2026-2027
Draft Action Plan
City of Sunnyvale
Community Development Block Grant Program
Home Investment Partnership Program
April 2026
Attachment 2
Contents
Executive Summary ....................................................................................................................................... 3 AP-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) ........................................................................ 3 PR-05 Lead & Responsible Agencies – 91.200(b) ...................................................................................... 6 AP-10 Consultation – 91.100, 91.200(b), 91.215(l) ................................................................................... 7 AP-12 Participation – 91.105, 91.200(c) ................................................................................................. 21 Expected Resources ................................................................................................................................ 24 AP-15 Expected Resources – 91.220(c)(1,2) ........................................................................................... 24 Annual Goals and Objectives ...................................................................................................................... 29 Projects ................................................................................................................................................... 31 AP-35 Projects – 91.220(d) ..................................................................................................................... 31 AP-38 Project Summary .......................................................................................................................... 33 AP-50 Geographic Distribution – 91.220(f) ............................................................................................. 38 Affordable Housing ..................................................................................................................................... 40 AP-55 Affordable Housing – 91.220(g) ................................................................................................... 40 AP-60 Public Housing – 91.220(h) ........................................................................................................... 41 AP-65 Homeless and Other Special Needs Activities – 91.220(i) ............................................................ 42 AP-75 Barriers to affordable housing – 91.220(j) ................................................................................... 44 AP-85 Other Actions – 91.220(k) ............................................................................................................ 47 Program Specific Requirements .................................................................................................................. 49
Attachment 2
Executive Summary
AP-05 Executive Summary - 24 CFR 91.200(c), 91.220(b)
1. Introduction
This FY 2026/27 Action Plan serves as an application for funds under two formula grant programs administered by the U.S. Department of Housing and Urban Development (HUD). These grants provide the City of Sunnyvale (City) with an average of roughly $1.1 million annually. For FY 2026/27, the City will receive an allocation of Community Development Block Grant (CDBG) in the amount of $1,023,080 and a HOME Investment Partnerships (HOME) Program grant of $382,897.32 . This Action Plan covers the fiscal year beginning July 1, 2026, and ending June 30, 2027, which is the second year of implementation under City’s 2025- 2030 Consolidated Plan (ConPlan) period. The Action Plan describes the eligible activities that the City intends to undertake in FY 2026/27 to address the priority needs and implement the strategies identified in the Plan, using the City’s CDBG and HOME grants. The activities described in this Action Plan are intended to primarily benefit the lower-income residents of Sunnyvale, affirmatively further fair housing choice, and meet priority needs. In addition to these grants, the City has a local Housing Mitigation Fund (HMF), which is used to support local affordable housing programs, including some that are not eligible for HUD funding. This fund is derived from fees received occasionally in varying amounts, and there is no guaranteed annual funding amount, therefore less emphasis is placed on these funds as a regular funding source in this Action Plan.
2. Summarize the objectives and outcomes identified in the Plan. This could be a restatement of items or a table listed elsewhere in the plan or a reference to another location. It may also contain any essential items from the housing and homeless needs assessment, the housing market analysis or the strategic plan.
The City has organized its priority needs based on the structure presented in HUD regulations (24 CFR
91.215): affordable housing, alleviation of homelessness, economic development, and non-housing community development. Priority is assigned based on the level of need that is demonstrated by the data that has been collected during the preparation of the Plan, specifically in the Needs Assessment and Market Analysis; the information gathered during the consultation and citizen participation process; current City policy, federal laws and regulations related to the HUD grants, and the availability of resources to address these needs. Based on these components, housing needs are considered a high priority, as well as alleviation of homelessness, economic development, and non-housing community development needs. The City's goals and objectives are organized into four categories:
• A. Affordable Housing (including housing for special needs households) • B. Alleviation of Homelessness
Attachment 2
• C
. Other Community Development Efforts (Public Services, Community Facilities and Infrastructure)
• D. Expanding Economic Opportunities.
Table 6 on page 31 summarizes the objectives and outcomes that will be addressed in this Action Plan. 3. Evaluation of past performance
The City is responsible for ensuring compliance with all rules and regulations associated with the CDBG and HOME entitlement grant programs. The City’s annual Action Plans and CAPERs, posted on the City’s website, provide details about the goals, projects and programs completed by the City. The City recognizes that the evaluation of past performance is critical to ensure the City and its subrecipients are implementing activities effectively and that those activities align with the City’s overall strategies and goals. The City evaluates the performance of subrecipients on a quarterly basis. Subrecipients are required to submit quarterly progress reports, which include client data, performance objectives, as well as data on outcome measures. Before the start of the program year, program objectives are developed collaboratively by the subrecipient and the City, ensuring that they are aligned with the City's overall goals and strategies. The City utilizes the quarterly reports to review progress toward annual goals.
During the past year, the City successfully implemented its planned programs and projects. Some projects take several years to complete, so in some cases they may not be completed in the same year in which they were initially funded, such. This is not unusual for projects involving major construction work.
4. Summary of Citizen Participation Process and consultation process The City, in collaboration with other local jurisdictions and the consultant team, launched a comprehensive outreach strategy to enhance and broaden citizen participation in the preparation of the Consolidated Plan. The team informed the public that it was in the process of creating the 2025-2030 Consolidated Plan and encouraged public participation in the process by conducting a Regional Needs Survey, hosting regional forums in collaboration with other jurisdictions in the County, and conducting local hearings.
In addition to the extensive consultation conducted for the Consolidated Plan, the City solicited additional input on this draft Action Plan. Consistent with the City's Citizen Participation Plan, the City provides multiple opportunities for public review and comment on the Action Plan and on any substantial amendments to it.
Prior to finalization, the Housing and Human Services Commission (HHSC) held public hearings to obtain community views on housing and community development needs and to review public service proposals. The City Council held an additional public hearing to receive citizen input and respond to proposals and questions. Public hearings on this Plan were held on April 14, 2026 and May 5, 2026. A notice of public hearings and an announcement of the 30-day public comment period was published in the Sunnyvale Sun in high threshold languages. An initial draft of the Action Plan was released on April Attachment 2
6 , 2026 on the City's website, and comments were accepted through May 6, 2026 for a 30-day public comment period.
All public hearings were held in the evenings to maximize attendance and were accessible to persons with disabilities. Bilingual assistance, sign language interpretation (with 72 hours advance notice), and TDD services were made available to ensure broad participation, including by non-English speaking residents and persons with disabilities. Members of the public unable to attend hearings were encouraged to submit comments directly to Housing Division staff.
It is the policy of the City of Sunnyvale to encourage and engage residents to participate in the planning, implementation, and evaluation of its housing and community development programs. All oral and written comments received during the public comment period were considered in preparing the final annual Action Plan. A summary of comments received, including those not accepted and the reasons therefor, is attached to this Plan.
5. Summary of public comments
All comments were accepted. Please refer to Attachment: "Proof of Publication and Citizen Participation Comments.”
6. Summary of comments or views not accepted and the reasons for not accepting them Not Applicable, all comments were accepted.
7. Summary
Not Applicable.
Attachment 2
PR-05 Lead & Responsible Agencies – 91.200(b)
1. Agency/entity responsible for preparing/administering the Consolidated Plan Describe the agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source.
Agency Role Name Department/Agency
CDBG Administrator SUNNYVALE Department of Community
Development
HOME Administrator SUNNYVALE Department of Community
Development
Table 1 – Responsible Agencies
The City of Sunnyvale is the Lead and Responsible Agency for HUD entitlement programs in Sunnyvale.
The Housing Division (HD), a division of the City’s Community Development Department (CDD), is responsible for administering the City’s HUD entitlement grants, including the Community Development Block Grant (CDBG) and HOME Investment Partnerships Program (HOME) grant. In order to continue receiving these grants, the City must develop and submit to HUD a five-year Consolidated Plan (ConPlan) and annual Action Plans listing priorities and strategies for the use of these federal funds. The ConPlan describes how the City plans to use its CDBG and HOME funds to meet the housing and community development needs of its residents in the next five years. To update its 2025-2030 ConPlan, the City collaborated with the County of Santa Clara (County) and other entitlement jurisdictions in the County to identify and prioritize housing and community development needs across the region, and to develop strategies to meet those needs. The 2026-27 Action Plan covers the second year of implementation of the 2025-2030 ConPlan period.
Consolidated Plan Public Contact Information
Trudi Ryan, Director of Community Development
Amanda Sztoltz, Housing Officer
456 W. Olive Avenue / PO Box 3707
Sunnyvale, CA 94088
Tel: (408) 730-7250
Fax: (408) 737-4906
Email: [email protected]
Housing Division website: https://sunnyvale.ca.gov/property/housing/default.htm Attachment 2
AP-10 Consultation – 91.100, 91.200(b), 91.215(l)
1. Introduction
The City has a long history of coordination and partnership with the local public housing provider, which is the Santa Clara County Housing Authority (SCCHA), and various assisted housing providers, such as Charities Housing, MidPen Housing Corp., First Community Housing, and others. The City also has a long history of coordinating with and/or providing funding to various local private and public health, mental health, and human services agencies, such as the County Mental Health Department, the local Valley Medical Center, and a variety of service providers that serve seniors, disabled clients, homeless clients, and other lower-income and at- risk clients.
In addition, in preparing the ConPlan, the City collaborated with eight other entitlement grantee jurisdictions (Entitlement Jurisdictions), including the cities of Cupertino, Gilroy, Mountain View, Milpitas, Palo Alto, San Jose, Santa Clara, and the County of Santa Clara (Urban County).
Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(l))
Public participation played a central role in the development of the ConPlan. The Entitlement Jurisdictions launched an in-depth, collaborative regional effort to consult with community stakeholders, many of whom represented public or assisted housing providers, health and service agencies, as well as elected officials, City and County staff, and beneficiaries of entitlement programs, to inform and develop the priorities and strategies contained within the ConPlan. The City, in partnership with Root Policy and the other Entitlement Jurisdictions, facilitated a comprehensive outreach process to enhance coordination with these stakeholders and discuss new approaches to using the HUD entitlement grant funds for eligible activities, projects, and programs throughout the county and/or in specific cities. Multiple community meetings took place in late 2024, and early 2025 and included participation from a variety of stakeholders.
Additionally, Root Policy (the City’s consultant), with direction from the Entitlement Jurisdictions, conducted a Regional Needs Survey to solicit input from residents, workers, and stakeholders in the region, which consisted of all of Santa Clara County. Survey respondents were informed that the purpose of this survey was to help the Entitlement Jurisdictions determine local priorities for use of their HUD entitlement funds, and that these funds must be used to fund projects or programs that primarily serve lower income residents or neighborhoods with a higher percentage of lower-income residents. The Survey polled respondents about the level of need in their respective neighborhoods for various types of Attachment 2
improvements, projects or programs that could possibly be funded by the HUD entitlement funds.
In addition to the extensive consultation in 2024 and 2025 noted above, the City solicited additional input for the FY 2026/27 annual Action Plan from community members at public hearings and planning meetings held on March 25, April 14, and May 5, 2026. The City and other community development organizations in the County coordinate frequently on a variety of initiatives.
City Housing staff participates in a monthly collaborative of HUD entitlement grantees within the County to discuss regional housing issues and identify strategies to advance shared housing and community development goals.
The City also coordinates with other regional agencies, such as the Housing Trust of Silicon Valley, SV@Home, Joint Venture Silicon Valley, and NOVA, others, to achieve the goals described within this Action Plan.
Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness.
The City has coordinated with the Santa Clara County Continuum of Care (CoC) for many years in its efforts to prevent and end homelessness countywide. The CoC is a broad coalition of stakeholders governed by the CoC Board, which takes a systems-change approach to addressing homelessness. Members meet monthly to plan CoC programs, identify gaps in services, establish funding priorities, and advance coordinated strategies to address homelessness across all subpopulations — including chronically homeless individuals and families, families with children, veterans, and unaccompanied youth, as well as those at risk of homelessness.
City Housing staff, , actively participate in the countywide CDBG Coordinators Group, where staff from Sunnyvale and other jurisdictions consult with County CoC staff on joint housing efforts. Additionally, the City participates in a quarterly Inter-City Unhoused Response Collaborative with other Santa Clara County cities and the County, which provides a dedicated forum for peer jurisdictions to align strategies, share best practices, and coordinate responses to regional homelessness challenges.
In 2019, Destination: Home — a public-private partnership committed to ending chronic homelessness — released the Community Plan to End Homelessness in Santa Clara County (Community Plan) in partnership with the CoC. The Community Plan outlined countywide strategies for ending homelessness by 2025 and was informed by a series of community summits held between April and December 2019, which included participation from Sunnyvale Housing staff and local stakeholders. The City formally endorsed the 2020-2025 Community Plan, affirming its commitment to the shared regional strategies outlined therein. The City's Attachment 2
Consolidated Plan and 2023-2031 Housing Element incorporate policies and programs consistent with the Community Plan's goals.
The County is now engaged in developing the next Community Plan, with community feedback convenings held in April and May 2026. The City intends to remain an active partner in this process and anticipates that the updated plan will continue to inform Sunnyvale's homelessness policy and investment priorities going forward.
Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards for and evaluate outcomes of projects and activities assisted by ESG funds, and develop funding, policies and procedures for the operation and administration of HMIS The City is not an ESG entitlement jurisdiction.
The CoC’s HMIS is administered by the County Office of Supportive Services and their consultant, BitFocus, using Clarity Human Services software. The project meets and exceeds HUD’s requirements for HMIS and complies with HUD HMIS Standards. The County’s HMIS is used by many service providers to record information and report outcomes.
2. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdiction’s consultations with housing, social service agencies and other entities Attachment 2
Table 2 – Agencies, groups, organizations who participated 1 Agency/Group/Organization Abode
Agency/Group/Organization Type Affordable housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
2 Agency/Group/Organization Affirmed Housing
Agency/Group/Organization Type Affordable Housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
3 Agency/Group/Organization Alta Housing
Agency/Group/Organization Type Affordable housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
4 Agency/Group/Organization Bay Area Legal Aid
Agency/Group/Organization Type
Fair housing and legal services
What section of the Plan was addressed by
Consultation? Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
Attachment 2
5 Agency/Group/Organization BHSD The Harm Reduction
Project
Agency/Group/Organization Type County Government
What section of the Plan was addressed by
Consultation? Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
6 Agency/Group/Organization Bill WIlson Center
Agency/Group/Organization Type Services for Families and Children
What section of the Plan was addressed by
Consultation? Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
7 Agency/Group/Organization Bridge Housing
Agency/Group/Organization Type City Government (San Jose) / Housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
8 Agency/Group/Organization Caminar
Agency/Group/Organization Type
What section of the Plan was addressed by
Consultation?
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
9 Agency/Group/Organization CARAS
Agency/Group/Organization Type County Government
Attachment 2
W
hat section of the Plan was addressed by
Consultation? Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
10 Agency/Group/Organization CASA
Agency/Group/Organization Type Youth Mentorship
What section of the Plan was addressed by
Consultation? Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
11 Agency/Group/Organization Catholic Charities
Agency/Group/Organization Type Faith based supportive services What section of the Plan was addressed by
Consultation? Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
12 Agency/Group/Organization City of Los Altos
Agency/Group/Organization Type City Government
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
13 Agency/Group/Organization City Team
Agency/Group/Organization Type Homelessness Services
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
Attachment 2
14 Agency/Group/Organization County Office of LGBTQ Affairs Agency/Group/Organization Type City Government
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
15 Agency/Group/Organization Destination Home
Agency/Group/Organization Type Homeless prevention
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
16 Agency/Group/Organization Downtown Streets Team
Agency/Group/Organization Type Homeless prevention
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
17 Agency/Group/Organization Eden Housing
Agency/Group/Organization Type Affordable housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
18 Agency/Group/Organization Golden State Manufactured
Homes Owners League
Agency/Group/Organization Type Nonprofit advocacy
Attachment 2
W
hat section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
19 Agency/Group/Organization Housing Trust Silicon Valley Agency/Group/Organization Type CDFI
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
20 Agency/Group/Organization Jamboree Housing
Agency/Group/Organization Type Affordable housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
21 Agency/Group/Organization Lived Experience Advisory
Board
Agency/Group/Organization Type Homeless prevention
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
22 Agency/Group/Organization Life Moves
Agency/Group/Organization Type Supportive Housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Attachment 2
B
riefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
23 Agency/Group/Organization Next Door Solutions to
Domestic Violence
Agency/Group/Organization Type
Domestic Violence Survivor
Resources
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
24 Agency/Group/Organization Path Ventures
Agency/Group/Organization Type Homelessness services
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
25 Agency/Group/Organization Pride Social
Agency/Group/Organization Type Advocacy
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
26 Agency/Group/Organization Project Sentinel
Agency/Group/Organization Type Fair Housing Legal Services What section of the Plan was addressed by
Consultation?
Needs Assessment
Attachment 2
B
riefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
27 Agency/Group/Organization Rebuilding Together Peninsula & Silicon Valley
Agency/Group/Organization Type Home Rehabilitation
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
28 Agency/Group/Organization Resources for Community
Development
Agency/Group/Organization Type Affordable housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
29 Agency/Group/Organization San Andreas Regional Center Agency/Group/Organization Type
Supportive Services for
Residents with Disabilities
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
30 Agency/Group/Organization Santa Clara County Housing Authority
Agency/Group/Organization Type Public housing authority What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Attachment 2
B
riefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
31 Agency/Group/Organization Satellite Affordable Housing Associates
Agency/Group/Organization Type Affordable housing
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
32 Agency/Group/Organization Senior Adults Legal Assistance Agency/Group/Organization Type Fair Housing Legal Services What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
33 Agency/Group/Organization Silicon Valley Independent Living Center
Agency/Group/Organization Type
Services for people with
disabilities
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
34 Agency/Group/Organization SOMOS Mayfair
Agency/Group/Organization Type Community Advocacy/Families What section of the Plan was addressed by
Consultation?
Needs Assessment
Attachment 2
B
riefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
35 Agency/Group/Organization Sourcewise
Agency/Group/Organization Type
Services for older adults and
people with disabilities
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
36 Agency/Group/Organization The LGBTQ Youth Space
Agency/Group/Organization Type
Community advocacy
organization
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
37 Agency/Group/Organization United Way Bay Area
Agency/Group/Organization Type Supportive services
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
38 Agency/Group/Organization Upwards
Agency/Group/Organization Type Childcare services
What section of the Plan was addressed by
Consultation?
Needs Assessment
Attachment 2
B
riefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
39 Agency/Group/Organization Vista Center for Blind and Visually Impaired
Agency/Group/Organization Type
Services for people with
disabilities
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
40 Agency/Group/Organization WeHOPE
Agency/Group/Organization Type
Unhoused nonprofit service
provider
What section of the Plan was addressed by
Consultation?
Needs Assessment
Market Analysis
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
41 Agency/Group/Organization YWCA Golden Gate Silicon
Valley
Agency/Group/Organization Type
Supportive services for
domestic violence survivors
What section of the Plan was addressed by
Consultation?
Needs Assessment
Briefly describe how the Agency/Group/Organization
was consulted. What are the anticipated outcomes of
the consultation or areas for improved coordination?
Stakeholder focus group in
December 2024
Identify any Agency Types not consulted and provide rationale for not consulting There were no agency types that were not consulted as part of the 2025-2030 Consolidated Plan process.
Attachment 2
Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the goals of each plan?
Continuum of Care Destination:Home
The D:H plan provides strategies for ending
homelessness and increasing affordable housing stock in the County. This effort aligns with the Strategic Plan's goals to increase/support Affordable Housing and
Alleviate Homelessness.
General Plan 2023-
2031 City of Sunnyvale
Two of the primary goals of each of these plans are
essentially the same: Increase/Support Affordable
Housing; and Addressing Homelessness. Both plans also
have goals related to improving local housing stock and neighborhoods and addressing priority needs (non-
housing community development needs). About 80% of
the content of the two plans are very similar.
Comprehensive
HIV Prevention &
Care Plan
Santa Clara County
HIV Planning
Council for
Prevention and Care
This plan guides the Santa Clara County HIV Planning
Council for Prevention and Care in its development of a compassionate system of HIV prevention and care for
the County. This effort aligns with the Strategic Plan's goal to address Other Community Development Needs
Regional Housing
Need Plan San
Francisco Bay Area
Association of Bay
Area Governments
This plan quantifies the needs of the 9-county Bay Area, which includes Sunnyvale, primarily for new housing
units to address population growth projected to occur in the next 8 years. The regional housing need is further
divided into an allocation or RHNA for each county and
city in the region. The plan indicates Sunnyvale needs
nearly 6,700 new housing units during this period. This plan aligns with the Strategic Plan's goals to
increase/support Affordable Housing and Alleviate
Homelessness. Sunnyvale's Housing Element describes
how the City can accommodate the new units through
its zoning and General Plan and provide some affordable units by using its special funds for affordable housing.
SCCHA Moving to
Work Annual Plan
Santa Clara County
Housing Authority
Addresses housing authority updates and strategies
pertaining to public housing and vouchers.
Economic
Development
Strategic Plan 2024
City of Sunnyvale Goals for strategic economic development to increase job opportunities, housing and investment in Sunnyvale.
Table 3 – Other local / regional / federal planning efforts Attachment 2
AP-12 Participation – 91.105, 91.200(c)
1. Summary of citizen participation process/Efforts made to broaden citizen participation Summarize citizen participation process and how it impacted goal-setting
It is the policy of the City of Sunnyvale to encourage and engage residents to participate in planning, implementation, and evaluation of its housing and community development programs.
The City encourages low- and moderate-income residents, minorities, those with disabilities, and non- English-speaking residents to attend community meetings and/or provide written comments on its plans. The City provides a statement in the languages identified in its Language Access Plan on all public notices regarding HUD-funded activities, and sends public notices to organizations representing the groups listed above. In accordance with the Citizen Participation Plan, the City will provide translation services to any resident who requests such services in advance at such hearings and meetings. The City has translated its primary Housing Program brochures into Spanish, in accordance with the Language Access Plan.
Sunnyvale Request for Proposals
The City has a long-standing practice of issuing a request for proposals (RFP), annually for capital/housing projects and every second year for human services grants and TBRA, to solicit applications for CDBG and HOME funds available to the City. This process aids in gathering community input on local needs and helps the City identify projects and programs that are eligible for and interested in HUD funding and have demonstrated capacity for successful implementation and compliance with HUD requirements. Staff issues the RFP, evaluates proposals for eligibility, scores the proposals according to criteria approved by the Housing and Human Services Commission, and provides funding recommendations to the Commission and Council for review. The Commission holds a public hearing before making its own funding recommendations to Council. The Commission and Council approve the final funding awards as part of the annual Action Plan public hearing.
Public Notice and Availability of the Action Plan
As required by HUD, the City provides multiple opportunities for public review and comment on the Action Plan and on any substantial amendments to it. Per the City’s Citizen Participation Plan, two public meetings are required to allow the community to review and comment on the plan. Community members had opportunities to attend public hearings on April 14, 2026 and May 5, 2026. A notice of public hearings and an announcement of the 30- day public comment period was published in the Sunnyvale Sun on March 27, 2026. An initial draft of the Action Plan was released on April 6, 2026, and comments were accepted through May 6, 2026. The proposed Plan was available for review at City Hall, One-Stop Center, or on the City’s website.
Attachment 2
Citizen Participation Outreach
Sort
Order
Mode of
Outreach
Target of
Outreach
Summary of
response/
attendance
Summary of
comments
received
Summary of
comments not
accepted
and reasons
URL
(If applicable)
1 Public
Meeting
Non-
targeted/
broad
community
The Housing and
Human Services
Commission (HHSC)
met on March 25, 2026,
to hear presentations
from non-profit profit
agencies, in response to
the Request for
Proposals for CDBG and
HOME funding for FY
2027.
The presenters
answered
questions of the
commissioners
and urged them
to support their
project/funding
request.
All comments
were accepted
2 Public
Meeting
Non-
targeted/
broad
community
The HHSC met on
March 25, 2026, to
discuss funding
recommendations for FY
2026/27 CDBG/HOME
grants. The HHSC
recommended funding
the HS proposals and
capital project proposal
in the amounts
recommended
by staff.
3 agencies
representatives
spoke during this
meeting. See
Attachment -
"Proof of
Publication and
Citizen
Participation
Comments."
All comments
were accepted
3 Newspaper Ad
Non-
targeted/
broad
community
A display ad was
published in the
Sunnyvale Sun on
March 27, 2026.
Attachment -
"Proof of
Publication and
Citizen
Participation
Comments."
Not applicable
Attachment 2
Sort
Order
Mode of
Outreach
Target of
Outreach
Summary of
response/
attendance
Summary of
comments
received
Summary of
comments not
accepted
and reasons
URL
(If applicable)
4 Website
Non-
targeted/
broad
community
Draft Action Plan
posted at:
https://sunnyvale.ca.go
v/property
/housing/default.htm
Attachment -
"Proof of
Publication and
Citizen
Participation
Comments."
Not applicable
https://sunnyva
le.ca.gov/prope
rty
/housing/defaul
t.htm
5 Public
Hearing
Non-
targeted/
broad
community
The HHSC held a public
hearing on April 14,
2026 to recommend to
the City Council to
approve the 2026
Action Plan.
Attachment -
"Proof of
Publication and
Citizen
Participation
Comments."
All comments
were
accepted
6 Public
Hearing
Non-
targeted/
broad
community
The City Council held a
public hearing on May
5, 2026 to consider the
Action Plan, consistent
with the 2025-2030
Consolidated Plan.
Attachment -
"Proof of
Publication and
Citizen
Participation
Comments."
All comments
were
accepted
Table 4 – Citizen Participation Outreach
Attachment 2
Expected Resources
AP-15 Expected Resources – 91.220(c)(1,2)
Introduction
As shown the table below, the City will receive $1,023,080 in 2026 entitlement CDBG funds and $382,897.32 in HOME funds. In addition, the City estimates that it will also receive approximately $163,000 in CDBG program income in FY 2025/26, to be determined at end of fiscal year, and has prior year unspent funds of $540,876.68 from entitlements and $275,684.70 from RLF program income funds.
The City will deposit all program income into the Revolving Loan Fund. This brings the total CDBG grant funding for FY 2026/27 to $1,563,956. This total of entitlement grant funds plus the Revolving Loan Fund of $275,684.70 gives the City total available funds of $1,839,641.38. This amount may increase slightly, as additional program income may be received before the end of this fiscal year. Total available HOME funding for FY 2026/27 will be $1,364,201.46 which includes the new allocation, plus estimated program income from the fiscal year, administrative reserves, and prior year unspent funds from the previous program year.
Local (City) Resources
The City has a local Housing Mitigation Fund (HMF) and Below Market Rate (BMR) In-Lieu Funds for the development, rehabilitation and/or acquisition of affordable housing. Since December 2020, the City allocated about $70 million to six affordable housing developments) through three separate competitive funding availabilities. Awarded developments include Meridian (397 S. Mathilda Ave), Ira D Hall Square (1178 Sonora Court), Orchard Gardens (245 W. Weddell Dr), 1171 Sonora Court, 295 S. Mathilda Ave, and 352 E. Java Drive. Combined these projects will increase the affordable housing stock by over 900- units. In addition to Housing Mitigation Funds, the City also has funds available in its Housing Successor Agency Low-Mod Housing Fund, these funds are allocated outside of the Action Plan process, but with a similar goal of expanding and preserving the City’s affordable housing stock.
The City also leverages General Fund resources to support housing and human services priorities beyond what federal grants alone can fund. General Fund resources support the HOME Tenant-Based Rental Assistance (HOME-TBRA) program, enabling the City to provided supportive services to households.
Additionally, the City uses General Fund dollars to support non-CDBG human services programs, ensuring continuity of critical services for low- and moderate-income residents.
Other Public Resources
Low-Income Housing Tax Credit Program (LIHTC)
The LIHTC program provides federal and state tax credits for developers and investors who agree to set aside all or a percentage of their rental units for low-income households for no less than 30 years. Most recently, MidPen Housing’s Ira D. Hall Square (1178 Sonora) was awarded tax credits for their 175 unit Attachment 2
d
evelopment in 2023.
Homeless Emergency and Rapid Transition to Housing (HEARTH) and Emergency Shelter Grants (ESG) Santa Clara County serves as lead agency for the County’s Continuum of Care (CoC), which receives Hearth Act, ESG, and similar federal grants to provide shelter, housing, and supportive services to homeless people residing anywhere in the County. The City has contributed some of its local funds to various county-wide projects and programs that often receive CoC support as well, such as shelter facilities, transitional and permanent supportive housing, tenant-based rental assistance, and supportive services.
Private Resources
Most of the City’s housing and human services programs leverage various sources of private financing. The City encourages the participation of local lenders in its housing and/or community development projects as needed. The City is a founding member of the Housing Trust of Santa Clara County, which raises voluntary contributions from the public and private sectors for affordable housing projects within the County. The City has contributed some of its local housing funds to the Trust, which then uses those seed funds to seek matching contributions from corporations and various other sources.
Attachment 2
Anticipated Resources
Program Source
of
Funds
Uses of Funds Expected Amount Available Year 1 Expected Amount
Available
Remainder
of ConPlan
$
Narrative Description
Annual
Allocation: $
Program
Income: $
Prior Year
Resources:
$
Total:
$
CDBG public -
federal
Acquisition
Admin and
Planning
Economic
Development
Housing
Public
Improvements
Public Services
1,023,080.00 150,000.00 816,561.38 1,989,641.38 3,069,240.00 Housing
Rehabilitation; Public
Infrastructure and
Facilities; Public
Services; Economic
Development;
Alleviation of
Homelessness;
Administration.
Expected amount
available for
remainder of plan is
4x the annual
allocation as funding
is uncertain.
HOME public -
federal
Acquisition
Homebuyer
assistance
Homeowner
rehab
Multifamily
rental
construction
Multifamily
rental rehab
Construction for
ownership
TBRA
382,897.32 50,000.00 981,304.14 1,414,201.46 1,148,691.96 Administration and
Planning Activities
Tenant Based Rental
Assistance.
Table 5 - Expected Resources – Priority Table
Attachment 2
Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied Entitlement Funds
Through the SCCHA and affordable housing developers, the City utilizes benefits from additional federal programs to provide community development activities, affordable housing activities, and supportive services. The other federal grant programs include:
• Section 8 Housing Choice Voucher Program;
• Section 202;
• Section 811; and
• Affordable Housing Program (AHP) through the Federal Home Loan Bank.
The City pursues and encourages its partner agencies to seek all available public and private funding sources in order to achieve the goals of the Consolidated Plan. Most projects and activities secure funding from a variety of sources, including public and private sector donations, grants, loans, and in- kind materials and services.
The City encourages the participation of local lenders in its housing and/or community development projects as needed. Tax credit projects such as Ira D. Hall Square, Block 15, Benner Plaza, and Onizuka Crossing, required millions of dollars in private equity and financing for construction and related costs.
The City does not require all applicants for CDBG and HOME funds for capital projects to provide a match, however, proposals often provide a match. Matching contributions and other financial management proficiency is considered when evaluating programs.
Matching funds may include other available financing sources, such as tax credits, other public sector loans or grants, private capital or donations, rent proceeds, and/or the value of in-kind services (i.e., volunteer and staff services or pro-bono professional services used to implement the capital project).
The City often provides more local funds than CDBG or HOME funds to assist major affordable housing projects, since those local funds are often available in larger amounts than federal funds.
Attachment 2
If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan
In recent years, the City has made several publicly owned properties available for affordable housing development, which is one of the needs identified in this plan. These projects included the Fair Oaks Plaza, Onizuka Crossing, Habitat Homes, Parkside Studios, Meridian, and Ira D. Hall Square. Another City- owned site known as 295 S. Mathilda of the Downtown Specific Plan is currently under Planning Entitlement review for 120 units of affordable housing.
Discussion
HUD allocations are critical to overcoming barriers; however, it is not sufficient to address all the needs of LMI households. Therefore, the City will continue to leverage other funding sources to provide services to populations in need.
Attachment 2
Annual Goals and Objectives
AP-20 Annual Goals and Objectives
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs
Addressed
Funding Goal Outcome
Indicator
1 Affordable
Housing 2025 2030 Affordable
Housing
Citywide
Target
Affordable
Housing
CDBG:
$839,540.00
HOME:
$57,434.60
Homeowner
Housing
Rehabilitated: 41
Housing Units
Other: 1
2 Expanding
Economic
Opportunity
for Low
Income HH
2025 2030
Non-Housing
Community
Development
Citywide
Target
Expanding
Economic
Opportunities
for LI
Households
CDBG:
$552,000.00
Jobs
created/retained:
20 Jobs
Other: 60 Other
3 Public Services 2025 2030
Homeless
Non-Homeless
Special Needs
Non-Housing
Community
Development
Citywide
Target
Community
Development
CDBG:
$177,800.00
Public service
activities other
than
Low/Moderate
Income Housing
Benefit: 500
Persons Assisted
4 Administration 2025 2030
Affordable
Housing
Homeless
Non-Homeless
Special Needs
Non-Housing
Community
Development
Administration
Citywide
Target
Affordable
Housing
Homelessness
Community
Development
Expanding
Economic
Opportunities
for LI
Households
CDBG:
$234,616.00
HOME:
$38,290.00
Other: 1 Other
5 Homelessness 2025 2030
Affordable
Housing
Homeless
Citywide
Target Homelessness HOME:
$1,000,000.00
Tenant-based
rental assistance /
Rapid Rehousing:
40 Households
Assisted
Table 6 – Goals Summary
Goal Descriptions
Attachment 2
1 Goal Name Affordable Housing
Goal
Description
Assist in the creation, improvement, and preservation of affordable housing for lower-income and special needs households by supporting affordable rental housing, and continuing the Home Improvement Program.
Additionally, the City is funding the Repair and Accessibility Modification Services program run by Rebuilding Together Silicon Valley. This program offers more rehabilitation repairs for low-income, owner-occupied households, focusing on safety and accessibility. The program aims to assist 32 households.
Affordable housing assistance is provided throughout the City, in order to avoid concentration of poverty, and to ensure fair access to affordable housing, rehabilitation assistance, and homeownership opportunities in all neighborhoods.
Included 15% CHDO set aside for HOME.
2 Goal Name Expanding Economic Opportunity for Low Income HH Goal
Description
Support economic development activities that promote employment growth and help lower-income and/or homeless people secure and maintain jobs. Upwards Boost will assist 60 microenterprise childcare facilities by providing coaching and digital tools to optimize operations allowing efficient management and expanding access to affordable working families. The program will also create approximately 20 new jobs among the providers that have capacity to grow their businesses. 3 Goal Name Public Services
Goal
Description
Assist clients with basic needs, such as food, shelter, transportation, health & mental health care, employment assistance/training, legal aid, etc. 4 Goal Name Administration
Goal
Description
Administrative allocation for oversight and management of CDBG and HOME. Includes $26,415 in Fair Housing Services funded from CDBG Admin.
Eligible Activity (Matrix Code): 21D.
5 Goal Name Homelessness
Goal
Description
Prevent homelessness through the Tenant Based Rental Assistance Program. Rental assistance and ongoing case management and employment assistance to households who are unhoused or at risk of homelessness.
Table 7 – Goals Descriptions
Attachment 2
Projects
AP-35 Projects – 91.220(d)
Introduction
The activities that the City will undertake in FY 2026/27 using CDBG and HOME funds include: human services grants; rental housing rehabilitation and energy efficiency; employment development services for homeless and at-risk clients; access improvements, fair housing services, and program administration, as shown below. All of these activities are eligible for the indicated funding type based on federal regulations associated with these grants, and all of them meet one or more priority needs as identified through the City's citizen participation process.
Projects
# Project Name
1 CDBG Administration and Monitoring
3 Minor Home Improvement Grants Program
4 Major Rehabilitation Program (RLF)
5 Rebuilding Together Silicon Valley Repair and Accessibility Modification Services 6 Upwards Care Boost Program
7 Public Services
8 Fair Housing Services
9 HOME Administration and Monitoring
10 Tenant Based Rental Assistance (TBRA)
11 CHDO Set Aside
Table 8 - Project Information
Describe the reasons for allocation priorities and any obstacles to addressing underserved needs Funding Priorities
The projects listed above were selected based on the needs identified in the Consolidated Plan, and in response to the proposals for funding received, and an evaluation of project feasibility.
Each year the City solicits proposals from local organizations for CDBG and HOME funding for eligible housing and community development programs or projects in Sunnyvale. The Request for Proposals sets forth the types of public services (human services) programs, capital and housing projects that are eligible for CDBG or HOME funding from the City and explains the City’s process for evaluating and scoring proposals, determining award amounts, and approving awards. The City provides human services grants for public services which address identified priority needs and principally benefit lower- Attachment 2
i
ncome people in Sunnyvale.
Applications for the human services grants are solicited every other year, following hearings held by the Housing and Human Services Commission (HHSC) and Council to determine the City’s current “priority human service needs.” The “Priority Needs” for the City of Sunnyvale's Community Development Block Grant Program were determined through a series of community meetings held between October 2024 and January 2025 and were adopted as part of the 2025-2030 Consolidated Plan in accordance with regulations established by HUD.
FY 2026/27 will be the second year of a two-year funding cycle for human services grantees who will have their contracts automatically renewed, adjusted for any variation of funding received.
Obstacles to Meeting Underserved Needs
In the past several years, the primary obstacle to meeting underserved local needs in the near term has been the significant delays and continued uncertainty regarding federal appropriations for the CDBG and HOME programs, and other HUD funded programs such as Section 8, as well as changes to the LIHTC created by the recent federal tax reform bill. The region also continues to struggle finding a qualified CHDO to allocate funds toward.
Attachment 2
AP-38 Project Summary
Project Summary Information
1 Project Name CDBG Administration and Monitoring
Target Area Citywide Target
Goals Supported Administration
Needs Addressed Affordable Housing
Homelessness
Community Development
Expanding Economic Opportunities for LI Households
Funding CDBG: $208,201.00
Description Program administration for CDBG activities.
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
N/A
Location Description Citywide
Planned Activities N/A
2 Project Name Minor Home Improvement Grants
Target Area Citywide Target
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $119,000.00
Description The City of Sunnyvale's Minor Home Improvement Program provides grants directly to lower-income, owner-occupied households for urgent or emergency repairs that address immediate health, safety, or habitability concerns. This program addresses time-sensitive repair needs that fall below the threshold for major rehabilitation loans.
Target Date 6/30/2027
Attachment 2
E
stimate the number
and type of families
that will benefit from
the proposed
activities
Assist at least 7 households with minor home improvement grants Location Description Citywide
Planned Activities The Home Improvement Program provides small grants for minor improvements, such as emergency repairs, Homes must be owned and occupied by a lower-income household to be eligible for this program. 3 Project Name Major Rehabilitation Program (RLF)
Target Area Citywide Target
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $240,000.00
Description The City of Sunnyvale’s Major Rehabilitation Program issues loans to qualifying single-family or mobile-homeowners, many seniors, who need major rehabilitation performed on their home for habitability purposes, including Activity Delivery Cost (CDBG matrix code 14H Rehabilitation Administration).
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
Approximately 2-3 households will benefit from this program Location Description Citywide
Planned Activities To issue loans to qualifying single-family or mobile-homeowners, many seniors, who need major rehabilitation performed on their home for habitability purposes.
4 Project Name Rebuilding Together Silicon Valley Repair and Accessibility Modification Services
Target Area Citywide Target
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding CDBG: $480,540
Attachment 2
D
escription Rebuilding Together Silicon Valley (RTSV) provides comprehensive home rehabilitation and accessibility modification services to low- income, owner-occupied households, prioritizing seniors and people with disabilities. Services include structural repairs, exterior improvements, and accessibility modifications such as grab bars, ramps, and widened doorways. RTSV delivers repairs on an ongoing basis throughout the program year, including through organized volunteer events that mobilize community resources to maximize the number of households served.
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
Assist 32 low-income, owner-occupied households with deferred maintenance of their homes, allowing the stock of naturally affordable housing to remain available. The households will also be able to further age in place as the program prioritizes seniors and those with disabilities.
Location Description Citywide
Planned Activities The program provides small grants for minor improvements, exterior painting, and accessibility improvements. Homes must be owned and occupied by a lower-income household to be eligible for this program. 5 Project Name Upwards Care Boost Program
Target Area Citywide Target
Goals Supported Expanding Economic Opportunity for Low Income HH Needs Addressed Expanding Economic Opportunities for LI Households Funding CDBG: $552,000.00
Description Upwards, Inc. provides support to microenterprise childcare facilities by providing coaching and digital tools to optimize operations allowing efficient management and expanding access and affordability to working families
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
Assist 60 microenterprise childcare facilities
Location Description Citywide
Attachment 2
P
lanned Activities To create Teaching Assistant positions to guide microenterprises to learn to optimize payment and marketing operations, access to free software, and maximize business capacity, affecting access and price of childcare.
6 Project Name Public Services
Target Area Citywide Target
Goals Supported Public Services
Needs Addressed Community Development
Funding CDBG: $177,800.00
Description Assist clients with basic needs, such as food, advocacy, mental health care, legal aid, etc. Public services are delivered by a network of five nonprofit agencies serving low-income Sunnyvale residents: Project Sentinel, Sunnyvale Community Services, Sunnyvale United Methodist Church, Child Advocates of Silicon Valley, and Bill Wilson Center.
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
Assist approximately 500 households with human services through separate non-profit programs that offer food, counseling, and foster youth support, and legal aid.
Location Description Citywide
Planned Activities Assist clients with basic needs, such as food, mental health care, legal aid, etc.
7 Project Name Fair Housing Services
Target Area Citywide Target
Goals Supported Administration
Needs Addressed Affordable Housing
Funding CDBG: $26,415.00
Description Project Sentinel provides fair housing services to low-income households. Fair Housing Services funded from CDBG Administration Eligible Activity (Matrix Code): 21D
Target Date 6/30/2027
Attachment 2
E
stimate the number
and type of families
that will benefit from
the proposed
activities
25 low-income households of Sunnyvale will benefit from this proposed activity.
Location Description Citywide
Planned Activities Provide fair housing services to low-income households 8 Project Name HOME Administration and Monitoring
Target Area Citywide Target
Goals Supported Affordable Housing
Administration
Needs Addressed Affordable Housing
Homelessness
Community Development
Expanding Economic Opportunities for LI Households
Funding HOME: $38,290.00
Description Funds are used for administering the HOME program, includes costs of HOME capital project management, tracking grant funds and program income, subrecipient monitoring, reporting, and compliance with federal requirements such as environmental, labor, and anti- discrimination. Indirect costs (overhead) are also included in program administration.
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
N/A
Location Description Citywide
Planned Activities Funds are used for administering the HOME program, includes costs of HOME capital project management, tracking grant funds and program income, subrecipient monitoring, reporting, and compliance with federal requirements such as environmental, labor, and anti- discrimination. Indirect costs (overhead) are also included in program administration.
Project Name Tenant Based Rental Assistance (TBRA)
Attachment 2
9 Target Area Citywide Target
Goals Supported Affordable Housing
Homelessness
Needs Addressed Affordable Housing
Homelessness
Funding HOME: $1,000,000.00
Description Sunnyvale Community Services provides rental assistance and ongoing case management and employment assistance to households who are unhoused or at risk of homelessness.
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
Provide 40 low-income households with rent and security deposit assistance
Location Description Citywide
Planned Activities To provide rental assistance and ongoing case management and employment assistance to households who are unhoused or at risk of homelessness.
10 Project Name CHDO Set Aside
Target Area Citywide Target
Goals Supported Affordable Housing
Needs Addressed Affordable Housing
Funding HOME: $57,434.60
Description To provide funding to a qualified Sunnyvale CHDO with a project site.
Target Date 6/30/2027
Estimate the number
and type of families
that will benefit from
the proposed
activities
N/A - No CHDO application was received for 2025 funds
Location Description TBD
Planned Activities Identify eligible Sunnyvale CHDO with a project site.
Table 9 - Project Summary
Attachment 2
AP-50 Geographic Distribution – 91.220(f)
Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed Investments will be allocated citywide for affordable housing services and related capital projects, homeless services, fair housing, and public services.
Geographic Distribution
Target Area Percentage of Funds
Citywide Target 100
Table 10 - Geographic Distribution
Rationale for the priorities for allocating investments geographically Most of the CDBG and/or HOME-funded programs and services are provided on a city-wide basis to income-eligible and/or special needs households. Certain capital projects are assisted at a specific site, based on the location of the project, but projects may be proposed in any area of the City. Projects that qualify for CDBG funding based on the area benefit method are limited to areas with the required proportion of lower- and moderate-income residents as determined by HUD.
Human services are supported in a number of facilities and locations throughout the City, and in some cases just outside the City, as long as Sunnyvale residents are being served by the program. Affordable housing assistance is generally provided anywhere in the City, as opportunities arise, in order to avoid concentration of poverty, and to ensure fair access to affordable rental housing, rehabilitation assistance, and homeownership opportunities in all neighborhoods. The City does not have any blighted areas requiring major redevelopment, and private development is occurring throughout the City.
Discussion
N/A
Attachment 2
Affordable Housing
AP-55 Affordable Housing – 91.220(g)
Introduction
The City’s housing programs are intended to prevent and/or end homelessness, improve the quality, affordability, and/or accessibility of housing, and preserve, maintain, and extend the useful life of existing affordable housing. The goals below include only the new CDBG and HOME activities to be funded in FY 2026/27. Other activities funded in prior years’ Action Plans through non-HUD programs, will continue to be funded using carry-over funds, and will assist additional households.
One Year Goals for the Number of Households to be Supported Homeless 40
Non-Homeless 41
Special-Needs 0
Total 81
Table 11 - One Year Goals for Affordable Housing by Support Requirement
One Year Goals for the Number of Households Supported Through Rental Assistance 40
The Production of New Units 0
Rehab of Existing Units 41
Acquisition of Existing Units 0
Total 81
Table 12 - One Year Goals for Affordable Housing by Support Type
Discussion
N/A
Attachment 2
AP-60 Public Housing – 91.220(h)
Introduction
This section is not applicable as there is currently no official public housing in Sunnyvale. The City collaborates with the SCCHA on its efforts to provide Section 8 vouchers, mortgage credit certificates, supportive services and other assistance to Sunnyvale residents. The City also supports the HACSC in its efforts to increase federal appropriations for Section 8 and other affordable housing programs in Sunnyvale and in the County.
Actions planned during the next year to address the needs to public housing Not applicable due to no official public housing in Sunnyvale. Details provided in Discussion section.
Actions to encourage public housing residents to become more involved in management and participate in homeownership
Not applicable due to no official public housing in Sunnyvale. Details provided in Discussion section.
If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance
Not applicable due to no official public housing in Sunnyvale. Details provided in Discussion section.
Discussion
Needs of Public Housing
This section is not applicable as there is currently no official public housing in Sunnyvale. The City collaborates with the SCCHA on its efforts to provide Section 8 vouchers, mortgage credit certificates, supportive services and other assistance to Sunnyvale residents. The City also supports the HACSC in its efforts to increase federal appropriations for Section 8 and other affordable housing programs in Sunnyvale and in the County.
The City has partnered with the Housing Authority in recent years on several Sunnyvale housing projects which were awarded project-based vouchers, including Block 15, the Fair Oaks Senior Housing project, two senior group homes, Parkside Studios, Onizuka Apartments, and Edwina Benner Plaza.
Attachment 2
AP-65 Homeless and Other Special Needs Activities – 91.220(i) Introduction
This Action Plan includes a planned allocation of $1,000,000 for a Tenant Based Rental Assistance (TBRA) program that helps individuals experiencing or at risk of homelessness with their rent payments. The program offers a rental subsidy so that the participants are never paying more than 30 percent of their income toward rent. The program also offers a stipend for utility allowances and payment of security deposits, to reduce additional barriers into secured housing. The program is coupled with wrap-around case management, and allows the participant up to two years to work to reduce existing barriers to affording their rent without subsidy. This time also offers access to housing while a household may be on a waitlist for affordable housing options that may be more sustainable.
In addition to funding various public services, several of which address homelessness and basic needs, the City continues to participate in the coordinated efforts to end homelessness throughout the County.
Since December 2020, the City approved about $40 million in funds to assist the development of Meridian, 1178 and 1171 Sonora Ct., and Orchard Gardens, Mathilda, and Java Drive, which will increase the City’s affordable housing supply by about 900-units.
Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs The Tenant Based Rental Assistance program accepts referrals through multiple pathways to ensure flexible and accessible entry into the program. Sunnyvale Community Services, the program administrator, oversees the application and intake process and assesses the needs of each client to determine eligibility and appropriate level of assistance.
Addressing the emergency shelter and transitional housing needs of homeless persons Local nonprofit agencies such as WeHOPE, the City of Sunnyvale’s contracted street outreach provider, and the Bill Wilson Center, the County’s North County Family Shelter provider, provides emergency shelter, transition housing, and services to households experiencing homelessness and victims of domestic violence.
Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again
Funded activities that help unhoused individuals transition to permanent housing includes the TBRA Attachment 2
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rogram. The total HOME funding planned for this activity is $1,000,000 in 2026.
Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs.
See discussion below.
Discussion
Several of the Human Services grants will support the provision of services intended to prevent homelessness of Sunnyvale residents including the grants to as well as the fair housing services provided by Project Sentinel, who offers eviction support and advocacy, and addresses discrimination practices that can lead to homelessness. In addition to CDBG funded activities, the City also provides assistance to other programs that aim to prevent homelessness using local funds, and previous year HOME funds.
These include grants to Senior Adults Legal Services, funding for tenant-landlord mediation programs, and the TBRA program.
Attachment 2
AP-75 Barriers to affordable housing – 91.220(j)
Introduction:
Land use controls, site improvement requirements, fees and exactions, permit processing procedures, and various other issues may act as barriers to affordable housing development. Additionally, land costs, construction costs, and market financing contribute to the cost of housing development and reinvestment and can potentially hinder the production of new affordable housing.
As part of its 2023-31 Housing Element update, the City of Sunnyvale conducted an analysis of both governmental and non-governmental constraints on affordable housing development and found the following, as listed below. The City is actively working to implement new policy and programs to reduce barriers to development.
Land Use Controls
• Mixed-use parking requirements involve the use of a parking calculator that is not available to the public. Parking requirements for studios and efficiency units in the Downtown district could be reduced.
• Several residential design guidelines are subjective, which has the potential to delay planning approvals.
• The City must continue to support the production of ADUs by limiting constraints and ensuring that the zoning code complies with State law.
• The Zoning Code does not explicitly allow employee housing of six or fewer employees, which may constrain farmworker housing.
• The Zoning Code may result in constraints to housing types for persons with special needs, including group homes, SROs, supportive housing, emergency shelters, low barrier navigation centers, and residential facilities.
• The Zoning Code may constrain the adaptive reuse of existing structures in industrial districts. • The Zoning Code may constrain some missing middle housing types in low-density, single-family zoning districts.
• Affordable housing and other higher density residential developments may be constrained by zoning regulations in Higher Opportunity Areas in southern Sunnyvale.
Processing and Permitting Procedures
• There is no established program to process SB 35 applications. • Residential planning permit procedures may lack clarity, increasing processing times, and do not Attachment 2
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dentify objective design standards.
Fees and Exactions
• Some development impact fees may be higher than other jurisdictions, which may increase overall residential development costs.
• Park dedicated in-lieu fees for Dual Urban Opportunity units with an urban lot split may be higher than other jurisdictions, which may act as a barrier to SB 9 projects.
Housing for Persons with Disabilities
• The Zoning Code’s definition of “family” may cause constraints on housing for persons with disabilities.
• Reasonable accommodation findings may be a constraint on the development of housing for persons with disabilities.
Non-governmental Constraints
• Lack of financing for affordable housing development severely constrains the creation of deed- restricted housing that is affordable for lower-income households. • Lack of affordable financing is a barrier to homeownership for low- to moderate-income households.
• Lack of affordable financing prevents many lower-income homeowners from completing needed accessibility improvements and repairs.
Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment
The City does not impose any public policies that unreasonably constrain housing development. There are no growth limitations or rent control policies, and property tax policies are largely set by the State.
The City’s land use designations and zoning are supportive of development of a wide variety of housing types, including single- and multi-family housing, ownership and rental, mobile homes, manufactured/modular housing, and so on. The City follows the State building code, and its fees and charges are reasonable and consistent with prevailing prices in the region. Since 2018, 6,605 new housing units were issued building permits, with 1,008 of those affordable to very low-, low-, or moderate-income households.
In 2023, the City adopted its 2023-2031 Housing Element, which includes a Constraints Analysis, as required under California Housing Element law (Government Code 65580), to analyze city policies and Attachment 2
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and use regulations to determine if they had any negative effects on development. The State determined, with its certification in March 2024, that the City does not currently implement policies that create barriers to affordable housing. As noted above, thousands of new dwelling units of various types and price points have been developed and additional units renovated in recent years, in most cases without any direct assistance from the City. This demonstrates that the City’s policies do not unduly constrain residential development. In addition, the City has successfully assisted a number of affordable housing developments in recent years, which demonstrates that City policies do not have negative effects on assisted housing production. Non-governmental barriers, primarily market factors such as high land costs, construction costs, and high prevailing market prices for housing, have been the primary challenges facing jurisdictions in the region, including Sunnyvale, in recent years, not city land use policies. These barriers are addressed, within the City’s limited ability to address them, through the housing activities listed above and through the goals and policies listed in the Housing Element.
Discussion:
N/A
Attachment 2
AP-85 Other Actions – 91.220(k)
Introduction:
This section discusses the City’s efforts in addressing the underserved needs, expanding and preserving affordable housing, reducing lead-based paint hazards, and developing institutional structure for delivering housing and community development activities.
Actions planned to address obstacles to meeting underserved needs The City has addressed obstacles to meeting underserved needs by adopting programs to generate local funds for affordable housing through impact fees or new development of affordable units (inclusionary zoning). The primary obstacle to meeting unmet needs is the continued decline in federal appropriations for affordable housing and community development programs. The City has established local policies to address needs to the extent possible with local resources.
Actions planned to foster and maintain affordable housing Please see AP-35 (i.e., Affordable Housing Rehabilitation, Fair Housing Services, and Home Improvement Program).
Actions planned to reduce lead-based paint hazards
The City provides financial assistance to income-eligible homeowners to abate lead-based paint hazards through its Home Improvement Program. Paint grants and loans, as well as housing rehabilitation loans, are provided, as well as free lead-based paint testing and education services. Lead-based paint hazards in rental housing can also be addressed through housing rehabilitation loans.
Actions planned to reduce the number of poverty-level families In 2014 the City adopted a new minimum wage ordinance increasing the local minimum wage, as of 2026 it is currently $19.50/hour. It will be adjusted annually thereafter by the CPI. This action alone will help many local low-wage workers increase their household incomes to above the federal poverty levels.
The North Valley Workforce and Investment Board (“NOVA”) helps prepare lower-income and unemployed residents of Sunnyvale for career growth and stable employment. NOVA provides employment and training services to low-income workers and dislocated professionals within Sunnyvale and the surrounding region under the federal Workforce Investment Act (WIA), with a goal of helping these clients obtain jobs and improve career prospects. In addition, many of the human services supported by the City help impoverished families meet their basic needs in the short term, or help them Attachment 2
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chieve living-wage employment.
The TBRA program is also a major anti-poverty program that helps Sunnyvale residents who are currently homeless or at imminent risk of homelessness have a chance to increase their incomes through secured housing allowing the flexibility to grow their careers, seek additional education, or remove barriers to work.
Actions planned to develop institutional structure
The institutional structure for carrying out the City’s housing and community development activities consists of the City’s cooperative relationships within its departments and other government agencies, local residents, non-profit organizations, and other institutions involved in the activities described herein.
Actions planned to enhance coordination between public and private housing and social service agencies
The City and other community development organizations in the County coordinate frequently on a variety of initiatives. The City Housing Division staff participates in a collaborative of HUD entitlement grantees within the County, which holds quarterly meetings to discuss activities, technical assistance issues, and identify future opportunities for coordination and cooperation between local governments, housing providers, social service agencies, and the Housing Authority.
The City also participates in the County’s Continuum of Care (CoC) meetings, comprised of governmental agencies, homeless service and shelter providers, unhoused individuals, housing advocates, affordable housing developers, and various private parties, including businesses and foundations. A CoC Steering Committee lead the charge to develop the 2022-2025 Community Plan to End Homelessness, which seeks to create a comprehensive and coordinated system of affordable housing and supportive services for the prevention, reduction, and eventual end of homelessness. The Plan provides a common guide for the County, cities, service providers, the faith community, the business sector, philanthropy, and the broader community to follow in addressing local housing and the goals and services needs for homeless people. The actions included in this Plan to address housing needs and homelessness are consistent with the CoC’s plans and policies. The County of Santa Clara is gearing up to develop a new Community Plan, and the City of Sunnyvale plans to be part of the community process. The City’s Housing Officer has served on the CoC’s “Review and Rank” panel, evaluating and scoring applications for CoC funding, for the past three years.
Sunnyvale also coordinates with other regional agencies, such as the Housing Trust of Silicon Valley, Joint Venture Silicon Valley, NOVA, the County-wide Fair Housing Task Force, and the Valley Transportation Authority, and a number of other non-profit or public agencies, to achieve the goals described within this Action Plan.
Attachment 2
Program Specific Requirements
AP-90 Program Specific Requirements – 91.220(l)(1,2,4)
Introduction:
Overall Benefit: FY 2026-2027
Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.
1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed 240,000
2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan. 0
3. The amount of surplus funds from urban renewal settlements 0
4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan 0
5. The amount of income from float-funded activities 0
Total Program Income: 240,000
Other CDBG Requirements
1. The amount of urgent need activities 0
2. The estimated percentage of CDBG funds that will be used for activities that benefit persons of low and moderate income. Overall Benefit - A consecutive period of one, two or three years may be used to determine that a minimum overall benefit of 70% of CDBG funds is used to benefit persons of low and moderate income. Specify the years covered that include this annual Action Plan.
90.00%
Attachment 2
HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)
1. A description of other forms of investment being used beyond those identified in Section 92.205 is as follows:
N/A
2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows:
Not applicable: The City has not allocated any HOME funds for homebuyer program activities since 2014. The City does not plan to fund any home buyer loans with HOME funds for the foreseeable future, since market-rate home prices in the City are far too high for such a program to be feasible, and the City has enough local (non-federal) Housing funds to meet demand for down payment assistance loans related to its inclusionary housing program.
For several years prior to 2014, the City allocated HOME funds for a First-Time Home Buyer (FTHB) Program, but only a very small number of HOME loans were made, and those were used to buy price- restricted affordable homes through the City’s inclusionary home buyer program. These homes are subject to a thirty-year resale restriction. Currently there are four outstanding FTHB loans made with HOME funds at that time. These four loans are subject to the “resale” restriction rather than the “recapture” provision, consistent with the City’s First Time Home Buyer Program guidelines, and the inclusionary program’s resale restrictions. These restrictions are also included in the HOME loan documents and affordability covenants recorded against the home. The FTHB Program Guidelines, available online, and the provisions of the City’s HOME Promissory Note and Loan Agreement comply with the resale provisions and requirements set forth in 24 CFR 92.254, and were approved by HUD in 2011. For the four participants who purchased inclusionary homes, the “resale option” was used to meet HOME program requirements. Although the market-rate home purchase option was made available for the several years during which the HOME FTHB program operated, and during that time the City had loan documents and guidelines available to impose the “recapture” provisions, the City never made any HOME loans to assist with purchase of market-rate homes, as none ever progressed to an escrow closing. The City does not plan to allocate HOME funds to home buyer activities in the future because the unpredictability of such transactions occurring in any given year does not mesh well with the expenditure deadlines imposed by the HOME regulations, and because there is no inventory of market-rate homes affordable to lower- income buyers.
3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows:
Please see above. The City’s FTHB program has not been funded with HOME funds since 2014 and the City does not intend to fund such activities in the future. The four outstanding HOME-funded FTHB loans made before 2014 used the resale method, which is a 30-year price restriction imposed through the City’s inclusionary housing program (a.k.a. Below Market Rate Home Ownership Program, Sunnyvale Municipal Code 19.67) documents and is also included in the FTHB loan Attachment 2
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ocuments. For more information about the FTHB guidelines and the BMR Program, please see the information on the City’s website:
https://sunnyvale.ca.gov/civicax/filebank/blobdload.aspx?BlobID=22887 [note that Guidelines still reference HOME funds as a possible funding source, although the City is no longer allocating HOME funds to this program.
4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows:
Not Applicable. The City has not and does not plan to use HOME funds to refinance existing debt on multi-family housing.
5. If applicable to a planned HOME TBRA activity, a description of the preference for persons with special needs or disabilities. (See 24 CFR 92.209(c)(2)(i) and CFR 91.220(l)(2)(vii)).
The TBRA program, funded by HOME entitlement funds, requires participants to have an income of less than 50% of the area median income. This preference is due to the lack of affordable housing compared to the demand for it in Sunnyvale.
6. If applicable to a planned HOME TBRA activity, a description of how the preference for a specific category of individuals with disabilities (e.g. persons with HIV/AIDS or chronic mental illness) will narrow the gap in benefits and the preference is needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2)(ii) and 91.220(l)(2)(vii)).
Economic conditions have caused the cost of housing in the area to increase faster than average incomes and has left housing options unaffordable to more and more residents. This has widened the gap of services for those with incomes below the AMI and the City's HOME TBRA program narrows the gap in these services by providing rental and down payment assistance.
7. If applicable, a description of any preference or limitation for rental housing projects. (See 24 CFR
92.253(d)(3) and CFR 91.220(l)(2)(vii)). Note: Preferences cannot be administered in a manner that limits the opportunities of persons on any basis prohibited by the laws listed under 24 CFR 5.105(a).
Not applicable.
Attachment 2