notice and an opportunity to comment on the proposed HOME-ARP allocation plan of no less than 15 calendar days. The PJ must follow its adopted requirements for “reasonable notice and an opportunity to comment” for plan amendments in its current citizen participation plan. In addition, PJs must hold at least one public hearing during the development of the HOME-ARP allocation plan and prior to submission.
PJ
s are required to make the following information available to the public:
• The amount of HOME-ARP the PJ will receive, and
• The range of activities the PJ may undertake.
Des
cribe the public participation process, including information about and the dates of the public comment period and public hearing(s) held during the development of the plan:
• Dat
e(s) of public notice: 2/10/2023
• Public comment period: start date - 2/11/2023 end date - 3/21/2023 • Date(s) of public hearing: 2/22/2023 and 3/21/2023
The Public Comment period for the HOME-ARP Allocation Plan began on February 11, 2023 – and concluded on Tuesday, March 21, 2023. A public notice was published in the Sunnyvale Sun on Friday, February 10, 2023. Additionally, the City held two public hearings – the first was the City’s Housing and Human Services Commission (HHSC) Wednesday, February 22, 2023 (virtual) – and the second was the City Council meeting of Tuesday, March 21, 2023 (in- person). The City wanted to provide the public as many opportunities to comment on the HOME-ARP Allocation Plan as possible, and extended its public comment period – and added an additional public hearing.
Attachment 2
4 De
scribe efforts to broaden public participation:
In addition to extending the public comment period and holding two public hearings – the City issued a survey to the community, and met individually with stakeholders, in addition to the community meetings and public hearings to ensure there was an ongoing open dialogue with community partners. The City held meetings during work hours and during evening hours to accommodate various schedules and needs. The City maintains strong relationships and partnerships with local non-profit and human service agencies and welcomed all feedback surrounding the topic at any time.
Sum
marize the comments and recommendations received through the public participation process either in writing, or orally at a public hearing:
Note: this section will be updated after the public community period ends on March 21, 2023.
Su
mmarize any comments or recommendations not accepted and state the reasons why:
Not applicable.
Needs Assessment and Gaps Analysis
In accordance with Section V.C.1 of the Notice (page 14), a PJ must evaluate the size and demographic composition of all four of the qualifying populations within its boundaries and assess the unmet needs of each of those populations. If the PJ does not evaluate the needs of one of the qualifying populations, then the PJ has not completed their Needs Assessment and Gaps Analysis. In addition, a PJ must identify any gaps within its current shelter and housing inventory as well as the service delivery system. A PJ should use current data, including point in time count, housing inventory count, or other data available through CoCs, and consultations with service providers to quantify the individuals and families in the qualifying populations and their need for additional housing, shelter, or services.
Attachment 2
5 Describe the size and demographic composition of qualifying populations within the PJ’s boundaries:
Homeless as defined in 24 CFR 91.5
On behalf of Sunnyvale, the County of Santa Clara’s Office of Supportive Housing provided data based on the most recent Point in Time Count, and information available in the Coordinated Assessment system for the next series of questions. Data identified the City of Sunnyvale has 385 unhoused clients living in areas not meant for human habitation, of which 279 are unsheltered and 106 are sheltered. It should be noted the City saw a 38% decrease in homelessness between the 2019 and 2022 PIT Count.
At Risk of Homelessness as defined in 24 CFR 91.5
According to the Homeless Prevention database, the City currently has 331 households who, without continued support, are at-risk of experiencing an episode of homelessness.
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking, as defined by HUD in the Notice According to the available data, 8% of homeless Countywide self-reported currently fleeing domestic violence, which estimates approximately 30 individuals.
Other populations requiring services or housing assistance to prevent homelessness and other populations at greatest risk of housing instability, as defined by HUD in the Notice
According to the available data for the County, the City can estimate the following:
• 26 unhoused Veterans.
• 107 unhoused clients with the status of Chronically Homeless – estimated that 61% who are male, 37% who are female and 1% who are Transgender.
Describe the unmet housing and service needs of qualifying populations:
Homeless as defined in 24 CFR 91.5
The City, and generally, Santa Clara County have a shortfall in shelter beds, case- management capacity and homeless prevention (i.e., rental assistance) resources. For example, Sunnyvale has a total of 175 shelter beds, with an unhoused population of 279.
During the consultation process – community stakeholders echoed the need for more shelter beds, stronger case management programs and more rental assistance opportunities.
At Risk of Homelessness as defined in 24 CFR 91.5
The City, and Santa Clara County need more resources to prevent episodes of homelessness – and one mechanism to do so is a shorter-term rental assistance program, like TBRA, that can provide interim support to families who can achieve higher levels of self-sufficiency with adequate support. As described during the consultation process – rental assistance programs need more than just rental assistance and are most successful when coupled with supportive Attachment 2
6 services. The City has 300+ households that can benefit from an expansion of its rental assistance programs.
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking, as defined by HUD in the Notice The City, and generally Santa Clara County, need additional short term (up to one year) to medium term (up to two years) rental assistance and case management opportunities for households fleeing, or attempting to flee domestic violence. During the consultation process, it was echoed that a major benefit to this population would be expanding opportunity for impacted households to transition into a safe housing environment, which would immediately enhance the ability for service-providers to more effectively administer case management assistance.
Other populations requiring services or housing assistance to prevent homelessness and other populations at greatest risk of housing instability as defined by HUD in the Notice
Based on the feedback from the consultation process, Sunnyvale needs more housing and case management opportunities for the other populations cited in the HUD notice. For example, several organizations serving clients with disabilities and veterans expressed concern for clients living on fixed incomes who are not currently residing in affordable apartments. The organizations cited something like a shallow subsidy could greatly benefit their clients – and similarly agencies serving older adults echoed that sentiment. Overall, there is a housing affordability crisis in the City, especially for those on fixed incomes – and agencies are most interested in how to assist their clients sooner rather than later, as the need is tremendous.
Identify any gaps within the current shelter and housing inventory as well as the service delivery system:
The City has 279 unhoused individuals living in areas not meant for human habitation with a shelter capacity of 175 beds. The consultation process brought to light that current clients of the Sunnyvale Shelter could benefit from additional case management to transition out of the shelter system, as many clients have been there for long durations (90+ days) due to insufficient case management opportunities (i.e., housing search, self-sufficiency planning, benefits counseling, linkages to services, etc.). The City and County have invested in outreach services at a higher level than supportive services – therefore there is a large demand for shelter, but not adequate support to move people on from the shelter once they arrive. The consultation process further high-lighted a need for additional shelter beds – and exposed a gap in the system focused on case management services for clients of the shelter.
Under Section IV.4.2.ii.G of the HOME-ARP Notice, a PJ may provide additional characteristics associated with instability and increased risk of homelessness in their HOME- ARP allocation plan. These characteristics will further refine the definition of “other populations” that are “At Greatest Risk of Housing Instability,” as established in the HOME- ARP Notice. If including these characteristics, identify them here:
Attachment 2
7 Not applicable.
Identify priority needs for qualifying populations:
The main priority needs cited during the consultation process were the need for more rental assistance for those at risk of homelessness or currently homeless, and supportive services for individuals enrolled in current rental assistance and shelter programs. There is an increasing challenge of moving individuals from shelter to housing due to inadequacies in case management – and a diminishing supply of rental assistance funds (state rental assistance funding has largely dried up, which is a concern for several agencies). Focusing the HOME-ARP allocation on rental assistance and supportive services, based on consultation, will create opportunities to support eligible populations in a more expedited manner, which is a priority for the community.
Explain how the PJ determined the level of need and gaps in the PJ’s shelter and housing inventory and service delivery systems based on the data presented in the plan:
The City worked with the County Office of Supportive Housing to assess data on the state of homelessness in Sunnyvale, including data from the 2022 Point in Time Count, and other existing resources available. The data indicated the scope of the issue, specifically for eligible populations – and this data was shared with service-providers serving eligible populations during the consultation process. Since the City and agencies participating in the consultation process have access to the most recent data, and expertise from the service-providers – the City was able to have constructive discussions on how to maximize the HOME-ARP allocation.
HOME-ARP Activities
Describe the method(s)that will be used for soliciting applications for funding and/or selecting developers, service providers, subrecipients and/or contractors:
The City plans to release a HOME-ARP Request for Proposals (RFP) in December 2023, in alignment with its regular CDBG and HOME entitlement grant process. Based on the community meetings and surveys, the City anticipates receiving multiple applications for eligible HOME-ARP projects/programs. The City will develop the RFP and ranking/scoring criteria – and present the draft documents to the community through its Housing and Human Services Commission public meeting in November 2023. Once the RFP and ranking/scoring criteria are approved – the City will release the RFP, formulate an Evaluation Committee, and award funding to proposals/organizations that most effectively meet the objectives of the HOME-ARP funding. Final funding recommendations will be considered in March 2024 with funds available shortly after.
Describe whether the PJ will administer eligible activities directly:
The City will directly award funding to one or several sub-recipients to facilitate eligible activities, and will be an active participant in the planning, implementation and monitoring of HOME-ARP projects.
Attachment 2
8 If any portion of the PJ’s HOME-ARP administrative funds are provided to a subrecipient or contractor prior to HUD’s acceptance of the HOME-ARP allocation plan because the subrecipient or contractor is responsible for the administration of the PJ’s entire HOME-ARP grant, identify the subrecipient or contractor and describe its role and responsibilities in administering all of the PJ’s HOME-ARP program:
Not applicable – funds awarded to a sub-recipient will specifically be for programming, and non- profit operating, the City will administer the funds.
In accordance with Section V.C.2. of the Notice (page 4), PJs must indicate the amount of HOME-ARP funding that is planned for each eligible HOME-ARP activity type and demonstrate that any planned funding for nonprofit organization operating assistance, nonprofit capacity building, and administrative costs is within HOME-ARP limits.
Attachment 2
9 Template:
Use of HOME-ARP Funding
Funding Amount Percent of the
Grant
Statutory
Limit
Supportive Services $ 375,000
Acquisition and Development of Non-
Congregate Shelters $ #
Tenant Based Rental Assistance (TBRA) $ 828,133
Development of Affordable Rental Housing $ #
Non-Profit Operating $ 75,000 5 % 5%
Non-Profit Capacity Building $ 25,000 2 % 5%
Administration and Planning $ 200,000 13 % 15%
Total HOME ARP Allocation $ 1,503,133
Describe how the PJ will distribute HOME-ARP funds in accordance with its priority needs identified in its needs assessment and gap analysis:
The City plans to allocate 55% of its HOME-ARP allocation toward TBRA, and 25% toward supportive services – then the balance of 20% will support non-profit operating and administration/planning. The City concluded, based on the consultation process, that rental assistance coupled with a range of supportive services will maximize the use of HOME-ARP funds to serve eligible populations more quickly, while addressing priorities/concerns expressed by service-providers. The City has an existing TBRA program, therefore multiple service- providers serving a variety of eligible populations can potentially support the program by coordinating with the current Administrator. During the Consultation process, several agencies agreed creating a referral system for a rental assistance program that includes multiple partners serving eligible populations could be a benefit to the clients they serve.
Describe how the characteristics of the shelter and housing inventory, service delivery system, and the needs identified in the gap analysis provided a rationale for the plan to fund eligible activities:
The insufficient supply of shelter beds and affordable housing units compelled the City, after consulting with the local community, to move toward allocating funds to TBRA as it will create an expedited path, when compared to development projects, to serve clients struggling sooner.
The City has been operating a TBRA program for nearly 10-years and has a framework in place to expand the program further, and create a referral system that will include a variety of eligible populations. Additionally, the funding for case management will ensure clients at the local shelter and those enrolled in the TBRA program will have access to a robust range of case management services. The City has invested nearly $40 million in local funds since 2019 toward the development of more affordable and supportive rental units – so the HOME-ARP funds can provide relief to households now as more permanent housing is developed in the long term. In addition, with development costs increasing rapidly for affordable housing, the City’s limited HOME ARP allocation can go much further with financing tenant services than constructing new units at this time.
Attachment 2
10 HOME-ARP Pro duction H ousing Goals
Template
Estimate the number of affordable rental housing units for qualifying populations that the PJ will produce or support with its HOME-ARP allocation:
The City anticipates being able to serve up to fifty (50) households with rental assistance and case management se rvices w ith the HOME-ARP allocation. No units will be produced using HOME ARP funding. This estimate is based on current TBRA enrollment when looking at average rent portions, and length of stay in the program for existing clients, and typical case management expenses and households served.
Describe the specific affordable rental housing production goal that the PJ hopes to achieve and describe how the production goal will address the PJ’s priority needs:
Not applicable
Attachment 2
11 Preferences
A preference provides a priority for the selection of applicants who fall into a specific Qualifying Population (QP) or category (e.g., elderly or persons with disabilities) within a QP (i.e., subpopulation) to receive assistance. A preference permits an eligible applicant that qualifies for a PJ-adopted preference to be selected for HOME-ARP assistance before another eligible applicant that does not qualify for a preference. A method of prioritization is the process by which a PJ determines how two or more eligible applicants qualifying for the same or different preferences are selected for HOME-ARP assistance. For example, in a project with a
preference for chronically homeless, all eligible QP applicants are selected in chronological order for a HOME-ARP rental project except that eligible QP applicants that qualify for the preference of chronically homeless are selected for occupancy based on length of time they have been homeless before eligible QP applicants who do not qualify for the preference of chronically homeless.
Pleas
e note that HUD has also described a method of prioritization in other HUD guidance.
Section I.C.4 of Notice CPD-17-01 describes Prioritization in CoC CE as follows:
“Prioritization. In the context of the coordinated entry process, HUD uses the term “Prioritization” to refer to the coordinated entry-specific process by which all persons in need of assistance who use coordinated entry are ranked in order of priority. The coordinated entry prioritization policies are established by the CoC
with input from all community stakeholders
and
must ensure that ESG projects are able to serve clients in accordance with written standards that are established under 24 CFR 576.400(e). In addition, the coordinated entry process must, to the maximum extent feasible, ensure that people with more severe service needs and levels of vulnerability are prioritized for housing and homeless assistance before those with less severe service needs and lower levels of vulnerability. Regardless of how prioritization decisions are implemented, the prioritization process must follow the requirements in Section II.B.3. and Section I.D. of this Notice.”
If a
PJ is using a CE that has a method of prioritization described in CPD-17-01, then a PJ has preferences and a method of prioritizing those preferences. These must be described in the HOME-ARP allocation plan in order to comply with the requirements of Section IV.C.2 (page 10) of the HOME-ARP Notice.
In
accordance with Section V.C.4 of the Notice (page 15), the HOME-ARP allocation plan must identify whether the PJ intends to give a preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project. • Preferences cannot violate any applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a). • The PJ must comply with all applicable nondiscrimination and equal opportunity laws and requirements listed in 24 CFR 5.105(a) and any other applicable fair housing and civil rights laws and requirements when establishing preferences or methods of prioritization.
Attachment 2
12 While PJs are not required to describe specific projects in its HOME-ARP allocation plan to which the preferences will apply, the PJ must describe the planned use of any preferences in its HOME-ARP allocation plan. This requirement also applies if the PJ intends to commit HOME- ARP funds to projects that will utilize preferences or limitations to comply with restrictive eligibility requirements of another project funding source. If a PJ fails to describe preferences or limitations in its plan, it cannot commit HOME-ARP funds to a project that will implement a preference or limitation until the PJ amends its HOME-ARP allocation plan.
For HOME-ARP
rental housing projects, Section VI.B.20.a.iii of the HOME-ARP Notice (page 36) states that owners may only limit eligibility or give a preference to a particular qualifying population or segment of the qualifying population if the limitation or preference is described in the PJ’s HOME-ARP allocation plan. Adding a preference or limitation not previously described in the plan requires a substantial amendment and a public comment period in accordance with Section V.C.6 of the Notice (page 16).
I
dentify whether the PJ intends to give preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project:
The City does not intend to implement any preferences for its HOME-ARP projects. Instead, the City plans to serve a broad range of eligible populations by collaborating with agencies on program referrals and placements.
If a preference was identified, explain how the use of a preference or method of prioritization will address the unmet need or gap in benefits and services received by individuals and families in the qualifying population or subpopulation of qualifying population, consistent with the PJ’s needs assessment and gap analysis:
Not applicable.
Referral Methods
PJs are not required to describe referral methods in the plan. However, if a PJ intends to use a coordinated entry (CE) process for referrals to a HOME-ARP project or activity, the PJ must ensure compliance with Section IV.C.2 of the Notice (page10).
A PJ may use only the CE for direct referrals to HOME-ARP projects and activities (as opposed t
o CE and other referral agencies or a waitlist) if the CE expands to accept all HOME-ARP qualifying populations and implements the preferences and prioritization established by the PJ in its HOME-ARP allocation plan. A direct referral is where the CE provides the eligible applicant directly to the PJ, subrecipient, or owner to receive HOME-ARP TBRA, supportive services, admittance to a HOME-ARP rental unit, or occupancy of a NCS unit. In comparison, an indirect referral is where a CE (or other referral source) refers an eligible applicant for placement to a project or activity waitlist. Eligible applicants are then selected for a HOME-ARP project or activity from the waitlist.
Attachment 2
13 The PJ must require a project or activity to use CE along with other referral methods (as provided in Section IV.C.2.ii) or to use only a project/activity waiting list (as provided in Section IV.C.2.iii) if:
1. the CE does not have a sufficient number of qualifying individuals and families to refer to the PJ for the project or activity;
2. the CE does not include all HOME-ARP qualifying populations; or,
3. the CE fails to provide access and implement uniform referral processes in situations where a project’s geographic area(s) is broader than the geographic area(s) covered by the CE
If a PJ uses a CE that prioritizes one or more qualifying populations or segments of qualifying populations (e.g., prioritizing assistance or units for chronically homeless individuals first, then prioritizing homeless youth second, followed by any other individuals qualifying as homeless, etc.) then this constitutes the use of preferences and a method of prioritization. To implement a CE with these preferences and priorities, the PJ must include the preferences and method of prioritization that the CE will use in the preferences section of their HOME-ARP allocation plan.
Use of a CE with embedded preferences or methods of prioritization that are not contained in the PJ’s HOME-ARP allocation does not comply with Section IV.C.2 of the Notice (page10).
Identify the referral methods that the PJ intends to use for its HOME-ARP projects and activities. PJ’s may use multiple referral methods in its HOME-ARP program. (Optional):
The City plans to implement a direct referral model through a collaboration with service- providers working with a variety of eligible populations within the City. The City does not plan to utilize the County’s Coordinated Assessment system.
If the PJ intends to use the coordinated entry (CE) process established by the CoC, describe whether all qualifying populations eligible for a project or activity will be included in the CE process, or the method by which all qualifying populations eligible for the project or activity will be covered. (Optional):
Not applicable.
If the PJ intends to use the CE process established by the CoC, describe the method of prioritization to be used by the CE. (Optional):
Not applicable.
If the PJ intends to use both a CE process established by the CoC and another referral method for a project or activity, describe any method of prioritization between the two referral methods, if any. (Optional):
Not applicable.
Attachment 2
14 Limitations in a HOME-ARP rental housing or NCS project
Limiting eligibility for a HOME-ARP rental housing or NCS project is only permitted under certain circumstances.
• PJs must follow all applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a).
This includes, but is not limited to, the Fair Housing Act, Title VI of the Civil Rights Act, section 504 of Rehabilitation Act, HUD’s Equal Access Rule, and the Americans with Disabilities Act, as applicable.
• A PJ may not exclude otherwise eligible qualifying populations from its overall HOME- ARP program.
• Within the qualifying populations, participation in a project or activity may be limited to persons with a specific disability only, if necessary, to provide effective housing, aid, benefit, or services that would be as effective as those provided to others in accordance with 24 CFR 8.4(b)(1)(iv). A PJ must describe why such a limitation for a project or activity is necessary in its HOME-ARP allocation plan (based on the needs and gap identified by the PJ in its plan) to meet some greater need and to provide a specific benefit that cannot be provided through the provision of a preference. • F
or HOME -ARP rental housing, section VI.B.20.a.iii of the Notice (page 36) states that owners may only limit eligibility to a particular qualifying population or segment of the qualifying population if the limitation is described in the PJ’s HOME-ARP allocation plan.
• PJs may limit admission to HOME-ARP rental housing or NCS to households who need the specialized supportive services that are provided in such housing or NCS. However, no otherwise eligible individuals with disabilities or families including an individual with a disability who may benefit from the services provided may be excluded on the grounds that they do not have a particular disability.
Describe whether the PJ intends to limit eligibility for a HOME-ARP rental housing or NCS project to a particular qualifying population or specific subpopulation of a qualifying population identified in section IV.A of the Notice:
The City does not intend to limit eligibility for its HOME-ARP programs – and intends to serve a broad range of eligible populations.
If a PJ intends to implement a limitation, explain why the use of a limitation is necessary to address the unmet need or gap in benefits and services received by individuals and families in the qualifying population or subpopulation of qualifying population, consistent with the PJ’s needs assessment and gap analysis:
Not applicable.
If a limitation was identified, describe how the PJ will address the unmet needs or gaps in benefits and services of the other qualifying populations that are not included in the limitation Attachment 2
15 through the use of HOME-ARP funds (i.e., through another of the PJ’s HOME-ARP projects or activities):
Not applicable.
Attachment 2
16 HOME-ARP Refinancing Guidelines
If the PJ intends to use HOME-ARP funds to refinance existing debt secured by multifamily rental housing that is being rehabilitated with HOME-ARP funds, the PJ must state its HOME- ARP refinancing guidelines in accordance with 24 CFR 92.206(b). The guidelines must describe the conditions under with the PJ will refinance existing debt for a HOME-ARP rental project, including:
•
Establish a minimum level of rehabilitation per unit or a required ratio between rehabilitation and refinancing to demonstrate that rehabilitation of HOME-ARP rental housing is the primary eligible activity
Not applicable.
• Require a review of management practices to demonstrate that disinvestment in the property has not occurred; that the long-term needs of the project can be met; and that the feasibility of serving qualified populations for the minimum compliance period can be demonstrated.
Not applicable.
• State whether the new investment is being made to maintain current affordable units, create additional affordable units, or both.
Not applicable.
• Specify the required compliance period, whether it is the minimum 15 years or longer.
Not applicable.
• State that HOME-ARP funds cannot be used to refinance multifamily loans made or insured by any federal program, including CDBG.
Not applicable.
• Other requirements in the PJ’s guidelines, if applicable:
Not applicable.
Attachment 2