SR 09-13-2022 5E
City Council
Report
City Council Meeting: September 13, 2022
Agenda Item: 5.E
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To: Mayor and City Council
From: Andy Agle, Director, Community Services Department, Housing and Human
Services
Subject: Approval of Amended 2021-22 Annual CDBG and HOME Action Plan
Incorporating Proposed HOME Investment Partnerships – American Rescue
Plan (HOME-ARP) Allocation Plan
Recommended Action
Staff recommends that the City Council:
1. Approve amendment of the 2021-22 Annual CDBG and HOME Action Plan to
incorporate the proposed HOME Investment Partnerships – American Rescue
Plan (HOME-ARP) Allocation Plan (Attachment A).
2. Authorize the City Manager to submit all documents required to receive the City’s
HOME-ARP funds to the U.S. Department of Housing and Urban Development
(HUD).
Summary
Santa Monica is a longtime recipient of HOME Investment Partnerships Program
(HOME) entitlement funds provided through the United States Department of Housing
and Urban Development (HUD). In 2021, HUD awarded $2,220,124 in onetime funding
to the City of Santa Monica under the HOME Investment Partnerships – American
Rescue Plan (HOME-ARP). To access HOME-ARP funding, the City has developed a
HOME-ARP Allocation Plan (Attachment A) proposing use of HOME-ARP funds for
eligible activities benefiting qualifying populations, as defined in HUD’s September 2021
notice: Requirements for the Use of Funds in the HOME-ARP Program.
Staff recommends that HOME-ARP funds be used to address the escalating need for
homeless prevention services exacerbated by rising rents, inflation, and the sunsetting
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of COVID protections. Specifically, staff proposes to use HOME-ARP funds to
implement broader eviction prevention services, including legal services, case
management, and behavioral health care, and to provide financial assistance payments
for housing deposits, utilities, back rent, short-term rent relief, and moving costs needed
to prevent vulnerable Santa Monica renters from becoming homeless. The proposed
strategy would shore up local homeless services and homeless prevention work in
anticipation of a potential eviction wave when COVID relief and protections end for
renters and may include additional funding for the City’s current Rent Control
Adjustment Relief program (RCAR) if demand for assistance from HOME-ARP-eligible
households exceeds available resources. The recommendations align with feedback
resulting from consultation and public participation processes conducted in accordance
with HOME-ARP regulations and include input from the Los Angeles Homeless
Services Authority (LAHSA), the Los Angeles Continuum of Care (LA CoC), local
service providers, rent-controlled Santa-Monica households, and members of the public.
The proposed HOME-ARP Allocation Plan must be submitted for HUD’s review and
consideration as a Council-approved substantial amendment to the City’s 2021-22
Annual CDBG/HOME Action Plan (Attachment B).
Discussion
Current Homeless Prevention Efforts
Even before the City adopted Preventing Homelessness as one of the Four Pillars in
addressing homelessness, Santa Monica has had a history of investing in services to
prevent eviction and keep vulnerable Santa Monica renters housed. Programs originally
designed to support people leaving homelessness to stay housed have expanded to
include an array of social services, legal services, and flexible City funding to address
tenant harassment, unlawful evictions, rent arrears, underemployment, hoarding, and
behavioral issues that put any low-income renter at risk of becoming homeless. COVID
put these services front and center and made eviction prevention a key priority across
the country. While state, regional, and local rental assistance programs combined with
myriad eviction moratoriums to help hundreds of Santa Monica renters stay housed
over the past three years, those assistance programs and moratoriums are rapidly
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sunsetting at a time when low-income households are now facing the impacts of
inflation and rising rents.
The City has taken several steps to address increased needs, including expansion of
eviction prevention services through both the Right to Counsel program that guarantees
legal representation to any low-income Santa Monica renter who has an active eviction
case as well as enhanced administrative and case management support for these
households to help them address longer-term needs such as assistance completing
housing and benefits applications. HOME-ARP funding would be used to provide
supplemental financial assistance to pay back rents to resolve eviction cases, as well as
shallow, short-term assistance with forward-rent to help at-risk renters stabilize. In
addition, HOME-ARP funds would be used to keep these legal and support services
going beyond the current commitment funding, which expires in 2023.
The City is also working to address the impacts of the Rent Control General Adjustment
scheduled for September 1 that will place an additional rent burden on already
struggling households, The Rent Control Adjustment Relief program (RCAR) makes
available $750,000 in City funds to provide short-term assistance to cover the amount of
rent increases for approximately 1,100 Extremely Low-Income (less than or equal to
30% of area median income) and Very Low-Income (between 30% and 50% of area
median income) rent-controlled residents who are Severely Cost Burdened (paying
more than 50% of monthly income towards rent). The City-administered program will
provide assistance in the form of one-time payments directly to property
owners/managers on behalf of eligible program applicants. Further, the City has also
enacted an eviction moratorium that will protect qualifying tenants who need more
time to pay increased rent, applicable only to rent due between September 1, 2022
and January 31, 2023. If voters approve the proposed ballot measure in November,
the maximum allowable rent increase, currently at 6%, would revert to less than 1% in
February and cap future rent increases at 3%. Should the measure fail to pass, the City
will need to consider additional measures in order to provide longer-term assistance to
impacted renters using resources beyond what is currently available.
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While RCAR will provide temporary and much-needed relief for a portion of vulnerable
households in rent-controlled apartments, there are already signs of a growing need for
much deeper rental assistance beyond the impact of the increase. HUD’s most recent
Comprehensive Housing Affordability Strategy (CHAS) data from 2018 estimates that
there are 5,535 very low- and extremely low-income renters in Santa Monica who are
severely rent-burdened (paying 50 percent or more of their income on rent). These
households are susceptible to even small increases in rent as well as the cost of basic
living essentials such as food and utilities that put them at greater risk of falling behind
on rent. These vulnerabilities put such households at increased risk of eviction once the
Los Angeles County eviction moratorium expires December 31, 2022, shortly followed
by expiration of the City’s moratorium on January 31, 2023.
It is in this environment that staff recommends the use of one-time HOME-ARP funds to
sustain and expand homeless prevention efforts.
Summary of HOME-ARP
The American Rescue Plan Act of 2021 appropriated $5 billion to provide housing,
services, and shelter to eligible vulnerable populations, to be allocated by formula to
jurisdictions that qualified for HOME allocations in Fiscal Year 2021. HUD published
formula allocations of HOME-ARP funding on April 8, 2021, which included onetime
funding of $2,220,124 to the City of Santa Monica. Though allocated to participating
HOME jurisdictions, HOME-ARP itself is a unique funding source with a dedicated set of
regulatory requirements. On September 13, 2021, HUD published a notice titled:
Requirements for the Use of Funds in the HOME-ARP Program, which articulated the
process by which HOME-ARP recipients must develop and submit a HOME-ARP
Allocation Plan. The HOME-ARP Notice detailed the program-specific regulatory
requirements for preparation of the allocation plan, including requirements for
consultation and public participation, and definitions of eligible activities and qualifying
populations for which use of HOME-ARP funds may be proposed. The notice also
specified that proposed HOME-ARP Allocation Plans must be submitted to HUD as a
substantial amendment to its 2021-22 CDBG/HOME Annual Action Plan, a document
originally approved by Council on April 27, 2021.
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Consultation and Public Participation
The Proposed HOME-ARP Allocation plan was developed though a consultation and
public participation process conducted in alignment with the requirements outlined in the
HOME-ARP Notice. Per the notice, HOME-ARP participating jurisdictions (PJs) must
demonstrate consultation with the Continuum of Care serving the jurisdiction’s
geographic area, homeless service providers, 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. In addition, PJs must
provide for and encourage public participation in the development of the HOME-ARP
Allocation Plan by holding a well-advertised public hearing to discuss development of
the plan and by making the complete proposed plan available for a 15-day public review
and comment prior to submission.
The HOME-ARP consultation requirements outlined above includes unique features that
differ from what is normally required for the City’s Consolidated Plan. Specifically,
HOME-ARP requirements lean heavily on consultation with the HUD-designated
Continuum of Care Lead Agency to ensure that HOME-ARP funds are used by PJs in
ways that align with and support the regional goals of the Continuum of Care in
addressing homelessness. In compliance with this requirement, the City consulted
extensively with the Los Angeles Homeless Services Authority (LAHSA), lead agency
for the Los Angeles Continuum of Care (LA CoC), following release of their December
21, 2021 memorandum entitled “2021 HOME-ARP Funding Recommendations from the
LA CoC”. Additional consultation efforts undertaken by City staff included participating in
a LAHSA-hosted webinar with members of the LA CoC to discuss HOME-ARP
recommendations, attending individual office hours with LAHSA staff to engage in an in-
depth discussion about uses of the City’s HOME-ARP allocation, and a City-convened
Homeless Resource Coordination meeting bringing together local service providers,
policymakers, healthcare organizations, and staff from a host of City and County
departments for a robust discussion about LAHSA’s recommendations for HOME-ARP.
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The City’s efforts to encourage public participation included an advertised public hearing
at the May 23, 2022 meeting of the Social Services Commission and the release of a
Housing Needs Survey to assess the needs of Santa Monica renters. The survey was
open from June 24 to July 11, 2022, and made available in English and Spanish, both
online and on-paper at a variety of City facilities and local service providers. Rent
Control included a link to the survey in a mailer to over 27,500 residents in rent-
controlled apartments, and the survey was also publicized via City social media
channels with a distribution list of over 47,000. The complete Proposed HOME-ARP
Allocation Plan was made available for a 15-day public review period beginning on
August 27, 2022. All public comments received to-date are included in the proposed
plan. Any input received through the public review process or in response to this
Council agenda will be incorporated into the final plan prior to HUD submittal.
Proposed Activities
HUD’s HOME-ARP notice specifies the activities that are eligible for HOME-ARP
funding, including acquisition and development of non-congregate shelter, tenant-based
rental assistance, supportive services, administration and planning, and nonprofit
operating and capacity building assistance. The notice further defines the qualifying
populations for whom HOME-ARP activities must be designed to assist, including
sheltered and unsheltered homeless populations, those currently housed populations at
extreme risk of homelessness, those fleeing or attempting to flee domestic violence or
human trafficking, households at greatest risk of housing instability, and other families
requiring services or housing assistance or to prevent homelessness.
Based on HUD’s eligibly criteria and taking into account the onetime nature of HOME-
ARP funds, LAHSA recommended that LA CoC participants use HOME-ARP for
activities including acquisition of permanent housing resources, master leasing of multi-
unit housing, and provision of supportive services such as diversion, homelessness
prevention, and short-term financial assistance. Notably, LAHSA recommended against
use of HOME-ARP funding for non-congregate shelter due to the lack of permanent
housing exits in the current system and the lack of operating dollars available to sustain
new programs.
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Attendees at both the Homeless Resources Coordination meeting and the Social
Services Commission meeting expressed support for using HOME-ARP funds for
homeless prevention and supportive services to keep vulnerable households from
becoming homeless or returning to homelessness. Participants cited the on-going
economic impacts on vulnerable households facing barriers to maintaining or returning
to work, such as lack of childcare, need to quarantine due to illness or close contact
with infected persons, and impacts of inflation as exacerbating factors likely to increase
housing instability. LAHSA agreed that homeless prevention efforts would be consistent
with LAHSA recommendations and would support efforts to reduce the inflow of
households into homelessness, which has been contributing to the increase in
homelessness in the LA CoC despite increased rates of housing placements. Other
LAHSA recommendations are largely duplicative of existing Santa Monica resources.
For example, the City supports affordable housing development through a local housing
trust fund and has identified other sources of funding for Emergency Housing Voucher
(EHV) navigation services and move-in costs.
Responses to the Housing Needs Survey also highlighted the need for additional
supportive services, with respondents identifying difficulties in affording rent, utilities,
and other basic needs along with an inability to find safe and decent housing at
affordable costs among the top housing issues they experienced in the last six months.
Among the approximately 25 percent of respondents who stated that they currently
need assistance with rent, the average amount of rental assistance needed is $971 per
month, showing a need for deep rental subsidies. Regarding the upcoming Rent Control
General Adjustment in September 2022, 62 percent of respondents in rent-controlled
units stated that they will not be able to afford the 6 percent rent increase ($140 max).
In alignment with input received throughout the consultation and public participation
processes, and consistent with HOME-ARP requirements for eligible activities and
qualifying populations, staff recommends use of HOME-ARP funds for time-limited
activities that address the emergent needs of Santa Monica’s most vulnerable
households, as detailed in the table below. In preparing the HOME-ARP Allocation Plan,
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staff assessed the possibility of allocating a full $2 million in HOME-ARP funds to rental
assistance for eligible households. For example, exclusive use of HOME-ARP funds for
rent assistance could provide 1,000 eligible households with a onetime payment of
$2,000, after which all resources would be expended. However, after further discussion,
staff ultimately identified a primary concern that maximizing the ability of HOME-ARP to
provide short-term assistance would leave the City without adequate resources to
support the wave of vulnerable Santa Monicans likely to be impacted by the sunset of
eviction protections.
The resulting proposed HOME-ARP funding allocations are balanced to meet both the
near-term needs of vulnerable households struggling to pay rent as well as the
anticipated needs of the many households who may be at imminent risk of
homelessness following the expiration of current eviction protections in late 2022 and
early 2023. HOME-ARP funding would be used to support services for the next two to
three years to coincide with the expected peak of housing instability in 2023-2025.
Using the funding in such a manner would also advance the City’s goal of cultivating an
equitable and inclusive economic recovery and would support the homelessness
prevention pillar of the four-pillar strategy to address homelessness.
In the event that demand for Administration and Planning resources falls short of
proposed amounts, funds would be reallocated to Supportive Services and Homeless
Prevention Services.
Supportive Services and Homeless Prevention Services - $2,000,000
Homeless Prevention Services
The upcoming expiration of current eviction protections marks the arrival of the long-
looming eviction cliff, an event widely anticipated to result in issuance of a wave of
unlawful detainers. For perspective, the Legal Aid Foundation of Los Angeles (LAFLA)
took on 28 unlawful detainer (UD) eviction cases in the first quarter of 2022 alone, a
trend that projects to an estimated 110 annually at a time when eviction protections
still remain in place. UD cases are widely projected to rise following the sunset of
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eviction protections, placing many vulnerable households at imminent risk of
homelessness, with economic impacts from COVID continuing through 2025. Current
funding for enhanced homeless prevention services expires in FY2023-24. Use of
HOME-ARP funds to continue to provide supportive and preventative services will
ensure that the City has a range of resources available to assist qualifying households
in accessing and maintaining housing. Resources may include legal services, case
management, behavioral health care, housing search and counseling services, and
property manager/tenant mediation. Onetime HOME-ARP funds for supportive
services will be made available to local service providers and awarded via a
competitive process to agencies proposing eligible activities most responsive to
anticipated needs.
Financial Assistance Funds
The City proposes to retain a portion of HOME-ARP funding to provide flexible
financial assistance to eligible households at great risk of homelessness or housing
instability that would be available to eligible households upon HUD’s approval of the
allocation plan. These may be households that have been issued unlawful detainers
or otherwise identified by service providers as requiring financial resources in order to
avoid becoming homeless. Funds would be used by the City to issue payments on
behalf of eligible households to property owners, utility companies, and other third
parties for costs such as back-rent/rent arrears (up to the allowable six months),
short-term rental assistance, utility and housing deposits, and moving costs needed to
successfully close UD cases and prevent Santa Monica renters from becoming
homeless. While HOME-ARP funds will not be available for use until HUD approves
the allocation plan, if there are extremely low-income, severely rent-burdened
households in Rent Controlled apartments not served by RCAR, HOME-ARP
Financial Assistance Funds could also be available to assist more of those
households.
Administration and Planning (A&P) - $220,124
10% of HOME-ARP funding is allocated to staff-time and resources required
to administer the program in compliance with federal regulations.
TOTAL HOME-ARP FUNDED ACTIVITES - $2,220,124
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Next Steps
Once Council approves the HOME-ARP Allocation Plan, the City will prepare a final
submission to HUD within 10 business days. HUD will then have 45 days to review the
plan, provide feedback and/or request changes. Following HUD’s acceptance of a final
Plan, the City must complete a procurement process to identify service providers for
newly approved activities. That process will include a 30-day Request for Proposals
(RFP) followed by 30 days for proposal review, 45 days to prepare a staff report
requesting contractual authority from Council, and 10 days for contract execution. If all
goes to plan, new services would start no earlier than March 1, 2023. To the extent
possible, staff will make every effort to identify efficiencies that may shorten this
timeline.
Note that any HOME-ARP funds set aside to provide financial assistance would be
immediately available following HUD’s approval of the allocation plan, projected for
November 2022, as payments would be administered directly by the City. Assistance
would be available to participants engaged by current homeless prevention efforts such
as LAFLA’s Right to Counsel and eviction prevention programs, as well as to extremely
low-income, severely rent-burdened households that are unable to be served with
current RCAR funding.
Past Council Actions
Meeting Date Description
April 27, 2021 (Attachment C) Approval of FY 2021-22 Annual Action Plan
Financial Impacts and Budget Actions
Staff seeks authority to accept HOME Investment Partnerships – American Rescue
Plan (HOME-ARP) funding from the United States Department of Housing and Urban
Development (HUD). In order to accept funding, staff recommends the following budget
changes. If renewals are awarded, budget changes will be included in subsequent year
budgets, contingent on Council budget approval.
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FY 2022-23 Grant Budget Changes
Establish Revenue Budget Appropriate Funds
Account Number(s) Amount Account Number(s) Amount
20400001.405890 $2,220,124 20400021.556050 $220,124
20400021.556040 $2,000,000
Total $2,220,124 Total $2,220,124
Prepared By: Marc Amaral, Administrator
Approved
Forwarded to Council
Attachments:
A. Attachment A: Proposed Santa Monica HOME-ARP Allocation Plan (Public
Review)
B. Attachment B: 2021-22 CDBG/HOME Annual Action Plan
C. Attachment C: April 27, 2021 Staff Report
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Santa Monica Home ARP Allocation Plan (Proposed) – For Public Review
PROPOSED
HOME-ARP ALLOCATION PLAN
For Public Review August 2022
Abstract
The City of Santa Monica has been allocated HOME-ARP funds through the U.S.
Department of Housing and Urban Development. HOME-ARP funds assist individuals
or households who are homeless, at risk of homelessness, and other vulnerable
populations, by providing assistance to increase housing stability This plan outlines
the City’s intended uses of HOME-ARP funds to achieve these outcomes.
5.E.a
Packet Pg. 223 Attachment: Attachment A: Proposed Santa Monica HOME-ARP Allocation Plan (Public Review) (5290 : HOME-ARP Allocation Plan)
Santa Monica Home ARP Allocation Plan (Proposed) – For Public Review
Executive Summary
The American Rescue Plan of 2021 (ARP), also called the COVID-19 Stimulus Package, Pub.L.
117–2 (March 11, 2021) provides $5 billion to assist individuals or households who are
homeless, at risk of homelessness, and other vulnerable populations, by providing housing,
rental assistance, supportive services, and non-congregate shelter, to reduce homelessness
and increase housing stability across the country. These grant funds will be administered
through HUD’s HOME Investment Partnerships Program (HOME) and are known as HOME-
ARP funds. Eligible HOME-ARP activities include acquisition and development of non-
congregate shelter, tenant based rental assistance, supportive services, HOME-ARP rental
housing, administration and planning, and nonprofit operating and capacity building
assistance. A certain portion of HOME-ARP funds must assist people in HOME-ARP "qualifying
populations,” which include:
• Sheltered and unsheltered homeless populations, as defined in section 103(a) of the
McKinney-Vento Homeless Assistance Act (42 U.S.C. 11302(a));Those currently
housed populations at risk of homelessness, as defined in section 401(1) of the
McKinney-Vento Homeless Assistance Act (42U.S.C. 113060(1));
• Those fleeing or attempting to flee domestic violence, dating violence, sexual assault,
stalking, or human trafficking;
• Other families requiring services or housing assistance or to prevent homelessness
In September 2021, HUD announced that the City of Santa Monica will receive $2,220,124 in
HOME-ARP funds. This supplemental funding was allocated by formula under the HOME
entitlement program. To receive the HOME-ARP allocation, the City must develop a HOME-
ARP Allocation Plan that will become part of the City’s PY2021 HUD Annual Action Plan by
substantial amendment. The Allocation Plan includes 1) an outline of the consultation and
public participation processes undertaken, 2) an assessment of the needs of qualifying
populations and gaps in local housing and services systems, and 3) planned uses of HOME-
ARP funds for prioritized populations and eligible activities.
To ensure broad input into the HOME-ARP Allocation Plan, the City engaged in consultation
with stakeholders and the public, including an online survey, virtual consultation sessions,
direct contact with HUD-required organizations that did not participate in a virtual session, a
public hearing, and a 15-day public comment period. The Santa Monica City Council is
scheduled to consider approval of the HOME-ARP Allocation Plan on September 13, 2022.
An assessment and analysis of needs and gaps resulted in the following key findings:
• According to the HUD Continuum of Care Homeless Assistance Programs Homeless
Populations and Subpopulations data for Los Angeles County and City from 2020, 63,706
persons were identified as homeless with 46,090 (72.3%) of those persons unsheltered
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Packet Pg. 224 Attachment: Attachment A: Proposed Santa Monica HOME-ARP Allocation Plan (Public Review) (5290 : HOME-ARP Allocation Plan)
Santa Monica Home ARP Allocation Plan (Proposed) – For Public Review
and 24,482 (38.4%) identified as chronically homeless. In Santa Monica, specifically, there
were 907 people experiencing homelessness, among these, 601 were unsheltered.
• According to the 2020 HUD Point in Time Count Data for the Los Angeles City and County
Continuum of Care service area, 83% of homeless individuals living with a severe mental
illness are unsheltered, and 94% of homeless individuals living with chronic substance
abuse issues are unsheltered.
• Based on the 2020 Los Angeles City and County Continuum of Care Point in Time Count,
3,884 (6%) of homeless individuals were fleeing domestic violence and of these 3,143
(80%) were unsheltered. In LAHSA’s 2020 Homeless Count, it was reported that 1,993
people experiencing homelessness in Servicing Planning Area (SPA) 5, which includes
Santa Monica, had experienced domestic violence/intimate partner violence.
• HUD’s 2020 Homeless Assistance Programs Homeless Populations and Subpopulations
data for Los Angeles City and County CoC found 3,681 homeless veterans. Of those, 2,804,
or 76%, were unsheltered
• In Santa Monica, nearly 19% of all households are cost burdened and spend between 30
and 50% of their income on housing costs.
• According to CHAS data, the City of Santa Monica has a larger percentage of renter-
occupied households as compared to the national average. In Santa Monica, 71% (32,495)
of households are renter households;2 as compared to 36% nationally.
• Renters in Santa Monica are reporting a greater housing cost burden than those
homeowners in similar AMI categories. This burden is especially prevalent for renter
households earning less than 30% AMI, as 34% (4,590) of all renters in this earning
category report spending more than 30% of their income or more on rent. Of that total,
3,935 households are classified as severely rent burdened, with 50% or more of their
income being paid towards rent.
• While some protections exist for renters under Santa Monica’s rent control law, the Rent
Control Board announced a September 2022 General Adjustment (GA) of up to 6.0% for
eligible units, with a maximum $140 increase for units with current maximum allowable
rents of $2,325 and above. In a survey conducted by the City of Santa Monica renters,
62% of respondents in rent-controlled units stated “No” that they will not be able to
afford the 6% rent increase ($140 max).
• In FY 21/22, Legal Aid Foundation of Los Angeles closed 541 housing-related cases. Many
of these cases were repeat eviction cases for the same tenant, reflecting a trend of
2
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Packet Pg. 225 Attachment: Attachment A: Proposed Santa Monica HOME-ARP Allocation Plan (Public Review) (5290 : HOME-ARP Allocation Plan)
Santa Monica Home ARP Allocation Plan (Proposed) – For Public Review
property managers filing new cases even after a previous one was closed, increasing the
risk of eviction for the most vulnerable tenants in Santa Monica.
• The stock of available rental units has dropped significantly in the Los Angeles area since
January 2021 to just above a 4% vacancy rate, which increases competition for all units
but especially affordable units.
To address these needs and gaps, the City will utilize HOME-ARP funds for supportive services
for qualifying populations, including legal services; case management; behavioral health care;
payments for utility and housing deposits, short-term rent, rent arrears (up to the allowable
six months), and moving costs. The City will solicit applications from developers, service
providers, and/or subrecipient organizations to provide a range of services designed to
address the underlying issues that have put a renter household at risk of homelessness and
to help them retain their housing or identify an alternate housing option to prevent them
from experiencing homelessness. Those already experiencing homelessness will be
connected to services that will help them access shelter and housing.
1. Consultation
A. Process
Describe the consultation process including methods used and dates of consultation. The City of Santa Monica is part of the Los Angeles Continuum of Care (CoC) led by the Los
Angeles Homeless Services Authority (LAHSA). LAHSA establishes priorities for the CoC,
including performance standards, evaluation, and Coordinated Entry System (CES) procedures.
The City coordinates with the CoC by actively participating in the Los Angeles County Homeless
Initiative, which is driven by the County Executive Office and LAHSA. The City participates in
quarterly CoC meetings to discuss funding priorities, evaluation tools, and performance
measures. The City also participates in the continued development and implementation of the
CES, which brings together local resources with county departments, housing authorities,
mainstream benefits, the Veterans Administration (VA), and private sector partners. Staff from
the City’s Housing and Human Services Division also participates in CoC planning meetings,
quarterly CoC meetings and LAHSA Commission meetings to provide comment on critical CoC
issues such as performance measures, evaluation tools, and NOFA prioritization.
Within the City itself, the Community Services Department’s (CSD) Housing and Human Services
Division (HHSD) contains staffing for the Santa Monica Housing Authority (SMHA), the City’s
local Public Housing Agency (PHA). SMHA staff participates in quarterly meetings hosted by the
Los Angeles County Development Authority (LACDA) inviting all Los Angeles County PHAs to
discuss topical issues, ideas, and concerns related to combatting homelessness. These meetings
are part of the County’s Homeless Initiative Strategy E10: The Regional Coordination of Los
Angeles County Housing Authorities.
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Packet Pg. 226 Attachment: Attachment A: Proposed Santa Monica HOME-ARP Allocation Plan (Public Review) (5290 : HOME-ARP Allocation Plan)
Santa Monica Home ARP Allocation Plan (Proposed) – For Public Review
In preparing the HOME-ARP Allocation Plan, the City of Santa Monica sought to utilize this
existing network of stakeholders and partnerships to ensure compliance with HUD’s
requirements that, at a minimum, participating jurisdictions (PJs) consult with the CoC serving
the PJ’s geographic area, service providers for people experiencing homelessness and victims of
domestic violence, veterans groups, public housing agencies (PHAs), public agencies that
address the needs of qualifying populations, and public or private organizations that address
fair housing, civil rights, and the needs of persons with disabilities.
The City’s outreach and consultation strategies included the following:
• On December 21, 2021, LAHSA released a memorandum to all 27 HOME-ARP PJs in the Los
Angeles CoC entitled “2021 HOME-ARP Funding Recommendations from the LA CoC.” The
memo provided a summary of the HOME-ARP program requirements as it relates to
collaboration with a local CoC and use of the CES. The memo also provided recommendations
from LAHSA, lead agency for the LA CoC, to local jurisdictions for use of HOME-ARP funding
that support and advance the goals of the CoC.
• On February 9, 2022, City staff participated in a HOME-ARP webinar hosted by LAHSA to
discuss LAHSA recommendations for use of HOME-ARP funds. The invitation to the webinar
was extended to all HOME-ARP PJs in the LA CoC, collectively representing a total of $196
million in HOME-ARP funding.
• On March 2, 2022, a representative from the City attended LAHSA office hours to engage in
an in-depth discussion of LAHSA recommendations and ideas for the use of the City’s
allocation. LAHSA agreed that homeless prevention efforts would be consistent with LAHSA
recommendations and would support efforts to reduce the inflow of households into
homelessness, which has been contributing to the increase in homelessness in LA CoC despite
increased rates of housing placements.
• On April 7, 2022, the City conducted a session of its local Homeless Resource Coordination
meeting dedicated to use of HOME-ARP funds. The meeting brought together service
providers (homeless services, healthcare, DV, behavioral health, shelter operators, outreach
operators, employment programs), policymakers, members of the faith community,
healthcare organizations, representatives from LAHSA and County Board of Supervisors
District 3, and staff from a host of City and County departments for a robust discussion about
LAHSA’s recommendations for HOME-ARP and the City’s intent to propose eligible activities
in alignment with said recommendations in its HOME-ARP Allocation Plan. The attendees
supported recommendations to focus HOME-ARP on homelessness prevention efforts.
• On May 23, 2022, City staff attended the public convening of the Social Services Commission
to provide a brief overview of HOME-ARP funding and seek input on development of the
HOME-ARP Allocation Plan.
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• On July 13, the City attended a meeting of the Los Angeles Veterans Collaborative (LAVC) to
discuss use of HOME-ARP for supportive services that veterans could utilize to prevent
evictions as well as those needed by veterans currently in the homeless services system who
are moving out of shelters or off the streets into new homes. Members of the Housing and
Homelessness workgroup recommended strategies to support homeless vets moving into
housing and to keep them stably housed, including move-in and short-term rent assistance.
• To reach potential consumers of HOME-ARP-funded services, from June 24, 2022 to July 11,
2022 the City issued an informal Housing Needs Survey to gauge the needs of Santa Monica
renters. The survey was available in English and Spanish, on-line, with paper copies available
at City Hall, parks and library facilities, and through social service agencies. Rent Control
included a link to the survey in a mailer to over 27,500 residents in rent controlled
apartments. The survey was also publicized via City social media channels with a distribution
list of over 47,000. Of the 259 completed survey responses, 243 were from Santa Monica
renters, a majority of whom reported concerns about their ability to pay rent.
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B. Organizations Consulted
List the organizations consulted.
Agency / Organization
Consulted
Type of
Agency/
Organization
If a Service Provider, Qualifying
Population Served
Method of Consultation
Chrysalis Non-Profit
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
County of Los Angeles
– Department of
Mental Health
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
Disability Community
Resource Center
Non-Profit
Service
Provider
People at Risk of Homelessness;
People with Disabilities
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
Legal Aid Foundation
of Los Angeles
Non-Profit
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
Fair Housing
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
Los Angeles Homeless
Services Authority
CoC Lead
Agency
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
PJA HOME ARP Meeting (Virtual Session)
HOME ARP Office Hours Meetings (Virtual
Session)
Los Angeles Veterans
Collaborative
Advocacy
Network
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
Veterans
Veterans Collaborative Homeless and
Housing Working Group
(Virtual Session)
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Office of Los Angeles
County Supervisor
Sheila Kuehl
Policy
Development
N/A City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
Providence Saint
John’s Medical Center
Non-Profit
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
Santa Monica Housing
Authority (SMHA)
Public
Housing
Agency (PHA)
N/A City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
City of Santa Monica
Social Services
Commission
City
Commission
N/A City of Santa Monica Virtual Commission
Meeting
The People Concern Non-Profit
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
UCLA - Santa Monica
Medical Center
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
Venice Family Clinic Non-Profit
Service
Provider
People Experiencing Homelessness;
People at Risk of Homelessness;
Victims of domestic violence;
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
WISE & Healthy Aging Non-Profit
Service
Provider
People at Risk of Homelessness;
Seniors; People with Disabilities
City of Santa Monica – Homeless Resource
Coordination Meeting (Virtual Session)
City of Alhambra LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Baldwin Park LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
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City of Bellflower LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Burbank LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Compton LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Downey LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of El Monte LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Gardena LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Hawthorne LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Huntington
Park
LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Inglewood LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Los Angeles LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
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City of Lancaster LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Lynwood LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Montebello LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Monterey Park LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Norwalk LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Palmdale LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Paramount LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Pomona LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Rosemead LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Santa Clarita LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
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City of Southgate LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Torrance LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
City of Whittier LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
County of Los Angeles LA CoC PJ N/A LAHSA Webinar: HOME- ARP: The LA CoC's
Recommendations to Participating
Jurisdictions (Virtual)
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C. Summary of Feedback Received
Summarize feedback received and results of upfront consultation with these entities.
LA CoC recommendations for use of HOME-ARP funds included: acquisition of permanent
housing resources, master leasing of multi-unit housing, and provision of supportive services such
as diversion, homelessness prevention, and short-term financial assistance. Notably, LAHSA did
not recommend use of HOME-ARP funding for non-congregate shelter. LAHSA specifically
recommended that jurisdictions not utilize HOME-ARP funds for non-congregate sheltering, for
reasons including: 1) the lack of permanent housing exits in the current system, a gap which
would be exacerbated by increasing shelter capacity without corresponding increases in other
system resources such prevention, outreach, services, rental subsidies, and permanent
supportive housing; and 2) the lack of operating dollars available to sustain new shelter
programs, a substantial recurring expense, which is an ineligible use of onetime HOME-ARP funds
and for which no other funding is currently available. Other LAHSA recommendations are largely
duplicative of existing Santa Monica resources. For example, the City supports affordable housing
development through a local housing trust fund and has identified other sources of funding for
Emergency Housing Voucher (EHV) navigation services and move-in costs.
The Los Angeles Veterans Collaborative Housing and Homelessness workgroup recommended
strategies to support homeless vets (including those that are ineligible for VA resources) moving
into housing and to keep them stably housed, including move-in and short-term rent assistance,
landlord incentives, and resources to help older veterans age in place.
Participants in both the Homeless Resources Coordination meeting as well as the Social Services
Commission meeting expressed support for focusing one-time funding to keep vulnerable
households from becoming homeless or returning to homelessness in order to proactively stem
the tide of people needing more expansive homeless housing and services. Participants cited the
on-going economic impacts on vulnerable households struggling to recover and facing barriers
to returning to work such as lack of child care, need to quarantine due to illness or close contact
with infected persons, and impacts of inflation.
On June 23, 2022, the City’s Housing and Human Services Division (HHSD) partnered with the
Rent Control office and 311 to open a Housing Needs Survey designed to identify housing and
housing-related service needs throughout the City. Santa Monica respondents identified the cost
of housing and basic needs as the biggest barrier to obtaining and maintaining housing, and
building and maintaining affordable housing as their top housing-related priorities. The survey
approach is described in more detail in the Efforts to Broaden Public Participation section of this
Plan, and the results are referenced throughout. A summary of the survey results follows.
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Santa Monica respondents (composed of over 90% renters) identified difficulty in affording other
basic necessities, paying rent and/or mortgage, paying utility bills or making utility deposits, and
inability to find safe and decent housing at affordable costs as the top housing issues they
experienced in the last six months. Santa Monica respondents identified the cost of housing as
the overwhelming barrier to obtaining housing. Similarly, Santa Monica respondents identified
keeping existing affordable apartments affordable for current and future renters, building new
apartments for households with low or moderate incomes, and providing long-term rental
assistance/subsidies as the top priorities for helping residents obtain and maintain affordable
housing. 31.3% % of Santa Monica renter respondents make less than $45,000 annually.
Among respondents who state that they currently need assistance with rent (about a quarter of
all respondents), the average amount of rental assistance needed is $971/month showing a need
for deep rental subsidies. Very few survey respondents successfully accessed local and state
rental assistance program rolled out during the pandemic.
Regarding the upcoming Rent Control General Adjustment in September 2022, 62% of
respondents in rent-controlled units stated “No” that they will not be able to afford the 6% rent
increase ($140 max). 46.2% of respondents living in rent-controlled units make less than $45,000
annually.
2. Public Participation
A. Process
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.
The City considers the involvement of public to be essential to the development of the
HOME-ARP Allocation Plan. In accordance with HUD requirements, the City held a well-
advertised public hearing at the May 23, 2022 meeting of the Social Services Commission
to invite input on the development of the plan from commissioners and members of the
public. To further inform the plan, the City’s opened a Housing Needs Survey on June 23,
2022 to solicit further input on proposed uses of HOME-ARP funding. The complete
Proposed HOME-ARP Allocation Plan is now made available for a 15-day public review
period beginning August 27, 2022. City Council is scheduled to formally consider approval
of the HOME-ARP Allocation Plan as a substantial amendment to the FY 2021-22 Annual
Action Plan on September 13, 2022.
The public review period and public hearings were advertised via official notices in the
Santa Monica Daily Press, email notification to local grantees, service providers,
neighborhood associations, and Housing and Human Services boards, commissions, and
workgroups, and a notice in the April SaMoNews email blast to over 40K Santa Monica
community members. Notices invited participation from Spanish speakers and offered
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accommodations for people with disabilities upon request. Taken together, these
outreach and engagement strategies are part of a concerted effort to obtain significant
public input during preparation of the plan.
Date(s) of Public Notice:
Public Hearing: May 7, 2022; May 21-22, 2022 (Notice published in the Santa Monica Daily
Press)
Public Comment Period: August 27-28, Sept 3-4, 2022 (Notices published in the Santa
Monica Daily Press)
Date of Public Hearing: May 23, 2022
Date of City Council Approval: September 13, 2022
B. Efforts to Broaden Public Participation
Describe efforts to broaden public participation.
The public hearing held at the May 23, 2022 meeting of the City’s Social Services
Commission was advertised in the May 7, 2022 and May 21-22, 2022 editions of Santa
Monica Daily Press. The ad included a portion of the notice translated into Spanish as well
as an invitation to contact the City with any requests for accommodations. In order to
promote accessibility, the public hearing was conducted remotely and featured Spanish
interpretation, American Sign Language (ASL), and closed captioning. Once completed,
the meeting was posted to the Social Services Commission’s website at
www.smgov.net/ssc for continued access.
On June 23, 2022, the City’s Housing and Human Services Division (HHSD) partnered with
the Rent Control office and 311 to open a Housing Needs Survey designed to identify
housing and housing-related service needs throughout the City. Specifically, the survey
was crafted with a dual purpose: 1) to better understand the expected impact on
residents of the Rent Control General Adjustment going into effect in September 2022,
and 2) to inform how the City intends to use $2.2 million in HOME-ARP for activities to
support efforts to prevent homelessness and/or permanently house people experiencing
homelessness.
The survey was made available online in English and Spanish and was included in the Rent
Control summer mailer that went out on June 24, which goes to over 27,500 households
living in rent-controlled apartments. A link to the survey was included in the SaMoNews
digital newsletter, with an email distribution list of over 40,000 individuals. The survey
was also posted on a variety of City social media channels, and paper surveys were
distributed to City Hall, Parks, Libraries, City Hall, and key services provider sites which
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are open to the public. The City also provided an option for community members to
contact 311 to submit the survey over the phone or request a paper copy. In order to
reach homebound individuals with limited access to media and the internet, information
about the survey was also included in almost 300 local Meals on Wheels West deliveries
during the open period. The survey closed on July 11, 2022.
C. Comments and Recommendations Received
Summarize the comments and recommendations received through the public participation
process either in writing, or orally at a public hearing.
During the public hearing held at the May 23, 2022 meeting of the Social Services
Commission, commissioners expressed verbal support for the City’s intent to align with
LAHSA recommendations for use of HOME-ARP funding, specifically to fund supportive
services aimed at preventing eviction and homelessness. Commissioners also voiced
support for including short-term assistance within the range of proposed prevention
services. Individual commissioners also inquired about the availability of referral services
at City courts and the eligibility of tenants without lease documentation for HOME-ARP
funded services. No oral public comment was given during the meeting, but the City
received one written comment in response to advertisement of the public hearing,
recommending that the City allocate funds to earthquake retrofitting and balcony repair
for multi-unit buildings of less than 15 units.
Any comments made or received during the City Council’s September 13, 2022 meeting
to consider approval of the HOME-ARP Allocation Plan will be incorporated into this
document prior to HUD submittal.
D. Comments or Recommendations Not Accepted
Summarize any comments or recommendations not accepted and state the reasons why.
All comments/recommendations were accepted for consideration.
3. Needs Assessment and Gaps Analysis
A. Size and Demographic Composition of Qualifying Populations
Describe the size and demographic composition of qualifying populations within the PJ’s
boundaries.
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The needs assessment and gap analysis must evaluate the “demographic composition of
qualifying populations within its boundaries and assess the unmet needs of those populations.”1
The qualifying populations are as follows and will be described more fully throughout this section:
• Homeless
• At risk of Homelessness
• Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault,
Stalking, or Human Trafficking
• Other Populations (Other Families Requiring Services or Housing Assistance to Prevent
Homelessness and Households At Greatest Risk of Instability)
Homeless, as defined in 24 CFR 91.5
According to the HUD Continuum of Care Homeless Assistance Programs Homeless Populations
and Subpopulations data for Los Angeles County and City from 2020, 63,706 persons were
identified as homeless, with 46,090 (72.3%) of those persons unsheltered, and 24,482 (38.4%)
identified as chronically homeless. In Santa Monica, specifically, there were 907 people
experiencing homelessness, of which 601 were unsheltered.
As shown in the summaries below for Los Angeles County and City, households without children
represented almost 93% of the homeless households, and about 80% of people experiencing
homelessness were in households without children. Nearly 12% of homeless individuals were
under 18. Approximately 66.5% of individuals were male, nearly 32% were female, just over 1%
were transgender, and less than 1% were gender non-confirming or nonbinary.
1 HOME ARP Guidance.
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With respect to race and ethnicity, Black/African American and White individuals each
represented about 45% of the homeless population, about 1.8% were Asian, nearly 2.3% were
American Indian or Alaskan Native, and 3.8% were multiple races. About 26% were Hispanic.
With respect to likelihood of a particular race to be unsheltered, the illustration below shows
that while the Asian population has the lowest number of people experiencing homelessness,
Asians were more likely to be unsheltered.
Race Unsheltered Total Percent Unsheltered
Black or African
American
19,845 28,998 68.4%
White 21,854 29,236 74.7%
Asian 975 1,168 83.4%
American Indian or
Alaskan Native
1,124 1,449 77.5%
Hispanic 16,726 23,005 72.7%
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According to the 2020 HUD Point in Time Count Data for the Los Angeles City and County
Continuum of Care service area, 83% of homeless individuals living with a severe mental illness
are unsheltered, and 94% of homeless individuals living with chronic substance abuse issues are
unsheltered. The graphic below illustrates the 2020 Point in Time Count by Sub Population. Only
parenting youth and children of parenting youth are more likely to be sheltered than unsheltered.
Among unsheltered individuals, the subpopulations represented from largest to smallest are (1)
those experiencing chronic substance abuse (14,284), those who are severely mentally ill
(11,711), those fleeing domestic violence (3,148),veterans (2,804),persons with HIV/AIDS (857),
unaccompanied youth (2,119), children of parenting youth (298), and parenting youth (168).
Source: 2020 HUD Point in Time Count Data for the Los Angeles City and County Continuum of Care service
area
According to the Los Angeles Homeless Service Authority (LAHSA), data from the 2020 City of Santa
Monica Point in Time (PIT) Count indicated that the overall homeless population decreased by 19% from
1,002 in 2019 to 811 in 2020. From 2019 to 2020, the unsheltered population count decreased by 14.4%
from 752 to 642. The unsheltered population accounts for persons residing on the street, cars, vans,
RV/Campers, makeshift shelters, and tents.
With respect to demographics served by current efforts of the COC, the Cumulative Coordinated Entry
System Statistics for the period January 1, 2022 to March 31, 2022 for the City of Santa Monica are
provided below along with the same numbers for the first quarter of 2021. Assessments decreased by
53% in the first quarter of 2022 as compared to 2021. Individuals remain the most frequently assessed
although the percent of individuals increased as compared to families in 2022. The percent of individuals
assessed in 2021 was 81.5% as compared to 88.9% in 2022. The percent of families assessed in 2021 was
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14.4% as compared to 6.7% in 2022. Further the percentage of youth increased slightly in 2022 while the
percentage of persons aged 62 year or older decreased slightly.
Cumulative CES Statistics from HMIS, January – March
CES Assessments 2021 2021 % of total 2022 2022 % of Total
Total Persons
Assessed
733 100% 343 100%
Individuals 598 81.5% 305 88.9%
Youth 33 4.5% 16 5.2%
Families 106 14.4% 23 6.7%
Veterans 59 8% 31 9%
Persons Aged 62+ 114 15.5% 45 13.1%
Source: Homeless Statistics by City, Los Angeles Homeless Services Authority
At Risk Of Homelessness, as defined in 24 CFR 91.5
As defined in the HOME ARP Guidance, households at risk of homelessness are those with
incomes below 30% AMI that do not have resources or family, friend, or faith-based support
networks to prevent homelessness, and:
1. Has moved because of economic reasons two or more times during the 60 days,
2. Lives in the home of another because of economic hardship,
3. Has received a 21-day eviction notice,
4. Lives in a hotel or motel, which is not paid for with assistance from a charitable
organization or government,
5. Lives in overcrowded conditions as defined by HUD, OR
6. Is exiting a publicly funded institution or system of care.
According to Comprehensive Housing Affordability Strategy Data, 2015-2018 (CHAS), nearly 15%
of households in Santa Monica earn less than 30% AMI. This is the second largest income group
following households earning greater than 100% AMI. This category represents 6,800
households that meet the threshold criteria in the HOME-ARP guidance for those at risk of
homelessness.
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Cost burden is an indication of housing need and the need for reduced costs. Households who
pay more than 30% of their income for rent and utilities are considered cost burdened. In Santa
Monica, nearly 19% of all households are cost burdened and spend between 30 and 50% of their
income on housing costs. According to CHAS data, the City of Santa Monica has a larger
percentage of renter-occupied households as compared to the national average. In Santa
Monica, 71% (32,495) of households are renter households;2 as compared to 36% nationally.3
Renters in Santa Monica are reporting a greater housing cost burden than those homeowners in
similar AMI categories. This burden is especially prevalent for renter households earning less than
30% AMI, as 34% (4,590) of all renters in this earning category report spending more than 30%
of their income or more on rent. Those households earning less than 30% AMI while experiencing
cost burden of greater than 30% of their income are significantly at risk of housing instability and
homelessness.
2 Comprehensive Housing Affordability Strategy Data, 2015-2018 (CHAS). Note: Includes data for Santa
Monica Census County Division (CCD), Los Angeles County, California
3 Census, 2020.
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Source: Comprehensive Housing Affordability Strategy Data, 2015-2018 (CHAS).
Note: Includes data for Santa Monica Census County Division (CCD), Los Angeles County, California. Cost
burden is the ratio of housing costs to household income. For renters, housing cost is gross rent (contract
rent plus utilities). For owners, housing cost is "select monthly owner costs", which includes mortgage
payment, utilities, association fees, insurance, and real estate taxes.
COVID-19 Related Emergency Rental Assistance
The Coronavirus Response and Relief Supplemental Appropriations Act of 2021 included
emergency rental assistance for households economically impacted by COVID-19. The package
includes $25 billion for emergency rental assistance to be distributed and overseen by the U.S.
Department of the Treasury (Treasury). Funds allocated to States and local government
administrations to operate emergency rental assistance programs for local landlords and tenants.
Many of the eligibility requirements for Treasury’s emergency rental assistance programs (ERAP)
overlap with HOME APR eligibility requirements, including:
• At risk of homelessness or experiencing housing instability (e.g. past due notice, non-
payment of rent, or eviction notice) and
• A household income less than 80% AMI.4
Data from the Santa Monica and State of California’s Emergency Rental Assistance Programs can
help quantify those individuals and households in Santa Monica that are housing insecure.
4 While 80% AMI is the upper limit of assistance, many state and local ERA programs have developed systems to
prioritize assistance for households earning 30% AMI.
4,590
2,480 2,515
1,510
2,475
760
530 620
370
2,170
0
1,000
2,000
3,000
4,000
5,000
6,000
0-30% AMI 30-50% AMI 50-80% AMI 80-100% AMI More than 100%AMI
Income Cost Burden, by AMI
Renter Owner
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• Between July 2020 and August 2022, 2,935 households in Santa Monica received rental
assistance through two Emergency Rental Assistance Programs, totaling more than $40
million:
o State of California’s Emergency Rental Assistance Program5
Households served: 2,299
Average assistance amount: $16,442
o Santa Monica’s Emergency Rental Assistance Program6
Households served: 636
Average assistance amount: $4,360
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or
Human Trafficking, as defined by HUD in the HOME-ARP Notice
According to Rainbow Services, in Los Angeles, 49% of unsheltered adult women report a history
of intimate partner violence in their lifetime. Based on the 2020 Los Angeles City and County
Continuum of Care Point in Time Count, 3,884 (6%) of homeless individuals were fleeing domestic
violence and of these 3,143 (80%) were unsheltered. In LAHSA’s 2020 Homeless Count, it was
reported that 1,993 people experiencing homelessness in Servicing Planning Area (SPA) 5, which
includes Santa Monica, had experienced domestic violence/intimate partner violence. This
represents 33% of the total of people over 18 experiencing homelessness in SPA 5. Typically,
Santa Monica’s homeless population represents nearly 30% of the homeless individuals in SPA 5
and so it can be expected that about a third of those individuals were homeless in Santa Monica.
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 HOME-ARP Notice
The HOME-ARP notice defines families “Requiring Services or Housing Assistance to Prevent
Homelessness” as households (i.e., individuals and families) who have previously been qualified
as “homeless” as defined in 24 CFR 91.5, are currently housed due to temporary or emergency
assistance, including financial assistance, services, temporary rental assistance or some type of
other assistance to allow the household to be housed, and who need additional housing
assistance or supportive services to avoid a return to homelessness.
The HOME-ARP notice defines “Other Populations At Greatest Risk of Housing Instability” in two
ways. The first definition includes those with annual income that is less than or equal to 30% of
the area median income, as determined by HUD and is experiencing severe cost burden (i.e., is
paying more than 50% of monthly income on housing costs.) In Santa Monica there are 3,935
extremely low income and severely cost burdened households, which places them at imminent
risk of becoming homeless.
5 Housing is Key.
6 Data from Marc.
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The second definition is that the household has an annual income that is less than or equal to
50% of the area median income, as determined by HUD, and meets one of the conditions of “At
risk of homelessness.” In Santa Monica, 10,470 households, or 23% of all households, earn 50%
AMI or less. Of these households, 8,885 (84.8%) are renter households. The CHAS data does not
have the same “at risk of homelessness” conditions as HOME-ARP. However, 7,305 of the renter
households earning 50% AMI or less renter households reported one of the four housing
problems (incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per
room, and cost burden greater than 30%). Renter households include:
• Two-person households, one or both of who are age 62 or older
• Small families with 2-4 non-elderly people
• Large families with 5 or more people
• People living alone or with non-relatives who are age 62 or older
• People living alone or with non-relatives, none of whom are age 62 or older
HOME ARP Guidance specifically identifies “Veterans and Families that include a Veteran Family
Member” as another eligible population under HOME-ARP. HUD’s 2020 Homeless Assistance
Programs Homeless Populations and Subpopulations data for Los Angeles City and County CoC
found 3,681 homeless veterans. Of those, 2,804, or 76%, were unsheltered.
B. Current Resources Available to Assist Qualifying Populations
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).
The City places great emphasis upon seeing that decent, safe affordable housing is available for
low-income residents along with services to address community needs. Homeless activities,
ranging from providing emergency shelter to preventing homelessness receive a high priority.
Thus, the City will continue to focus on multiple efforts including rental assistance, rental
rehabilitation, new rental construction (using local, non-federal funds), as well as home
modifications to accommodate persons with special needs and in many instances prevent
homelessness. The following section provides information on current resources available for
shelter units, supportive services, TBRA, and affordable and permanent supportive rental
housing.
Shelter Units
The City owns two properties that are leased to a local non-profit at below-market rates for the
operations of homeless services at the Access Center and the SAMOSHEL emergency shelter. A
third City-owned facility is leased to a non-profit providing services to seniors, including those
that are disabled and/or low-income.
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While the City continues to support over 250 year-round interim housing beds in the community,
shelter capacity has remained significantly reduced due to COVID-related “decompression”
orders by the L.A. County Department of Public Health to prevent the spread of COVID-19 among
vulnerable populations. Multiple COVID outbreaks at facilities on the Westside resulted in fewer
new intakes at these facilities until Public Health could provide clearance to lift the outbreak
status.
Supportive Services
The Human Services Grants Program (HSGP) provides approximately $8 million in annual funding
for services offered by nonprofit organizations that respond to clearly identified community
needs in Santa Monica and advance the City’s priorities. The program aims to improve the
wellbeing and quality of life of Santa Monica’s youth and families, people with disabilities,
seniors, victims of domestic violence, low-income households, and people experiencing
homelessness. HSGP funding levels are approved by Council annually as part of the adoption of
the City’s budget. The Funding awarded through the HSGP comes from multiple sources both
locally and nationally. Between 2020 and 2021 Santa Monica Human Services Grant Program
served:
• 3,249 individuals with disabilities
• 417 military veterans
• 121 victims of Domestic Violence
• 1,877 individuals experiencing homelessness or at risk of homelessness
The City is also working to address the impacts of the Rent Control General Adjustment scheduled
for September 1 that will place an additional rent burden on already struggling households, The
Rent Control Adjustment Relief program (RCAR) makes available $750,000 in City funds to
provide short term assistance to reduce the impact of rent increases for approximately 1,100
Extremely Low Income (less than or equal to 30% of area median income) and Very Low Income
(between 30% and 50% of area median income) rent controlled residents who are Severely Cost
Burdened (paying more than 50% of monthly income towards rent). This City-administered
program will provide assistance in the form one-time payments directly to property
owners/managers on behalf of eligible program applicants. If voters approve a proposed ballot
measure in November, the maximum allowable rent increase, currently at 6%, will revert to less
than 1% in February and cap future rent increases at 3%. Should the measure fail to pass, the City
will need to consider additional measures in order to provide longer-term assistance to impacted
renters using resources beyond what is currently available.
Tenant Based Rental Assistance
The City currently uses HOME funding for Tenant Based Rental Assistance (TBRA) and continues
to closely monitor available federal funding, adjusting its lease up as necessary. The City adheres
to income limits established by HUD in order to determine eligibility for programs and for income
targeting purposes. Income eligibility is determined by comparing the annual income of an
applicant to the applicable income limits for their family size. In order to be income eligible a
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family must be a very low-income, low-income, or moderate-income family. The Santa Monica
Housing Authority is the local public housing authority and is currently administering 874 tenant
based rental assistance vouchers.
Affordable and Permanent Supportive Housing
Affordable Housing
The City recently reviewed various City-owned properties and evaluated the sites for potential
affordable housing development. The sites represented a range of development potential
involving near-term and long-term opportunities, as well as housing production ‘yield’. One
particular site was ready for redevelopment, and during 2019, the City Council authorized the
property at 1318 4th Street to be developed as 100% affordable housing, including a requirement
that a significant portion of the future affordable housing be targeted to persons experiencing
homelessness. The City will continue to monitor the development potential and readiness of
other City-owned properties for use as affordable housing.
The City is required by the California Department of Housing and Community Department to
report on its progress towards meeting housing goals and its Regional Housing Needs Allocation
(RHNA) set forth in the adopted Housing Element. Each year, the City must identify how many
housing units have been proposed, approved, and built. For 2020, 64 affordable housing units
were completed and in 2021 39 affordable housing units were completed. The affordability
percentages for these units are noted in the graphic below.
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Source: Santa Monica Housing Element Update Dashboard
Additionally, the City’s report provides information on the number of affordable housing units
pending, under construction, and approved. The totals for 2020 and 2021 are represented in the
chart below.
Affordable Housing Unit
Status
2020 2021
Pending 0 69
Under Construction 81 73
Approved 272 131
Permanent Supportive Housing
The City uses the county’s vulnerability assessment tool to prioritize highly vulnerable households
for permanent housing. Using the City’s HMIS and monthly care coordination meetings, the City
works closely with local and regional providers to track the progress of these individuals into
housing, assisting with advocacy and resources to remove system and process barriers in order
to shorten the length of homelessness.
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In 2021, under the American Rescue Plan, the Department of Housing and Urban Development
(HUD) allocated 104 Emergency Housing Vouchers (EHVs) to the City to be issued to people
experiencing or at risk of homelessness. The City prioritized its allocation of EHVs to exit people
in local shelter programs and unsheltered individuals referred by City-funded Street engagement
teams into permanent housing with supportive services.
In calendar year 2021, the City-funded multidisciplinary teams, made more than 11,000 contacts
with people experiencing homelessness and provided direct medical or psychiatric services to
808 participants. In 2021, these teams placed 57 people into interim housing and 24 individuals
into permanent housing. The two Point-in-Time Homeless Counts conducted since the C3 teams
were launched recorded reductions of 19% (2019) and 14% (2020) in areas where C3 had been
deployed. The City continues to support efforts to increase regional bed capacity through its
participation in the Westside Cities Council of Government (WSCCOG). The WSCCOG is a vehicle
through which the City champions regional solutions and problem solving in tandem with the
leadership of neighboring communities. The WSCCOG is currently developing a housing and
services needs assessment. During this period, Culver City – a WSCCOG member – was awarded
$26.6 million in state funding for two Homekey developments, creating 37 new residences of
permanent supportive housing and 39 interim housing beds on the Westside through
hotel/motel conversions.
C. Unmet Housing and Service Needs of Qualifying Populations
Describe the unmet housing and service needs of qualifying populations.
Homeless, as defined in 24 CFR 91.5
When completing a simple gap analysis using the HUD Continuum of Care Homeless Assistance
Programs Homeless Populations and Subpopulations data from 2020, there is a clear shortage of
emergency, transitional, and supportive housing beds in the Los Angeles City and County
Continuum of Care service area. In 2020 in Los Angeles City and County, 63,706 persons were
identified as homeless with 46,090 of those persons unsheltered. In Santa Monica, specifically,
there were 907 people experiencing homelessness, among these, 601 were unsheltered. The
total number of beds reported in the Los Angeles County and City Housing Inventory Count was
49,713 and 369 in the City of Santa Monica, resulting in an overall shortage of 13,993 beds in Los
Angeles City and County and a shortage of 438 in Santa Monica.
Gap Analysis – Homeless Individuals Inventory Total Beds, by CoC (2020)
Geography Number of
Homeless
Persons (PIT)
Total Beds
(HIC)
Shortage/Surplus
(HIC minus PIT)
Unsheltered
Persons (PIT)
Los Angeles City and
County CoC Totals
63,706 54,699 Shortage 13,993 46,090
City of Santa Monica 907 369 Shortage 438 601
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Sources: HUD 2020 Continuum of Care Homeless Assistance Programs Housing Inventory Count Report;
HUD Continuum of Care Homeless Assistance Programs Homeless Populations and Subpopulations. Los
Angeles City and County CoC.
This analysis does not account for shortages of beds to serve specific demographics. As shown
in the demographics section, 51,155 of homeless households in Los Angeles County and City are
households without children. The Housing Inventory Count reports that only 28,477 of the bed
counted are adult-only beds.
At Risk of Homelessness, as defined in 24 CFR 91.5
HUD defines those at risk of homelessness as individuals and families who have an income below
30% of the area median income (AMI), do not have sufficient resources or support networks to
prevent them from becoming homeless, or live with instability, like moving two or more times
during the last 60 days due to economic reasons.
Cost burden and extreme cost burden are the most common housing problems for Santa Monica
renter households earning less than 30% AMI. A total of 5,935 renter households earn 30% AMI
or less. About 87% of renters earning 30% AMI or below are either cost burdened (paying 30% or
more for housing costs) or severely cost burdened (paying 50% or more for housing costs). Those
earning 30% AMI or less make up nearly 34% of all cost burdened renter households in the City
and over 41% of all severely cost burdened renter households in the City.
As incomes for many renters stay stagnant, costs of rents have been steadily increasing. Rental
prices dipped at the outset of the pandemic as vacancies increased with families consolidating in
the face of financial uncertainty but starting midway through 2021 rents began increasing and
have continued to rise. According to Apartment List, an online data source for rent and vacancy
information nationally, the current median cost of a 1-bedroom unit in Santa Monica is $2,073
and the current median cost of a 2-bedroom unit is $2,583. See graphic below. As rents increase,
renters will spend increasingly higher percentages of their income on housing costs, which will
further deepen concerns of housing instability.
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Source: Apartment List Rent Estimate Data, August 2022
While some protections exist for renters under Santa Monica’s rent control law, the Rent Control
Board announced a September 2022 General Adjustment (GA) of 6.0% for eligible units, with a
maximum $140 increase for units with current maximum allowable rents of $2,325 and above.
On August 4, 2022 Santa Monica City Council approved a resolution to place a measure on the
November 8, 2022 ballot that would amend the City Charter to establish for 2022 an average
General Adjustment (GA) cap of 3% or $70 and establish a maximum GA of 3% for future years.
This measure will support tenants of rent-controlled units who will be impacted by the 6% rent
increase GA that will take effect September 1, 2022. If the ballot measures are approved by the
voters, they will go into effect January 1, 2023. Maximum Allowable Rent for units subject to rent
control would then increase by 6% effective September 1, 2022, as currently scheduled, then be
reduced to 0.8% on February 1, 2023, resulting in an overall increase of 3% for the year. For units
in which owners implement no more than a 3% increase in September, no reduction on February
1, 2023, will be required. While the outcome of the November ballot remains to be seen, renters
in rent-controlled units should be bracing for possible increases beginning in September. In the
Housing Needs Survey discussed in the consultation section of this report, 62% of respondents in
rent-controlled units stated “No” that they will not be able to afford the 6% rent increase ($140
max). Approximately 46% of respondents living in rent-controlled units make less than $45,000
annually. For renters who already struggle to pay their rent, even modest increases can mean the
risk of homelessness.
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or
Human Trafficking, as defined by HUD in the Notice
Domestic violence or human trafficking survivors often lack easy access to short-term shelter and
quick access to medical and mental health services. In addition, there are only informal networks
to connect survivors to job opportunities. Without economic independence, many survivors are
caught in abusive relationships and the gains they make with traditional social services are not
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fully realized. The major unmet housing needs for survivors are availability of affordable housing
and shelter/interim housing beds for survivors.
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 HOME-ARP Notice
Extremely low income and severely cost burdened households are those with housing expenses
greater than 50% of their income and earning less than 30% AMI. In Santa Monica there are 3,935
extremely low income and severely cost burdened households, which places them at imminent
risk of becoming homeless.
The issues already discussed in the previous sections for those at risk of homelessness, including
the cost of housing, apply equally to those facing housing instability generally. It is also important
to discuss the limited eviction prevention services as an unmet need of those facing housing
instability.
In FY 21/22, Legal Aid Foundation of Los Angeles closed 541 housing-related cases. Many of these
cases were repeat eviction cases for the same tenant, reflecting a trend of property managers
filing new cases even after a previous one was closed, increasing the risk of eviction for the most
vulnerable tenants in Santa Monica. With the end of the state rental assistance program in March
2022 and no other large-scale rent relief programs in place, the need for rental assistance has
increased as many households are still recovering economically post-pandemic and have no
other resources. In addition, with the passage of AB 2179, households can be evicted for non-
payment of rent from April 2022 – June 2022, and there has since been a steady increase in the
number of eviction actions and requests for rental assistance related to non-payment of rent for
these months.
These eviction increases are consistent with the findings in a 2020 study prepared for The Public
Justice Center. In this study, it was found that the financial stresses of the pandemic on both
renters and landlords may result in higher evictions and that it is critical for low-income renters
to remain in their homes or be connected to services that can assist with finding resources, both
of which can be achieved by access to a right to counsel.7 The study noted that for tenants in
cities across the country, having legal representation is often the difference between maintaining
housing and becoming homeless. The study noted the benefits of the right to counsel as:
• More favorable outcomes for tenants;
• Decreased likelihood of shelter entry or living unsheltered;
• Increased housing stability and ability to re-rent, if necessary;
• Decreased impact on employment, credit score, and eviction record;
• Decreased impact on physical and mental health;
• Decreased negative impact on children, including health, education, and potential future
earnings;
7 “The Economic Impact of an Eviction Right to Counsel in Baltimore City,” Stout Risius Ross,.LLC, prepared for the
Public Justice Center, May 9, 2020.
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• Increased family and community stability;
• Decreased impact on law enforcement; and
• Increased trust in the justice system and civic engagement.
As seen in this list of benefits, the outcomes to providing access to counsel to low-income renters
facing eviction do not just serve the renter but also the community and local service providers
through the preservation of other resources such as shelter services and law enforcement.
D. Gaps within Current Shelter and Housing Inventory, and Service Delivery Systems
Identify any gaps within the current shelter and housing inventory as well as the service delivery system.
As described throughout this Plan, Santa Monica is a city of predominantly renters and the effects
of the pandemic and market shifts have been greatest on renter households. Renter households
are cost burdened at high rates, they are facing rising rent costs and low rental vacancies, rent
control increases are imminent, and evictions are on the rise. These factors also make it more
difficult for those already experiencing homelessness to enter the rental market. Gaps in the
current shelter, housing, and service delivery system that need to be filled to better support
HOME-ARP qualifying populations include additional services to help low-income individuals and
households manage pandemic era shifts that will impact their ability to secure housing and their
likelihood of maintaining housing. The City has a strong COC and shelter services in place,
however, a rapid increase in people entering homeless will strain the system. The City also has a
pipeline of affordable housing units in production and an existing tenant-based voucher program.
Services to support those experiencing homelessness and those at risk of homelessness or
housing instability to navigate the specific impacts of the pandemic, market shifts, and changes
in policies, however, are most lacking in the community.
Santa Monica has a long history of investing in services to prevent eviction and keep vulnerable
Santa Monica renters housed. Programs originally designed to support people leaving
homelessness to stay housed have expanded to include an array of social services, legal services,
and flexible City funding to address tenant harassment, unlawful evictions, rent arrears,
underemployment, hoarding, and behavioral issues that put any low-income renter at risk of
becoming homeless. COVID put these services front and center and made eviction prevention a
key priority across the country. While state, regional, and local rental assistance programs
combined with a myriad of eviction moratoriums to help hundreds of Santa Monica renters stay
housed over the past three years, those assistance programs and moratoriums are rapidly
sunsetting at a time when low-income households are now facing the impacts of inflation and
rising rents.
While the City’s RCAR program will provide temporary and much-needed relief for a portion of
vulnerable households in rent-controlled apartments, there are already signs of a growing need
for much deeper rental assistance beyond the impact of the increase. HUD’s most recent
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Comprehensive Housing Affordability Strategy (CHAS) data from 2018 estimates that there are
5,535 very low and extremely low-income renters in Santa Monica who are severely rent
burdened (paying 50 percent or more of their income on rent). These households are susceptible
to even small increases in rent as well as the cost of basic living essentials such as food and
utilities that put them at greater risk of falling behind on rent. These vulnerabilities put such
households at increased risk of eviction once County and local eviction moratoriums expire on
December 31, 2022 and January 31, 2023, respectively.
E. Additional Characteristics Associated with Instability and Increased Risk of
Homelessness
Optional: 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.
The City does not plan to formally adopt additional definitions of “other populations,” however,
a look at additional characteristics that can help clarify the stressors placing renters in Santa
Monica at risk of housing instability is helpful.
Limited Housing Availability: Beyond the issues already discussed in the previous sections,
including the cost of housing, adjustments to rent control measures, and increasing eviction
cases, the stock of available rental units has dropped significantly in the Los Angeles area since
January 2021 to just above a 4% vacancy rate. This has contributed to the increasing rent costs
over this same time period, but also means that renters who lose their housing would face the
challenge of finding not just units they can afford and qualify for based on income level and credit
worthiness, but also the challenge of finding available units generally. In a tight rental market,
landlords can be selective about who they choose as tenants, and this means greater competition
for units.
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Source: Apartment List Vacancy Index, August 2022
Living Wage: High cost burden is a housing characteristic strongly linked with instability and an
increased risk of homelessness. Cost burden is affected by a household’s ability to earn a living
wage. The federal minimum wage is $7.25/hour. The current state minimum wage is
$15.00/hour. Massachusetts Institute of Technology, Department of Urban Studies and Planning
Living Wage Calculator reported the Los Angeles metropolitan area living wage for an individual
is $21.62. For a single parent with three children, the living wage is $73.93 per hour. For two
working parents with three children the living wage is $37.54 each per hour.
Families with Childcare Needs: Childcare allows parents to participate in the workforce, continue
their education, and secure housing—strengthening their family’s resiliency, economic mobility,
and housing stability. Further, children’s access to quality early childhood development and
learning opportunities lays the foundation for their optional development across a range of
indicators including physical and mental health, educational attainment, and employment.
Through the City’s Human Services Grant Program (HSGP), Connections for Children (CFC)
provides financial assistance to low-income families so that they can afford the high cost of
childcare and better balance their overall household costs. The HSGP-funded subsidy program
helps low-income families bridge the financial gap between childcare tuition and what they can
afford. In FY 2020-21, CFC administered childcare subsidies for 195 low-income Santa Monica
children. Eighty-six percent of children enrolled in the subsidy program reside in the Pico
neighborhood (90404/90405). CFC is not able to serve all families in need, however, and as of
12/31/21 there were 135 children from 93 families on the subsidy eligibility list, waiting for
financial assistance in order to access the childcare that allows them to work and maintain their
housing.
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F. Identify Priority Needs for Qualifying Populations
Identify priority needs for qualifying populations.
The following priority needs have been identified for qualifying populations:
• Services to address underlying causes of increasing housing and economic instability of
those facing and experiencing homelessness;
• Services that connect individuals experiencing homelessness and at risk of homelessness
or housing instability with resources such as homeless prevention services, legal services,
case management, and behavioral health care.
• Financial assistance that supports renters and potential renters such as funds needed to
pay rent arrears, short-term rental assistance, moving costs, fees, and utility and housing
deposits, which allows individuals to access and maintain housing; and
• Additional affordable units.
G. Determination of Level of Need and Gaps in Shelter and Housing Inventory and Service
Delivery Systems
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 level of need and gaps in shelter and housing inventory and service delivery systems was
determined through careful consideration of input from multiple sources, including the public,
the COC, homeless service providers, veterans’ groups, domestic violence agencies, the public
housing agency and other public or private organizations that address fair housing, civil rights,
and the needs of persons with disabilities. The City also considered data available through the
coordinated entry system, Census, ACS, CHAS, and data collected by individual organizations on
the populations served through their programs.
4. HOME-ARP Activities
A. Method(s) of Selection
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 proposes to focus use of HOME-ARP funds to provide supportive services directed to
addressing the causes of increasing housing and economic instability as a result of the pandemic.
These services may include connecting qualifying populations to legal services, case
management, behavioral health care, and payments for utility and housing deposits, rent arrears
(up to the allowable six months), and moving costs.
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For its HOME-ARP program, the City intends to subgrant at least some portion of available funds
to local organization(s) to provide the supportive services described above. The City will comply
with the requirements applicable to the expenditure of the federal grant funds found at 2 CFR
200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200).
City staff shall identify applicable federal requirements and effect their implementation in the
subgrant agreements.
All purchasing and contracting will be accomplished in the best interests of the City and in
accordance with 2 CFR 200, California Code, and City purchasing guidelines. City procurement
methods are documented at Chapter 2-24 of the Municipal Code. To the extent they conform to
federal law, the City’s methods will also reflect state and local law.
The selection of supportive service provider(s) will be conducted using either a competitive or
non-competitive method of procurement as described below:
Competitive Proposals - This method of procurement involves more than one source submitting
an offer and award of either a fixed price or cost- reimbursement type of contract. It is used when
conditions are not appropriate for the use of sealed bids. If this method is used, then:
1. RFPs shall be publicized and identify all evaluation factors and their relative importance.
All responses shall be considered to the maximum extent practical;
2. Proposals shall be solicited from an adequate number of qualified sources;
3. The City shall have a written method for conducting technical evaluations of the proposals
received and for selecting recipients;
4. Contracts shall be awarded to the responsible firm whose proposal is most advantageous
to the program, with price and other factors considered; and
5. For qualifications-based procurement of architectural/engineering professional services
only, this method can be used without including price as a selection factor. This does not
apply when other types of services are purchased through architectural or engineering
firms.
Noncompetitive Proposals - This method of procurement consists of solicitation of a proposal
from only one source. It may only be used when one or more of the following circumstances
apply:
1. The item is available only from a sole source;
2. The public exigency or emergency for the requirement will not permit a delay resulting
from competitive solicitation;
3. The federal awarding agency or pass-through entity expressly authorizes this method in
response to a written request from the City; or
4. After solicitation from a number of sources, competition is determined inadequate.
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B. Direct Administration by PJ
Describe whether the PJ will administer eligible activities directly.
The City will contract with a sub grantee to administer supportive services and/or serve as a
service navigator. However, in the event such supportive services include financial assistance
costs, then those funds will be distributed by the City directly.
C. Use of Subrecipient
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.
The City has not provided funds to a subrecipient or contractor prior to HUD’s acceptance of the
HOME-ARP Allocation Plan and will not allocate funds to a subrecipient nor contractor to
administer the entire HOME-ARP grant.
D. Use of HOME-ARP Funding
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.
Funding Amount Percent of the
Grant
Supportive Services $2,000,000 90%
Acquisition and Development of Non-Congregate
Shelters $ 0 0%
Tenant Based Rental Assistance (TBRA) $ 0 0%
Development of Affordable Rental Housing $ 0 0%
Non-Profit Operating $ 0 0%
Non-Profit Capacity Building $ 0 0%
Administration and Planning $ 220,124 10%
Total HOME ARP Allocation $ 2,220,124 100%
Distribution of HOME-ARP Funds In Accordance With Priority Needs
Describe how the PJ will distribute HOME-ARP funds in accordance with its priority needs identified in its needs assessment and gap analysis.
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The City intends to distribute funds to address the priority supportive service needs identified
through the analysis in this Plan. Supportive services that connect qualifying populations to
resources that will assist them in accessing and maintaining housing will shore up local homeless
services and homeless prevention work in anticipation of the eviction wave when COVID relief
and other protections end for renters and when rents increase due to changes in rent control
policy. These services may include connecting qualifying populations to legal services, case
management, behavioral health care, housing search and counseling services, and financial
assistance such as payments for utility and housing deposits, rent arrears (up to the allowable six
months), short to medium term rental assistance, and moving costs.
HOME ARP funding would be used to support services for the next two to three years as the peak
housing instability is expected to be in 2023-2025. This would also support the City’s economic
recovery goal and align with the City’s homelessness prevention pillar.
Rationale for Funding Based on Characteristics of Needs Identified in the Gap Analysis
Describe how the characteristics of the shelter and housing inventory, service delivery system, and
the needs identified in the gap analysis provided a rationale for the plan to fund eligible activities. The 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 supportive services. These
needs are the result of an ever-challenging rental market in which rent costs are increasing,
available units are limited, rent control policies have shifted, and evictions are on the rise. These
characteristics mean increased housing instability for all renters who are currently housed as well
as greater challenges in accessing housing for those experiencing homelessness. Further, the
upcoming expiration of current eviction protections on December 31, 2022 marks the arrival of
the long-looming eviction cliff, an event widely anticipated to result in issuance of a wave of
unlawful detainers. UD cases are widely projected to rise following the sunset of eviction
protections, placing many vulnerable households at imminent risk of homelessness, with
economic impacts from COVID continuing through 2025. Use of HOME-ARP funds to provide
supportive and preventative services will ensure that the City has a range of resources available
to assist qualifying households in accessing and maintaining housing.
The strategy to provide supportive services with HOME-ARP funds is also aligned with the LAHSA
recommendations to do more to prevent new cases of homelessness, which frees resources for
those who are already experiencing homelessness. While the gap analysis also identified the
need for more affordable housing, the City believes that the level of HOME-ARP funds received
is more effectively used for supportive services to address these imminent service needs,
especially given that other resources are already being used to fund the pipeline of affordable
units described in the City’s Housing Element.
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5. HOME-ARP Production of Housing Goals
A. Estimated Number of Affordable Rental Housing Units for Qualifying
Populations
Estimate the number of affordable rental housing units for qualifying populations that the PJ will produce or support with its HOME-ARP allocation.
The City will not be using the HOME-ARP allocation toward affordable rental housing units for
qualifying populations. The focus of the City’s HOME-ARP funding will be for supportive services
for qualifying populations.
B. Rental Housing Production Goals and Correspondence with Need
Describe the specific affordable rental housing production goal that the PJ hopes to achieve and
describe how the production goal will address the PJ’s priority needs.
Not applicable to chosen HOME-ARP Activities.
6. Preferences
The City has not given a preference to any of the qualifying populations or sub-populations under
its plan for HOME-ARP supportive services.
A. Identification of Preference
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.
There will be no preference for qualifying populations. The solicitation for applications will
entertain projects targeted toward any or all qualifying populations who may need supportive
services as described in this Allocation Plan. The City will issue guidance in its request for
proposals regarding serving all populations.
B. Using Preference to Address Unmet Need
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. As described above, no preference has been identified.
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7. Referral Methods
PJs are not required to describe referral methods in the plan. However, if a PJ intends to use a
coordinated entry (CE) process for referrals to a HOME-ARP project or activity, the PJ must
ensure compliance with Section IV.C.2 of the Notice (page10).
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 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). Not applicable to the City’s chosen HOME-ARP activities.
8. Limitations
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.
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.
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).
Not applicable to the City’s chosen HOME-ARP activities.
9. 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).
Not applicable to the City’s chosen HOME-ARP activities.
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