Title
HOME-ARP Allocation Plan and 2020-24 Consolidated Plan's 2021-22 Annual Action Plan Substantial Amendment
Description
Request City Council approval of a Substantial Amendment to the 2020-24 Consolidated Plan's 2021-22 Annual Action Plan to add the U.S. Department of Housing and Urban Development (HUD) HOME Investment Partnerships Program (HOME) American Rescue Plan Act of 2021 (ARP) allocation of $21,354,777; submit the HOME-ARP Allocation Plan to HUD for approval; and take all necessary actions and execute all documents and agreements required by HUD authorized under Section 3205 of the American Rescue Plan Act of 2021, Public Law 117-2, enacted on March 11, 2021, for the purposes of providing homelessness assistance and supportive services due to the continued impact of the COVID-19 pandemic on the economy, public health, state and local governments, individuals, and businesses. Further request to authorize the City Treasurer to accept and the City Controller to disburse all funds related to this item.
Report
Summary
The 2020-24 Consolidated Plan's 2021 Annual Action Plan defines how the City's Community Development Block Grant, Emergency Solutions Grant, HOME, and Housing Opportunities for Persons with AIDS programs be used to address the priorities and goals outlined in the five-year plan.
- The Housing Department is proposing the following Substantial Amendment to add HOME-ARP funding allocations for the purposes of:
- Providing homelessness assistance and supportive services due to the continued impact of the COVID-19 pandemic on the economy, public health, state and local governments, individuals, and businesses;
- Waiving the matching contribution requirements;
- Waiving the set-aside requirements for Community Housing Development Organizations;
- Waiving the requirements for the 24-month deadline for the commitment of funds;
- Waiving the requirements for home buyer or existing homeowner activities in the National Affordable Housing Act; and
- Implementing all HOME-ARP waivers.
The following outlines how the City of Phoenix intends to utilize these funds and waivers to provide homelessness assistance and supportive services in response to the continued impact of the COVID-19 pandemic:
1. Add the HOME-ARP allocation of $21,354,777 to support the following activities:
- Production or Preservation of Affordable Housing - $8,209,650;
- Supportive Services including services designated at 24 CFR 578.53(e) - $2,500,000;
- Purchase and development of Non-Congregate Shelter - $8,209,649;
- Operating Costs for Community Housing Development Organizations, other non-profit organizations, and homeless providers - $300,000 (maximum allocation allowed for this activity is 5 percent or $1,067,289); and
- Administration costs - $2,135,478 (Maximum allocation allowed for this activity is 15 percent or $3,203,216).
2. Utilization and implementation of all HOME-ARP waivers as authorized by HUD's Community Planning and Development memo dated Sept. 8, 2021.
Prior to implementation of these funds, HUD requires that the City complete an in-depth assessment to determine the needs for the qualifying populations as well as submit a HOME-ARP Allocation Plan. The City contracted with a consultant to complete the required analysis and plan. Upon approval by the City Council, the HOME-ARP Allocation Plan will be submitted to HUD for final approval and authorization to utilize these funds. The HOME-ARP Allocation Plan also includes a preference for non-congregate shelter and rental housing projects that serve people experiencing homelessness. Further City Council action will be required to enter into any new agreements, or to modify any existing contracts, with service providers for services funded under these eligible activities.
Procurement Information
Services may be procured, as needed, by utilizing procurement in accordance with Administrative Regulation 3.10 to implement and administer HUD funded programs intended to prevent, prepare for, and respond to the COVID-19 national pandemic.
Financial Impact
These programs are federally funded by HUD. There is no impact to the General Fund.
Public Outreach
As part of the HOME-ARP Allocation Plan process, HUD requires that proposed substantial amendments be made public and provide for a 15-day public comment period. Additionally, as part of the American Rescue Plan Act of 2021, Public Law 117-2, enacted on March 11, 2021, HUD approved an abbreviated process to allow flexibility to institute more streamlined requirements to address immediate needs relative to the Coronavirus. The HUD abbreviated process includes the following:
- The reduction of the 30-day public comment period and the implementation of a public comment period of no less than 15 days in an effort to expedite the Consolidated Plan Substantial Amendment process and allow the City to respond as quickly as possible to the immediate needs in the community; and
- The elimination of the in-person public hearings and the implementation of virtual public hearings when national and or local health authorities recommend social distancing and limiting public gatherings for public health reasons; and virtual hearings provide reasonable notification and access for citizens in accordance with Phoenix's certifications, timely responses from local officials to all citizen questions and issues, and public access to all questions and responses.
The City of Phoenix published a 15-day comment period and public hearing notice in the Arizona Republic on Aug. 29, 2022. A virtual public hearing was held to provide an opportunity for public comment on Sept. 12, 2022. The public comment period was open from Sept. 13 to Sept. 27, 2022.
In addition to the public outreach required by HUD, Housing staff conducted six virtual listening sessions for community stakeholders and interviewed numerous service agencies and housing providers directly. More than 66 agencies participated in interviews and listening sessions.
Concurrence/Previous Council Action
This item was recommended for approval at the Community and Cultural Investment Subcommittee meeting on Nov. 2, 2022.
Department
Responsible Department
This item is submitted by Deputy City Managers Gina Montes and Alan Stephenson, and the Housing and Neighborhood Services departments.