Proposed Resolution - 2/7/20231
RESOLUTION NO.________ OF 2023
A resolution adopting an amendment to the One-Year Action Plan for 2021-2022
to include the American Rescue Plan (ARP) Act of 2021 Housing and Urban Development
HOME Investment Partnerships Program funding.
WHEREAS, Salt Lake City Council approved Resolution No. 14 of 2021, an
appropriations resolution adopting the One-Year Annual Action Plan for 2021-2022, which
includes HOME Investment Partnerships Program funding received from the U.S. Department of
Housing and Urban Development; and
WHEREAS, Salt Lake City Corporation (City) is eligible under Code of Federal
Regulations (CFR) Title 24, Part 91, et. al., to receive ARP Act 2021 U.S. Department of
Housing and Urban Development (HUD) HOME Investment Partnerships Program (HOME-
ARP) funds in the amount of $3,533,195 from HUD for the program year 2021-2022; and
WHEREAS, it is in the best interests of the people of Salt Lake City that the City file an
application with HUD for said funds in accordance with 24 CFR Part 91; and
WHEREAS, in order to receive said funds, the City is required to substantially amend the
adopted 2021-2022 Annual Action Plan to include a HOME-ARP Allocation Plan; and
WHEREAS, the public notices and other pre-submission requirements as set forth in 24
CFR Part 91 have been accomplished by the City, including but not limited to the following: The
first public comment period was held on the substantial amendment and draft allocation plan
May 22 through June 8, 2022, and an Administration public hearing on June 1, 2022. A second
public comment period was held on February 7 through March 21, 2023, and a City Council
public hearing on February 21, 2023; and
WHEREAS, the City Council does now meet on this day of _______________, 2023
to adopt the Substantial Amendment to the 2021-2022 Annual Action Plan to include the
HOME-ARP Allocation Plan.
NOW, THEREFORE, be it resolved by the City Council of Salt Lake City, Utah, as
follows:
1. That the City hereby adopts the substantial amendment to the 2021-2022
Annual Action Plan to include the HOME-ARP Allocation Plan for HOME-
ARP funds as set forth in Exhibit “A” attached hereof by this reference.
2. That the Mayor, as the official representative of Salt Lake City, or her designee,
is hereby authorized to submit for the HOME-ARP funds with such additional
information and certifications as may be required under 24 CFR Part 91 to the
U.S Department of Housing and Urban Development.
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3. That the Mayor, as the official representative of the City, or her designee, is
hereby authorized to sign and execute a grant agreement with HUD (the “HUD
Grant Agreement”) regarding the aforementioned federal grant funds, and any
and all subsequent agreements between the City and other public entities
resulting from and consistent with the HUD Grant Agreement, subject to final
approval as to form by the City Attorney.
Passed by the City Council of Salt Lake City, Utah, this day of ______________, 2023.
SALT LAKE CITY COUNCIL
By _____________________________
CHAIR
Approved as to form: __________________________
Kimberly K. Chytraus
Salt Lake City Attorney’s Office
Date: ___________________________
ATTEST:
_________________________________
CITY RECORDER
February 7, 2023
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EXHIBIT “A”
Salt Lake City HOME-ARP Allocation Plan
See attached.
1
SALT LAKE CITY
HOME-ARP ALLOCATION PLAN
MAYOR
ERIN MENDENHALL
CITY COUNCIL
VICTORIA PETRO, VICE CHAIR
ALEJANDRO PUY
CHRIS WHARTON
ANA VALDEMOROS
DARIN MANO, CHAIR
DAN DUGAN
AMY FOWLER
Prepared by
S A L T L A K E C I T Y
HOUSING STABILITY DIVISION
DEPARTMENT of COMMUNITY and NEIGHBHORHOODS
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Table of Contents
Table of Contents ........................................................................................................................................ 2
Consultation................................................................................................................................................. 4
Public Participation .................................................................................................................................. 14
Needs Assessment and Gaps Analysis ..................................................................................................... 16
HOME-ARP Activities ............................................................................................................................. 25
HOME-ARP Production Housing Goals ................................................................................................ 27
Preferences................................................................................................................................................. 29
Referral Methods ...................................................................................................................................... 31
Limitations in a HOME-ARP rental housing or NCS project .............................................................. 32
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Salt Lake City 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).
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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.
Participating Jurisdiction: Salt Lake City Date: 3/16/2022
Describe the consultation process including methods used and dates of consultation:
This HOME-ARP allocation plan was prepared in consultation with agencies and service
providers whose clientele include the HOME-ARP qualifying populations (QPs). QPs include:
• Individuals or households that are currently homeless or are at-risk of experiencing
homelessness, or
• People who are fleeing or attempting to flee domestic violence, dating violence, sexual
assault, human trafficking, or
• Populations for whom supportive services would prevent the family’s homelessness or
having a high risk of housing instability, or
• Households with a veteran family member that meets one of the above criteria.
A wide variety of agencies serve the needs of QPs, including, but not limited to, entities that
focus on homeless services, veterans’ groups, individuals with disabilities, persons facing
violence and abuse, and those offering mental health services. On the front lines daily, these
entities have provided invaluable insights and data for inclusion in this allocation plan and
provide the foundation of our allocation plan analysis.
In order to receive as much input as possible from the QPs, a survey was provided to 79 entities
(listed below) to identify unmet needs and gaps in facilities and services, as well as to solicit
feedback from these agencies on identifying HOME-ARP eligible activities currently taking
place in their jurisdiction.
A cover letter explaining the purpose of the survey and the importance of each entity’s feedback,
signed by representatives from Salt Lake City and Salt Lake County, was also sent with the
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survey. The survey was conducted from January 24, 2022, through February 25, 2022, with
follow-up phone calls and e-mails sent to non-responsive entities after that time period. In some
cases, follow-up interviews took place in order to gather more data and a deeper understanding
of current needs – especially unmet needs. The survey response rate was approximately 42%. All
CoCs, PHAs, Domestic Violence Service Providers, and Veteran Services responded to the
survey. A brief summary of responding organizations and the comments received are shown in
the table below.
In addition to the survey responses, extensive research and data was gathered regarding
homelessness, populations at risk of homelessness, veterans, and persons attempting to flee
situations of violence (domestic, dating, sexual assault, human trafficking, etc.). Major data
sources used include: Comprehensive Housing Affordability Strategy (CHAS), local point-in-
time counts (PIT), CoC data, South Valley Services (Sanctuary), YWCA, Utah Community
Action and United States Census data.
List the organizations consulted:
Agency/Org
consulted
Type of Agency/Org Method of
Consultation
Feedback
Advantage
Services, Inc.
Homeless Services,
Veterans’ Group,
Organization Serving
Persons with disabilities
Survey Highest unmet need is Homeless –
Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in housing is lack of
affordable housing.
Alliance House Homeless Services,
Organization Serving
Persons with Disabilities
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gaps in housing are truly
affordable housing.
TheSoap2Hope Homeless Services,
Human Trafficking
Survey Highest unmet need is Fleeing, or
Attempting to Flee (Domestic
Violence, Dating violence, Sexual
Assault, Stalking, or Human
Trafficking).
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Preferred use of funds is for
Nonprofit Operating and Capacity
Building Assistance.
Organization Comments:
Greatest gaps in housing/shelter
are safety, openings, crisis
undisclosed shelter for victims,
trauma informed services.
Shelters are understaffed and
overwhelmed.
We need HOME-ARP funding in
areas where the population can
access resources without barriers.
Department of
Workforce Services
Government Entity,
Services for Low Income
Families/Individuals,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for
Acquisition Development of Non-
Congregate Shelter Units.
Organization Comments:
Need available affordable
housing.
Assist Inc. Fair Housing
Organization,
Organization Serving
Persons with Disabilities
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in services is
permanent supportive services
and case management for persons
experiencing homelessness.
Family Support
Center
Homeless Services,
Domestic Violence
Survivors, Human
Trafficking Survivors,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is Homeless
– Individual and Family.
Preferred use of funds is for
Nonprofit Operating and Capacity
Building Assistance.
Organization Comments:
7
Greatest gap in housing/shelter is
for family sober living. Greatest
gap in services is mental health
care providers.
Journey of Hope,
Inc.
Homeless Services,
Domestic Violence
Services, Human
Trafficking Services,
Organization Serving
Persons with
Disabilities.
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in housing/shelter is
not enough DV/SA trafficking
beds on the Wasatch Front.
Family Promise
Salt Lake
Homeless Services Survey Highest unmet need is Homeless
– Individual or Family.
Preferred use of funding is for
Nonprofit Operating and Capacity
Building Assistance.
Housing Authority
of Salt Lake City
Homeless Services,
Domestic Violence
Services, Veterans'
Group, Fair Housing
Organization,
Organization Serving
Persons with
Disabilities,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for
Nonprofit Operating and Capacity
Building Assistance.
Organization Comments:
The greatest gap to
housing/shelter is affordable
accessible housing with limited
qualifying restrictions.
State of Utah,
Office of Homeless
Services
Government Entity,
Homeless Services
Survey Highest unmet need is Homeless-
Individual or Family.
Preferred use of funds is for
Acquisition / Development of
Non-Congregate Shelter Units.
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YWCA Utah Homeless Services,
Domestic Violence
Services, Human
Trafficking Services
Survey Highest unmet need is Fleeing, or
Attempting to Flee (Domestic
Violence, Dating Violence,
Sexual Assault, Stalking, or
Human Trafficking).
Preferred use of funds is for
Nonprofit Operating and Capacity
Building Assistance.
Utah Community
Action
Homeless Services,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is Fleeing, or
Attempting to Flee (Domestic
Violence, Dating Violence,
Sexual Assault, Stalking, or
Human Trafficking).
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
The Road Home Homeless Services Survey Highest unmet need is Homeless-
Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in housing/shelter is
the extreme lack of deeply
affordable housing stock. This
deficit leads to reduced shelter
outflow and means we are able to
serve fewer people with
emergency shelter and housing.
Fourth Street Clinic Homeless Services,
Healthcare Provider
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for the
Acquisition / Development of
Non-Congregate Shelter Units.
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Asian Association
of Utah
Refugee & Immigrant
Service Provider
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
First Step House Homeless Services,
Veterans' Group,
Substance Use Disorder
and Mental Health
Treatment, Organization
Serving Persons with
Disabilities
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Many of the homeless and
chronically homeless
concurrently struggle with co-
occurring and chronic mental
health conditions that will not
ever resolve. Our systems must
realign to support these
individuals over long periods of
time, in some cases indefinitely.
Veterans Affairs
SLC
Veteran Services Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gaps in needed
housing/shelter are in the aging
population - over age 55. We are
seeing an alarming rate of seniors
being displaced from their homes.
They do not have the ability to
increase their income based on
their age. We need more
affordable senior housing.
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Disability Law
Center
Civil Rights
Organization, Fair
Housing Organization,
Organization Serving
Persons with Disabilities
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for
Supportive Services.
Rape Recovery
Center
Domestic Violence
Services, Human
Trafficking Services
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for
Nonprofit Operating and Capacity
Building Assistance.
Organization Comments:
Non-profit organizations need
capacity building dollars.
Crossroads Urban
Center
Homeless Services,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Focus on deeply targeted
affordable housing and
Permanent Supportive Housing.
Helping Hand
Association - DBA
The Haven
Homeless Services,
Organization Serving
Persons with Disabilities
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for
Supportive Services.
The INN Between Homeless Services,
Healthcare Provider
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in housing/shelter is
access to appropriate services to
obtain the very limited housing
available. Lack of seasonal
shelters.
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Utah Domestic
Violence Coalition
Domestic Violence
Services, Human
Trafficking Services
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for
Acquisition / Development of
Non-Congregate Shelter Units.
Organization Comments:
Greatest gap in needed services is
flexible funding to help remove
barriers for survivors of violence
to gain access to housing or
maintain their current housing.
NeighborWorks of
Salt Lake
Low-Income Home
Buyer Assistance
Survey Highest unmet need is Fleeing, or
Attempting to Flee (Domestic
Violence, Dating Violence,
Sexual Assault, Stalking, or
Human Trafficking).
Preferred use of funds is to create
Affordable Rental Housing.
Organization Comments:
Greatest gap in needed services is
for mental health, substance
abuse, affordable healthcare
access in general.
Salt Lake Valley
Habitat for
Humanity
Low-Income Home
Buyer Assistance,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is Families
seeking stable housing.
Preferred use of funds is to create
Affordable Rental Housing.
Clean Slate Utah Low Income Legal
Services
Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is to create
Affordable Rental Housing.
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211/United Way of
SLC
Homeless Services,
Domestic Violence
Services, Human
Trafficking Services,
Civil Rights
Organization,
Organization Serving
Persons with
Disabilities,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for
Tenant-Based Rental Assistance
(TBRA).
Organization Comments:
The greatest gap in
housing/shelter is tenant choice
housing vouchers that reflect
current cost of local average rent
and not based on prior year
domestic rent values. Also, the
aging population is rapidly facing
homelessness due to fixed
income/retirement no longer
keeping pace with senior housing
voucher values.
Salt Lake City
Mission
Homeless Services, Food
Pantry
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for
Supportive Services.
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Department of
Health and Human
Services
Government Entity Survey Highest unmet need is At Risk of
Homelessness.
Preferred use of funds is for
Tenant-Based Rental Assistance
(TBRA).
Organization Comments:
The greatest gaps in needed
housing/shelter are too many
restrictive conditions and
definitions. Hard to find
information on certain programs
and website information being
incorrect with no response to
inquiry's online about programs
by staff. We do not have enough
special housing programs with
services for people with
disabilities.
Shelter the
Homeless
Homeless Services Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in housing/shelter is
deeply affordable housing, non-
congregate shelter. Greatest gap
in services is in case management
and medical support.
West Valley City
Housing Authority
Housing Authority,
Domestic and Other
Violence Services, Fair
Housing Organization,
Organization Serving
Persons with
Disabilities,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is Homeless -
Individual or Family.
Preferred use of funds is for
Tenant-Based Rental Assistance
(TBRA).
Organization Comments:
Greatest gap in housing/shelter is
the lack of affordable, safe, and
decent rental units.
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Public Housing
Authority DBA
Housing Connect
Housing Authority,
Domestic and Other
Violence Services,
Veterans' Group, Fair
Housing Organization,
Organization Serving
Persons with
Disabilities,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is Homeless -
Unaccompanied Youth under 25
Years of Age.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap in housing/shelter is
deeply affordable housing.
Greatest gap in services is
supportive services that focus on
housing retention.
Salt Lake City and
Salt Lake County
CoC - Salt Lake
Valley Coalition to
End Homelessness
Homeless Services,
Government Entity,
Families/Individuals at
Risk of Homelessness
Survey Highest unmet need is
Homeless - Individual or Family.
Preferred use of funds is for the
Creation of Affordable Rental
Housing.
Organization Comments:
Greatest gap is housing - 2,950
housing units now and 1,400
additional units annually.
Shelter - 450+ overflow shelter
beds. Greatest gap in services is
in case management and
behavioral health.
Summarize feedback received and results of upfront consultation with these entities:
The feedback received is backed up by the data researched and forms the basis for our allocation
of HOME-ARP funds. Specifically, our allocation plan prioritizes the gaps described by survey
respondents and identified in the data. The major unmet eligible needs described by respondents
include creation of deeply affordable rental housing and supportive services for the qualifying
populations of individuals or families experiencing homelessness, at risk of homelessness, and
domestic violence victims.
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
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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
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.
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: 5/22/2022
• Public comment period: start date - 5/22/2022 end date - 6/8/2022
• Date(s) of public hearing: 6/1/2022
• Date(s) of public notice: 2/7/2023
• Public comment period: start date - 2/7/2023 end date - 3/21/2023
• Date(s) of public hearing: 2/21/2023
Describe the public participation process:
Salt Lake City will conduct two public comment periods and public hearings, one during the
creation of the plan from May 22, 2022, to June 8, 2022, and another to be completed after
Council review. The public hearing on June 1, 2022, had no attendees. There were no public
comments during the first comment period. The draft allocation plan was available on the Salt
Lake City Housing Stability website for any person to view and comment on. The public notice
can be found here and is an attachment to this plan. More information will be included after the
second public hearing.
Describe efforts to broaden public participation:
The notice of the public comment period and public hearing is posted in the local newspaper,
online at Salt Lake City Housing Stability’s webpage, and through City Council postings. The
posting was available in English and Spanish as well as ADA compliant.
Summarize the comments and recommendations received through the public participation
process either in writing, or orally at a public hearing:
There were no public comments received during the public comment period from May 22, 2022,
to June 8, 2022, and no attendees of the public hearing on June 1, 2022. More information will be
included after the second public comment period.
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Summarize any comments or recommendations not accepted and state the reasons why:
There were no comments nor recommendations not accepted by Salt Lake City.
Needs Assessment and Gaps Analysis
In accordance with Section V.C.1 of the Notice (page 14), a PJ must evaluate the size and
demographic composition of all four of the qualifying populations within its boundaries and
assess the unmet needs of each of those populations. If the PJ does not evaluate the needs of one
of the qualifying populations, then the PJ has not completed their Needs Assessment and Gaps
Analysis. In addition, a PJ must identify any gaps within its current shelter and housing
inventory as well as the service delivery system. A PJ should use current data, including point in
time count, housing inventory count, or other data available through CoCs, and consultations
with service providers to quantify the individuals and families in the qualifying populations and
their need for additional housing, shelter, or services.
Homeless Needs Inventory and Gap Analysis Table
Homeless
Current Inventory Homeless Population Gap Analysis
Family Adults Only Vets Family
HH (at
least 1
child)
Adult
HH
(w/o
child)
Vets Victims
of DV
Family Adults Only
# of
Beds
# of
Units
# of
Beds
# of
Units*
# of
Beds
# of
Beds
# of
Units
# of
Beds
# of
Units
Emergency
Shelter 483 47 862 Not
Avail. 0
Transitional
Housing 226 60 136 Not
Avail. 80
Permanent
Supportive
Housing
1,155 333 1,394 Not
Avail. 622
Other
Permanent
Housing
0 0 0 0
Sheltered
Homeless 634 1,055 73 329
Unsheltered
Homeless 0 268 7 26
Current
Gap 1,230 Not
Avail. 1,069 Not
Avail.
Data Source: CoC Housing Inventory Count (HIC) and Point in Time Count (PIT) (2020)
Although there is an aggregate surplus of family and adult shelter beds, according to the above
table, there is a difference with each population. For example, there are 1,323 adults
experiencing homelessness in Salt Lake City and 862 beds available for immediate need.
Transitional and permanent housing may take time to achieve, and a person will have to utilize a
shelter bed while waiting on an application to transition or permanent housing. The gap for
shelter beds available to families are 151. The gap for adult only shelter beds are 461. It is likely
that all permanent supportive housing currently in Salt Lake City is rented at capacity.
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Housing Needs Inventory and Gap Analysis Table
Non-Homeless
Current Inventory Level of Need Gap Analysis
# of Units # of Households # of Households
Total Rental Units 42,179
Rental units Affordable to HH
at 30% AMI (At-Risk of
Homelessness)
4,745
Rental units Affordable to HH
at 50% AMI (At-Risk of
Homelessness)
14,850
0%-30% AMI Renter HH w/ 1
or more severe housing
problems (At-Risk of
Homelessness)
6,555
30%-50% AMI Renter HH w/1
or more severe housing
problems (other populations)
2,380
Current Gaps
8,935
Data Source: Comprehensive Housing Affordability Strategy (CHAS) (2014-2018)
The above table shows a surplus of housing units available and affordable to households at 50%
AMI. When looking at households at or below 30% AMI there is a significant gap of 1,810 units.
This shows the need for deeply affordable rental units for residents at or below 30% AMI. It is
likely that the number of households will continue to grow as Salt Lake City population grows
over the next five to ten years. Providing more deeply affordable housing will keep up with the
continued population growth that Salt Lake City is seeing.
Describe the size and demographic composition of qualifying populations within the PJ’s
boundaries:
Within the boundaries of Salt Lake City, we have the following data regarding the HOME-ARP
qualifying populations:
1,958 people met the HUD definition of Homeless, residing in local shelters, transitional
housing, or unsheltered during the HUD 2020 Point in Time Count. As shown in the table above,
there are 7 unsheltered homeless veterans and 73 sheltered homeless veterans. There are 26
unsheltered victims of domestic violence and 329 sheltered victims of domestic violence.
Other data received, including 2021 Fall Point in Time Counts indicate an increase in
homelessness during the Covid-19 pandemic. The data shows that during Covid-19 unsheltered
counts increased significantly. In 2021, the unsheltered PIT count represented approximately
17% of the homeless population. Further, approximately 18% of the homeless population
avoided access to shelters due to Covid-19. In addition, the number of unsheltered individuals
from 2019-2020 increased by 39% while the overall homeless population only increased by
6.3%.
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2018 2019 2020 2021 Fall
Unsheltered 136 193 268 306
Sheltered 1668 1651 1690 1502
Total 1804 1844 1958 1808
Source: Salt Lake City/Salt Lake County PIT
Of concern is the fact that unsheltered unaccompanied youth increased by 121% between 2019
and 2020, although show some decrease in 2021.
Population 2018 2019 2020 2021 Fall
Persons in Households with Adult(s) and Child(ren) - - - 4
Persons in Households with Only Children 1 - - -
Persons in Households with Only Adults 135 193 268 302
Chronically Homeless Individuals 44 86 120 91
Veterans 7 12 7 15
Unaccompanied Youth 9 19 42 8
Persons with HIV 5 1 6 5
Source: Salt Lake City/Salt Lake County PIT
According to the 2020 Point in Time Count, the largest demographic of those experiencing
homelessness are those people who identify as White at 71%; the second largest demographic are
people who identify as Black at 13%. In addition, people identifying as American Indian or
Alaska Native represent 5%; Pacific Islanders represent 3%; Asians represent 1%; and multiple
races represent 7%.
Homeless as defined in 24 CFR 91.5
The total number of emergency shelter beds in Salt Lake City are 1,349 (HIC, 2020). As shown
in the table above, the number of homeless individuals is 1,958 (PIT, 2020). This indicates a
shortage in emergency shelter beds versus homeless individuals. In addition, 4,166 people
became homeless for the first time in 2020.
At Risk of Homelessness as defined in 24 CFR 91.5
According to 2014-2018 CHAS data, approximately 76% of the City’s cost-burdened households
are renters and 60% are severely cost-burdened. According to CHAS data, Salt Lake City has
12,550 households that have an annual income under 30% AMI. This increases the risk of
homelessness for those that are trying to maintain their current housing as house prices and rental
rates continue to surge at an alarming pace. Median rent in Salt Lake City has increased by
nearly 75% from 2000-2019 (2015-2019 ACS 5-Year Estimates). Close to 84% of survey
respondents indicated development of rental housing is extremely important to qualifying
populations. In addition, 97% stated permanent housing should be expanded to meet the needs of
qualifying populations.
19
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault,
Stalking, or Human Trafficking, as defined by HUD in the Notice
There are two primary domestic violence service providers, South Valley Services (SVS) and
YWCA Utah. These organizations serve individuals fleeing, attempting to flee, domestic
violence, dating violence, sexual assault, stalking or human trafficking, as defined by the HUD
Notice CPD-21-10. Together, within a one-year period, the two agencies have provided housing,
safety and other services to 1,597 individuals that include men, women, and children in the State
of Utah. SVS has received 2,217 hotline calls, 923 Lethality Assessment Program (LAP) calls,
case-managed 1,007 individuals, and provided therapy to 426 individuals. YCWA served 2,112
individuals by domestic violence programs in the last year. The YWCA had 309 requests for
services that could not be met and 48% of those were for housing. There are more data gaps in
our Domestic Violence and Human Trafficking data due to more strict confidentiality rules
surrounding this qualifying population.
Other populations requiring services or housing assistance to prevent homelessness and
other populations at greatest risk of housing instability, as defined by HUD in the Notice
Other populations include individuals or households experiencing evictions, those earning under
50 percent of AMI, and those living in neighborhoods with low mobility rates. CHAS data
indicates there are 22,610 households in Salt Lake City that are below 50% AMI. In the
consultation survey, respondents identified lower-income renters and the elderly as especially
vulnerable to housing instability due to rising rents and home prices. In conjunction with job
losses and unemployment due to the pandemic, as well as a reliance by the elderly on fixed
incomes, there is an increasing gap between incomes and housing costs.
Service providers indicated an increased need in services, including hotline calls, requests for
shelter, eviction prevention, mental health services, medical care, case management and housing
supports. Nearly 89% of survey respondents stated homelessness prevention services should be
expanded in the regional area to support qualifying populations.
Identify and consider the current resources available to assist qualifying populations,
including congregate and non-congregate shelter units, supportive services, TBRA, and
affordable and permanent supportive rental housing (Optional):
According to the 2020 HIC report, the current resources to meet the needs of qualifying
populations are as follows: 4,915 total year-round beds which include, 1,712 of emergency, safe
haven and transitional housing beds, and 3,203 of permanent housing beds which include
permanent supportive housing, rapid re-housing, and other permanent housing.
The HIC report specifically identifies 2,199 family beds, 2,711 adult only beds and 5 child only
beds. Subsets of the total year-round inventory include 757 beds for veterans, 110 beds for youth
and 1,501 beds to serve the chronically homeless. In addition, there are 58 seasonal beds, and
160 overflow/vouchers. Data is not available to distinguish between congregate and non-
congregate shelter units. Salt Lake City used motel vouchers to create non-congregate shelter
units, currently there are no non-congregant shelters in Salt Lake City.
20
Salt Lake City has made efforts to offer a wide range of services including TBRA,
medical/dental services, mental health counseling, domestic violence shelters and counseling,
legal aid and resources to identify available affordable housing.
In November 2020 the Kem C. Gardner Policy Institute provided a report outlining the current
challenges in serving qualifying populations given the existing governance structure and made
several recommendations for improvements, including the appointment of a statewide homeless
services officer, a homeless council, and a philanthropic consortium. In addition, as reflected in
the consultation process, the need for affordable housing is a high priority to service providers
and government entities.
Describe the unmet housing and service needs of qualifying populations:
As discussed in the sections above, the number of unsheltered homeless individuals has
increased by 39% from 2019-2020. According to survey respondents, nearly 54% indicated a gap
in affordable housing inventory in the regional area. This is also shown in the 2014-2018 CHAS
data. As stated, multiple times throughout the consultation process, the need for services has
increased and access to these services has become cumbersome for qualifying populations. In
addition to limiting barriers to access these services, service providers are in need of qualified
staff to assist with providing services and support. As shown in the graph below, survey
respondents stated there is a gap in case management services for qualifying populations.
While the need for more affordable housing and more case management services was listed as a
need for all groups, as shown in the survey responses below, specific needs for the various
qualifying populations are listed following the two graphs.
0 5 10 15 20
Affordable housing (deeply affordable)
Non-congregate shelters
Online/hotline housing assistance
Emergency shelter (beds)
Permanent supportive housing
Rental assistance
More dispersed location of shelters and…
Supportive services
Specific populations including aging
Where are the Greatest Gaps in Needed
Housing/Shelter for Qualifying Populations?
21
Homeless as defined in 24 CFR 91.5
Over 60 percent of survey respondents indicated that their primary services were directed to
this group of qualifying populations. Major unmet needs for this group include:
• Availability of deeply affordable housing for individuals or families
• Tenant Based Rental Assistance
• Homeless Service Support
• Additional Shelter Beds
At Risk of Homelessness as defined in 24 CFR 91.5
Around 30 percent of survey respondents indicated that their primary services were directed
to populations at risk of homelessness. Major unmet needs for this group include:
• Supportive services and case management services
• Affordable Housing Options
• Tenant Based Rental Assistance
• Aging populations accessing affordable housing
Fleeing, or Attempting to Flee, Domestic Violence, Dating Violence, Sexual Assault,
Stalking, or Human Trafficking, as defined by HUD in the Notice
Over 48 percent of survey respondents indicated that their primary services were directed this
group of qualifying populations. Major unmet needs for this group include:
• Crisis shelters for victims
• Staffing and Services
• Non-congregate shelter options
0 2 4 6 8 10 12 14
Case management/continuum of services
Medical
Mental health/substance abuse services
Disabilities
Housing support/assistance
Supportive services for homelessness
Domestic abuse/violence
More staffing
Aging populations
Where are the Greatest Gaps in Needed Services for
Qualifying Populations?
22
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
Approximately 61 percent of survey respondents indicated that their primary services were
directed at other populations requiring services or housing assistance for those at greatest risk
of housing instability. Major unmet needs for this group include:
• Affordable Housing
• Provide Supportive Services
Identify any gaps within the current shelter and housing inventory as well as the service
delivery system:
Based on the data provided by the CoC Housing Inventory Count (HIC) and Point in Time Count
(2020), there is currently sufficient inventory to match the homeless population, as seen in the
above Homeless table. However, this count is a summation of all homeless inventory available to
all populations included in the homeless count and does not account for gaps within the total
inventory such as needs for specific homeless services and beds. The count also does not include
the potential needs for families and individuals at greater risk of homelessness, such as those
staying in hotels, doubled up with family, or cars. Those populations may not be counted in some
of these numbers and many families under 50% AMI are housing cost burdened, paying over
30% of their income towards rent. Being housing cost burdened increases your likelihood of
eviction as one financial emergency can remove the ability to pay rent.
The housing inventory gap analysis also shows a surplus in aggregated housing inventory
available to households under 50% AMI. However, when only considering households with 0-
30% AMI and the inventory available to these households which are at risk of homelessness,
there appears to be a gap of 1,810 units available. This indicates that there is a substantial need in
additional affordable housing at the lower level of AMI to better meet the needs of those at risk
of homelessness.
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:
According to CHAS, there are 1,010 households with at least two persons where either one or
both are 62 years old or older and have a total household income of less than 50 percent of
HAMFI. The Salt Lake School District had a mobility rate of 17.1% among its families in the
2019-2020 school year according to data provided by the Utah State Board of Education. This
percentage may have been affected by COVID-19 as the previous 6 school years each had a
mobility rate of at least 23.7%.
23
Identify priority needs for qualifying populations:
As indicated by the survey results and shown in the graph below, the qualifying population with
the highest unmet need is homeless individual or family at 54.04%.
Next, when asked to rank the preferred use of HOME-ARP funds for qualifying populations, the
creation of affordable rental housing ranked the highest with 52.94%.
In addition, when asked whether permanent housing should be expanded to qualifying
populations, 97.22% strongly agreed/agreed with the statement.
0%10%20%30%40%50%60%
Homeless - Individual or Family
Homeless - Unaccompanied Youth under 25
Years of Age
At Risk of Homelessness
Fleeing, or Attempting to Flee (Domestic
Violence, Dating Violence, Sexual Assault,
Stalking, or Human Trafficking)
Other (please specify)
Which Qualifying Population has the Highest Unmet
Need?
0%10%20%30%40%50%60%
Creation of Affordable Rental Housing
Tenant-Based Rental Assistance (TBRA)
Supportive Services
Acquisition / Development of Non-Congregate
Shelter Units
Nonprofit Operating and Capacity Building
Assistance
Preferred use of HOME-ARP Funds
24
Lastly, when survey respondents commented on any other areas related to the eligible use of
HOME-ARP that should be considered as a funding priority, 53.57% indicated housing; of those
who indicated housing, the following specific types of housing were mentioned:
• Deeply targeted affordable housing – 20%
• Senior housing – 13%
• Long-term housing – 13%
• Supportive housing – 6%
• Non-congregate housing – 6%
• Sustainable housing – 6%
To summarize, the data and survey results conclude the qualifying population with the greatest
unmet need is homeless individual or family and the priority need suggests affordable housing
should be expanded within the regional area.
Explain how the PJ determined the level of need and gaps in the PJ’s shelter and housing
inventory and service delivery systems based on the data presented in the plan:
The methodology used in the creation of this HOME-ARP Allocation Plan were derived from
various sources, including 2020 and 2021 (Fall) PIT, 2020 HIC, 2014-2018 CHAS, U.S. Census
Bureau 2015-2019 ACS 5-Year Estimates and through the consultation process with service
providers and government entities.
0%20%40%60%80%100%120%
Agree
Neither agree nor disagree
Permanent Housing Should be Expanded to Qualifying
Populations
25
HOME-ARP Activities
Describe the method(s)that will be used for soliciting applications for funding and/or selecting
developers, service providers, subrecipients and/or contractors:
Salt Lake City will solicit applications through a competitive application process. This process
will be similar to that of the annual HUD funding Salt Lake City receives. Agencies and
developers will be able to apply for funding through an application open for a minimum of thirty
days. Eligible projects will then go through the public process which includes going before a
public City review board, the Mayor, and City Council for final recommendations and approval.
During the process Salt Lake City will outreach and collaborate with non-profit agencies, Other
Salt Lake City Divisions, the Redevelopment Agency of Salt Lake, and other local municipalities
to maximize the impact of HOME-ARP funding.
Describe whether the PJ will administer eligible activities directly:
Salt Lake City will work with a subrecipient or developer to administer the selected activities.
Salt Lake City will provide oversight, but will not administer eligible activities directly.
If any portion of the PJ’s HOME-ARP administrative funds are provided to a subrecipient or
contractor prior to HUD’s acceptance of the HOME-ARP allocation plan because the
subrecipient or contractor is responsible for the administration of the PJ’s entire HOME-ARP
grant, identify the subrecipient or contractor and describe its role and responsibilities in
administering all of the PJ’s HOME-ARP program:
This question is not applicable. Salt Lake City Housing Stability has not provided any
administrative funds to a subrecipient or contractor. We will provide program oversight and
administration of the HOME-ARP funding. While subrecipients will be selected to undertake
approved activities, Salt Lake City will not be contracting out the administration of our HOME-
ARP grant or program oversight.
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.
Use of HOME-ARP Funding
Funding Amount Percent of the
Grant
Statutory
Limit
Supportive Services (Rental Assistance, Case
Management, Victim Services, etc.) $ 753,215.75
26
Acquisition and Development of Non-
Congregate Shelters $ 0
Tenant Based Rental Assistance (TBRA) $ 0
Development of Affordable Rental Housing $ 2,250,000
Non-Profit Operating $ 0 # % 5%
Non-Profit Capacity Building $ 0 # % 5%
Administration and Planning $ 529,979.25 15% 15%
Total HOME ARP Allocation $ 3,533,195
Describe how the PJ will distribute HOME-ARP funds in accordance with its priority needs
identified in its needs assessment and gap analysis:
The survey and data gathered for Salt Lake City identified deeply affordable housing and case
management supportive services as a major need and gap.
City Council previously approved $176,659.75 as administration funds for Housing Stability to
use for the required consultation process and the creation of the allocation plan. Salt Lake City
can use up to $529,979.25 for administration and planning costs which can go to Housing
Stability staff that have been working on the allocation plan and will continue to administer the
HOME-ARP funding until 2030.
To address the need for deeply affordable housing, Housing Stability will fund the development
of affordable rental housing for the amount of $2,250,000. Salt Lake City will prioritize the use
of these funds for developments that incorporate mixed-income and family housing. This
funding can be used in conjunction with a current project, as long as federal requirements are
adhered to, for acquisition, rehabilitation, or new construction of affordable rental housing. All
HOME units must be set aside for qualifying populations as defined in the HOME-ARP Notice
CPD-21-10 to include: individuals or families experiencing homelessness, individuals or families
at risk of homelessness, individuals or families fleeing or attempting to flee domestic violence,
victims of human trafficking, individuals or households at risk of housing instability or requiring
services to prevent homelessness, and veterans or families with a veteran. All qualifying
populations must be considered to comply with HOME-ARP requirements.
To address the need for supportive services, specifically rental assistance and case management,
Housing Stability will fund $753,215.75. This funding can be used with one or multiple
subrecipient nonprofits in the community. Supportive services can be used to fund life skills
training, mental health services, outpatient health services, outreach services, substance abuse
treatment services, transportation, case management, mediation, credit repair, victim services,
and financial assistance for rental housing. Rental assistance through supportive services
provides added flexibility from typical HOME TBRA, including longer assistance times and full
rental assistance rather than partial. For this reason, Salt Lake City is opting to utilize the
Supportive Services category, and will prioritize a portion of this funding for rental assistance.
Many organizations are already providing these resources but are reaching staff capacity and the
need is much higher than the availability. This would allow for nonprofits to receive additional
27
funding to hire or retain staff that are assisting Salt Lake City residents, who meet the definition
of a qualifying population, in their housing needs.
Salt Lake City has decided to prioritize Supportive Services and Development of Affordable
Housing over the other activities based on the survey responses. The other activities do not fit
within our current community need, based on the providers that currently serve the qualifying
populations as defined in HUD Notice CPD-21-10.
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:
According to the data gathered and the survey respondents there is a high need in additional
affordable housing. There seems to be a gap of 8,935 rental units for individuals and families
making at or below 50% AMI. That gap continues to grow in the current economy of increased
inflation and increased rental rates that wages are not able to keep up with. Currently Salt Lake
City has two of the five homeless resource centers in its incorporated boundary and one domestic
violence shelter. To promote housing first and take the survey into consideration, creating deeply
affordable housing would address both the housing inventory gap and the current amount of
people utilizing the homeless resource centers.
The nonprofits that provide resources to the qualifying population state that their staffing
capacity is low due to recruitment challenges and low retention, additional supportive services
funding is necessary at this time. Funding supportive services will allow nonprofits to increase
capacity to serve qualifying populations in Salt Lake City.
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:
If Salt Lake City provides $2,250,000 in funding affordable housing development, it can assist
with one to three development projects depending on the need and size of the project. HUD
waived the maximum per-unit subsidy for HOME-ARP development dollars. It would be
anticipated that a project will be mixed with fair market, high affordability, and low affordability
units to sustain the project for at least 15 years. This mix can also include units of varying size,
from studio to four bedrooms to accommodate individuals and families. According to the HUD
Housing Production Goal Calculation spreadsheet, Salt Lake City estimates producing or
supporting 5-15 units for HOME-ARP qualifying populations. Salt Lake City estimated spending
around $400,000 of HOME-APR dollars on each deeply affordable HOME unit. That number is
based on a recent deeply affordable project as well as accounting for the increasing material and
labor costs in the construction market.
Describe the specific affordable rental housing production goal that the PJ hopes to achieve
and describe how the production goal will address the PJ’s priority needs:
28
Affordable rental housing production is part of Salt Lake City’s 2020-2024 Consolidated Plan
under the goal of housing. This goal is to expand housing options, specifically affordable
housing citywide. The 2020- 2024 Consolidated Plan identified 5,075 households assisted over
the four-year timeframe, which is 1,268 annually (Consolidated Plan SP-45, 2020-2021 Action
Plan AP-20). The number identified includes annual CDBG, ESG, HOME, and HOPWA funding
for projects like rehabilitation, development, home ownership, and rental assistance. Since this
funding would be including development and supportive services it can support the goal of
assisting 1,268 household. Based on the 2020-2021 CAPER it is likely that HOME-ARP will
assist in 11 of the rental housing production goal for the 2020-2024 Consolidated Plan.
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Preferences
A preference provides a priority for the selection of applicants who fall into a specific QP or
category (e.g., elderly or persons with disabilities) within a QP (i.e., subpopulation) to receive
assistance. A preference permits an eligible applicant that qualifies for a PJ-adopted preference
to be selected for HOME-ARP assistance before another eligible applicant that does not qualify
for a preference. A method of prioritization is the process by which a PJ determines how two or
more eligible applicants qualifying for the same or different preferences are selected for HOME-
ARP assistance. For example, in a project with a preference for chronically homeless, all
eligible QP applicants are selected in chronological order for a HOME-ARP rental project
except that eligible QP applicants that qualify for the preference of chronically homeless are
selected for occupancy based on length of time they have been homeless before eligible QP
applicants who do not qualify for the preference of chronically homeless.
Please note that HUD has also described a method of prioritization in other HUD guidance.
Section I.C.4 of Notice CPD-17-01 describes Prioritization in CoC CE as follows:
“Prioritization. In the context of the coordinated entry process, HUD uses the term
“Prioritization” to refer to the coordinated entry-specific process by which all persons in need
of assistance who use coordinated entry are ranked in order of priority. The coordinated entry
prioritization policies are established by the CoC with input from all community stakeholders
and must ensure that 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
30
civil rights laws and requirements when establishing preferences or methods of
prioritization.
While PJs are not required to describe specific projects in its HOME-ARP allocation plan to
which the preferences will apply, the PJ must describe the planned use of any preferences in its
HOME-ARP allocation plan. This requirement also applies if the PJ intends to commit HOME-
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).
Identify whether the PJ intends to give preference to one or more qualifying populations or a
subpopulation within one or more qualifying populations for any eligible activity or project:
The survey respondents have clearly stated that more deeply affordable housing is needed in Salt
Lake City for families and individuals experiencing homelessness. Homeless individuals and
families defined in the HOME-ARP Notice, according to ESG and CoC. It is proposed that
deeply affordable housing being created would prioritize families and individuals experiencing
homelessness.
Supportive services would not have a prioritization based on qualifying populations and can be
open to any agencies that provide an eligible service to any qualifying population.
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:
According to the housing inventory numbers previously shown there is a gap in deeply
affordable units, for individuals and families making less than 30% AMI. There are currently
4,745 units available to Salt Lake City residents at or under 30% AMI with 6,555 households in
Salt Lake City falling under the 30% AMI threshold. That leaves a gap of 1,810 units needed for
the current residents. That does not consider the increase in population that Utah and Salt Lake
City will likely see over the next five years.
Creating deeply affordable housing units and prioritizing families and individuals currently
experiencing homelessness will address the gap in housing since most individuals and families
experiencing homelessness fall under 30% AMI and are currently priced out of the rising rental
market.
31
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.
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).
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):
Local subrecipients will be required to operate HOME-ARP funded programs with no exclusions
in the following way. All supportive service projects will be utilized on a first come, first eligible
basis. The Development projects must be required to use a first come, first served basis, unless
the family or individual is currently experiencing homelessness. That family or individual
currently experiencing homelessness can be prioritized for the HOME units in the project being
created. All subrecipients and projects will be required to have a waitlist for the HOME-ARP
program. Based on the qualifying population, required documentation will be needed to support
the qualifying status. Documentation may include but is not limited to; Utah Homeless
Management Information System (UHMIS), Paystubs/ Tax Returns, Case Manager Verification,
State Assistance Verification (SNAP, TANF, Unemployment), VA Verification.
32
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):
Salt Lake City does not intend to use the coordinated entry process established by the CoC since
it does not serve all the qualifying populations listed in the HOME-ARP Notice CPD-21-10.
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):
Not Applicable
If the PJ intends to use both a CE process established by the CoC and another referral method
for a project or activity, describe any method of prioritization between the two referral
methods, if any. (Optional):
Not Applicable
Limitations in a HOME-ARP rental housing or NCS project
Limiting eligibility for a HOME-ARP rental housing or NCS project is only permitted under
certain circumstances.
• PJs must follow all applicable fair housing, civil rights, and nondiscrimination
requirements, including but not limited to those requirements listed in 24 CFR 5.105(a).
This includes, but is not limited to, the Fair Housing Act, Title VI of the Civil Rights Act,
section 504 of Rehabilitation Act, HUD’s Equal Access Rule, and the Americans with
Disabilities Act, as applicable.
• A PJ may not exclude otherwise eligible qualifying populations from its overall HOME-
ARP program.
• Within the qualifying populations, participation in a project or activity may be limited to
persons with a specific disability only, if necessary, to provide effective housing, aid,
benefit, or services that would be as effective as those provided to others in accordance
with 24 CFR 8.4(b)(1)(iv). A PJ must describe why such a limitation for a project or
activity is necessary in its HOME-ARP allocation plan (based on the needs and gap
identified by the PJ in its plan) to meet some greater need and to provide a specific
benefit that cannot be provided through the provision of a preference.
• For HOME-ARP rental housing, section VI.B.20.a.iii of the Notice (page 36) states that
owners may only limit eligibility to a particular qualifying population or segment of the
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.
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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:
Salt Lake City does not intend to limit eligibility for HOME-ARP rental housing.
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:
Not Applicable
If a limitation was identified, describe how the PJ will address the unmet needs or gaps in
benefits and services of the other qualifying populations that are not included in the limitation
through the use of HOME-ARP funds (i.e., through another of the PJ’s HOME-ARP projects
or activities):
Not Applicable