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HomeMy WebLinkAboutResolutions - 2022.12.08 - 37799 AGENDA ITEM: Grant Application with the U.S. Department of Housing and Urban Developments for the FY 2021 HOME Investment Partnership - American Rescue Plan (HOME- ARP) Program 22-428 COMMITTEE MEETING: Board of Commissioners DATE: Thursday, December 8, 2022 9:52 AM - Click to View Agenda ITEM SUMMARY SHEET DEPARTMENT SPONSORED BY Health & Human Services - Neighborhood and Housing Development Penny Luebs INTRODUCTION AND BACKGROUND This is a request to approve the submission of the FY 2021 HOME-American Rescue Plan allocation plan in total amount of $10,396,043 to the U.S. Department of Housing and Urban Development. The HOME Investment Partnerships American Rescue Plan Program (HOME-ARP) provides funding to HOME Participating Jurisdictions (PJs) to reduce homelessness and increase housing stability across the country. BUDGET AMENDMENT REQUIRED: No Committee members can contact Michael Andrews, Policy and Fiscal Analysis Supervisor at 248.858.5115 (office) or andrewsmb@oakgov.com, or the department contact persons listed for additional information. CONTACT Shane Bies, Manager Neighborhood & Housing Development-UNI Biess@oakgov.com ITEM REVIEW TRACKING Penny Luebs, Created/Initiated - 12/8/2022 David Woodward, Board of Commissioners Approved - 12/8/2022 Hilarie Chambers, Executive's Office Approved - 12/9/2022 Lisa Brown, Clerk/Register of Deeds Final Approval - 12/13/2022 AGENDA DEADLINE: 12/08/2022 11:15 AM COMMITTEE TRACKING 2022-11-29 Public Health & Safety - Recommend and Forward to Finance 2022-11-30 Finance - Recommend to Board 2022-12-08 Full Board - Adopted ATTACHMENTS 1. Grant Review Sign-Off 2. 20210921_Oakland County_HOME ARP_2021GrantTransmittalLetter 3. SF-424 HOME-ARP for Signatures 4. HOME-ARP_Allocation_Plan_Oakland 2022-11-15 December 8, 2022 RESOLUTION #2022-2302 _ 22-428 Sponsored By: Penny Luebs Health & Human Services - Neighborhood and Housing Development - Grant Application with the U.S. Department of Housing and Urban Developments for the FY 2021 HOME Investment Partnership - American Rescue Plan (HOME-ARP) Program Chairperson and Members of the Board: WHEREAS the United States Department of Housing and Urban Development (HUD), by letter dated September 21, 2021, transmitted to the Neighborhood & Housing Development Division a FY 2021 allocation of the HOME Investment Partnership - American Rescue Plan (HOME-ARP) Program in the amount of $10,396,043 for the program year period of September 21, 2021 through September 30, 2030; and WHEREAS partial HOME-ARP funds for administrative and planning purposes, in the amount of $519,802, were accepted via MR #22136; and WHEREAS the HOME-ARP Allocation Plan was unanimously endorsed by the Citizen Advisory Council on November 10, 2022; and WHEREAS the grant funds will continue to fund the following six (6) Full-Time Eligible Special Revenue (SR) positions in the Department of Health and Human Services/Neighborhood & Housing Development Division (1060701): one (1) Supervisor N&HD Administrative Services position (#01371), two (2) Supervisor N&HD positions (#00999 and 03182), one (1) N&HD Community Liaison position (#14811), one (1) Chief N&HD position (#14810), one (1) Manager N&HD position (#14809); and WHEREAS the grant application has completed the Grant Review Process in accordance with the Grants Policy approved by the Board at their January 21, 2021 meeting. NOW THEREFORE BE IT RESOLVED that the Oakland County Board of Commissioners approves the submission of the FY 2021 HOME Investment Partnership - American Rescue Plan allocation plan in total amount of $10,396,043 to the U.S. Department of Housing and Urban Development. BE IT FURTHER RESOLVED to continue to fund the following six (6) Full-Time Eligible Special Revenue (SR) positions in the Department of Health and Human Services/Neighborhood & Housing Development Division (1060701): one (1) Supervisor N&HD Administrative Services position (#01371), two (2) Supervisor N&HD positions (# 00999 and 03182), one (1) N&HD Community Liaison position (#14811), one (1) Chief N&HD position (#14810), one (1) Manager N&HD position (#14809). BE IT FURTHER RESOLVED that a budget amendment is not required at this time. Chairperson, the following Commissioners are sponsoring the foregoing Resolution: Penny Luebs. Date: December 08, 2022 David Woodward, Commissioner Date: December 09, 2022 Hilarie Chambers, Deputy County Executive II Date: December 13, 2022 Lisa Brown, County Clerk / Register of Deeds COMMITTEE TRACKING 2022-11-29 Public Health & Safety - Recommend and Forward to Finance 2022-11-30 Finance - Recommend to Board 2022-12-08 Full Board - Adopted VOTE TRACKING Motioned by Commissioner Penny Luebs seconded by Commissioner Charles Cavell to adopt the attached Grant Application: with the U.S. Department of Housing and Urban Developments for the FY 2021 HOME Investment Partnership - American Rescue Plan (HOME-ARP) Program . Yes: David Woodward, Kristen Nelson, Philip Weipert, Gwen Markham, Angela Powell, Marcia Gershenson, William Miller III, Yolanda Smith Charles, Charles Cavell, Penny Luebs, Janet Jackson, Gary McGillivray, Robert Hoffman (13) No: Michael Gingell, Michael Spisz, Karen Joliat, Eileen Kowall, Christine Long, Chuck Moss, Adam Kochenderfer (7) Abstain: None (0) Absent: (0) Passed ATTACHMENTS 1. Grant Review Sign-Off 2. 20210921_Oakland County_HOME ARP_2021GrantTransmittalLetter 3. SF-424 HOME-ARP for Signatures 4. HOME-ARP_Allocation_Plan_Oakland 2022-11-15 STATE OF MICHIGAN) COUNTY OF OAKLAND) I, Lisa Brown, Clerk of the County of Oakland, do hereby certify that the foregoing resolution is a true and accurate copy of a resolution adopted by the Oakland County Board of Commissioners on December 8, 2022, with the original record thereof now remaining in my office. In Testimony Whereof, I have hereunto set my hand and affixed the seal of the Circuit Court at Pontiac, Michigan on Thursday, December 8, 2022. Lisa Brown, Oakland County Clerk / Register of Deeds GRANT REVIEW SIGN-OFF –Health & Human Services – Neighborhood Housing & Development GRANT NAME: 2021 HOME-American Rescue Plan Program Grant Administrative Funds FUNDING AGENCY: HUD, CFDA Number 14.239 Home Investment Partnerships Program DEPARTMENT CONTACT: Shane Bies 248-858-5403 STATUS: Grant Amendment #1 (Greater than or Equal to 15% Variance from Current Award) DATE: 11/18/2022 Please be advised the captioned grant materials have completed internal grant review. Below are the returned comments. The Board of Commissioners’ liaison committee resolution and grant amendment package (which should include this sign-off and the grant amendment with related documentation) may be requested to be placed on the agenda(s) of the appropriate Board of Commissioners’ committee(s) for grant amendment by Board resolution. DEPARTMENT REVIEW Management and Budget: Approved – Sheryl Johnson (11/18/2022) Human Resources: Approved by Human Resources. Continues positions with no changes. – Heather Mason (11/16/2022) Risk Management: Approved – Robert Erlenbeck (11/16/2022) Corporation Counsel: Approved – Heather Lewis (11/17/2022) U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OFFICE OF COMMUNITY PLANNING AND DEVELOPMENT DETROIT FIELD OFFICE 477 MICHIGAN AVENUE, STE. 1600 DETROIT, MI 48226-2592 DetroitCPD@hud.gov www.hud.gov espanol.hud.gov DetroitCPD@hud.gov September 21, 2021 Shane Bies, Manager Neighborhood & Housing Development County of Oakland 250 Elizabeth Lake Road, Suite 1900 Pontiac, Michigan 48341-0415 Dear Shane Bies: The American Rescue Plan Act of 2021 appropriated $5 billion to provide housing, services, and shelter to individuals experiencing homeless and other vulnerable populations, to be allocated by formula to jurisdictions that qualified for HOME Investment Partnerships Program allocations in Fiscal Year 2021. On September 13, 2021, the Department published a notice, titled: Requirements for the Use of Funds in the HOME-American Rescue Plan Program (the Notice), which you are encouraged to review to assist in developing your program. Enclosed is the Grant Agreement for the HOME Investment Partnerships – America Rescue Plan (HOME-ARP) program: In accordance with the Notice, and the HOME ARP Grant Agreement, a Participating Jurisdiction (PJ), as of the Federal Award Date, may use up to five percent of its total award for administrative and planning costs. Once your HOME-ARP Allocation Plan is approved by HUD, the remaining award will be made available. HOME Investment Partnerships - American Rescue Plan (HOME-ARP) $10,396,043.00 Transmittal of this Grant Agreement does not constitute approval of the activities described in your HOME-ARP Allocation Plan. You are reminded that you, as the PJ, are responsible for ensuring that all grant funds are used in accordance with all program requirements. An executed Grant Agreement is a legally binding agreement between the Department of Housing and Urban Development and Oakland County. To establish a Line of Credit for the HOME-ARP award, it will be necessary for your agency to sign, execute and return one (1) copy of the Grant Agreement. If there is a need to add or remove individuals authorized to access the Integrated Disbursement Information System (IDIS), please submit an IDIS Online Access Request Form (HUD 27055). Also, please ensure the IDIS Online Access Request Form is notarized and returned to this office with your Grant Agreement. Additionally, if there is a need to establish or change the depository account where these funds are to be wired, a Direct Deposit Sign-Up form (SF-1199A) must be completed by your financial institution and returned to this office with a copy of a voided check. You are reminded that certain activities are subject to the provisions of 24 CFR Part 58 (Environmental Review Procedures). Funds for such activities may not be obligated or expended until HUD has approved the release of funds in writing. A request for release of funds (RROF) must be accompanied by an environmental certification, and until the RROF is approved and notification is received, no HUD funds should be committed. If the project or activity is exempt per 24 CFR 58.34 or categorically excluded (except in extraordinary circumstances), no RROF is required. Please execute two (2) copies of the HOME-ARP Grant Agreement with electronic signatures. In response to COVID-19, HUD authorizes you to electronically execute the grant agreement with your electronic signature. Return one (1) of the agreements to this office to the attention of CPD General Correspondence Mailbox, at DetroitCPD@hud.gov. Maintain a copy of the agreement with your original signature on site in your program files. HUD congratulates Oakland County on its grant award, and we look forward to assisting you in accomplishing your programs goals. If you have any questions or need further information of assistance, please contact Darlene White, Senior CPD Representative at (313) 234-7336 or Darlene.E.White@hud.gov. Sincerely, Keith E. Hernández, AICP, PMP Director Office of Community Planning and Development Enclosures cc: OMB Number: 4040-0004 Expiration Date: 12/31/2022 * 1. Type of Submission:* 2. Type of Application: * 3. Date Received: 4. Applicant Identifier: 5a. Federal Entity Identifier:5b. Federal Award Identifier: 6. Date Received by State:7. State Application Identifier: * a. Legal Name: * b. Employer/Taxpayer Identification Number (EIN/TIN):* c. UEI: * Street1: Street2: * City: County/Parish: * State: Province: * Country: * Zip / Postal Code: Department Name:Division Name: Prefix:* First Name: Middle Name: * Last Name: Suffix: Title: Organizational Affiliation: * Telephone Number:Fax Number: * Email: * If Revision, select appropriate letter(s): * Other (Specify): State Use Only: 8. APPLICANT INFORMATION: d. Address: e. Organizational Unit: f. Name and contact information of person to be contacted on matters involving this application: Application for Federal Assistance SF-424 Preapplication Application Changed/Corrected Application New Continuation Revision County of Oakland, Michigan 386004876 HZ4EUKDD7AB4 250 Elizabeth Lake Road Suite 1900 Pontiac Oakland MI: Michigan USA: UNITED STATES 48341-0414 Health and Human Services Neighborhood & Housing Develop Mr.Shane Bies Manager 248 858-5403 248 858-5311 biess@oakgov.com M-21-DP-26-0210 * 9. Type of Applicant 1: Select Applicant Type: Type of Applicant 2: Select Applicant Type: Type of Applicant 3: Select Applicant Type: * Other (specify): * 10. Name of Federal Agency: 11. Catalog of Federal Domestic Assistance Number: CFDA Title: * 12. Funding Opportunity Number: * Title: 13. Competition Identification Number: Title: 14. Areas Affected by Project (Cities, Counties, States, etc.): * 15. Descriptive Title of Applicant's Project: Attach supporting documents as specified in agency instructions. Application for Federal Assistance SF-424 B: County Government U.S. Department of Housing and Urban Development 14.239 HOME Investment Partnerships Program M21-DP260210 Home Investment Partnerships Program Non-congregate shelter development and/or rehabilitation, supportive services for eligible households, non-profit operating/capcity building support for eligible non-profits. View AttachmentsDelete AttachmentsAdd Attachments View AttachmentDelete AttachmentAdd AttachmentSee attachment * a. Federal * b. Applicant * c. State * d. Local * e. Other * f. Program Income * g. TOTAL . Prefix:* First Name: Middle Name: * Last Name: Suffix: * Title: * Telephone Number: * Email: Fax Number: * Signature of Authorized Representative:* Date Signed: 18. Estimated Funding ($): 21. *By signing this application, I certify (1) to the statements contained in the list of certifications** and (2) that the statements herein are true, complete and accurate to the best of my knowledge. I also provide the required assurances** and agree to comply with any resulting terms if I accept an award. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001) ** The list of certifications and assurances, or an internet site where you may obtain this list, is contained in the announcement or agency specific instructions. Authorized Representative: Application for Federal Assistance SF-424 * a. Applicant Attach an additional list of Program/Project Congressional Districts if needed. * b. Program/Project * a. Start Date:* b. End Date: 16. Congressional Districts Of: 17. Proposed Project: MI-008 Add Attachment Delete Attachment View Attachment 10/01/2021 09/30/2030 10,396,043.00 10,396,043.00 a. This application was made available to the State under the Executive Order 12372 Process for review on b. Program is subject to E.O. 12372 but has not been selected by the State for review. c. Program is not covered by E.O. 12372. Yes No Add Attachment Delete Attachment View Attachment ** I AGREE Mr.David/David Coulter/Woodward County Executive/Chair Board of Commissioners 248 858-0484/248 858-0100 * 20. Is the Applicant Delinquent On Any Federal Debt? (If "Yes," provide explanation in attachment.) * 19. Is Application Subject to Review By State Under Executive Order 12372 Process? If "Yes", provide explanation and attach coulterd@oakgov.com/woodwardd@oakgov.com MI-009, MI-011, MI-014 1 HOME-ARP Allocation Plan Template with Guidance Instructions: All guidance in this template, including questions and tables, reflect requirements for the HOME-ARP allocation plan, as described in Notice CPD-21-10: Requirements of the Use of Funds in the HOME-American Rescue Plan Program, unless noted as optional. As the requirements highlighted in this template are not exhaustive, please refer to the Notice for a full description of the allocation plan requirements as well as instructions for submitting the plan, the SF-424, SF-424B, SF-424D, and the certifications. References to “the ARP” mean the HOME-ARP statute at section 3205 of the American Rescue Plan Act of 2021 (P.L. 117-2). Consultation In accordance with Section V.A of the Notice (page 13), before developing its HOME-ARP allocation plan, at a minimum, a PJ must consult with: CoC(s) 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. State PJs are not required to consult with every PHA or CoC within the state’s boundaries; however, local PJs must consult with all PHAs (including statewide or regional PHAs) and CoCs serving the jurisdiction. Template: Describe the consultation process including methods used and dates of consultation: Neighborhood & Housing Development Manager, Shane Bies, hosted and attended meetings that consisted of a variety of groups representing the stated QPs and adjacent. Information regarding HOME-ARP allowable activities, spending timeframe and restrictions, and options for how to give feedback were presented. HOME Consortium – July 8, 2021 CAC – October 26, 2021 CAC – February 2, 2022 CAC – June 23, 2022 CAC – November 10, 2022 2 Shelter Providers – August 4, 2022 Alliance for Housing and Potential Use of CE for NCS – August 30, 2022 Homeless Healthcare Collaboration – August 12, 2022 Meeting with Various Groups – September 21, 2022 Meeting with Public Housing Agencies and others – September 22, 2022 List the organizations consulted: Agency/Org Consulted Type of Agency/Org Method of Consultation Feedback HOME Consortium Citizens of their municipality Meeting 7/8/2022 Other partner program jurisdictions (CDBG grantees that partner within a HOME Consortium) Citizens’ Advisory Council Advises on CDBG related funding which is viewed across all QPs Meeting 10/26/2021, 2/2/2022, 6/23/2022, 11/10/2022 Community based group comprised of commissioners, CVTs, community orgs, citizens. Includes Alliance, homeless shelter providers, CHDO, FQC among others Lighthouse of MI Homeless, At Risk of Homelessness, Other Populations, Food assistance, transitional housing Shelter providers consultation meeting 8/4/2022 Alliance for Housing of Oakland County Continuum of Care, across all QPs Shelter providers consultation meeting 8/4/2022; One on one consultation as CoC 8/31/2022 Leads the CoC South Oakland Citizens for the Homeless/Welcome Inn Homeless, Transitional housing Shelter providers consultation meeting 8/4/2022 HOPE Hospitality Homeless, At Risk of Homelessness, Other Populations Shelter providers consultation meeting 8/4/2022 HAVEN, Inc Domestic violence and human trafficking Shelter providers consultation meeting 8/4/2022 Homeless Healthcare Collaborative Homeless, At Risk of Homelessness, Transitional Housing, Other populations Meeting 8/12/2022 Reps from healthcare, shelters, service provider agencies, gov representatives, health division, and representatives of the lead agencies Community Housing Network Homeless, At Risk of Homelessness, Other Populations, Community Organization consultation 3 transitional housing, disability housing meeting 9/21/2022 Samaritas At risk of homelessness, other populations Community Organization consultation meeting 9/21/2022 Refugee resettlement agency that works within rental/affordable housing including housing choice voucher holders, also develops housing for refugees and seniors Pontiac Housing Commission At risk of homelessness, other populations Public Housing Assistance Consultation meeting 9/22/2022 Ferndale Housing Commission At risk of homelessness, other populations Public Housing Assistance Consultation meeting 9/22/2022 Invited but did not attend The ARC of Oakland County Disability population across all QPs Southfield Public Housing Authority At risk of homelessness, other populations Royal Oak Township Public Housing Authority At risk of homelessness, other populations Oakland Livingston Human Service Agency (OLHSA) Human services across all QPs Disability Network of Eastern Michigan (DNEM) Disability population across all QPs Summarize feedback received and results of upfront consultation with these entities: Leah McCall, Executive Director, Alliance for Housing I support the plan to increase non-congregate shelter space but the additional points for this funding is as important. If possible, we want to prevent homelessness with prevention assistance, if homeless have open shelter space, then quickly connect to affordable housing. Marc Craig – President Community Housing Network via email 10/11/2022 I would support the plan to use a portion of the funding for creating de-congregated shelter beds. I would urge the County to have smaller shelter locations scattered around the county, as opposed to building more beds in Pontiac. 4 While ideally, I would prefer to reduce our dependance on shelters because I believe that they are inherently traumatizing, creating viable alternatives is a long-term proposition which will require a substantial number of resources. Meanwhile, there is a dramatic shortage of shelter capacity, and much of the existing capacity is more congregated than it could be. If funds are available, I would also support the use of funds for tenant based rental assistance specifically targeted to people with disabilities. This population has been particularly hard hit by the pandemic, along with the dramatic increase in rental costs in the county. COMMENTS/QUESTIONS FROM ALL THE CONSULTATIONS: Q: In relation to non-congregate shelter, is there a component that is transitional housing as part of that? Supply as many shelters as you like but if you don’t offer transition for them, what is the purpose. Q: How narrowly defined is vulnerable populations? Q: Can you tell us a little bit about how the homeless veteran community can be supported? Q: Is there a timeframe that county really wants to see the funding spent, given that it is 9-year deadline. Q: Heard that MSHDA was contemplating making some $$ available for non-congregate shelter development and possibly for other allowable. Haven’t done yet and not anything on horizon that we know of yet. Has Shane heard anything about it yet? Public Participation In accordance with Section V.B of the Notice (page 13), PJs must provide for and encourage citizen participation in the development of the HOME-ARP allocation plan. Before submission of the plan, PJs must provide residents with reasonable notice and an opportunity to comment on the proposed HOME-ARP allocation plan of no less than 15 calendar days. The PJ must follow its adopted requirements for “reasonable notice and an opportunity to comment” for plan amendments in its current citizen participation plan. In addition, PJs must hold at least one public hearing during the development of the HOME-ARP allocation plan and prior to submission. PJs are required to make the following information available to the public: The amount of HOME-ARP the PJ will receive, and The range of activities the PJ may undertake. Throughout the HOME-ARP allocation plan public participation process, the PJ must follow its applicable fair housing and civil rights requirements and procedures for effective communication, accessibility, and reasonable accommodation for persons with disabilities and 5 providing meaningful access to participation by limited English proficient (LEP) residents that are in its current citizen participation plan as required by 24 CFR 91.105 and 91.115. Template: Describe the public participation process, including information about and the dates of the public comment period and public hearing(s) held during the development of the plan: Date(s) of public notice: 10/31/2022 Public comment period: start date - 10/31/2022 end date - 11/15/2022 Date(s) of public hearing: 11/10/2022 Describe the public participation process: Public hearing notice was posted on oakgov.com/nhd website, shared with partners, announced in the printed and web editions of the paper of record for Oakland County, meeting of the Citizens’ Advisory Council, public comment period ran concurrently, community partners were alerted. Describe efforts to broaden public participation: Public hearing notice was posted on oakgov.com/nhd website, shared with partners, announced in the printed and web editions of the paper of record for Oakland County, meeting of the Citizens’ Advisory Council, public comment period ran concurrently, community partners were alerted including immigrant advocacy groups, community foundations, human service organizations, shelter providers, emergency food providers, sheriff community engagement liaison, and others. The immigrant and community groups (outside of the shelter providers) have not traditionally been involved in the department efforts until 2020 under a new County Executive. Summarize the comments and recommendations received through the public participation process either in writing, or orally at a public hearing: No public comments have been received Summarize any comments or recommendations not accepted and state the reasons why: N/A Needs Assessment and Gaps Analysis In accordance with Section V.C.1 of the Notice (page 14), a PJ must evaluate the size and demographic composition of all four of the qualifying populations within its boundaries and assess the unmet needs of each of those populations. If the PJ does not evaluate the needs of one of the qualifying populations, then the PJ has not completed their Needs Assessment and Gaps Analysis. In addition, a PJ must identify any gaps within its current shelter and housing inventory as well as the service delivery system. A PJ should use current data, including point in time count, housing inventory count, or other data available through CoCs, and consultations 6 with service providers to quantify the individuals and families in the qualifying populations and their need for additional housing, shelter, or services. 7 Template: OPTIONAL Homeless Needs Inventory and Gap Analysis Table Homeless Current Inventory Homeless Population Gap Analysis Family Adults Only Vets Family Adults Only # of Beds # of Units # of Beds # of Units # of Beds Family HH (at least 1 child) Adult HH (w/o child) Vets Victims of DV # of Beds # of Units # of Beds # of Units Emergency Shelter 56 25 120 #4 Transitional Housing 67 23 25 #0 Permanent Supportive Housing 300 84 343 #51 Other Permanent Housing 207 47 29 #0 Sheltered Homeless 161 123 6 25 Unsheltered Homeless 0 32 3 1 Current Gap -38 5 -10 # Suggested Data Sources: 1. Point in Time Count (PIT); 2. Continuum of Care Housing Inventory Count (HIC); 3. Consultation 8 Describe the size and demographic composition of qualifying populations within the PJ’s boundaries: Homeless as defined in 24 CFR 91.5 The most recent Point In Time count conducted by Alliance of Housing and the Continuum of Care shows over 1,200. These are persons experiencing literal homelessness, residing on the street, in a shelter, in a safe haven, transitional housing or a place not meant for habitation. This can often be an undercount given the survey difficulties of the Point in Time count (e.g. enough volunteers to conduct the count, weather impact, etc.). Persons experiencing homelessness are disproportionately Black or African American at 61%, compared to 14% for the county overall. Persons with disabilities are impacted at higher rates by homelessness than the non-disabled population. Only 14% of all persons experiencing homelessness have a disability, compared to 12% in the County. However, the data warehouse only counts disabilities if they are identified by Emergency Shelter, Transitional Housing or Street Outreach projects which is believed to severely undercount the number of persons with disabilities experiencing homelessness or at risk of homelessness. At Risk of Homelessness as defined in 24 CFR 91.5 McKinney Vento for students defines homelessness slightly different from HUD’s standard definition. The McKinney Vento defines a homeless student as one who lacks a fixed, regular and adequate nighttime residence, so this includes both Category 1 (literally homeless) and Category 2 (those doubled-up). It is reported that approximately 70-72% of homeless students are Category 2 (doubled-up). Oakland Schools reports that annually in OC, an estimated 6,000 students are homeless based on economic insecurity/economic disadvantage. Also, in the 3 years leading up to COVID, between 2,200-2,600 students annually were identified by public schools as homeless. The number of identified students decreased during the pandemic, likely due to challenges identifying students via remote learning platforms as well as a reduction in evictions due to the moratorium. During the last two years, 1,300 homeless students were identified with about 935 identified as being doubled up each year. The beginning of the 2022-2023 academic year has seen an increase in identified students likely due to the end of the eviction moratorium and the increases in rental costs experienced countywide. According to the most recent CHAS data available (2015-2019), there is an estimate 48,565 households in Oakland County that live at or below 30% of the HUD Area Median Family Income. All of these households also report at least one housing problem as defined by HUD. Given that the CHAS data also shows that 24% (121,920) of all Oakland County household are Cost Burdened (>30%), there are many households that are at risk of homelessness in Oakland County. Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking, as defined by HUD in the Notice 9 Oakland County has one Domestic Violence (DV) Shelter in our community which has 52 beds for singles and families in a mostly non-congregate setting. A recent HMIS report identified 36 persons answered Yes to “Are you currently fleeing domestic violence?” Upon doing the Danger Assessment (DA), case managers are reporting more persons eligible for Category 4. One of the CoC providers will be starting their DV-Rapid ReHousing (DV-RRH) project this year. This will expand an existing RRH project to include 30 year-round scattered site, RRH rental assistance beds specifically for DV. This will increase housing as assistance for DV survivors within the community, in addition to rental assistance, with stabilization services, financial coaching and overall adding more capacity for housing assistance in the community, which is greatly needed. Other populations requiring services or housing assistance to prevent homelessness and other populations at greatest risk of housing instability, as defined by HUD in the Notice On the Alliance for Housing prioritization registry, there are 205 literally homeless individuals who have been referred, some as early as 2021 to present, who are waiting for a housing opportunity. 15 of those remain on the shelter list, created during COVID for those with lower prioritization “scores,” who were assisted due to the influx of COVID money into the community. That shelter list can no longer be used as the money has dwindled and cannot be assisted with further rental assistance. The HARA reports receiving 30,901 calls and closed 28,457 since Oct 1, 2021. They received a 50% increase in calls since CERA portal closed June 30 compared to this time last year. There are numerous callers in the queue, awaiting a callback to be screened who could be eligible for housing services across all the HUD defined homeless categories. This information suggests that the need for assistance is still great. The HARA reports these needs from callers they have screened: 1) Increase in calls stating landlords are evicting since they are no longer receiving CERA funding. 2) Denied CERA and is being evicted 3) Shelters are full and need emergency hotel funding 4) Need affordable housing unit lists 5) Section 8 status 6) Service agency calls wanting to know the housing process 7) Homeless in car or place not meant for human habitation 8) Couch surfing 9) Looking for resources 10) Holiday food gift baskets and presents for kids 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): 10 There are a very limited number of permanent non-congregate shelter beds available in Oakland County. Most of these beds support persons fleeing domestic violence and smaller number of the beds support single adults discharged to “home” after hospitalization. Oakland County Board of Commissioners and the County Executive also recently appropriate $10 million SLRF-ARPA funds to support affordable housing unit development (rental or homeownership). An additional $1 million of annual HOME funding goes to support affordable rental unit development. While the need outstrips the resources, there does currently exist some Permanent Housing and Transitional Housing funding (supported in part by the Emergency Solutions Grant). Identify and describe gaps and the unmet housing and service needs of qualifying populations: Homeless as defined in 24 CFR 91.5 Oakland County has two existing overnight shelters. One of which, up until now, has served adult singles (20 beds) and families (10 beds). Going forward, that shelter will focus on serving families so this creates a new need for sheltering more single adults, with the loss of 20 beds. During COVID, with the influx of additional funding, (79) overflow beds were used for motel sheltering. With the loss of COVID dollars, those beds are no longer available. The second existing shelter serves single adults in one location with a congregate setting. It also has an additional location with beds in its recuperative shelter. Starting in December of 2022, with newly acquired funding, a new third seasonal overnight shelter (congregate setting as well) will open to shelter adults only who access the services of their day shelter program. This overnight shelter will initially provide 20 beds. And while these 20 beds would appear to make up for the 20 lost, our shelters are generally full, turning away singles and families most every night. Even if all current shelter space in Oakland County is taken into consideration (e.g. permanent space, temporary space, congregate, non-congregate, etc.), there is not nearly enough shelter space to cover the estimated 1,200 literal homelessness persons in Oakland County. When permanent non-congregate space is considered, there is practically no units available. There is currently some ESG funding to support shelter operations and HPRP/TH programs, but this funding is insufficient to support the need. At Risk of Homelessness as defined in 24 CFR 91.5 With the influx of COVID dollars, through the Covid Emergency Rental Assistance (CERA) program, Alliance for Housing and the Continuum of Care were able to help 15,000 persons with rental assistance payments including arrears who fall under Category 2. That program has unfortunately ended, and there are few resources to assist those who are doubled up or are couch-surfing. 11 While there is gap in available affordable rental housing Oakland County has recently created some programs to support renters. This includes a Housing Trust Fund supported by $2 million of annual General Funds, $10 million of one-time SLRF-ARPA funds and an additional annual $1 million of HOME funds to support the gap financing of affordable rental unit development. An additional $2 million of SLRF-ARPA funds have also been appropriated to provide legal representation to households facing an eviction or foreclosure and $315,000 for a landlord mitigation fund to encourage landlords to rent to persons with a Housing Choice Voucher. Additional support services, however, can always be beneficial for this population since the need is so great. Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault, Stalking, or Human Trafficking, as defined by HUD in the Notice There currently exists a 52 bed recently developed non-congregate shelter for persons fleeing domestic violence in Oakland County. Although there appears to be a reasonable amount of shelter space for persons fleeing domestic violence, additional service support to transition this population into housing is needed. Other populations requiring services or housing assistance to prevent homelessness and other populations at greatest risk of housing instability as defined by HUD in the Notice Enter narrative response here. 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: Enter narrative response here. Identify priority needs for qualifying populations: Enter narrative response here. 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: Enter narrative response here. HOME-ARP Activities Template: 12 Describe the method(s)that will be used for soliciting applications for funding and/or selecting developers, service providers, subrecipients and/or contractors: Oakland County will solicit Request For Proposals (RFPs) for non-congregate shelter development in accordance with Oakland County procurement policies and within HOME-ARP guidelines. RFPs will also be solicited for non-profit operating and capacity building support funds to all non-profits Describe whether the PJ will administer eligible activities directly: Oakland County Neighborhood & Housing Development Division does not intend to directly administer any services or eligible activities. Oakland County will solicit/select successful RFPs for funding and establish contracts with third parties to complete the eligible activities. 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: Oakland County will not be contracting with any third party to directly administer the overall HOME-ARP program. 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. 13 Template: Use of HOME-ARP Funding Funding Amount Percent of the Grant Statutory Limit Supportive Services $ 500,000 Acquisition and Development of Non- Congregate Shelters $ 8,396,043 Tenant Based Rental Assistance (TBRA) $ 0 Development of Affordable Rental Housing $ 0 Non-Profit Operating $ 250,000 2.4 %5% Non-Profit Capacity Building $ 250,000 2.4 %5% Administration and Planning $ 1,000,000 9.6 %15% Total HOME ARP Allocation $ # Describe how the PJ will distribute HOME-ARP funds in accordance with its priority needs identified in its needs assessment and gap analysis: Enter narrative response here. 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: Enter narrative response here. 14 Preferences A preference provides a priority for the selection of applicants who fall into a specific QP or category (e.g., elderly or persons with disabilities) within a QP (i.e., subpopulation) to receive assistance. A preference permits an eligible applicant that qualifies for a PJ-adopted preference to be selected for HOME-ARP assistance before another eligible applicant that does not qualify for a preference. A method of prioritization is the process by which a PJ determines how two or more eligible applicants qualifying for the same or different preferences are selected for HOME- ARP assistance. For example, in a project with a preference for chronically homeless, all eligible QP applicants are selected in chronological order for a HOME-ARP rental project except that eligible QP applicants that qualify for the preference of chronically homeless are selected for occupancy based on length of time they have been homeless before eligible QP applicants who do not qualify for the preference of chronically homeless. Please note that HUD has also described a method of prioritization in other HUD guidance. Section I.C.4 of Notice CPD-17-01 describes Prioritization in CoC CE as follows: “Prioritization. In the context of the coordinated entry process, HUD uses the term “Prioritization” to refer to the coordinated entry-specific process by which all persons in need of assistance who use coordinated entry are ranked in order of priority. The coordinated entry prioritization policies are established by the CoC with input from all community stakeholders and must ensure that ESG projects are able to serve clients in accordance with written standards that are established under 24 CFR 576.400(e). In addition, the coordinated entry process must, to the maximum extent feasible, ensure that people with more severe service needs and levels of vulnerability are prioritized for housing and homeless assistance before those with less severe service needs and lower levels of vulnerability. Regardless of how prioritization decisions are implemented, the prioritization process must follow the requirements in Section II.B.3. and Section I.D. of this Notice.” If a PJ is using a CE that has a method of prioritization described in CPD-17-01, then a PJ has preferences and a method of prioritizing those preferences. These must be described in the HOME-ARP allocation plan in order to comply with the requirements of Section IV.C.2 (page 10) of the HOME-ARP Notice. In accordance with Section V.C.4 of the Notice (page 15), the HOME-ARP allocation plan must identify whether the PJ intends to give a preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project. Preferences cannot violate any applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a). The PJ must comply with all applicable nondiscrimination and equal opportunity laws and requirements listed in 24 CFR 5.105(a) and any other applicable fair housing and civil rights laws and requirements when establishing preferences or methods of prioritization. 15 While PJs are not required to describe specific projects in its HOME-ARP allocation plan to which the preferences will apply, the PJ must describe the planned use of any preferences in its HOME-ARP allocation plan. This requirement also applies if the PJ intends to commit HOME- ARP funds to projects that will utilize preferences or limitations to comply with restrictive eligibility requirements of another project funding source. If a PJ fails to describe preferences or limitations in its plan, it cannot commit HOME-ARP funds to a project that will implement a preference or limitation until the PJ amends its HOME-ARP allocation plan. For HOME-ARP rental housing projects, Section VI.B.20.a.iii of the HOME-ARP Notice (page 36) states that owners may only limit eligibility or give a preference to a particular qualifying population or segment of the qualifying population if the limitation or preference is described in the PJ’s HOME-ARP allocation plan. Adding a preference or limitation not previously described in the plan requires a substantial amendment and a public comment period in accordance with Section V.C.6 of the Notice (page 16). Template: Identify whether the PJ intends to give preference to one or more qualifying populations or a subpopulation within one or more qualifying populations for any eligible activity or project: Enter narrative response here. 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: Enter narrative response here. Referral Methods PJs are not required to describe referral methods in the plan. However, if a PJ intends to use a coordinated entry (CE) process for referrals to a HOME-ARP project or activity, the PJ must ensure compliance with Section IV.C.2 of the Notice (page10). A PJ may use only the CE for direct referrals to HOME-ARP projects and activities (as opposed to CE and other referral agencies or a waitlist) if the CE expands to accept all HOME-ARP qualifying populations and implements the preferences and prioritization established by the PJ in its HOME-ARP allocation plan. A direct referral is where the CE provides the eligible applicant directly to the PJ, subrecipient, or owner to receive HOME-ARP TBRA, supportive services, admittance to a HOME-ARP rental unit, or occupancy of a NCS unit. In comparison, an indirect referral is where a CE (or other referral source) refers an eligible applicant for placement to a project or activity waitlist. Eligible applicants are then selected for a HOME-ARP project or activity from the waitlist. 16 The PJ must require a project or activity to use CE along with other referral methods (as provided in Section IV.C.2.ii) or to use only a project/activity waiting list (as provided in Section IV.C.2.iii) if: 1. the CE does not have a sufficient number of qualifying individuals and families to refer to the PJ for the project or activity; 2. the CE does not include all HOME-ARP qualifying populations; or, 3. the CE fails to provide access and implement uniform referral processes in situations where a project’s geographic area(s) is broader than the geographic area(s) covered by the CE If a PJ uses a CE that prioritizes one or more qualifying populations or segments of qualifying populations (e.g., prioritizing assistance or units for chronically homeless individuals first, then prioritizing homeless youth second, followed by any other individuals qualifying as homeless, etc.) then this constitutes the use of preferences and a method of prioritization. To implement a CE with these preferences and priorities, the PJ must include the preferences and method of prioritization that the CE will use in the preferences section of their HOME-ARP allocation plan. Use of a CE with embedded preferences or methods of prioritization that are not contained in the PJ’s HOME-ARP allocation does not comply with Section IV.C.2 of the Notice (page10). Template: Identify the referral methods that the PJ intends to use for its HOME-ARP projects and activities. PJ’s may use multiple referral methods in its HOME-ARP program. (Optional): Enter narrative response here. If the PJ intends to use the coordinated entry (CE) process established by the CoC, describe whether all qualifying populations eligible for a project or activity will be included in the CE process, or the method by which all qualifying populations eligible for the project or activity will be covered. (Optional): Enter narrative response here. 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): Enter narrative response here. 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): Enter narrative response here. Limitations in a HOME-ARP rental housing or NCS project Limiting eligibility for a HOME-ARP rental housing or NCS project is only permitted under certain circumstances. 17 PJs must follow all applicable fair housing, civil rights, and nondiscrimination requirements, including but not limited to those requirements listed in 24 CFR 5.105(a). This includes, but is not limited to, the Fair Housing Act, Title VI of the Civil Rights Act, section 504 of Rehabilitation Act, HUD’s Equal Access Rule, and the Americans with Disabilities Act, as applicable. A PJ may not exclude otherwise eligible qualifying populations from its overall HOME- ARP program. Within the qualifying populations, participation in a project or activity may be limited to persons with a specific disability only, if necessary, to provide effective housing, aid, benefit, or services that would be as effective as those provided to others in accordance with 24 CFR 8.4(b)(1)(iv). A PJ must describe why such a limitation for a project or activity is necessary in its HOME-ARP allocation plan (based on the needs and gap identified by the PJ in its plan) to meet some greater need and to provide a specific benefit that cannot be provided through the provision of a preference. For HOME-ARP rental housing, section VI.B.20.a.iii of the Notice (page 36) states that owners may only limit eligibility to a particular qualifying population or segment of the qualifying population if the limitation is described in the PJ’s HOME-ARP allocation plan. PJs may limit admission to HOME-ARP rental housing or NCS to households who need the specialized supportive services that are provided in such housing or NCS. However, no otherwise eligible individuals with disabilities or families including an individual with a disability who may benefit from the services provided may be excluded on the grounds that they do not have a particular disability. Template Describe whether the PJ intends to limit eligibility for a HOME-ARP rental housing or NCS project to a particular qualifying population or specific subpopulation of a qualifying population identified in section IV.A of the Notice: The PJ does not intend to limit eligibility. While NCS projects may focus more on serving some populations (e.g. single adults, families, etc.), all will be capable of accepting all qualifying populations initially assuming space is available. Thereafter the various shelters will work within the Continuum of Care to ensure transfer of shelter guests to the most appropriate shelter location. If a PJ intends to implement a limitation, explain why the use of a limitation is necessary to address the unmet need or gap in benefits and services received by individuals and families in the qualifying population or subpopulation of qualifying population, consistent with the PJ’s needs assessment and gap analysis: The PJ does not intend to implement a limitation. 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): 18 Not applicable