DATE: October 20, 2026
TO: Board of Supervisors
SUBMITTED BY: Steven E. White, Director
Department of Public Works and Planning
SUBJECT: Substantial Amendment to the HOME Investment Partnerships - American Rescue Program (HOME-ARP) Allocation Plan
RECOMMENDED ACTION(S):
TITLE
1. Amend FY 2021-22 Action Plan and HOME-ARP Allocation Plan;
2. Authorize the Director of the Department of Public Works and Planning or designee to execute Standard Form 424s and Certifications for the HOME Investment Partnerships - American Rescue Plan;
3. Amend FY 2025-29 Consolidated Plan to delete HOME-ARP projects, HOME-ARP funds, and relevant references to the HOME-ARP program; and
4. Amend FY 2025-26 and FY 2026-27 Action Plans to delete HOME-ARP projects, HOME-ARP funding, and relevant references to the HOME-ARP program.
REPORT
There is no Net County Cost (NCC) inherently associated with the recommended actions. The recommended actions are necessary for the County's use of its HOME Investment Partnerships - American Rescue Plan (HOME-ARP) program, permitting staff to amend the FY 2021-22 Action Plan and HOME-ARP Allocation Plan and to submit the amendments to the U.S. Department of Housing and Urban Development (HUD). The third and fourth recommended actions are necessary to remove references to the HOME-ARP program from the 2025-29 Consolidated Plan and 2026-27 Action Plan based on HUD direction that the HOME-ARP program is to be included only in the 2021-22 Action Plan. This item is countywide.
ALTERNATIVE ACTION(S):
Your Board may choose not to approve the first and second recommended actions, in which case the County will not amend the HOME-ARP Allocation Plan to establish preferences for qualified populations served in projects funded by HOME-ARP, and the proposed Sendero Commons project will be ineligible for funding. In the more than three years since the HOME-ARP Allocation Plan was adopted, no developers have been willing to navigate the complex HOME-ARP process until now, and it is uncertain if any other projects will apply and be under agreement before the funds expire on September 30, 2030. There is no viable alternative action for the third and fourth recommended actions, as failing to make those changes will leave the specified plan documents out of compliance with HUD’s direction.
FISCAL IMPACT:
There is no increase in NCC associated with the recommended actions. The County has already been granted an allocation of $4,960,751 under the HOME-ARP program administered by HUD, which is available for use through September 30, 2030. The HOME-ARP funds are included in the Department of Public Works and Planning - Org 5512-2035 FY 2026-27 Approved Budget, and any projects funded under the HOME-ARP program will be allocated from this account. Further, any future project funded following this amendment will be presented for approval by your Board.
DISCUSSION:
On March 14, 2023, the Board approved a substantial amendment to the 2021-22 Action Plan to adopt a HOME-ARP Allocation Plan, which was necessary to accept the allocation of HOME-ARP funds. Congress established the program under Section 3205 of the American Rescue Plan Act of 2021 (Public Law 117-2), signed into law on March 11, 2021, in response to the COVID-19 Pandemic. HOME-ARP requires jurisdictions fund activities that benefit four specific qualifying populations (QPs) to address housing instability and homelessness. The four QPs encompass: homeless; at risk of homelessness; fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking; and other populations who do not qualify under any of the populations above but require services or housing assistance to prevent homelessness or are at the greatest risk of housing instability.
Establishing Limitations and Preferences on Qualifying Populations
Jurisdictions may not exclude any QPs from HOME-ARP funding but may establish a preference or limitation if justified in their Allocation Plan. These preferences may be project specific. However, the County’s original HOME-ARP Allocation Plan did not establish a preference amongst the QPs.
Sendero Commons has applied for HOME-ARP housing construction funding assistance. Currently in pre-development, the project proposes to build 87 units of permanent supportive housing (and one manager unit for a total of 88 units) for extremely low-income households (30% Area Median Income or less) in the city of Sanger. The project is also assisted with Homekey+ and No Place Like Home (NPLH) funding awarded by the California Department of Housing and Community Development.
Both Homekey+ and NPLH’s funding requires that all of the project’s 87 affordable units be rented to households with at least one member experiencing serious mental illness or a behavioral health challenge. The project’s Homekey+ terms also have specific provisions requiring that entering tenants be persons experiencing or at risk of homelessness, and half the units have a preference for veteran households.
Because the Sendero Commons project establishes eligibility requirements to serve individuals and households who are homeless or at risk of homelessness, veterans, and persons with serious mental illness or mental health issues, it is not eligible for HOME-ARP funding without amending the HOME-ARP Allocation Plan to establish the limitation and preference.
The proposed Substantial Amendment to the 2021-22 Action Plan and HOME-ARP Allocation Plan (Substantial Amendment) would establish a project-level preference/limitation for this project’s populations defined above, but all other projects would still be required to demonstrate no preferences for or against any of the four QPs.
Removal of Match Requirement
When the County originally submitted its HOME-ARP Allocation Plan, it established a 100% match requirement to HOME-ARP rental housing development assistance, to be provided by the project developer. As Sendero Commons, which has 100% of the activity’s allocation, has secured all other project funding from other sources, this match requirement is not necessary. As funded, HOME-ARP would fund approximately 10% of the project’s construction costs and assist 10 units.
The proposed Substantial Amendment would remove that developer match requirement and amend the number of units in the HOME-ARP housing production goal from an estimated “10-20 units” to the planned 10 units of the Sendero Commons proposal.
Reallocation of Activity Funding
HOME-ARP allows participating jurisdictions to allocate funding to specific activities: nonprofit operating assistance, nonprofit capacity building, supportive services, acquisition and development of non-congregate shelter, tenant based rental assistance (TBRA), development of affordable rental housing which covers both construction and ongoing operating costs, and administration. The County’s Allocation Plan allocated funding to all activities besides development of non-congregate shelter and TBRA.
This component of the amendment is not necessary to support the Sendero Commons project. However, to help streamline administrative requirements and allow a larger pool of funding to be more attractive to future applicants while better serving all four QPs, the proposed Substantial Amendment would realign funding previously allocated to Nonprofit Operating Assistance ($247,600) and Nonprofit Capacity Building ($247,600) to Supportive Services. Further, Rental Housing Ongoing Operating Costs ($450,000) are no longer needed, as the period of time HOME-ARP is eligible to support is already fully subsidized by State funding sources to Supportive Services. Supportive Services allocation would be amended to $1,717,851 to account for these reallocated funds.
Amendments to FY 2025-29 Consolidated Plan, FY 2021-22, 2025-26 and 2026-27 Action Plans Also Required
On August 5, 2025, your Board adopted the FY 2025-29 Consolidated Plan, which included the FY 2025-26 Action Plan. On May 19, 2026, your Board adopted the FY 2026-27 Action Plan. The proposed substantial amendments to the 2025-29 Consolidated Plan, the FY 2025-26 Action Plan, and the FY 2026-27 Action Plan, will remove HOME-ARP projects, HOME-ARP funds, and relevant references to the HOME-ARP program from these plans based on HUD direction that the HOME-ARP program is to be included only in the 2021-22 Action Plan. Substantial amendments require a public notice to be published 30 days prior to the meeting at which action will be taken. Notice of today’s meeting was published in the Business Journal and posted on the Community Development webpage on September 18, 2026.
HUD Approval Following Board Approval
If approved by your Board, staff will submit the Substantial Amendment for HUD’s review, which is expected to take 45 days. If HUD approves the substantial amendment, the Sendero Commons project will be eligible for HOME-ARP funding, and a final funding agreement would return to your Board for approval at a later date.
REFERENCE MATERIAL:
BAI #8, May 19, 2026
BAI #16, August 5, 2025
BAI #9, March 14, 2023
BAI #8, May 11, 2021
ATTACHMENTS INCLUDED AND/OR ON FILE:
On file with Clerk - Draft Substantial Amendment to the 2021-22 Action Plan and HOME-ARP Allocation Plan
On file with Clerk - Draft Substantial Amendment to the 2025-29 Consolidated Plan, including the 2025-26 Annual Action Plan
On file with Clerk - Draft Substantial Amendment to the 2026-27 Annual Action Plan
CAO ANALYST:
Dylan McCully