HomeMy WebLinkAboutAgenda Report - July 15, 2020 G-04 PHAGENDA ITEM G-4
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AGENDA TITLE:Public Hearing to Consider Adopting a Resolution Adopting a Five-Year Plan
for the Permanent Local Housing Allocation (PLHA) Grant Program, Approving
Submission of the 2020 PLHA Grant Application and Authorizing the City
Manager to Enter into Agreements with the California Department of Housing
and Community Development for a Permanent Homeless Shelter Project -
Predevelopment Phase ($2,01 7,590)
MEETING DATE: July 15,2020
PREPARED BY: Community Development Director
RECOMMENDED ACTION: Public Hearing to Consider Adopting a Resolution Adopting a
Five-Year Plan for the Permanent Local Housing Allocation
(PLHA) Grant Program, Approving Submission of the 2020
PLHA Grant Application and Authorizing the City Manager to Enter into Agreements with the
California Department of Housing and Community Development for a Permanent Homeless
Shelter Project - Predevelopment Phase ($2,017,590)
BACKGROUND INFORMATION: The California Department of Housing and Community
Development released a Notice of Funding Availability (NOFA) in
February 2020 for the Permanent Local Housing Allocation
Program. This grant program provides funds to local governments for housing-related projects and
programs that assist in addressing unmet housing needs in their local communities. The application
deadline is July 27,2020.
ln 2017 Governor Jerry Brown signed a package of housing bills aimed at addressing California's
housing shortage and high housing costs. This legislation package included Senate B¡ll (SB) 2,
the Building Homes and Jobs Act, which established a $75 recording fee on real estate documents to
increase the supply of affordable homes in California and to address other urgent housing issues.
Under SB 2 the revenue from these recording fees is deposited into the established Building Homes
and Jobs Trust Fund. Beginning in 2019 seventy (70) percent of the monies collected and deposited
into this fund are allocated to the Permanent Local Housing Allocation (PLHA) program to support
locally administered affordable housing.
ln February 2020 the Department of Housing and Community Development (HCD) released a Notice
of Funding Availability (NOFA) announcing the availability of approximately $195 million in funding for
the entitlement and non-entitlement local government formula component of the PLHA program. All
entitlement and non-entitlement local governments are eligible for an allocation of PLHA funds on an
annual basis for up to five years. For entitlement jurisdictions (including the City of Lodi), the amount
of funding allocated is based on the jurisdiction's share of the total Community Development Block
Grant (CDBG) allocation in California. For Fiscal Year 2019-2020, the City of Lodi is eligible to receive
$336,265 PLHA funding. Over the five-year period, the City is eligible to receive an estimated
$2,017,590 in PLHAfunds, based on HCD's estimatesforannual allocations overthe nextfive years.
APPROVED:
rStephen uer, City Manager
Permanent Local Housing Allocation (PLHA) GrantAppl¡cation
July 15, 2020
Page 2 of 3
Actual funding amounts over the five-year period will be issued by HCD on an annual basis. PLHA
grants are non-competitive; however, there are threshold requirements that must be met in order for
funding to be approved (e.9. the jurisdiction must have an adopted Housing Element that is in
compliance with state law and must submit a complete PLHA application with all required
information).
Projects proposing to use PLHA funding must help local governments achieve one or more of the
following objectives:
. lncrease the supply of housing for households at or below 60% of area median income. lncrease assistance to affordable owner-occupied workforce housing. Assist persons experiencing or at risk of homelessness. Facilitate housing affordability, particularly for lower- and moderate-income households. Promote projects and programs to meet the local government's unmet share of regional
housing needs allocation
The City of Lodi, along with many cities in California, began facing a homeless crisis in 2017. The
City's unsheltered homeless population grew to 139 individuals in2019, as measured by the County's
Point-ln-Time Count, although local social service providers projected that the real number could be
up to 100 more. ln response to this crisis, the Lodi Committee on Homelessness (LCOH) mobilized to
find resources and greater collaboration among social services agencies. Additionally, the City of Lodi
Police Department created a new Homeless Liaison Officer position to provide street outreach to find
housing and services for the unsheltered homeless population in Lodi. While this program
experienced success in assisting more than 100 unsheltered homeless persons to find resources and
housing, severely chronically homeless individuals still face obstacles and need solutions that go
beyond the resources provided in the City's program. The LCOH, in collaboration with several local
and regional homeless experts, identified that a permanent low-bar shelter with supportive services
would be critical to assisting the City's unsheltered homeless population. Services would include case
management, physical health, mental health, food, personal care, transitional housing, job
preparation, and more.
Considering the above, City staff intends to pursue PLHA grant funding for the maximum amount of
$2,017,590, which includes the first allocation of $336,265 for Fiscal Year 2019-2020, for
predevelopment, infrastructure and site improvements for a permanent low-bar homeless shelter.
PLHA Program guidelines allow the City to use up to 5o/o of the annual allocation amount for costs
related to the administration of the activities for which the grant allocation is made.
As required by HCD, staff has prepared a PLHA plan that outlines the anticipated project costs and
schedule over the five-year period. The PLHA program guidelines do not require a detailed
expenditure plan for the funds; rather, the PLHA plan must simply identify which eligible activity or
activities the City intends to fund each year, the percentage of PLHA funds to be allocated to each
activity in each year, the income levels of individuals and households to be served, and a general
timeline for completion of the funded activities. The PLHA Plan is included as pages 4 through 6 of the
draft PLHA Grant Application (Attachment A).
The City of Lodi has also applied for funding from the Local Early Action Planning (LEAP) grant
program, another non-competitive grant program administered by HCD, for the planning phase of this
permanent homeless shelter project including '1) identifying appropriate sites,2) conceptual designs,
and 3) preliminary environment studies, and 4) creating a business and operational plan. Lodi's LEAP
grant application was submitted to HCD on July 1 ,2020.
Staff is requesting that the City Council hear public testimony on the proposed PLHA Plan, and
subsequently adopt a resolution approving the PLHA Plan and submittal of the grant application, as
required by HCD.
Permanent Local Housing Allocâtion (PLHA) Grant Appl¡cation
July 15, 2020
Page 3 of 3
FISCAL IMPAGT:
FUNDING AVAILABLE: Not applicable
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Attachments:
A. Draft PLHA Grant Application
There is no fiscal impact for consideration of adoption of the Resolution.
The City is eligible to receive an estimated $2,017,590 to support
predevelopment of a permanent homeless shelter in Lodi. There is no
obligated City match for this grant program.
John Della Monica Jr
unity Development
PLHA Page 1 Instructions & Checklist
"Red" shaded cells indicate the Sponsor has failed to meet a requirement of the program. Point cells in the Scoring worksheet shaded in "red" indicate that the Sponsor has failed to
meet the minimum points required.
Instructions Rev. 2/26/20
When opening this file, a yellow banner at the top may appear with a button that says "Enable Content". It is essential that you click this box so that the macros are
enabled. Enabling macros is necessary for full worksheet functionality. Macros do not work with Microsoft's Excel version for Apple Mac.
HCD will only accept applications through a postal carrier service such as U.S. Postal Service, UPS, FedEx or other carrier services that provide date stamp verification confirming
delivery to HCD’s office. A complete original application and an electronic copy on a USB flash drive with all applicable information must be received by HCD via postal carrier no later
than 5:00 p.m. on:
Monday, July 27, 2020
Applications must be on the Department’s forms and cannot be altered or modified by the Applicant. Excel forms must be in Excel format and unprotected, not a .pdf document. For
application errors please fill out the Application Support worksheet and email the entire workbook to Application Support for application errors at AppSupport@hcd.ca.gov.
General Instructions (Additional instructions and guidance are given throughout the Supplemental Application in "red" text and in cell comments.
Guideline references are made with "§" and the corresponding guideline section number.
"Yellow" cells are for Sponsor input. Failure to provide the required attachments and documentation may disqualify your application from consideration or may negatively impact your
point score.
Required attachments are indicated in "orange" throughout the Supplemental Application. Failure to provide the required attachments and documentation may disqualify your
application from consideration or may negatively impact your point score. Electronically attached files must use the naming convention in the Supplemental Application. For Example:
"App1 Payee Data" for Sponsor 1 Payee Data Record/STD. 204.
Threshold items are indicated in "blue" cells.
Sponsor must complete the following worksheets in the PLHA Formula Allocation Application.
Formula Allocation Application
X App1 Signature Block Signature Block - upload in Microsoft Word Document Included
302(c)(4) Plan
Legislative Contacts
Checklist
App1 Resolution PLHA webpage for Resolution Document Included
Not Included
Disclosure of Application (California Public Records Act Statutes of 1968 Chapter 1473): Information provided in the application will become a public record available for review
by the public, pursuant to the California Public Records Act Statutes of 1968 Chapter 1473. As such, any materials provided will be disclosable to any person making a request under
this Act. The Department cautions Applicants to use discretion in providing information not specifically requested, including but not limited to, bank accounts, personal phone numbers
and home addresses. By providing this information to the Department, the Applicant is waiving any claim of confidentiality and consents to the disclosure of submitted material upon
request."
Binder
Tab #
Threshold
Requirement Electronic File Name Document Description Included?
1 X
2
3 X App1 TIN Taxpayer Identification Number Document
Included
Included
§302(c)(4)(D) Evidence that the Plan was authorized and adopted by resolution by the Local
jurisdiction and that the public had an adequate opportunity to review and comment on its
content.
Plan Adoption 5
Legally binding agreement between Delegating and Administering Local Governments 4 X Applicant Agreement
PLHA Page 2 Formula Allocation Application
Local Government Formula Allocation Rev. 2/26/20
CA Zip:95240 San Joaquin
§300(d) Is Applicant delegated by another Local government to administer on its behalf its formula allocation of program funds?
N/A
File Name:PLHA webpage for Resolution Document Attached and on USB?
State:
Attached and on USB?N/A
Eligible Activities, §301
Taxpayer Identification Number Document Attached and on USB?Yes
Instructions: If the Local Government Recipient of the PLHA Formula Allocation delegated its PLHA formula allocation to a Local Housing Trust Fund or to another Local Government,
the Applicant (for which information is required below) is the Local Housing Trust Fund or administering Local Government. The PLHA award will be made to the Applicant (upon
meeting threshold requirements) and the Applicant is responsible for meeting all program requirements throughout the term of the Standard Agreement.
The 302(c)(4) Plan template worksheet requires first choosing one or more of the Eligible Activities listed below. If "Yes" is clicked, the 302(c)(4) Plan worksheet opens a series of
questions about what precise activities are planned. Some specific activities, such as providing downpayment assistance to lower-income households for acquisition of an affordable
home, could be included under either Activity 2 or 9. Please only choose one of those Activities; don't list the downpayment assistance under both Activities.
If the PLHA funds are used for the same Activity but for different Area Median Income (AMI) level, select the same Activity twice (or more times) and the different AMI level the Activity
will serve. Please enter the percentage of funds allocated to the Activity in only the first Activity listing to avoid double counting the funding allocation.
Eligible Applicants §300
§300(a) Eligible Applicants for the entitlement formula component described in Section §100(b)(1) are limited to the metropolitan cities and urban counties allocated a grant for the
federal fiscal year 2017 pursuant to the federal CDBG formula specified in 42 USC, Section §5306.
Applicant: City of Lodi
Address:
County:
File Name:Applicant Agreement Legally binding agreement between Delegating and Administering Local
Governments
§301(a)(6) Assisting persons who are experiencing or At-risk of homelessness, including, but not limited to, providing rapid re-housing, rental assistance,
supportive/case management services that allow people to obtain and retain housing, operating and capital costs for navigation centers and emergency shelters, and
the new construction, rehabilitation, and preservation of permanent and transitional housing.
§301(a)(5) Capitalized Reserves for services connected to the preservation and creation of new permanent supportive housing.
§301(a)(4) Matching portions of funds available through the Low- and Moderate-Income Housing Asset Fund pursuant to subdivision (d) of HSC Section 34176.
§301(a)(3) Matching portions of funds placed into Local or Regional Housing Trust Funds.
§301(a)(2) The predevelopment, development, acquisition, rehabilitation, and preservation of affordable rental and ownership housing, including Accessory Dwelling
Units (ADUs), that meets the needs of a growing workforce earning up to 120 percent of AMI, or 150 percent of AMI in high-cost areas. ADUs shall be available for
occupancy for a term of no less than 30 days.
§301(a)(1) The predevelopment, development, acquisition, rehabilitation, and preservation of multifamily, residential live-work, rental housing that is affordable to
Extremely low-,Very low-, Low-, or Moderate-income households, including necessary operating subsidies.
Included?§301(a) Eligible activities are limited to the following:
Eligible Applicant Type: Entitlement
Local Government Recipient of PLHA Formula Allocation: Lodi
221 W. Pine Street
City:Lodi
Yes
File Name:
Approximate PLHA Formula Allocation Amount:$16,813Allowable Local Admin (5%):$336,265
No
App1 TIN
App1 Signature Block
App1 Resolution
§300(d) If Applicant answered "Yes" above, has the Applicant attached the legally binding agreement required by §300 (c) and (d)?
Signature Block - upload in Microsoft Word Document Attached and on USB?Yes
File Name:
YES
YES
YES
YES
YES
YES
PLHA Page 3 Formula Allocation Application
City Zip
Yes
§302(c)(4) Does the application include a Plan in accordance with §302(c)(4)?
§302(c)(3) Applicant certifies that, if the Local Government proposes allocation of funds for any activity to another entity, the Local government’s selection process had no
conflicts of interest and was accesible to the public.
§302(c)(2) Applicant certifies that submission of the application was authorized by the governing board of the Applicant.
§302(a) Housing Element compliance: Applicant or Delegating Local Government's Housing Element was adopted by the Local Government’s governing body by the
application deadline and subsequently determined to be in substantial compliance with state Housing Element Law pursuant to Government Code Section 65585.
Yes
Yes
YesApplicant agrees to adhere to §501, Audits/Monitoring of PLHA Files.
YesApplicant agrees to adhere to §500, Accounting Records.
Yes
§302(c)(5) Applicant certifies that the Plan submitted is for a term of five years. Local Governments agree to inform the Department of changes made to the Plan in each
succeeding year of the term of the Plan.Yes
§302(c)(6) Applicant certifies that it will ensure compliance with §302(c)(6) if funds are used for the acquisition, construction, or rehabilitation of for-sale housing projects or
units within for-sale housing projects.
§302(c)(8) Has Applicant attached a program income reuse plan describing how repaid loans will be reused for eligible activities specified in Section 301?No
Yes
Administration
Yes
Entity Address 221 W. Pine Street Lodi State CA 95240
On behalf of the entity identified below, I certify that: The information, statements and attachments included in this application are, to the best of my knowledge and belief, true and
correct and I possess the legal authority to submit this application on behalf of the entity identified in the signature block.
Signature Date
Entity name:City of Lodi Phone Number:209-333-6700
City Manager
Certifications
Stephen Schwabauer
TitleAuthorized Representative Printed Name
Applicant agrees to adhere to §503, Reporting.Yes
Applicant agrees to adhere to §502, Cancellation/Termination.
§302(c)(4)(D) Applicant certifies that the Plan was authorized and adopted by resolution by the Local Government and that the public had an adequate opportunity to review
and comment on its content
§302(c)(7) Applicant certifies that it will ensure that the PLHA assistance is in the form of a low-interest, deferred loan to the Sponsor of the Project, if funds are used for the
development of an Affordable Rental Housing Development. The loan shall be evidenced through a Promissory Note secured by a Deed of Trust.Yes
Threshold Requirements, §302
§301(a)(10) Fiscal incentives made by a county to a city within the county to incentivize approval of one or more affordable housing Projects, or matching funds invested
by a county in an affordable housing development Project in a city within the county, provided that the city has made an equal or greater investment in the Project. The
county fiscal incentives shall be in the form of a grant or low-interest loan to an affordable housing Project. Matching funds investments by both the county and the city
also shall be a grant or low-interest deferred loan to the affordable housing Project.
§301(a)(9) Homeownership opportunities, including, but not limited to, down payment assistance.
§301(a)(8) Efforts to acquire and rehabilitate foreclosed or vacant homes and apartments.
§301(a)(7) Accessibility modifications in Lower-income Owner-occupied housing.
Yes
§302(b) Applicant or Delegating Local Government has submitted the current or prior year's Annual Progress Report to the Department of Housing and Community
Development pursuant to Governemnt Code Section 65400. Yes
YES
YES
YES
YES
PLHA Page 4 302(c)(4) Plan
§301(a)(6) Assisting persons who are experiencing or At risk of homelessness, including, but not limited to, providing rapid rehousing, rental assistance, supportive/case management
services that allow people to obtain and retain housing, operating and capital costs for navigation centers and emergency shelters, and the new construction, rehabilitation, and
preservation of permanent and transitional housing.
§302(c)(4)(C) Provide a description of how the Plan is consistent with the programs set forth in the Local Government’s Housing Element.
Program 4.3 of the City of Lodi's Housing Element (2014-2023) is to "Pursue Regional Solutions to Homeless Needs." This implementation program calls on the City to collaborate with
nonprofit service organizations in the region to support and implement solutions to homelessness. The City has created an interagency Lodi Committee on Homelessness (LCOH), and
City staff participates with community groups and service organizations in the San Joaquin Continuum of Care (SJCoC), a regional program promoting community-wide action to end
homelessness. These efforts focus on leveraging partnerships to create effective solutions to homelessness, and the goal to establish a permanent emergency shelter for homeless
individuals and families in Lodi has been identified as one of the top priorities of both the LCOH and the SJCoC. Construction and operation of a shelter is one of the most immediate
and concrete actions the City can take in implementing Program 4.3 of the Housing Element to address homelessness.
§301(a)(1) The predevelopment, development, acquisition, rehabilitation, and preservation of multifamily, residential live-work, rental housing that is affordable to extremely low-,very
low-, low-, or moderate-income households, including necessary Operating subsidies.
§302(c)(4) Plan Rev. 2/26/20
§302(c)(4)(A) Describe the manner in which allocated funds will be used for eligible activities.
PLHA funds will be used for capital costs for a permanent emergency homeless shelter, including predevelopment, infrastructure and site improvements.
§302(c)(4)(B) Provide a description of the way the Local government will prioritize investments that increase the supply of housing for households with incomes at or below 60 percent
of Area Median Income (AMI).
Lodi does not currently have a permanent shelter for people experiencing homelessness. The Lodi Committee on Homelessness, in collaboration with several local and regional
homeless experts, has determined that a low-bar shelter with supportive services is critical to assisting the city's unsheltered homeless population. The proposed facility will provide
temporary emergency shelter for individuals and families that are typically at or below 30 percent of Area Median Income. The emergency shelter will serve as an interim step in
assisting the unsheltered homeless population in securing long-term housing.
Activities Detail (Activities Detail (Must Make a Selection on Formula Allocation Application worksheet under Eligible Activities, §301))
§301(a)(2) The predevelopment, development, acquisition, rehabilitation, and preservation of Affordable rental and ownership housing, including Accessory Dwelling Units (ADUs), that
meets the needs of a growing workforce earning up to 120 percent of AMI, or 150 percent of AMI in high-cost areas. ADUs shall be available for occupancy for a term of no less than
30 days.
§301(a)(3) Matching portions of funds placed into Local or Regional Housing Trust Funds.
§301(a)(4) Matching portions of funds available through the Low- and Moderate-Income Housing Asset Fund pursuant to subdivision (d) of HSC Section 34176.
§301(a)(5) Capitalized Reserves for Services connected to the preservation and creation of new permanent supportive housing.
PLHA Page 5 302(c)(4) Plan
PLHA funds will be used to support predevelopment, infrastructure and site improvements for a permanent homeless shelter. Specific activities may include: identifying a site,
preliminary environmental studies, business and operational plan, conceptual design, site layout, site and facility improvement plans, cost estimates, development schedule,
entitlements, construction documents, contractor bid and selection process, site preparation and infrastructure improvements and maintenance/operations.
Complete the table below for each proposed Activity to be funded with 2019-2023 PLHA allocations. If a single Activity will be assisting households at more than one level of Area
Median Income, please list the Activity as many times as needed to capture all of the AMI levels that will be assisted, but only show the percentage of annual funding allocated to the
Activity one time (to avoid double counting).
2021 2022 2022
100%
§302(c)(4)(E)(i) Percentage of
Funds Allocated for the
Proposed Activity
100%100%100%Emregency SheltersEmregency SheltersEmregency SheltersEmregency SheltersFunding Allocation Year 2019 2019 2020 2020 2021 2023 2023
Emregency SheltersEmregency SheltersEmregency SheltersTOTAL50%30%50%30%50%§302(c)(4)(E)(ii) Area Median
Income Level Served 30%50%
§302(c)(4)(E)(i) Provide a description of how allocated funds will be used for the proposed Activity.
§302(c)(4)(E)(ii) Unmet share of
the RHNA at AMI Level 244 253 497
30%50%30%Emregency Shelters100%
Type of Activity for Persons
Experiencing or At Risk of
Homelessness
Emregency SheltersEmregency Shelters
PLHA Page 6 302(c)(4) Plan
§301(a)(7) Accessibility modifications in Lower-income Owner-occupied housing.
Predevelopment phase and apply for planning entitlements - July 2020 to March 2021
Approval of entitlements, draft construction documents, contractor bid and selection process, issuance of building permits – March to November 2021
Infrastructure and site improvements (Phase 1) – March 2022 to February 2023
Site improvements (Phase 2) – March 2023 to February 2024
50
§302(c)(4)(E)(iv) Period of
Affordability for the Proposed
Activity (55 years required for
rental housing projects)
N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
§302(c)(4)(E)(ii) Projected
Number of Households Served 45 5
§302(c)(4)(E)(iii) A description of major steps/actions and a proposed schedule for the implementation and completion of the Activity.
§301(a)(8) Efforts to acquire and rehabilitate foreclosed or vacant homes and apartments.
§301(a)(9) Homeownership opportunities, including, but not limited to, down payment assistance.
§301(a)(10) Fiscal incentives made by a county to a city within the county to incentivize approval of one or more affordable housing Projects, or matching funds invested by a county in
an affordable housing development Project in a city within the county, provided that the city has made an equal or greater investment in the Project. The county fiscal incentives shall
be in the form of a grant or low-interest loan to an affordable housing Project. Matching funds investments by both the county and the city also shall be a grant or low-interest deferred
loan to the affordable housing Project.
File Name:Plan Adoption
§302(c)(4)(D) Evidence that the Plan was authorized and adopted by resolution by the
Local jurisdiction and that the public had an adequate opportunity to review and comment
on its content.
Attached and on USB?Yes
PLHA Page 7 Legislative Contacts
State Senate Member
U.S. House of Representatives
Activity Location 1 (if different from applicant location)
District #First Name Last Name
State Assembly Member
Rev. 2/26/20Legislative and Congressional Information
U.S. House of Representatives 9 Jerry McNerney
District #First Name Last Name
State Assembly Member 9 Jim Cooper
Provide the Legislative and Congressional information for the applicant and each activity location, (if different than applicant location), included in this application.
To locate or verify the Legislative and Congressional information, click on the respective links below and enter the applicant office location zip code, the activity
location site zip code(s) (i.e. zip code(s) where activities are performed), and any additional activity location site(s), as applicable.
Applicant Office Location
State Senate Member 5 Cathleen Galgiani
California State Assembly California State Senate U.S. House of Representatives
City of Lodi
2020 Permanent Local Housing
Allocation (PLHA) Grant
Application
Presented by
Community Development Department
July 2020
Permanent Local Housing Allocation
California Senate Bill 2 (2017) established a $75 real
estate recording fee to increase supply of affordable
housing
Lodi is eligible to receive $336,265 for the 2019-2020
Fiscal Year and is estimated to receive $2,017,590 over
the next 5 years
Lodi must submit a grant application and a 5-Year Plan
describing the use of funds to the California Department
of Housing and Community Development (HCD) to be
eligible for funds
Submission of the PLHA grant application requires
comment from the public and City Council approval
Permanent Local Housing Allocation
The 5-Year Plan is tentative. In proceeding years,
changes to the 5-Year Plan that result in a reallocation of
more than 10 percent of funds would require HCD and
Council approval
Lodi’s PLHA funding would be used for capital costs for
a permanent emergency homeless shelter, including
predevelopment, infrastructure, and site improvements
Council is not approving the planned project, but the
submission of the PLHA grant application
City staff is working to acquire additional grant funds for
the permanent emergency homeless shelter project
Recommendation
Public Hearing to Consider Adopting a Resolution
Adopting a Five-Year Plan for the Permanent Local
Housing Allocation (PLHA) Grant Program, Approving
Submission of the 2020 PLHA Grant Application and
Authorizing the City Manager to Enter into Agreements
with the California Department of Housing and
Community Development for a Permanent Homeless
Shelter Project -Predevelopment Phase ($2,017,590)
Questions/Comments
Questions/Comments?