HomeMy WebLinkAboutContinuum-Care_LtrToHUD_20160923Y
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City Attorney's Office
990 Palm Street. San Luis Obispo CA 93401-3249
805 781 7140
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September 23, 2016
Delivered via electronic portal at www.regulations.gov
Regulations Division
Office of General Counsel
Department of Housing and Urban Development
451 7th Street SW, Room 10276
Washington, DC 20410-0500
Re: Docket Number: HUD -2016-0078
Continuum of Care Program: Solicitation of Comment on Continuum of Care Formula
Dear HUD Representatives:
The City of San Luis Obispo ("City") supports the proposed changes to the formula used to
determine the maximum amount of Continuum of Care funding for which a community may
qualify. The City strongly recommends adoption of Alternative A, as it will result in the
highest funding for our community.
The funding formula for the Continuum of Care homeless assistance programs should use data
that most closely reflect the rate of homelessness in each community. HUD's analysis, cited
in the Notice (Docket No. FR -5476-N-04), shows that the formula currently used by HUD
does not use the determinants of homelessness that are most strongly associated with rates of
homelessness. HUD's analysis found three factors to be most strongly associated with rates
of homelessness: Renter -Occupied Units, Rent -Burdened Extremely Low Income (ELI)
Households, and the Affordability Gap (the difference between the supply of and demand for
affordable rental units available to ELI households). None of these three factors are used in
the existing formula.
The City encourages HUD to adopt a new formula that incorporates Renter -Occupied Units,
Rent -Burdened Extremely Low Income Households, and the Affordability Gap, so that
communities with the greatest number of homeless persons will receive a more proportional
amount of resources.
While San Luis Obispo County (CoC CA -614) is a small metropolitan area with a population
of 270,000, the majority of those residents live in rural areas.
• The San Luis Obispo housing market was recently ranked as the 6th most unaffordable
in the County, and in 2013, the county had the lowest rental vacancy rate in California
at only 1.7%,
• Renter occupied units within the City of San Luis Obispo account for nearly 64% of
total housing units,
• Within the City of San Luis Obispo, nearly 33% of residents are considered below the
poverty level,
• As of the 2015 Point in Time Count, the county's homeless population is 2,186, with
1,515 (70%) of those homeless individuals being unsheltered.
Despite having a severe unsheltered homeless problem and an increasingly unaffordable
housing market, our county only received about $1 million in CoC funds for FYI 3. The City,
which has Major City Goals focused on increasing affordable housing and reducing
homelessness, urges HUD to modify the existing incommensurate formula and adopt
Alternative A to provide fair compensation. The formula was established decades ago based
on factors that made sense for broad community development needs; however, a closer look
now needs to be taken to most accurately reflect the rate of homelessness in each community.
Thank you for providing this opportunity to comment.
in ly,
Christine Dietrick
City Attorney
City of San Luis Obispo