HomeMy WebLinkAbout033008 ORD - 03/28/2023Ordinance authorizing and approving a Substantial Amendment to the
Corpus Christi FY2022/PY2021 Consolidated Annual Action Plan for the U.S.
Department of Housing and Urban Development and approval of the Corpus
Christi HOME-ARPA Allocation Plan
Whereas, on March 22, 2022, the City Council enacted Ordinance No. 032701 accepting
and appropriating a grant of $4,213,937.00 from the U.S. Department of Housing and
Urban Development ("HUD") for the HOME Investment Partnership Program- American
Rescue Plan Act funds ("HOME-ARPA");
Whereas, these HOME-ARPA funds are to be used by the City to assist homeless
persons, persons at risk of homelessness, persons fleeing domestic abuse, sexual
assault victims, human trafficking victims or other persons in need of assistance as further
outlined in the HOME -ARP grant guidelines; and
Wh :'rias, before the City can access any of the HOME-ARPA grant funds, the City must
consult with Continuum of Care agencies serving the City's geographic area, homeless
and domestic violence service providers, veterans' groups, public housing agencies,
social services groups, public and private organizations that address fair housing, civil
rights, and the needs of persons with disabilities in the area to develop a HOME-ARPA
Allocation Plan;
Whereas, on March 5, 2023, the City published notice in the Corpus Christi Caller Times
that it was making the City's HOME -ARP Plan available for public review and comment
for at least 15 days and that two public hearings on the HOME-ARPA Plan would be held
on March 21, 2023 and March 28, 2023;
Whereas, the City Council has determined that the Substantial Amendment to the City's
FY2022/PY2021 Consolidated Annual Action Plan ("CAAP") for the HOME-ARPA
Allocation Plan is in the best interest of the city and will serve the public health, safety,
necessity, convenience and the general welfare of the citizens of Corpus Christi, Texas.
Now, Therefore, be it ordained by the City Council of the City of Corpus Christi,
Texas, that:
Section 1. The City's FY2022/PY2021 Consolidated Action Plan for the U.S.
Department of Housing and Urban Development be amended by adopting the City of
Corpus Christi HOME-ARPA Allocation Plan attached hereto and incorporated herein by
reference as Exhibit "A."
Section 2. Public Hearings were held to receive public input on the Corpus Christi
HOME-ARPA Allocation Plan on March 21, 2023 and March 28, 2023 following notice
published in the Caller Times.
Section 3. The City Manager or the City Manager's designee is authorized to submit
the City's HOME-ARPA Allocation Plan to HUD for review and approval.
033 008
1
SCANNED
Section 4. The City Manager or the City Manager's designee is authorized to execute
funding agreements and all other documents necessary to implement the Substantial
Amendment to the FY2022/PY2021 Consolidated Action Plan with the HOME-ARPA
Allocation Plan attached hereto as Exhibit "A."
That the foreaoing ordinance was read for the first time and passed to its second reading
on this the I5 of '\e(t , 2023.
Paulette Guajardo Everett Roy
Roland Barrera Dan Suckley
Gil Hernandez4-1\A"-"A
Sylvia Campos
A►
Michael Hunter Jim Klein /^
Mike PusleyI jr-
That the foregoing ordinance was read for the second time and passed finally on this the
11)
day of 11k 2023, by the following vote:
Paulette Guajardo
Roland Barrera
Gil Hernandez
Michael Hunter
Mike Pusley
Ay(
Everett Roy Ai Q
�-
Dan Suckley n
James Klein ✓'1
Lo,
A,-))),
Sylvia Campos
PASSED AND APPROVED on this the )4fglay of
ATTEST:
ti
Rebecca Huerta
r,rrc.)h
, 2023.
6W�
Paulette Guajardo ,
City Secretary Mayor
033 008
C'ty of
OrpUS Christi
The City of Corpus Christi
HOME ARP Draft Allocation Plan
City of Corpus Christi
HOME -ARP Allocation Plan
In 2021, the Department of Housing and Urban Development (HUD) allocated the City of Corpus
Christi $4,213,937 in HOME funds through the American Rescue Plan Act (ARPA). The HOME -
ARP funds are intended to serve primarily people experiencing homelessness or at risk of
homelessness. Funds can be used on a range of activities to support this population with housing
stability including rental assistance, non -congregate shelter, affordable housing development, and
supportive services. The City sought a range of stakeholder input and compiled community data
in development of this plan.
Consultation
Before developing its plan, a PJ must consult with the CoC(s) serving the jurisdiction's geographic
area, homeless and domestic violence service providers, veterans' groups, public housing
agencies (PHAs), public agencies that address the needs of the qualifying populations, and public
or private organizations that address fair housing, civil rights, and the needs of persons with
disabilities, at a minimum. State PJs are not required to consult with every PHA or CoC within
the state's boundaries; however, local PJs must consult with all PHAs (including statewide or
regional PHAs) and CoCs serving the jurisdiction.
Summarize the consultation process:
City staff held calls, virtual and in-person meetings with the Texas Balance of State Continuum of
Care (CoC) that covers Corpus Christ, domestic violence provider agencies, agencies that serve
persons with disabilities, public housing authority leadership, homeless service provider agencies,
a local worship center serving black, indigenous and persons of color, and public agencies to discuss
gaps in services and their priorities for the funding.
A survey was distributed widely to community groups including the following: CoC membership
agencies, domestic violence task force agencies, homeless veteran working group agencies, faith
based organizations, public housing authority, and all social services and affordable housing
agencies funded by the City of Corpus Christi.
List the organizations consulted, and summarize the feedback received from these entities.
Agency/Org
Consulted,
Type of
Agency/Org
Method of
Consultation
Feedback
Homeless Issues
Local CoC Agency
Presentation at
Case management and other
Partnership
regular meeting.
supportive services to see clients
through to stabilization is lacking.
There is great need for mental
health services and substance use
disorder treatment. Rental
assistance until a public housing
voucher is available is needed.
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The Purple Door
Domestic Violence
Shelter
Phone call
Reports the needs to be TBRA and
Supportive Services. Can serve 75-
100 households each year with
TBRA and Supportive Services.
The Purple Door doesn't want to
own housing.
The Salvation Army
Local homeless
shelter and service
provider
Phone call
Homeless prevention is a priority.
TBRA is a priority. PSH is a
priority. Additional case
management for longer periods of
time is required for chronically
homeless to be success. Supportive
services in addition to case
management is a priority.
Corpus Christi
Housing Authority
Local PHA
In person
meeting
PHA is not currently developing
additional permanent affordable
housing units but has considered
creating transitional units.
City of Corpus
Christi Fair Housing
Unit
Government Fair
Housing Officers
In person
consultation
Providing homeless prevention
services and rapid rehousing for
those being evicted are priority.
Assistance with knowing their
rights and where to go for help and
answers is a priority.
Endeavors
Veterans Services
Phone call
Veterans are facing housing
instability. Housing and support
services are needed by Veterans.
New Life Refuge
Ministries
Child sex trafficking
treatment
Phone call
Children served are not considered
homeless in their care.
Coastal Bend Center
for Independent
Living
Provides services to
persons with
disabilities
Phone call
Permanent supportive housing and
TBRA are priorities. Current
HOME TBRA recipient.
Corpus Christi Hope
House
Local homeless
shelter and service
provider
Phone call
Lack of affordable housing, wait
list to get into public housing or
Section 8, staff capacity and wait
time for services for larger size of
households.
Nueces Center for
Mental Health and
Intellectual
Disabilities
Provides services to
those needing.
assistance with
mental and
behavioral health
Phone call
Supportive services, TBRA and
PSH are priorities. Needs include
affordable housing, cost and
startup costs, shelter options, low -
barrier shelters, shelter with
medical options, and follow up
care.
Texas Balance of
State Continuum of
Care
CoC
Phone call and
email
Provided the CE prioritization
standards for CoC programs and
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HOME ARP Allocation Plan DRAFT for Comment
referred to Point In Time (PIT)
resources and local providers.
Corpus Christi Police
Department
Public Agency — law
enforcement
Meeting
Lack of rental assistance and
supportive services are a need.
Services that keep people in
shelters and housing are needs.
Coastal Bend Aging
and Disability
Resource Center
Aging and Disability
Organization
Phone Call
Lack of adequate supply of
shelters, affordability, supportive
services, accessible and integrated
housing to meet the needs of
seniors and people with
disabilities.
Corpus Christi Fair
Housing Compliance
Unit
Public Agency — fair
housing compliance
Meeting
Needs are the availability of
affordability housing, availability
of accessible units, geographic
distribution of available units,
education, rental assistance,
supportive services during job
training or education that include
rent, child care and transportation.
Nueces County
Department of Social
Services
Government Agency
on Social Services
Phone call and
email
Not enough affordable housing,
focus on prevention of evictions
and utility disconnections.
Supportive services are a priority
need.
Texas Department of
Housing and
Community Affairs
State Agency on
Housing
Phone call and
email
Lack of affordable housing,
affordability of local rents and
staff capacity for agencies who
receive state department funds.
Wenholz House
Transitional House
Support for
Substance Abuse
Recovery
Phone call
Filled to maximum capacity. No
wait list and strong partnerships
with Cenikor and Nueces Center
for Mental Health and Intellectual
Disabilities.
Brooks AME
Worship Center
Faith Based Church
BIPOC
Meeting
Slum and Blight due to Harbor
Bridge Realignment, lack of
investment in Hillcrest
neighborhood area for affordable
housing, supportive services and
infrastructure.
Corpus Christi
Independent School
District
Public School
District
Meeting
Immediate services needed for
emergency food, hotel emergency
assistance, substance abuse
treatment. Shelter and medical
assistance for minors. Supportive
services are a priority need.
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Christus Spohn
Hospital System
Meeting
Affordable Housing, supportive
services, street outreach,
transitional housing or hospice,
respite care or hospital step-down.
Choice Living
Community
Provide services to
persons with
Disabilities
Phone Call
TBRA and supportive services
identified as priority needs.
Health and Human
Services Commission
Public agency
services to persons
with Disabilities
Phone Call
Transitional supportive services
identified as priority needs.
Bloomberg Harvard
Innovation Track
Various services
providers, homeless
persons, residents,
and business owners
Stakeholder
groups, in person
street interviews,
meetings
Gaps exist within the existing
system for providing adequate
access to services and access to
housing.
Community Groups
Response to
Homelessness
Survey
Various community
groups including
service providers,
government
agencies, business
owners and
community
members
Survey
Priority populations in order are
persons who are homeless, persons
who are at -risk of homelessness,
persons who are fleeing, or
attempting to flee, domestic
violence, dating violence, sexual
assault, stalking, or human
trafficking, and other households
who require services or housing
assistance to prevent homelessness.
Number one priority assistance was
supportive services. Tied for second
are TBRA and production or
preservation of housing and third is
purchase and development of non -
congregate shelter.
Various Civil
Rights Groups
CASA, American
GI Forum, National
Association for the
Advancement of
Colored People,
The Mosaic Project
of South Texas and
Coastal Bend Pride
Center
Various attempts
to make contact
with groups.
Affordable housing and shelter
needs. Supportive services
identified as priority need.
Responses received from The
Mosaic Project of South Texas and
Coastal Bend Pride Center.
Coastal Bend
Wellness
Foundation
Social Service
agency
Phone Call
Transitional housing is a need.
Supportive services identified as a
priority.
Summarize feedback received and results of upfront consultation with these entities:
Continuum of Care
The Texas Balance of State Continuum of Care provided their prioritization standards for
Coordinated Entry which identifies where the CoC believes the greatest need to be. During the
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development of the plan, the CoC made the decision to revert to pre-COVID priorities. The CoC
Rapid Re -housing priorities, in priority order, are those with the highest service needs, households
sleeping in an unsheltered sleeping location, households with the longest history of homelessness
and households with the earliest enrollment date in HMIS or HMIS-comparable database. For
Permanent Supportive Housing, the CoC prioritizes, in order or priority, chronically homeless
individuals and families with the longest history of homelessness and with the most severe service
needs, chronically homeless individuals and families with the longest history of homelessness,
chronically homeless individuals and families with the most severe service needs and then all other
chronically homeless individuals and families. The CoC deferred to local service providers for the
best information on local gaps in services. The local CoC partner identified gaps with case
management, substance use disorder treatment, mental health services.
Homeless Services Providers
Homeless service providers overall reported shelter and staff capacity issues, affordable housing,
supportive service needs, non -congregate shelter needs, shelter space for people unable to
ambulate or use facilities without assistance, homeless prevention, and TBRA. Additionally,
transitional housing waiting lists for public housing and Section 8, job skills training deficit, social
services waitlist dependent on size of households needing services were also identified as
obstacles. TBRA and supportive services were stated as priority need.
Human Trafficking/Domestic Violence Service Providers
Human trafficking social service providers identified priority needs as affordable housing and
reliable child care. Social services were identified as a priority need. The domestic violence service
provider identified TBRA and supportive service as the primary needs to include legal assistance
and child care.
Educational Institution
Corpus Christi Independent School District (CCISD) identified student's biggest need as
assistance with emergency food, hotel emergency assistance, and substance abuse treatment. The
school district reported attendance went from 76 to 91 percent just after opening food pantry at
CCISD. At- risk of homelessness and homelessness are in the biggest need of assistance with 85%
predominantly Hispanic students served in the school system. Junior high schools show the highest
rate of runaways and highest number of homelessness, highest number of dropouts, and highest
number for truancy and discipline issues in middle school. Area needs identified a shelter for
minors or young adults and medical assistance because of the age of parental consent. Gaps in
services include supportive services, youth placement and bed availability for minors in area
shelters. Supportive services were identified as a priority need.
Hospital Systems
Christus Spohn identified substance use disorder treatment, mental health treatment, and case
management as priority needs. Gaps in services included access to affordable housing, social
services, street outreach, transitional housing or hospice, respite care or hospital step-down. Target
population to benefit most from these services is homelessness and at -risk of homelessness.
Supportive services were identified as a priority need.
Veterans Groups
Agencies who provide Veteran's services stated concerns with uncoordinated services for the
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Veteran population and recommended focusing funds on homeless prevention for sustainability
with a concentration on coordinated entry and supportive services. Priority was given to supportive
services as a primary need.
Public Housing
Corpus Christi Housing Authority (CCHA), which services as the City's primary housing agency
(PHA), stated supply of rental housing is low and affordable rental housing is even lower,
affordability is not really affordable and what is available is substandard. CCHA not only stated
an affordable housing crisis but also an income crisis; with too many people existing at income
levels too low to cover their housing needs; in terms of subsidized housing (section 8 vouchers,
etc).
CCHA stated the following priority needs for qualifying populations:
1. The more doorsteps there are the more pressure there is on the landlords to make their
properties appealing and healthy, and safe, the more opportunities for progression;
attention by the property management company to take care of their tenants and ensure a
safe experience.
2. Supportive services to help people understand accountability and teach them to be good
renters.
3. Displacement programs to assist with involuntary removal in any apartment complex; all
must take vouchers;
4. Give anyone experiencing or about to become homeless a tenant protection voucher for a
certain amount of money for a certain amount of months; people can use the vouchers for
a lease period, work with CCHA for supportive service during that time and then transition
to a CCHA voucher — CCHA would administer this program. Give the CCHA 100 tenant
protection vouchers and establish a preference rating system. The City could develop its
own preference and CCHA would administer (Veterans Affairs Supportive Housing is the
model). CCHA would give a 100 point preference for Corpus Christi Voucher Partnership
between the City and the Housing Authority to get people into housing and when the
program ends, they get a CCHA voucher, which becomes permanently funded.
CCHA supports the idea of a using HOME ARP funding to purchase a hotel for use as transitional
housing and share the cost of operations after acquisition. The costs could be shared by the City,
CCHA and rental income.
Public Agencies
Coastal Bend Aging and Disability Resource Center (CBADRC) provides a single coordinated
system of information and access for all persons seeking housing assistance. There is a great need
for additional accessible, affordable and integrated housing in the 11 counties served. Lack of
adequate supply of shelters, affordable, accessible and integrated housing to meet the needs of
seniors and persons with disabilities is an unmet need that hinders housing options for people to
choose where they want to live.
The current subsidized housing inventory listing complied by CBADRC includes shelters,
however due to some accessibility concerns and strict regulations at the shelters; many of the
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qualifying populations do not consider going to a shelter and thus a gap does exist for this
temporary housing option.
The following priorities were identified to be considered for qualifying populations as follows: 1).
Accessibility features at all shelters, 2). No work requirements, 3). Able to stay at shelters during
the day.
Overall, public agencies identified lack of affordable housing, staff capacity, high housing costs,
supportive services and wait list for supportive service programs as a gap. Priorities included
transitional housing, supportive services, some type of other permanent housing, TBRA for rental
assistance, utility assistance, and security deposits and services for persons with disabilities as top
priorities followed by services related to fair housing/Civil Rights, rapid rehousing, homeless
prevention, new construction of affordable housing units, and the need for emergency and
temporary shelters. Consensus centered around TBRA and supportive services instead of
constructing a building or shelter.
Fair Housing
The Fair Housing Unit identifies the needs as the availability and affordability of units for both
homeowners and rents, the available of accessible units and geographic distribution affordable
units. Priorities include education about options, rights, and resources, rental assistance, and
supportive services. Supportive services identified included job training, education, homeless
prevision, child care, legal services, and transportation.
Public or Private Organizations
Affordable housing developers are building one to two projects in Corpus Christi per year.
Permanent financing options that allow for affordable rents are limited and properties that are
developed using Low-income Housing Tax Credits must compete with other communities in our
area. New projects include units for persons at or below 80% of the area median income (AMI),
60% AMI, 50% AMI and 30% AMI but the lower the AMI served the more difficult the project
is to develop. The deeper income
targeting requires deeper development subsides, rent subsidies (TBRA or PHA vouchers), and
healthy operating and replacement reserves.
Bloomberg Harvard City Leadership Innovation Track
Throughout 2022 the City of Corpus Christi was a member of the Bloomberg Harvard City
Leadership Initiative Innovation Track with creating solutions in response to homelessness as the
focus. Through that program, 169 services providers, unsheltered homeless persons, residents,
and businesses were engaged. Engagements included identifying issues, examining gaps, and
testing assumptions. Responses received through the program identified that there are gaps
throughout the continuum of care for the homeless and current options are not adequate. This
presents a problem for people unable to access the care and services they need trapping
individuals in a cycle of homelessness. Gaps in the continuum of care were identified as rental
assistance, supportive housing, supportive services such as transportation, job training, mental
health services, substance use disorder treatment, maintaining adequate documents such as
identification and other supportive services. The negative impacts of homelessness on
neighborhoods and businesses were discussed as well.
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Law Enforcement
Corpus Christi Police Department stated that people in shelters and transitioning into housing
need case management, life skills training, mental health services and substance use disorder
treatment. Housing is available in the community but without supportive services people
experience homelessness repeatedly.
Community Groups Survey
A six -question survey was sent to 96 community groups who included nonprofit service
providers, government agencies, Civil Rights groups, businesses, community members, mental
health service providers and groups representing persons with disabilities. The response rate was
22.9%. Survey respondents ranked the eligible populations that would benefit the most from
services in the following order: 1) persons who are homeless; 2) person who are at -risk of
homelessness; 3) persons who are fleeing, or attempting to flee, domestic violence, dating
violence, sexual assault, stalking, or human trafficking; and 4) other households who require
services or housing assistance to prevent homelessness. The ranking of the types of housing
assistance or supportive services available was in the following order: 1) supportive services; 2)
TBRA and production and preservation of affordable housing; and 3) purchase and development
of non -congregate housing. The types of supportive services were ranked in the following order:
1) case management; 2) mental health services; 3) housing search assistance; 4) employment
assistance; 5) life skills training; 6) substance use treatment; 7) food; 8) utility deposits; 9)
outpatient health services; 10) outreach services; 11) transportation; 12) education services; 13)
child care; 14) moving costs; and 15) legal services.
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Public Participation
Describe the public participation process, including information about and the dates of the
public comment period and public hearing(s) held during the development of the plan:
• Date(s) of public notice: 3/5/2023
• Public comment period: start date - 3/6/2023 end date - 3/20/2023
• Date(s) of public hearing: 3/21/2023
The public comment period began on March 6, 2023, beginning with the publication of the Notice of
Public Comment period in the Corpus Christi Caller Times Newspaper. The comment period was
open until March 20, 2023. The draft HOME ARP allocation plan was posted on the City's website
at https://www.cctexas.com/detail/2023-home-arp and available for viewing at the Neighborhood
Services Department and the La Retama Library.
Describe efforts to broaden public participation:
The City broadened participation by launching a survey across stakeholders, community and
Civil Rights groups and incorporated the Bloomberg Harvard City Leadership Innovation Track
with creating solutions in response to homelessness as the focus. The track tasks
interdisciplinary city teams to build innovation capabilities as they design, test, and prototype
solutions to a pressing city problem. Homelessness was the focus of the track and identified
gaps in services and priority needs.
The survey asks the community groups to reflect on the priority needs. The public also had the
opportunity to comment at the in-person Corpus Christi City Council meeting held on March 21,
2023, at City Hall. The meeting site is wheelchair accessible. Aids and services, including deaf
interpreters, and translation services were made available.
Throughout 2022, the City was a member of the Bloomberg Harvard City Leadership Initiative
Innovation Track looking at the issues of homelessness in the community. Throughout the
process, the City engaged service providers, persons who are homeless, residents and business
owners. The City conducted stakeholder meetings, held on street interviews at common homeless
gathering points and service provider locations, attended service events such as feedings and free
stores and conducted interviews with businesses. The City engaged 169 people through these
personal interactions.
Also, throughout the HOME -ARP Allocation Plan development, the City engaged community
stakeholders not commonly considered part of the homelessness response network. These
engagements included organizations in the health system, public education, fair housing, BIPOC
places of faith, and law enforcement.
A PJ must consider any comments or views of residents received in writing, or orally at a public
hearing, when preparing the HOME -ARP allocation plan.
Summarize the comments and recommendations received through the public participation
process either in writing, or orally at a public hearing:
See the table summary of consultation meeting responses and summary of comments above.
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Comments from the public hearing will be added after public hearing.
Summarize any comments or recommendations not accepted and state the reasons why:
Will provide summary after public hearing.
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Needs Assessment and Gaps Analysis
In accordance with Section V.C.1 of the Notice (page 14), a PJ must evaluate the size and
demographic composition of all four of the qualifying populations within its boundaries and
assess the unmet needs of each of those populations. If the PJ does not evaluate the needs of one
of the qualifying populations, then the PJ has not completed their Needs Assessment and Gaps
Analysis. In addition, a PJ must identify any gaps within its current shelter and housing
inventory as well as the service delivery system. A PJ should use current data, including point in
time count, housing inventory count, or other data available through CoCs, and consultations
with service providers to quantify the individuals and families in the qualifying populations and
their need for additional housing, shelter, or services.
Template:
OPTIONAL Homeless Needs Inventory and Gap Analysis Table
Homeless
Current Inventory
Family r
omeless Population
Gap Ana
Emergency
Shelter
Transitional
Housing
Permanent
Supportive
Housing
Other Permanent
Housing
Sheltered
Homeless
Unsheltered
Homeless
Current Gap
147
37
11
22
39
11
10
22
203
136
141
23
0
0
0
0
0
10
132
0
24
0
182
178
14
16
32
14
0
0
0
0
Data Sources: 1.2022 Point in Time Count (PIT); 2.2022 Continuum of Care Housing Inventory Count (BIC); 3. Consultations
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OPTIONAL Housing Needs Inventory and Gap Analysis Table
Suggested Data Sources: 1. American Community Survey (ACS); 2. Comprehensive Housing Affordability
Strategy (CHAS)
Describe the size and demographic composition of qualifying populations within the PJ's
boundaries:
Homeless as defined in 24 CFR 91.5
During the 2022 Point in Time Count (PIT Count), 257 sheltered and 186 unsheltered
persons experiencing homelessness were identified. Of those answering the question
regarding length of time they have been homeless, responses were: 102 persons for 3 years or
more; 1 person for 2-3 years; 46 persons for 1-2 years; 16 persons for 7-11 months; 47
persons for 4-6 months and 78 persons for 0-3 months. The PIT identified 67 people were
experiencing chronic homelessness and 110 people who were homeless for the first time.
The 2022 PIT Count identified 30 veteran households comprised of 33 persons. Of these, 12
persons were identified as chronically homeless and 3 were female. Twenty-four homeless
families with children were identified during the 2022 PIT Count. These households had 43
children under the age of 18. None of these families was unsheltered at the time of the 2022
PIT Count.
Males were 54% of the total persons counted. The racial breakdown was as follows; 41.8%
of the homeless count were non -Hispanic; 36.8% of people experiencing homelessness were
Hispanic; 60.5% of total individuals experiencing homelessness were White; 10.4% were
Black, African American, or African; 1.6% of the total count were American Indian, Alaska
Native or Indigenous; .9% Native Hawaiian or Pacific Islander; 0.7% Asian; and 0.5%
multiple races.
At Risk of Homelessness as defined in 24 CFR 91.5
According to the Comprehensive Housing Affordability Strategy (CHAS) data from the
2015-2019 American Community Survey (ACS), Corpus Christi has a total of 50,615 total
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Non -Homeless
Current Inventory
Level of Need
Gap Analysis
# of Units
# of Households
# of Households
Total Rental Units
50,615
Rental Units Affordable to HH at 30%
AMI At -Risk of Homelessness
5,780
Rental Units Affordable to HH at 50%
AMI (Other Populations)
8 665
0%-30% AMI Renter HH w/ 1 or more
severe housing problems
(At -Risk of Homelessness)
7,205
30%-50% AMI Renter HH w/ 1 or more
severe housing problems
(Other Populations)
3,690
Current Gaps
1,425
Suggested Data Sources: 1. American Community Survey (ACS); 2. Comprehensive Housing Affordability
Strategy (CHAS)
Describe the size and demographic composition of qualifying populations within the PJ's
boundaries:
Homeless as defined in 24 CFR 91.5
During the 2022 Point in Time Count (PIT Count), 257 sheltered and 186 unsheltered
persons experiencing homelessness were identified. Of those answering the question
regarding length of time they have been homeless, responses were: 102 persons for 3 years or
more; 1 person for 2-3 years; 46 persons for 1-2 years; 16 persons for 7-11 months; 47
persons for 4-6 months and 78 persons for 0-3 months. The PIT identified 67 people were
experiencing chronic homelessness and 110 people who were homeless for the first time.
The 2022 PIT Count identified 30 veteran households comprised of 33 persons. Of these, 12
persons were identified as chronically homeless and 3 were female. Twenty-four homeless
families with children were identified during the 2022 PIT Count. These households had 43
children under the age of 18. None of these families was unsheltered at the time of the 2022
PIT Count.
Males were 54% of the total persons counted. The racial breakdown was as follows; 41.8%
of the homeless count were non -Hispanic; 36.8% of people experiencing homelessness were
Hispanic; 60.5% of total individuals experiencing homelessness were White; 10.4% were
Black, African American, or African; 1.6% of the total count were American Indian, Alaska
Native or Indigenous; .9% Native Hawaiian or Pacific Islander; 0.7% Asian; and 0.5%
multiple races.
At Risk of Homelessness as defined in 24 CFR 91.5
According to the Comprehensive Housing Affordability Strategy (CHAS) data from the
2015-2019 American Community Survey (ACS), Corpus Christi has a total of 50,615 total
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occupied rental units. Of these units, 11,255 were occupied by households with incomes at or
below 30% of the area median income (AMI) and 8,425 were occupied by households with
income greater than 30% of AMI and at or below 50% of the AMI. There were 10,890
households experiencing a housing cost burden of greater than 50% and 11,120 with a
housing cost burden of greater than 30% but less than or equal to 50%.
Additional data in the 2015-2019 ACS shows that there are 4,115 vacant rental units. Of the
vacant units, 165 are affordable to households with incomes less than or equal to 30% AMI
and 975 units are affordable to household greater than 30% AMI and less than or equal to
50% AMI.
The total rental units affordable to households at or below 30% AMI is 5,780 and the rental
until affordable to households with incomes greater than 30% AMI and less than or equal to
50% is 8,665.
There are 7,205 renter households with incomes at or below 30% AMI with one or more
severe housing problems and 3,690 renter households with incomes greater than 30% AMI
and equal to or less than 50% AMI with one or more severe housing problems. Using severe
housing problems, the level of need for households at or below 30% AMI with severe
housing problems is 1,425 units.
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault,
Stalking, or Human Trafficking, as defined by HUD in the Notice
The Corpus Christi Police Department reports that 4,421 incidents were reported to the
Family Violence Unit in 2022. According to The Purple Door, Corpus Christi's domestic
violence service provider, they served between 800-900 nonresidential clients in 2022. They
served 573 residential clients in the same period. The total number of bed days was 17,001.
Ages of those served varies and generally falls between 18-55 years old some with minor
children. They serve men and women and see a small population of LGBTQ clients, but the
vast majority of clients are women. The racial distribution of clients is approximately 80%
Hispanic, 15% White, 5% Black and a small percentage is Asian. Among those they serve,
approximately 85-95% are below the poverty level, especially those seeking residential
services.
Other populations requiring services or housing assistance to prevent homelessness and
other populations at greatest risk of housing instability, as defined by HUD in the Notice
Other populations that may require services or housing assistance to prevent homelessness or
are at the greatest risk of housing instability include Veterans. At September 30, 2023, the
estimated number of Veterans in Nueces County was 24,991 of which 22,269 are male and
2,722 are female. The age distribution among Veterans is 6,212 17-44 years old, 8,877 45-64
years old, 8,716 years old and 1,186 over the age of 85.
Another population that may require services or housing assistance to prevent homelessness
or are the greatest risk of housing instability are seniors. In Corpus Christi, about 14% of the
population is 65 or older. Of the 44,529 seniors in Corpus Christi about 1,380 live at less than
50% of the poverty level, 5,299 live at less than 100% of the poverty level and 8,416 live at
less than 125% of the poverty level.
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Identify and consider the current resources available to assist qualifying populations,
including congregate and non -congregate shelter units, supportive services, TBRA, and
affordable and permanent supportive rental housing (Optional):
Enter narrative response here.
Describe the unmet housing and service needs of qualifying populations:
Homeless as defined in 24 CFR 91.5
The unmet housing and service needs of homeless persons include case management, mental
health services, substance use disorder treatment, food, transportation, legal services, life
skills training, job training, security deposits and rental assistance. Persons who are homeless
need initial case management and other supportive services while becoming sheltered and
transitioning to housing. Housing search assistance is critical. Finding a cooperating landlord
and securing a lease is difficult for the homeless. Rental assistance such as TBRA is required
while the household waits for a voucher or the situation otherwise stabilizes. Continued case
management can help the household remained housed and meet daily living activities.
At Risk of Homelessness as defined in 24 CFR 91.5
The unmet housing and service needs of those at risk of homelessness include child care,
transportation, mental health services, substance use disorder treatment, life skills training,
food, job training, utility assistance, and rental assistance. Due to low wages or other income
limiting factors, those at risk of homelessness benefit from assistance with child care and
transportation. Rents are rising but wages are not keeping up and those on fixed incomes
have limited options. Homeless prevention services like those listed, assist these households
with remaining housed. Homeless prevention reduces trauma, is less costly than rehousing,
and reduces the need for additional interventions.
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault,
Stalking, or Human Trafficking, as defined by HUD in the Notice
The unmet housing and service needs of those fleeing, or attempting to flee, domestic
violence, dating violence, sexual assault, stalking, or human trafficking include, case
management, mental health services, substance use disorder treatment, food, transportation,
child care, legal services, job training, security deposits, moving assistance, utility assistance,
and rental assistance. The needs of households in this category are like those who are
homeless as they establish new homes. Specialized case management and mental health
services are key to stabilization.
Other populations requiring services or housing assistance to prevent homelessness and
other populations at greatest risk of housing instability as defined by HUD in the Notice
Other populations requiring services or housing assistance to prevent homelessness and the
other populations at greatest risk of housing instability include child care, transportation,
mental health services, substance use disorder treatment, legal services, food, security
deposits, moving assistance, rental assistance and utility assistance. Legal services, eviction
prevention, fair housing interventions and other strategies for keeping this group housed are
important.
Identify any gaps within the current shelter and housing inventory as well as the service
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delivery system:
Gaps withing the system include rental assistance that covers costs for longer than three to six
months and until a voucher is available, housing search assistance finding a landlord that works
with subsidies, programs that help people maintain their participation in mental health treatment
programs and substance use disorder treatment. Robust supportive services during stabilization
to prevent homelessness from reoccurring or preventing homelessness. Many programs don't
include furnishings and household items. Also, nonprofit capacity is often limited and unable to
meet the demand.
Under Section IV.4.2.ii.G of the HOME ARP Notice, a PJ may provide additional
characteristics associated with instability and increased risk of homelessness in their HOME -
ARP allocation plan. These characteristics will further refine the definition of "other
populations" that are "At Greatest Risk of Housing Instability," as established in the HOME -
ARP Notice. If including these characteristics, identify them here:
None
Identify priority needs for qualifying populations:
Throughout the four qualifying populations the priority needs are:
• Supportive services
o Case management
o Mental health services
o Substance use disorder treatment
o Transportation
o Child care
o Legal Services
o Food
o Homeless prevention rental assistance and utility assistance
o Job training
o Life skills training
• Rental assistance for greater than three to six months
Explain how the PJ determined the level of need and gaps in the PJ's shelter and housing
inventory and service delivery systems based on the data presented in the plan:
The City determined the level of need and gaps by examining the available rental units in the
community by using the ACS and CHAS as compared to those who are homeless and
experiencing severe housing problems including being cost overburden. Using that information
and the feedback received during the extensive consultation process described above this plan
was developed. Information used was qualitative and quantitative.
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HOME -ARP Activities
Template:
Describe the method(s)that will be used for soliciting applications for funding and/or selecting
developers, service providers, subrecipients and/or contractors:
The City uses a formal application process for soliciting applications for funding. Funding will
be allocated through a competitive process open to all nonprofit organizations serving qualifying
populations. A Public Notice will be published in the local newspaper and posted on the City's
website. Notice of the opportunity will be posted on the City's social media and distributed to
local news outlets. A pre -application technical assistance workshop will be advertised to provide
an overview of the program and the application submittal process. Each proposed project for
funding shall be submitted electronically to the Neighborhood Services Department and will
include details of the project, project sources and uses, partners, impact on qualifying
populations, proposed beneficiaries, scope of work, experience providing these services,
experience administering federally funded programs, and other required information.
Neighborhood Services will perform a preliminary review on projects submitted for eligibility. A
review team of staff and stakeholders will conduct application reviews and interviews with
applicants. Applications will be scored based on the technical aspects of the applications and the
impact to beneficiaries.
Recommendations for funding to the City Council will be made based on the application scoring.
Applications will be subject to a public hearing during a City Council meeting. The
recommended projects will be published with the regular meeting agenda in accordance with
Texas rules and regulations. The nonprofits to carrying out activities, amounts of assistance,
beneficiaries, scopes of work and other related information will be posted.
Describe whether the PJ will administer eligible activities directly:
The City will not administer activities directly.
If any portion of the PJ's HOME ARP administrative funds are provided to a subrecipient or
contractor prior to HUD's acceptance of the HOME ARP allocation plan because the
subrecipient or contractor is responsible for the administration of the PJ's entire HOME ARP
grant, identify the subrecipient or contractor and describe its role and responsibilities in
administering all of the PJ's HOME -ARP program:
Not applicable.
In accordance with Section V.C.2. of the Notice (page 4), PJs must indicate the amount of
HOME -ARP funding that is planned for each eligible HOME -ARP activity type and demonstrate
that any planned funding for nonprofit organization operating assistance, nonprofit capacity
building, and administrative costs is within HOME -ARP limits.
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Template:
Use of HOME -ARP Funding
Describe how the PJ will distribute HOME ARP funds in accordance with its priority needs
identified in its needs assessment and gap analysis:
Based on the priority needs established through the consultations, $2,000,000 will be distributed
through supportive service providers $1,160,454 through TBRA, $210,696 through non-profit
operating, $210,696 through non-profit capacity building and $632,095.55 through administration
and planning.
Describe how the characteristics of the shelter and housing inventory, service delivery system,
and the needs identified in the gap analysis provided a rationale for the plan to fund eligible
activities:
Throughout the consultations, the need for supportive services and TBRA were identified as
priority needs. The City is funding these activities to meet those needs. The PIT Count and HIC
do not reflect a great need for non -congregate shelter and the City is funding, through other
sources, an additional 120 shelter beds. The consultations provided descriptions of the service
delivery system that demonstrates a rationale for providing supportive services including case
management, child care, transportation, mental health services, substance use disorder treatment,
legal services, utility assistance, other supportive services and TBRA for clients stabilizing their
housing situation. Providing these services will offer a gateway out of homelessness for the
unsheltered, help stabilize those at -risk and provide a healthy start for those fleeing, or
attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human
trafficking.
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Funding Amount
Percent of the Statutory
Grant Limit
Supportive Services
$ 2,000,000
Acquisition and Development of Non-
Con_retate Shelters
$ 0
Tenant Based Rental Assistance (TBRA)
$ 1,160,454
Development of Affordable Rental Housing
$ 0
Non -Profit Operating
$ 210,696
5 % 5%
Non -Profit Capacity Building
$ 210,696
5 % 5%
Administration and Planning
$ 632,090.55
15 % 15%
Total HOME ARP Allocation
$ 4,213,937
Describe how the PJ will distribute HOME ARP funds in accordance with its priority needs
identified in its needs assessment and gap analysis:
Based on the priority needs established through the consultations, $2,000,000 will be distributed
through supportive service providers $1,160,454 through TBRA, $210,696 through non-profit
operating, $210,696 through non-profit capacity building and $632,095.55 through administration
and planning.
Describe how the characteristics of the shelter and housing inventory, service delivery system,
and the needs identified in the gap analysis provided a rationale for the plan to fund eligible
activities:
Throughout the consultations, the need for supportive services and TBRA were identified as
priority needs. The City is funding these activities to meet those needs. The PIT Count and HIC
do not reflect a great need for non -congregate shelter and the City is funding, through other
sources, an additional 120 shelter beds. The consultations provided descriptions of the service
delivery system that demonstrates a rationale for providing supportive services including case
management, child care, transportation, mental health services, substance use disorder treatment,
legal services, utility assistance, other supportive services and TBRA for clients stabilizing their
housing situation. Providing these services will offer a gateway out of homelessness for the
unsheltered, help stabilize those at -risk and provide a healthy start for those fleeing, or
attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human
trafficking.
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HOME -ARP Production Housing Goals
Template
Estimate the number of affordable rental housing units for qualifying populations that the PJ
will produce or support with its HOME ARP allocation:
Based on feedback from the consultations, the allocation plan does not include affordable
housing rental production or preservation. This takes into consideration the costs associated with
the development of new units and the reserves required as compared to the $4.2 million
allocation and the substantial need for TBRA and supportive services.
Describe the specific affordable rental housing production goal that the PJ hopes to achieve
and describe how the production goal will address the PJ's priority needs:
Based on feedback from the consultations, the allocation plan does not include affordable
housing rental production or preservation. This takes into consideration the costs associated with
the development of new units and the reserves required as compared to the $4.2 million
allocation and the substantial need for TBRA and supportive services.
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Preferences
A preference provides a priority for the selection of applicants who fall into a specific QP or
category (e.g., elderly or persons with disabilities) within a QP (i.e., subpopulation) to receive
assistance. A preference permits an eligible applicant that qualifies for a PJ -adopted preference
to be selected for HOME -ARP assistance before another eligible applicant that does not qualify
for a preference. A method of prioritization is the process by which a PJ determines how two or
more eligible applicants qualifying for the same or different preferences are selected for HOME -
ARP assistance. For example, in a project with a preference for chronically homeless, all
eligible QP applicants are selected in chronological order for a HOME -ARP rental project except
that eligible QP applicants that qualify for the preference of chronically homeless are selected for
occupancy based on length of time they have been homeless before eligible QP applicants who
do not qualify for the preference of chronically homeless.
Please note that HUD has also described a method of prioritization in other HUD guidance.
Section I.C.4 of Notice CPD -17-01 describes Prioritization in CoC CE as follows:
"Prioritization. In the context of the coordinated entry process, HUD uses the term
"Prioritization" to refer to the coordinated entry -specific process by which all persons in need of
assistance who use coordinated entry are ranked in order of priority. The coordinated entry
prioritization policies are established by the CoC with input from all community stakeholders
and must ensure that ES G projects are able to serve clients in accordance with written standards
that are established under 24 CFR 576.400(e). In addition, the coordinated entry process must,
to the maximum extent feasible, ensure that people with more severe service needs and levels of
vulnerability are prioritized for housing and homeless assistance before those with less severe
service needs and lower levels of vulnerability. Regardless of how prioritization decisions are
implemented, the prioritization process must follow the requirements in Section II.B.3. and
Section I.D. of this Notice."
If a PJ is using a CE that has a method of prioritization described in CPD -17-01, then a PJ has
preferences and a method of prioritizing those preferences. These must be described in the
HOME -ARP allocation plan in order to comply with the requirements of Section IV.C.2 (page
10) of the HOME -ARP Notice.
In accordance with Section V.C.4 of the Notice (page 15), the HOME -ARP allocation plan must
identify whether the PJ intends to give a preference to one or more qualifying populations or a
subpopulation within one or more qualifying populations for any eligible activity or project.
• Preferences cannot violate any applicable fair housing, civil rights, and nondiscrimination
requirements, including but not limited to those requirements listed in 24 CFR 5.105(a).
• The PJ must comply with all applicable nondiscrimination and equal opportunity laws
and requirements listed in 24 CFR 5.105(a) and any other applicable fair housing and
civil rights laws and requirements when establishing preferences or methods of
prioritization.
While PJs are not required to describe specific projects in its HOME -ARP allocation plan to
which the preferences will apply, the PJ must describe the planned use of any preferences in its
HOME -ARP allocation plan. This requirement also applies if the PJ intends to commit HOME -
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ARP funds to projects that will utilize preferences or limitations to comply with restrictive
eligibility requirements of another project funding source. If a PJ fails to describe preferences
or limitations in its plan, it cannot commit HOME -ARP funds to a project that will
implement a preference or limitation until the PJ amends its HOME -ARP allocation plan.
For HOME -ARP rental housing projects, Section VI.B.20.a.iii of the HOME -ARP Notice
(page 36) states that owners may only limit eligibility or give a preference to a particular
qualifying population or segment of the qualifying population if the limitation or
preference is described in the PJ's HOME -ARP allocation plan. Adding a preference or
limitation not previously described in the plan requires a substantial amendment and a public
comment period in accordance with Section V.C.6 of the Notice (page 16).
Template:
Identify whether the PJ intends to give preference to one or more qualifying populations or a
subpopulation within one or more qualifying populations for any eligible activity or project:
The City does not intend to give preference to one or more qualifying populations.
If a preference was identified, explain how the use of a preference or method of prioritization
will address the unmet need or gap in benefits and services received by individuals and
families in the qualifying population or subpopulation of qualifying population, consistent
with the PJ's needs assessment and gap analysis:
No preference will be given.
Referral Methods
PJs are not required to describe referral methods in the plan. However, if a PJ intends to use a
coordinated entry (CE) process for referrals to a HOME -ARP project or activity, the PJ must
ensure compliance with Section IV.C.2 of the Notice (pagel0).
A PJ may use only the CE for direct referrals to HOME -ARP projects and activities (as opposed
to CE and other referral agencies or a waitlist) if the CE expands to accept all HOME -ARP
qualifying populations and implements the preferences and prioritization established by the PJ in
its HOME -ARP allocation plan. A direct referral is where the CE provides the eligible applicant
directly to the PJ, subrecipient, or owner to receive HOME -ARP TBRA, supportive services,
admittance to a HOME -ARP rental unit, or occupancy of a NCS unit. In comparison, an indirect
referral is where a CE (or other referral source) refers an eligible applicant for placement to a
project or activity waitlist. Eligible applicants are then selected for a HOME -ARP project or
activity from the waitlist.
The PJ must require a project or activity to use CE along with other referral methods (as
provided in Section IV.C.2.ii) or to use only a project/activity waiting list (as provided in Section
IV.C.2.iii) if:
1. the CE does not have a sufficient number of qualifying individuals and families to refer
to the PJ for the project or activity;
2. the CE does not include all HOME -ARP qualifying populations; or,
3. the CE fails to provide access and implement uniform referral processes in situations
where a project's geographic area(s) is broader than the geographic area(s) covered by
the CE
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If a PJ uses a CE that prioritizes one or more qualifying populations or segments of qualifying
populations (e.g., prioritizing assistance or units for chronically homeless individuals first, then
prioritizing homeless youth second, followed by any other individuals qualifying as homeless,
etc.) then this constitutes the use of preferences and a method of prioritization. To implement a
CE with these preferences and priorities, the PJ must include the preferences and method of
prioritization that the CE will use in the preferences section of their HOME -ARP allocation plan.
Use of a CE with embedded preferences or methods of prioritization that are not contained in the
PJ's HOME -ARP allocation does not comply with Section IV.C.2 of the Notice (page10).
Template:
Identify the referral methods that the PJ intends to use for its HOME ARP projects and
activities. PJ's may use multiple referral methods in its HOME ARP program. (Optional):
If the PJ intends to use the coordinated entry (CE) process established by the CoC, describe
whether all qualifying populations eligible for a project or activity will be included in the CE
process, or the method by which all qualifying populations eligible for the project or activity
will be covered. (Optional):
If the PJ intends to use the CE process established by the CoC, describe the method of
prioritization to be used by the CE. (Optional):
If the PJ intends to use both a CE process established by the CoC and another referral method
for a project or activity, describe any method of prioritization between the two referral
methods, if any. (Optional):
Limitations in a HOME -ARP rental housing or NCS project
Limiting eligibility for a HOME -ARP rental housing or NCS project is only permitted under
certain circumstances.
• PJs must follow all applicable fair housing, civil rights, and nondiscrimination
requirements, including but not limited to those requirements listed in 24 CFR 5.105(a).
This includes, but is not limited to, the Fair Housing Act, Title VI of the Civil Rights Act,
section 504 of Rehabilitation Act, HUD's Equal Access Rule, and the Americans with
Disabilities Act, as applicable.
• A PJ may not exclude otherwise eligible qualifying populations from its overall HOME -
ARP program.
• Within the qualifying populations, participation in a project or activity may be limited to
persons with a specific disability only, if necessary, to provide effective housing, aid,
benefit, or services that would be as effective as those provided to others in accordance
with 24 CFR 8.4(b)(1)(iv). A PJ must describe why such a limitation for a project or
activity is necessary in its HOME -ARP allocation plan (based on the needs and gap
identified by the PJ in its plan) to meet some greater need and to provide a specific
benefit that cannot be provided through the provision of a preference.
• For HOME -ARP rental housing, section VI.B.20.a.iii of the Notice (page 36) states that
owners may only limit eligibility to a particular qualifying population or segment of the
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qualifying population if the limitation is described in the PJ's HOME -ARP allocation
plan.
• PJs may limit admission to HOME -ARP rental housing or NCS to households who need
the specialized supportive services that are provided in such housing or NCS. However,
no otherwise eligible individuals with disabilities or families including an individual with
a disability who may benefit from the services provided may be excluded on the grounds
that they do not have a particular disability.
Template
Describe whether the PJ intends to limit eligibility for a HOME ARP rental housing or NCS
project to a particular qualifying population or specific subpopulation of a qualifying
population identified in section IV.A of the Notice:
The City does not intend to limit eligibility to any specific qualified population or subpopulation
that is to be assisted with HOME ARP resources.
If a PJ intends to implement a limitation, explain why the use of a limitation is necessary to
address the unmet need or gap in benefits and services received by individuals and families in
the qualifying population or subpopulation of qualifying population, consistent with the PJ's
needs assessment and gap analysis:
The City does not intend to limit eligibility to any specific qualified population or subpopulation
that is to be assisted with HOME ARP resources.
If a limitation was identified, describe how the PJ will address the unmet needs or gaps in
benefits and services of the other qualifying populations that are not included in the limitation
through the use of HOME -ARP funds (i.e., through another of the PJ's HOME ARP projects
or activities):
The City does not intend to limit eligibility to any specific qualified population or subpopulation
that is to be assisted with HOME ARP resources.
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HOME -ARP Refinancing Guidelines
If the PJ intends to use HOME -ARP funds to refinance existing debt secured by multifamily
rental housing that is being rehabilitated with HOME -ARP funds, the PJ must state its HOME -
ARP refinancing guidelines in accordance with 24 CFR 92.206(b). The guidelines must describe
the conditions under with the PJ will refinance existing debt for a HOME -ARP rental project,
including:
• Establish a minimum level of rehabilitation per unit or a required ratio between
rehabilitation and refinancing to demonstrate that rehabilitation ofHOME-ARP rental
housing is the primary eligible activity
City HOME -ARP funds will not be used for refinancing.
• Require a review of management practices to demonstrate that disinvestment in the
property has not occurred; that the long-term needs of the project can be met; and that
the feasibility of serving qualified populations for the minimum compliance period can
be demonstrated.
City HOME -ARP funds will not be used for refinancing.
• State whether the new investment is being made to maintain current affordable units,
create additional affordable units, or both.
City HOME -ARP funds will not be used for refinancing.
• Specify the required compliance period, whether it is the minimum 15 years or longer.
City HOME -ARP funds will not be used for refinancing.
• State that HOME -ARP funds cannot be used to refinance multifamily loans made or
insured by any federal program, including CDBG.
City HOME -ARP funds will not be used for refinancing.
• Other requirements in the PJ's guidelines, if applicable:
City HOME -ARP funds will not be used for refinancing.
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