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22-2468
ORDINANCE NO. 22-2468 AN ORDINANCE OF THE CITY OF DENTON APPROVING A SUBSTANTIALAMENDMENT TO THE CITY’S 202 1 ANNUAL ACTION PLAN FOR HOUSING AND COMMUNITY DEVELOPMENT, INCLUDING A HOME INVESTMENT PARTNERSHIPS GRANT-AMERICAN RESCUE PLAN (“HOME-ARP”) ALLOCATION PLAN AND ANAPPLICATION AND BUDGET FOR THE HOME-ARP GRANT IN THE AMOUNT OF $1,763,622.00; AUTHORIZING THE CITY MANAGER TO SIGN AND SUBMIT SAIDAMENDMENT; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the American Rescue Plan Act of 202 1 (“ARPA”) required the United States Department of Housing and Urban Development (“HUD”) to allocate ARPA funds to eligible government organizations using an allocation method similar to that which provides the City with its annual HOME grant allocation; and WHEREAS, in September of 2021, the City received notice that HUD had allocated to the City $1,763,622.00 in HOME-American Rescue Plan (“HOME-ARP”) grant funds; and WHEREAS, to receive the HOME-ARP funds, the City must prepare a HOME- American Rescue Plan Allocation Plan (“Allocation Plan”) for distributing the funds, and HUD must approve the Allocation Plan; and WHEREAS, on December 13, 2022, City Council held a public hearing to discuss and receive public comments on the Allocation Plan; and WHEREAS, citizen participation requirements, including a 15-day comment period, have been met; and WHEREAS, City Council must approve the Allocation Plan before its submittal to HUD; NOW THEREFORE, THE COUNCIL OF THE CITY OF DENTON HEREBY ORDAINS: SECTION 1. The findings and recitations contained in the preamble of this Ordinance are incorporated herein by reference. SECTION 2. City Council hereby adopts the HOME-ARP Allocation Plan set forth in “Exhibit A,” which is attached hereto and incorporated herein, to utilize the HOME- ARP grant of $ 1,763,622.00, and amends the Fiscal Year 202 1 Annual Action Plan to incorporate the Allocation Plan SECTION 2. The City Manager or their designee is authorized to submit the Allocation Plan to HUD and to distribute funds and undertake any administrative actions necessary to implement the amended Action Plan. SECTION 3. This ordinance shall become effective immediately upon its passage and approval. IIa1[]L d S e C ::: :: I to n t A:p==it h i SIT n ifa=a d e b y ) t hL e L::\>SITe S:f JplS S e d and approved by the following vote b - IL] : Aye Nay Abstain Absent Mayor Gerard Hudspeth: Vicki Byrd, District 1 : Brian Beck. District 2: Jesse Davis. District 3 : VACANT. District 4: Brandon Chase McGee, At Large Place 5 : Chris Watts, At Large Place 6: 1/‘ \/ / r b/ 1/ PASSED AND APPROVED this the 1 Db day of al 2023 GERARD HttDSFEN ATTEST: ROSA RIOS, CITY SECRETARY B 111(r : 2& Z/ APPROVED AS TO LEGAL FORM: MACK REINWAND, CITY ATTORNEY .„ g'## Exhibit 1 - HOME-ARP Allocation Plan HOME–ARP ALLOCATION PLAN CITY OF DENTON, TEXAS Community Development 401 N. Elm St. Denton, TX 76201 City of Denton HOME-ARP Allocation Plan In September of 2021, the City of Denton received notice of a HOME Investment Partnerships – America Rescue Plan (HOME-ARP) allocation in the amount of $1,763,622. To address the need for homelessness assistance and supportive services, Congress appropriated $5 billion in ARP funds to be administered through HOME to perform four activities that must primarily benefit qualifying individuals and families who are homeless, at risk of homelessness, or in other vulnerable populations. These activities include: 1. development and support of affordable housing, 2. tenant-based rental assistance (TBRA), 3. provision of supportive services; and 4. acquisition and development of non-congregate shelter units. ARP requires that funds be used to primarily benefit individuals and families in the following specified qualifying populations. 1. 2. 3. 4 Experiencing Literal Homelessness; At Risk of Homelessness; Fleeing, or Attempting to Flee Domestic Violence; OR Other Populations where services would prevent homelessness or would serve those at risk of housing instability. To receive funding, the City must develop and submit to HUD a HOME-ARP Allocation Plan, which describes the distribution of HOME-ARP funds and identifies any preferences for eligible activities. The development of the HOME-ARP Allocation Plan must also be informed through stakeholder consultation and community engagement. The following is the HOME-ARP Allocation Plan. CONSULTATION SUMMARIZE THE CONSULTATION PROCESS: The City partners with public and private entities, which several were consulted with during the development of the HOME-ARP Allocation Plan. These consulted stakeholders, members of Denton’s Housing Crisis Response System, have relevant knowledge that can speak to the needs, service gaps, and potential activities that would most benefit qualified populations. Stakeholders consulted included those who work with families or individuals experiencing or at-risk of homelessness, fleeing domestic violence, and other vulnerable qualifying populations. In the development of the allocation plan, the City consulted with stakeholders and asked for their input concerning the HOME-ARP grant, eligible activities, and the proposed budget. Stakeholders articulated the gap in their services and/housing needs by providing written and verbal input. The City has synthesized feedback from participants and the following table will provide summaries of the feedback received. The City will continue to meet with stakeholders throughout the implementation of the HOME-ARP activities to assess the ongoing needs of stakeholders’ clients. LIST THE ORGANIZATIONS CONSULTED, AND SUMMARIZE THE FEEDBACK RECEIVED FROM THESE ENTITIES Page 2 of 22 City of Denton HOME.ARP Allocation Plan AGENCIES/ORGANIZATIONS I TYPE OF CONSULTED AGENCY/ORG Denton Housing Authority I Public Housing Agency (PHA) METHOD OF CONSULTATION FEEDBACK Virtual Meeting (October 20, 2021) Need for more rental units and increased supportive services for Housing Choice Voucher holders Denton Affordable Housing I Community HousingCorporation I Development Organization (CH DO) Virtual Meeting (October 20, 2021) Need for more rental units and increased supportive services for special/vulnerable populations housed in CHDO properties Denton County Friends of the Family Domestic Violence Service Provider Virtual meeting (October 21, 2021) Communicated upcoming project, the Family Justice Center, including Transitional Housing for people experiencing homelessness as a result of domestic violence or sexual assault. In-person meeting (September Texas Homeless Network Continuum of Care Lead Agency Virtual meeting (March 1 Provided feedback to consult the Denton 30, 2022) 1 County Homeless Coalition and referred to need for rental assistance for literal homeless population. Denton County Homeless Coalition Local Homeless Coalition; Veterans Organization (Denton County Veterans Service Office) In-person meeting (August 31, 2022) Members in attendance indicated a need for funding to house people experiencing literal homelessness and the rising costs of rent North Texas Fair Housing Center Civil Rights/Fair Housing Consultation Letter (Sent November 15, 2022) No feedback was received North Central Texas Aging & Disability Resource Center Address the Needs of 1 Consultation Letter Persons with 1 (Sent November 15,Disabilities 1 2022) No feedback was received. Denton County MHMR Center Local Mental Health Authority Consultation Letter (Sent November 15, 2022) No feedback was received. PUBLIC PARTICIPATION DESCRIBE THE PUBLIC PARTICIPATION PROCESS, INCLUDING INFORMATION ABOUT AND THE DATES OF THE PUBLIC COMMENT PERIOD AND PUBLIC HEARING(S) HELD DURING THE DEVELOPMENT OF THE PLAN • Public comment period: November 27, 2022 – December 14, 2022; • Public hearing: December 13, 2022. Page 3 of 22 City of Denton HOME-ARP Allocation Plan The Public Comment period for the HOME-ARP Allocation Plan began on Sunday, November 27, 2022, and concluded on Wednesday, December 14, 2022. A Public Notice was published in the local newspaper, the Denton Record Chronicle, on November 27, 2022 and included information regarding the proposed plan as well as the scheduled Public Hearing. An additional Spanish Public Notice was published in the local newspaper December 4, 2022. The Public Hearing took place on Tuesday, December 13 at 6:30 p.m., as a part of the regular Council. During the public hearing, City staff discussed the development of the HOME-ARP Allocation Plan, which incorporated community needs and eligible activities related to HOME-ARP, along with an opportunity for the public to provide comments on the proposed budget and activities. Public comments were submitted by mail, phone, fax or email to Community Development. Three comments were received via email during the comment period and no comments were received in-person at the public hearing. Copies of communication efforts with the public are included in the appendix. DESCRIBE ANY EFFORTS TO BROADEN PUBLIC PARTICIPATION In addition to the Public Notice published in the Denton Record Chronicle and in-person consultation with various community partners, consultation letters were sent via email to key community stakeholders on November 15 requesting comment on the allocation plan. Organizations consulted included social service organizations, homeless service providers, advisory boards, and other nonprofit organizations. A list of these organizations and the letter are included in this plan. A copy of the Public Notice and draft HOME-ARP Allocation Plan were also posted to the City of Denton Community Development Department website. Notice of requests for comment were also shared via the City’s social media accounts (in English and Spanish), Constant Contact email blast, in the City’s weekly Friday Report to City Council and forwarded via email to the aforementioned stakeholders. SUMMARIZE THE COMMENTS AND RECOMMENDATIONS RECEIVED THROUGH THE PUBLIC PARTICIPATION PROCESS: Comments received stated support for prioritizing resources for people experiencing literal homelessness, and primarily pertained to supportive services needs of the qualifying populations including transportation and substance use treatment. Copies of comments received are included in the appendix. A comment was submitted recommending substance use treatment be included in the supportive services activities funded by HOME-ARP program. Staff plan to include this as an eligible expenditure and will continue to communicate with service providers in the community as program guidelines are developed. Additionally, a comment was received requesting the City fund viable transit options for people experiencing homelessness. Staff plan to include transportation as an eligible expenditure under supportive services activities as it is allowable for households enrolled in HOME-ARP programming. SUMIIVIARIZE ANY COMMENTS OR RECOMMENDATIONS NOT ACCEPTED AND STATE THE REASONS WHY: One comment received referred to the prioritization of local public resources for capital improvement projects that would benefit people living unsheltered such as sidewalk improvements and increased bike lanes. The comment also included a suggestion to prioritize improving public transportation for this population. While the suggestions provided in this comment are not activities that can be implemented utilizing HOME-ARP funding, City staff will share with the relevant departments and community members and continue to collaborate beyond the scope of HOME-ARP programming. NEEDS ASSESSMENT AND GAPS ANALYSIS To assess the unmet needs of HOME-ARP qualifying populations, the City evaluated the size and demographic composition of those populations. In addition, the City also identified gaps within its current shelter and housing Page 4 of 22 City of Denton HOME-ARP Allocation Plan inventory, as well as the service delivery system. In the needs assessment and gaps analysis the City utilized current data including Comprehensive Housing Affordability Data (CHAS), 2022 Point in Time Count (PIT Count), 2022 Housing Inventory Count (HIC), or other data available data sources. The following information includes the basis for the Needs Assessment and gap analysis for HOME-ARP qualified populations. TABLE 1: HOMELESS NEEDS INVENTORY AND GAP ANALYSIS TABLE Current Inventory Homeless Population I Gap AnalysisDRI t Family i AdultsOnlyHH I HH I . . . I Victims I ’ I ’ (21 1 (21 t Vets i of DV RDf =f mf child) I child) } I I Beds 1 Units 1 Beds ! Units Type of Need Family I Adults Onlyno HmoBeds I Units 1 Beds ! Units Vets # of Beds 0EmergencyShelter Transitional Housing Permanent Supportive Housing Other Permanent Housing Sheltered Homeless Unsheltered Homeless 29 1 9 1 174 10 32 1 8 1 5 1 o I o 20 1 13 1 86 1 o 1 10 ololo1 o 63 2 198 1 30 185 1 10 48 15 see below narrative Current Gap Data Sources: Point-In-Time (PIT) Count; Continuum of Care (CaC) Housing Inventory Count (HIC) TABLE 2: HOUSING NEEDS INVENTORY AND GAP ANALYSIS TABLE (NON-HOMELESS) Current Inventory # of Units* Level of Need # of Households Gap Analysis # of Households Total Rental Units Rental Units Affordable to HH at 30% AMI (At Risk of Homelessness) Rental Units Affordable to HH at 50% AMI (Other Populations) 0%-30% AMI Renter HH w/ 1 or more severe housing problems (At-Risk of Homelessness) 30%-50% AMI Renter HH w/ 1 or more severe housing problems (Other Populations) Current Gaps Data Source: Comprehensive Housing Affordability Strategy (CHAS) *2011-2015 CHAS Data; +2015-2019 CHAS Data Page 5 of 22 City of Denton HOME-ARP Allocation Plan There is a gap of 4,760 rental units for At-Risk households (30% Area Median Income) in Denton. For renter households at 50% Area Median Income, there is a surplus of 360 units. In total, there is a gap of 5,035 units. DESCRIBE THE SIZE AND DEMOGRAPHIC COMPOSITION OF QUALIFYING POPULATIONS WITHIN THE Pj’S BOUNDARIES: The City of Denton’s Participating Jurisdiction (PJ) boundaries for HOME-ARP funding are the geographic boundaries of the City. Qualifying population data pertaining to the City’s PJ boundaries (available via the annual Point-In-Time (PIT Count) and the Homeless Management Information System (HMIS)) is only available at the county level. Denton serves as the county seat and houses the majority of services for people experiencing or at risk of homelessness in Denton County. Data shared in this section is as of September 30, 2022, and is reflective of populations within the City of Denton’s PJ boundaries. EXPERIENCING LITERAL HOMELESSNESS (INCLUDING FLEEING OR ATrEMPT ING TO FLEE DOMESTIC VIOLENCE) The following data is from the Homeless Management Information System (HMIS), as of September 30, 2022 •A total of 480 households are experiencing literal homelessness in Denton County. 201 of the 480 households (41.8%) are experiencing chronic homelessness. Four (4) known households are experiencing homelessness while attempting to fleedomestic violence. Thirty-four (34) households experiencing homelessness are families, and 463 households are individuals. Thirty-six (36) households have been experiencing homelessness ten years or longer, 105 households for four the nine years, and 152 households for one to three years. 62.7% (291) of households experiencing literal homelessness are living with a disability, and 35.6% (170) have a chronic illness. Race & Ethnicity: The below data indicate the percentage breakdown of households experiencing homelessness in Denton County by race and ethnicity. o Black/African American – 25.68% o Multi-Racial – 4.21% o Native Hawaiian or Other Pacific Islander – 0.21% o White – 67.58% o Hispanic/Latino – 10.67% o Asian – 0.63% o American Indian or Alaskan Native – 1.68% • • • The total number of households experiencing homelessness in Denton County increased by 21.2% from September 2020 (396 households) to September 2022 (480). Chronically homeless households increased by 43.6% during that time as well (140 households in September 2020; 201 households in 2022). INDIVIDUALS & FAMILIES AT RISK OF HOMELESSNESS Households with income less than or equal to 30% AMI with a cost burden greater than 50% are also at risk of homelessness. Based on the CHAS data, there are 4,885 households in this category of potential risk. The Denton Housing Authority (DHA) reports approximately 7,000 people on the Housing Choice Voucher (formerly Section 8) program waitlist as of May 2022 (Source: United Way of Denton County 2022 Community Needs Assessment). The local Justice of the Peace precinct that includes primarily City of Denton recorded approximately 663 evictions in 2021 (January through December). The same precinct recorded 1,508 evictions from January 2022 through September 2022, a 138% increase in just nine (9) months. Individuals incarcerated in Denton as well as those receiving behavioral health services, including substance abuse disorder services, may also be at risk of homelessness upon discharge. These numbers are not readily available as multiple service providers serve these persons and discharge status varies. Some may be discharged to a shelter Page 6 of 22 City of Denton HOME.ARP Allocation Plan and others may be housed assisted by homeless service providers and then either provided additional services or transitioned to transitional or permanent housing. There is no county hospital in Denton County and private hospital systems do not have this data readily available. Denton County MHM R, the Local Mental Health Authority, reports that as of November 2022 approximately 10.6% of the total clients receiving behavioral health services were experiencing homelessness. Also, approximately 16.2% of MHMR consumers enrolled in Substance Use Services (SUD) reported experiencing homelessness, but not every consumer who could participate in SUD services has agreed to enroll. An estimated 840 children are experiencing homelessness in Denton Independent School District (ISD) as of May 2022. Denton ISD spans multiple cities and city-level data is not available. This includes children and youth who are who are sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason, are living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations, are living in emergency or transitional shelters, are abandoned in hospitals, or are awaiting foster care placement. RESIDENTS LIVING IN HOUSING INSTABILITY OR iN UNSTABLE HOUSING SITUATIONS HOME-ARP qualifying populations also include other populations who have previously qualified as homeless, are currently housed with temporary or emergency assistance, and who need additional housing assistance or supportive services to avoid a return to homelessness. According to the Denton County Homeless Management Information System, thirty-three (33) households returned to homelessness in a twelve (12) month period (October 2021 to September 2022) after being housed through a local housing program. In addition, HUD defines those at greatest risk of housing instability as households that have an annual income less than 30% AMI and are experiencing severe cost burden or have an income less than 50% AMI and meet a certain condition, like living in someone else’s home or living in a hotel due to an economic hardship. 56% of Denton renters have housing problems, and 33% have severe housing problems. In CHAS data, HUD defines housing problems as a household that has one or more of the following: lacking a kitchen or plumbing, having more than one person per room, or being housing cost burdened at 30% of more. Of these problems, housing costs negatively impact most renters whose household income is at or below 50% AMI. DESCRIBE THE UNMET HOUSING AND SERVICE NEEDS OF QUALIFYING POPULATIONS, INCLUDING BUT NOT LIMITED TO: SHELTERED AND UNSHELTERED HOMELESS POPULATIONS; THOSE CURRENTLY HOUSED POPULATIONS AT RISK OF HOMELESSNESS; OTHER FAMILIES REQUIRING SERVICES OR HOUSING ASSISTANCE OR TO PREVENT HOMELESSNESS; AND, THOSE AT GREATEST RISK OF HOUSING NSTABELITY OR IN UNSTABLE HOUSING SITUATIONS: SHE LTERED/UNSHELTERED'. The 2022 Point-In-Time Count identified 187 people living unsheltered and 261 staying in shelter in Denton County. According to HMIS data 480 households are currently experiencing literal homelessness. The following breakdown describes the system’s total housing need to stably house all 480 households currently experiencing homelessness in Denton County. Funding for wrap-around (supportive) services is needed for all households experiencing literal homelessness. • 19 households need Diversion, a housing intervention used to assist households seeking housing outside of emergency shelter by helping them identify immediate alternative housing arrangements, and if necessary, connecting them with services and/or financial assistance to return to permanent housing.) 206 households need Rapid Re-housing, a housing intervention that provides medium to long-term housing to bridge households from homelessness to permanent housing. 255 households need Permanent Supportive Housing, a Housing Intervention that provides long-term assistance along with intensive wrap around services (i.e. transportation, education, and employment) to chronically homeless households that could not support themselves otherwise. • • Page 7 of 22 City of Denton HOME-ARP Allocation Plan The county’s local service provider for domestic violence and sexual assault survivors was recently notified they will be receiving Emergency Solutions Grant Rapid Rehousing funding specifically to serve their clientele. This is the only guaranteed rental assistance funding for people experiencing literal homelessness in Denton AT-RISK OF HOMELESSNESS & HOMELESSNESS PREVENTION'. Approximately 2,171 households have been evicted in Denton since January 2021. Local eviction data in neighboring counties indicate that as low as 2% of eviction filings result in homelessness in North Texas (Source: City of Fort Worth HOME-ARP Allocation Plan). Currently there is approximately $8M of eviction prevention funding available in Denton County. More than 30% of Denton ISD’s population is considered at-risk (Source: United Way of Denton County 2022 Community Needs Assessment). Over 45% of Denton households earn below the ALICE (Asset Limited, Income Constrained, Employed) threshold, meaning they earn more than the Federal Poverty Level but earn less than the basic cost of living (Source: United Way of Denton County 2022 Community Needs Assessment). In Denton, Poverty and ALICE households combined make up 31% of the population. UNSTABLE HOUSING CONDITIONS'. Residents who have been previously homeless or are currently receiving some type of rental assistance may need the assistance to continue for a short or long period of time. Funding for housing assistance programs and supportive services is important to the housing stability of these individuals and families. There is also a need to assist residents living in unstable housing situations increase their income, build savings, and acquire assets through additional supportive services in the community. While safe, habitable and affordable housing units continue to be a need in Denton, the most emergent need in our community is rental assistance funding prioritized for the growing population of people experiencing literal homelessness. In addition to the immediate need of housing assistance for those currently experiencing homelessness, there are also supportive service needs to be met for this population. This includes case management support, transportation, employment training, child care, food, and physical and mental health services 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: There is a total of 203 shelter beds available in Denton County, all located in the City of Denton. On average, these shelters have an estimated vacancy rate of 7%. The City of Denton is projected to complete the construction of a 24/7 shelter for people experiencing or at-risk of homelessness within City limits, which will increase shelter beds by 36 for a total of 271 of shelter beds in the City/County of Denton. This will leave a gap of at least 209 shelter beds for people experiencing homelessness in Denton County. The new shelter will provide three meals a day at no cost and host supportive services on-site. 124 of shelter beds will be reserved for emergency stays, and thirty-two (32) beds will be designated for extended-stay with a right-of return and storage of belongings for individuals enrolled in a transitional program. The City of Denton has also allocated American Rescue Plan (ARP) State and Local Fiscal Recovery Funding (SLFRF) to provide forty (40) rooms of non-congregate shelter for special populations (including individuals with chronic health conditions and families) through December 2024 Currently, there is no guaranteed rental assistance or supportive services funding in Denton to support people living unsheltered or in emergency shelters moving into permanent housing. The Denton Housing Authority currently administers 1,922 Housing Choice Vouchers and has a waitlist of over 7,000. Available units for people exiting homelessness are limited, and many households are unable to afford units without short to medium term subsidies and supportive services as they work towards maintaining stability in their housing. Denton County Commissioners Court is currently of administering $8M of emergency rental assistance to households at-risk of eviction Page 8 of 22 City of Denton HOME-ARP Allocation Plan There are two Permanent Supportive Housing programs serving Denton County with a total of sixty-six (66) beds, both of which are consistently at capacity and rarely have vacancies. Affordable rental housing is limited. The City of Denton recently completed an Affordable Housing Assessment and developed a Strategic Toolkit for increasing Denton’s stock of affordable housing in the coming years, including lowering barriers for developers and relaxing zoning requirements. IDENTIFY ANY GAPS WITHIN THE CURRENT SHELTER AND HOUSING INVENTORY AS WELL AS THE SERVICE DELIVERY SYSTEM: SHELTER & HOUSING INVENTORY As stated in the previous section, by the end of 2022 there will be a gap of approximately 209 shelter beds for people experiencing homelessness in all of Denton County by the end of 2022. According to American Community Survey, Denton has a rental unit vacancy rate of approximately 7.9%. As previously stated, approximately 480 households are experiencing homelessness in Denton County as of September 2022, a 21% increase from the same time in 2020. 206 households experiencing homelessness in Denton County need medium to long-term housing assistance to sustain permanent housing – a 24% increase in this type of housing need from 2020. Additionally, the need for long-term housing assistance with intensive wrap- around services increase by 17% from 2020 (218 households) to 2022 (255 households). According to the United Way of Denton County’s 2022 Community Needs Assessment, the cost of living has outpaced the minimum wage in every state. As this continues to be the case, the number of households at-risk of and experiencing homelessness in Denton will increase as they have in previous years. SERVICE DELIVERY SYSTEM Since 2016, the City has collaborated with over twenty (20) organizations through the Denton County Homelessness Leadership Team (linked) to create a coordinated Housing Crisis Response System in Denton County. This initiative transformed and changed homelessness service agencies from working independently to a networked crisis response system across Denton County working together to prevent homelessness and rapidly return people who experience homelessness to stable housing. All homeless services agencies use a shared, centralized system, called the Homeless Management Information System (HMIS); any actions and referrals are tracked and can be seen by all agencies in Denton County in order to provide better service and outcomes. Every individual experiencing homelessness is assessed to identify their unique needs and be connected to the appropriate resources and housing intervention. This is referred to as the Coordinated Entry system assessment and can be done at any of the participating agencies. This creates a coordinated Housing Priority List (HPL), an actively managed and prioritized list of the names and unique needs of every household experiencing homelessness. A local team of approximately 15 case managers meets together every week to review and actively work through the HPL to determine who is new to the list (inflow), who has moved off the list (outflow), who may have changed in priority, and what housing units or funding is available or coming available in order to get individuals and families housed and stay housed. Because of the existing infrastructure of the Denton County Housing Crisis Response System that the community built collaboratively over four (4) years, emergency eviction prevention funding was quickly deployed, and thousands of families have remained housed throughout the instability of the COVID-19 pandemic. Denton County has the infrastructure and service delivery in place to help get and keep families housed. Additionally, the county currently has approximately $8M of eviction prevention funding available to keep families in their homes. The biggest resource deficit in our community after affordable housing is funding for rental assistance to house the Page 9 of 22 City of Denton HOME-ARP Allocation Plan increasing literal homeless population, and for supportive services to best support those households in maintaining permanent housing. IDENTIFY THE CHARACTERISTICS OF HOUSING ASSOCIATED WITH INSTABILITY AND AN INCREASED RISK OF HOMELESSNESS IF THE PJ WILL INCLUDE SUCH CONDITIONS IN ITS DEFINITION OF “OTHER POPULATIONS" AS ESTABLISHED IN THE HOME-ARP NOTICE: The City of Denton is not suggesting expanding the program eligibility beyond the populations noted above and those at greatest risk of housing instability (under 30% AMI and severely cost burdened) as provided by HUD in CPD Notice 21-10. DENTIFY PRIORITY NEEDS FOR QUALIFYING POPULATIONS: City of Denton Community Services staff are in regular communication with nonprofit and social service organizations and conducted activities specific to this allocation plan to solicit feedback regarding priority needs for this population. The immediate priority need identified for qualifying populations is tenant based rental assistance and supportive services prioritized for people experiencing literal homelessness. EXPLAIN HOW THE LEVEL OF NEED AND GAPS IN ITS SHELTER AND HOUSING INVENTORY AND SERVICE DELIVERY SYSTEMS BASED ON THE DATA PRESENTED IN THE PLAN WERE DETERMINED: The gaps in services and programs needed to provide shelter, housing, and services were determined using data from multiple sources. The level of need for unsheltered and shelter households experiencing homelessness was determined by evaluating the number of unsheltered households and the level of resources available to adequately house the families or individuals with permanent supportive housing and critical long-term supportive services to achieve housing stability. HOME-ARP ACTIVITIES DESCRIBE THE METHOD FOR SOLICITING APPLICATIONS FOR FUNDING AND/OR SELECTING DEVELOPERS, SERVICE PROVIDERS, SUBRECIPIENTS AND/OR CONTRACTORS AND WHETHER THE PJ WILL ADMINISTER ELIGIBLE ACTIVITIES DIRECTLY: The City of Denton will not administer HOME-ARP activities directly. Pending HUD approval of its HOME-ARP plan, the City will issue a Notice of Funding Opportunity (NOFO) for interested TBRA and Supportive Services providers. Subrecipient applications will be reviewed by the City’s Community Services Advisory Committee (CSAC), and the committee will make recommendations for funding to City Council. City Council will consider subrecipient contracts for approval. IF ANY PORTION OF THE PJ’S HOME-ARP ADMINISTRATIVE FUNDS WERE PROVIDED TO A SUBRECIPIENT OR CONTRACTOR PRIOR TO HUD’S ACCEPTANCE OF THE HOME-ARP ALLOCATION PLAN BECAUSE THE SUBRECIPIENT OR CONTRACTOR IS RESPONSIBLE FOR THE ADMINISTRATION OF THE PJ’S ENTIRE HOME- ARP GRANT, IDENTIFY THE SUBRECIPIENT OR CONTRACTOR AND DESCRIBE ITS ROLE AND RESPONSIBILITIES IN ADMINISTERING ALL OF THE PJ’S HOME-ARP PROGRAM: Not Applicable. Pis must indicate the amount of HOME-ARP funding that is planned for each eligible HOMEARP activity type and demonstrate that any planned funding for nonprofit organization operating assistance, nonprofit capacity building, and administrative costs is within HOME-ARP limits. The following table may be used to meet this requirement. USE OF HOME-ARP FUNDING Page 10 of 22 City of Denton HOME-ARP Allocation Plan Funding Amount $ 589,312.98 Percent of the Grant Statutory Limit Supportive Services Acquisition & Development of Non-Congregate Shelters Tenant Based Rental Assistance (TBRA) Development of Affordable Rental Housing Non-Profit Operating Non-Profit Capacity Building Administration and Planning Total HOME ARP Allocation ADDITIONAL NARRATIVE, IF APPLiCABLE: The City of Denton intends to allocate $374,769.68 of HOME-ARP funding for Supportive Services, $1,124,309.02 for Tenant Based Rental Assistance (TBRA), and $264,543.30 for administrative and planning uses as described in CPD Notice 21-10 for all qualifying populations, with a preference for populations experiencing homelessness. 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 homeless population in Denton County increased by 21% in two (2) years. There is currently no funding available to support the 480 households experiencing literal homelessness to obtain permanent housing, except for Emergency Solutions Grant Rapid Rehousing funding for survivors of domestic violence and sexual assault. While there is a lack of shelter beds, funding is needed to support successful exits from shelter and encampments to ensure the Housing Crisis Response System continues to achieve its goal of making homelessness rare, brief and rlonrecurrlrlg. HOME-ARP PRODUCTION HOUSING GOALS ESTIMATE THE NUMBER OF AFFORDABLE RENTAL HOUSING UNITS FOR QUALIFYING POPULATIONS THAT THE Pj WILL PRODUCE OR SUPPORT WITH ITS HOME-ARP ALLOCATION Not Applicable DESCRIBE THE SPECIFIC AFFORDABLE RENTAL HOUSING PRODUCTION GOAL THAT THE PJ HOPES TO ACHIEVE AND DESCRIBE HOW IT WILL ADDRESS THE PJ’S PRIORITY NEEDS: Not Applicable. PREFERENCES 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: Page 11 of 22 City of Denton HOME-ARP Allocation Plan • 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). • Pis are not required to describe specific projects to which the preferences will apply. The City of Denton will utilize all HOME-ARP funding to assist qualifying populations with a preference for individuals and households experiencing literal homelessness. 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 CATEGORY OF QUALIFYING POPULATION, CONSISTENT WITH THE PJ’S NEEDS ASSESSMENT AND GAP ANALYSIS: Based on the needs and gaps analysis, the City of Denton utilize all HOME-ARP funding to assist qualifying populations with a preference for households experiencing homelessness. In addition to housing instability, homeless individuals are more susceptible to acute health concerns, physical, sexual, and psychological trauma, and behavioral health disorders, making them some of the most vulnerable populations and in need of specialized and intense services. Rental assistance and supportive services will support these households in obtaining and maintaining permanent housing. IF A PREFERENCE WAS IDENTIFIED, DESCRIBE HOW THE PJ WILL USE HOME-ARP FUNDS TO ADDRESS THE UNMET NEEDS OR GAPS IN BENEFITS AND SERVICES OF THE OTHER QUALIFYING POPULATIONS THAT ARE NOT INCLUDED IN THE PREFERENCE As previously stated, there is currently funding in the community to support people at-risk of homelessness to remain housed and funding to assist survivors of domestic violence and sexual assault to obtain permanent housing. TBRA and supportive services funding will be made available to all qualifying populations, but the populations that are not prioritized will have multiple opportunities for funding available to them. The City will ensure any subrecipients receive referrals for all qualifying populations. 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 HOMEARP REFINANCING GUIDELINES IN ACCORDANCE WITH 24 CFR 92.206(B).THE GUIDELINES MUST DESCRIBE THE CONDITIONS UNDER WITH THE PJ WILL REFINANCE EXISTING DEBT FOR A HOME-ARP RENTAL PROJECT, INCLUDING ESTABLISH A MINIMUM LEVEL OF REHABILITATION PER UNIT OR A REQUIRED RATIO BETWEEN REHABILITATION AND REFINANCING TO DEMONSTRATE THAT REHABILITATION OF HOME-ARP RENTAL HOUSING IS THE PRIMARY ELIGIBLE ACTIVITY Not Applicable. REQUIRE A REVIEW OF MANAGEMENT PRACTICES TO DEMONSTRATE THAT DISINVESTMENT IN THE PROPERTY HAS NOT OCCURRED; THAT THE LONG-TERM NEEDS OF THE PROJECT CAN BE MET; AND THAT THE FEASIBILITY OF SERVING QUALIFIED POPULATIONS FOR THE MINIMUM COMPLIANCE PERIOD CAN BE DEMONSTRATED. Not Applicable. Page 12 of 22 City of Denton HOME-ARP Allocation Plan STATE WHETHER THE NEW INVESTMENT IS BEING MADE TO MAINTAIN CURRENT AFFORDABLE UNITS, CREATE ADDITIONAL AFFORDABLE UNITS, OR BOTH. Not Applicable. SPECIFY THE REQUIRED COMPLIANCE PERIOD, WHETHER IT IS THE MINIMUM 15 YEARS OR LONGER Not Applicable. STATE THAT HOME-ARP FUNDS CANNOT BE USED TO REFINANCE MULTIFAMILY LOANS MADE OR NSURED BY ANY FEDERAL PROGRAM, INCLUDING CDBG Not Applicable. OTHER REQUIREMENTS IN THE PJ’S GUIDELINES, IF APPLICABLE: Not Applicable. Page 13 of 22 City of Denton HOME-ARP Allocation Plan APPENDIX PUBLIC PARTICIPATION ACTIVITY SOCIAL MEDIA PROMOTION -$<>Ab-WE NEED lb V4bq hOUR INPUT The City of Denton's Community Services division is proposing changesto the 2021 Action Plan for housing and community development and we need your input. The City is accepting comments regarding theallocation of $1,763.622 in HOME Investment Partnership American Rescue Plan (HOME-ARP) funds received from the U.S. Department ofHousing and Urban Development (HUD) To view the proposed changes and provide comment, visit www.cityofdenton.com/communitydevelopment. -3:4;4 'kWE NEED 4bLb,}/I YOUR INPUT The City of Denton's Community Services division is proposing changes to the 2021Action Plan for housing and community development and we need your input.The City is accepting comments regarding the allocation of 51.763.622 in HOMEInvestment Partnership American Rescue Plan (HOME-ARP) funds received from the U.S. Department of Housing and Urban Development (HUD) To view the proposed changes and provide comment. visitwww.cityofdenton.com/communitydevelopment. Comments will be accepted from November 27 through December 14 City of Denton I ADA/EOA/ADEA I TDa (800) 73$2989 1 Twitter Graphic – English Page 14 of 22 City of Denton HOME-ARP Allocation Plan NECESITAMOS TU OPINl6N La divisi6n de Servicios Comunitarios de la Ciudad de Denton est6 proponiendo cambios aI Plan de Acci6n 2021 para vivienda y desarrollocomunitario y necesitamos su opini6n. La Ciudad esti aceptando comentarios sobre Ia asignaci6n de $1,763,622 en fondos deI Plan de Rescate Americano de HOME Investment Partnership (HOME-ARP) recibidos del Departamento de Vivienda y Desarrollo Urbano de losEstados Unidos Para ver los cambios propuestos y proporcionar comentarios. visite www.cityofdenton.com/community desarrollo Se aceptar6n comentarios hasta eI 14 de diciembre 7)larnliVrM4 V City of Denton } ADA/EOA/ADEA I TOO (800) 73$2989 1 www.ciryofdenton.com 1 12/22 Facebook Graphic – Spanish NECESITAMOSTU OPINl6N La divisi6n de Servicios Comunitarios de la Ciudad de Denton esti proponiendo cambiosal Plan de Acci6n 2021 para vivienda y desarrollo comunitario y necesitamos su opini6nLa Ciudad esti aceptando comentarios sobre la asignaci6n de $1.763,622 en fondos del Plan de Rescate Americana de HOME Investment Partnership (HOME-ARP) recibidos delDepartamento de Vivienda y Desarrollo Urbano de los Estados Unidos Para ver los cambios propuestos y proporcionar cornentarlos. vtsltewww.cityofdenton.com/community desarrollo Se aceptarin comentarios hasta eI 14 de diciembre City of Denton i ADA/EOA/ADEA ! TDD {800) 735-2989 1 www.cityofd Twitter Graphic – Spanish Page 15 of 22 City of Denton HOME-ARP Allocation Plan EMAIL PROMOTION Douangdan, Courtney From: SerIeTa SubJece aty of Denton Cnmmunity Services <communitydewlopment@€itwfdenDn.com> Sunday, Fhvember 27, 2022 IC}01 AM Douangdara, (nu rtney 15-Day Cnmment Period Beginning Nov. 27 ThIs rresnee has orblnaud from an Extern•l Scxrrn. Please En cautlals reBardlnB links and aRachrrnnB. BIJweni Community Services Home DIving Asgshnce ' Home Repair - Social Services ' Public Improvements ' Fair Housing I Page 16 of 22 CitY of Denton HOME-ARP Allocation Plan Now Accepting Feedback on the City of Denton's HOME-ARP Allocation Plan The City of Denton is accepting com ments on a draft HOME-ARP Allocation Plan. The plan details how the City intends to distribute the $1,763,622 in HOME Investment Partnership American Rescue Plan (HOME-ARP) funds received fromthe U.S. Department of Housing and Urban Development (HUD). The plan proposes to allocate funds to eligible entities through a Notice of Funding Opportunity (NOFO) application process to provide Tenant-Based Rental Assistance (TBRA) and Supportive Services. A public hearing will be held on Dec. 13, 2022, at 6:30 p.m. during a City Council meeting in Council Chambers at City Hall, 215 E McKinney Street Council Cham bers, Denton, TX 76201. The HOME-ARP Allocation Plan will be submitted as a substantial amendment to the 2021/22 Action Plan for Housing and Community Development. All comments received by December 14, will be considered by the City beforesubmission of the HOME-ARP Allocation Plan to HUD. VIEW THE HOME-ARP ALLOCATION PLAN W e Need Your Inout bv December 14 During a 15-day comment period from November 27 to December 14, the City of Denton will be accepting comments regarding this amendment. Help ensureour community needs are being addressed by providing input. Citizens and organizations can comment on this Substantial Amendment the following ways: • Email CommunityDevelopment@cityofdenton.com; • Phone (940) 349-7726; or • Fax (%O) 349-7753 Read more about current Community Development activities, and share information about how the Gty of Denton is making an impact in the community 2 Page 17 of 22 City of Denton HOME-ARP Allocation Plan ADA/EOE/ADEA - TDD (800) 735-2989 CItY of CHnton 1 215 E, McKinney St., Denton, TX 76201 Un$ub$qFlbegQyftnqylgfQ$$@£jtyQfdentQnlgqm VNete PrQflle I ';an stent Gq„ted Pru Nqtjge Sent by communitydevelopment@cityofdenton.com powered by CkxtstnntContactTry emdl m8rkebng fu free trxi8yl Page 18 of 22 City of Denton HOME-ARP Allocation Plan NEWSPAPER PROMOTION DRC &UEDIA COMPANY RE,CE,IVED NEWS & ADWrrWHG 80wrwB6au WaWU,•nB•& OtC 67 am 3556 DudHH DrfuBP.O. &n 389anton. TX 78Z02 941}387 381 1 h49c8tiool8l: Dateln R©erv&{:vwu+ BrIng duty gwen IOIn b IIu P\A#rrlw/arttwual ofDuBrnR8euWltMui•. n awol e w nDeIBa CarRy; H8woHOH d ned arn4aoon wMI he b•Blux8ndy eld r8euUy lol• BIlled of rUR be ItIerne WIn pM the dud tIe at=+a nalu. nd tha tInsad non wu n sad nuoo•r D+tUn R•en+C>vu$degdat„bdawulttn Wttrnae my hnd avI ofhdd nd: mNoiav MK DenIm CiB#Ity, Taxu O€NTON CIVy COUWNITy s£8vlaES401 NELH gTDENTON TX 78205 OTICE '@;:Mi{M;iARm WITiILg#H6B#H•r18&TdlWdHtyPH 70 :3:t ACT’as FUNFOR H3J£XG ;\\D <{JYHL RTf D£#LOPY£V CARPAL TUNNEL? i IT?! 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TX 7620290387-381 1 ad WIdely puU181bu! for a pebd of not be thaIon nu eu dae ol ttuatMnfnotln. nd tha tInsad nodn WIn in ud Deuan n•end.avg#sa D=!nRL8onnIIj:bmi:/::::n::KInalinI Calnty: al Q„'-ud arajgton MidI ha ha! q dan b•bwaH ;F#:+=Ej= 1::Tril:ruIntha Mh day of December. 2022 tyy a Wltnne my had nd of fIeld sed: name ol No©ry MH Denton Canty, DENTON CITY couMLHyrrY SERVICES401 N FI M STDENTON TX 78205 Ad IhHnbH: +9438 PIke: +49.80 Ad Guy:NECESITAAaos TU OPtNI •N La avI#'n d8 s&van Cat+twtxkr8 d8 l• atxlal da CXlntoa a8t' popaniuvloeatllS08 d PIn do Aod'n 202 t Dan viv+aid• y dc£sanolb n#hntwta vrrwitanab nr afwli'n. La at#InI o#t' •cnpt&xIa wrrnneb9 stAre la8slgnul'n da 81.783.822 nt twvl09 dd nn de Rese•to AmBZ&ba de HOME bw68tmul P•nrw3t+ (HOME'ARP) rocibklo• dol OVer#onto do Vbinxla yD6•&rollo Urbano do kn Estxlo• Unld08 Pwa vu kn canIH08 pn)lrurlsta• y www dqnkkmton.arrn4oormh#dtV d08andlo I, whIte Se UObrr•n aom8nUdos hwa d 14 de dIe$anbtB. Page 20 of 22 City of Denton HOME-ARP Allocation Plan PUBLIC COMMENTS RECEIVED Comment #1 – Received Monday, December 5, 2022 “Over the last few years, I’ve spent time working with the homeless and the employment component of their journey to a stable and sustainable life with the Goodwill North Central Texas Job Resource Center. Now, I’m a part of another component of that journey...reliable and affordable transportation. One of the most frustrating parts of helping those experiencing homelessness find meaningful employment was getting them to job interviews and work shifts. One of my current dreams is for there to be reliable and affordable demand-response transit that is consistently available for those transitioning from homelessness to a more stable and sustainable life. DCTA and GoZone are not making that happen. They’ve cut routes and raised prices. I’d like for the City of Denton to consider options for funding transit that would aid individuals experiencing homelessness in committing to work as part of a viable transition to a stable life." Comment #2 – Received Thursday, December 8, 2022 “I support the proposed draft plan to use funding to address the most unmet need of housing units and supportive services for the at-risk of homelessness populations Additionally, I would ask that the geographic distribution of both current and eligible 0-30% AMI groups be incorporated into phasing decisions of other projects from other funding sources to increase access of people with limited access to motor vehicles to potential jobs and necessary goods and services. This could include the phasing priority of small sidewalk projects, bike lane projects that connect to a wider network, transit supportive projects in conjunction with DCTA, or larger CIP projects which would include non-automobile access improvements to these populations. Optimizing more of our public investments to serve these at-risk populations first will help these populations progress more quickly out of needing wrap-around support, allowing us to use limited resources to serve more people in need.” Comment #3 - Received Thursday, December 8, 2022 “This is in response to the HOME-ARP Allocation Plan. As a Denton-based nonprofit that works closely with persons experiencing homelessness or at risk of homelessness, we would like to make a couple suggestions on the allocation, especially in reference to what Support Services might be funded. According to the city-wide needs assessment and the 2021 data compilation by the organization formerly known as Hope, Inc., Substance Use Disorder (SUD) plays a substantial part in the homelessness concern in our area. However, in this Allocation Plan that is solely dedicated toward long-term stability and housing for persons experiencing homelessness, SUD is not touched upon. We’re all working toward helping people change the course of their lives and we’re all dedicating ourselves completely to bolstering our communitY, which is such a beautiful purpose! So, we believe that bringing SUD services into the conversation will help every organization meet these goals and create a host of services that will almost guarantee long-term success for this population. Substance Use Disorder has been proven to be a root cause for homelessness, domestic violence, economic insecurity, and many more societal concerns in the United States. In our area, upward of 70% of homeless persons self-identify as having an issue with substances. It follows that if our community is to address homelessness in a holistic way, it would be a missed opportunity to not provide SUD services to this population through this funding allocation. We hope that the grant committee will consider including, in the Support Services category, funding for SUD treatment services Page 21 of 22 City of Denton HOME-ARP Allocation Plan Additionally, due to the massive impact SUD plays on this issue, we hope that local treatment providers might be included in discussions on how best to address homelessness in Denton County in the future and how to become a standard resource available to this population. Through working together, we can all reach a solution to this ever-increasing problem, rather than setting aside a major contributing factor that would instead prevent long-term success in this endeavor. We would be happy to discuss how that might be possible! We’d love to provide any insight that might be helpful or expand upon any information we have provided thus far. We appreciate that y’all called for input and hope you consider including SUD services in this funding opportunity! Have a wonderful day and a Merry Christmas!" 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