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HomeMy Public PortalAbout12) 10A_PLHA_Staff ReportMANAGEMENT SERVICES DEPARTMENT MEMORANDUM D ATE: October 6, 2020 TO: The Honorable City Council FROM: Bryan Cook, City Manager Via: Brian Haworth, Assistant to the City Manager Via: Scott Reimers, Interim Community Development Director By: Tinny Chan, Management Analyst SUBJECT: PERMANENT LOCAL HOUSING ALLOCATION FUNDING RECOMMENDATION: The City Council is requested to: 1. Provide direction on how the City should appropriate its Permanent Local Housing Allocation (PLHA) funding for fiscal year 2020-2021; and 2. Approve Resolution No. 20-5492, should Council direct staff to use PLHA funding for eligible, city-specific initiatives (Attachment “A”). BACKGROUND: 1.On Sept. 29, 2017, Governor Jerry Brown signed SB 2, the Building Homes and Jobs Act. The law established a permanent funding source—otherwise known as Permanent Local Housing Allocation (PLHA) funding—to increase the state’s supply of affordable housing. This was done by imposing a $75 recording fee on real estate documents. 2.On Feb. 26, 2020, the state’s Housing and Community Development Department announced that the County of Los Angeles would receive over $11 million in PLHA funding for fiscal year 2020-2021. Of this amount, the City would receive its first formula-based grant of $124,815. Subsequent fiscal year allocations will fluctuate based on the local real estate market. 3.On June 17, 2020, the Los Angeles County Development Authority (LACDA)—as the funding administrator—held a teleconference with local cities to introduce the new funding source. A proposal was also unveiled for this year’s countywide allocation of AGENDA ITEM 10.A. City Council October 6, 2020 Page 2 of 3 $11 million (in PLHA funds) for the LACDA’s Expanded Eviction Defense Program. Funds would support the tenant outfall of the current pandemic, i.e., limited and full scope legal representation, short-term rental assistance, case management, and “know-your-rights” workshops (Attachment “B”, pg. 4). 4. On June 26, 2020, it was confirmed that local cities could determine how to use its PLHA funding for eligible activities (Attachments “C” and “D”) rather than appropriating funding to the LACDA’s recommended eviction defense program. Once Council makes a decision on how to use this year’s allocation, staff must notify the LACDA of the City’s proposed funding activities—via resolution—no later than October 15, 2020. Funds would then be released in late-December with programs to start in January 2021. ANALYSIS: Tonight’s discussion centers on two questions: 1. Does Council wish to use this fiscal year’s PLHA funding on the LACDA’s Expanded Eviction Defense Program; or 2. Does Council wish to use this fiscal year’s PLHA funding on other eligible activities that better support local housing policies (e.g., RHNA, General Plan)? Should Council pursue the first option, no other action is needed. However, if Council wishes to pursue the second option, the attached matrix identifies eligible and city-specific initiatives for consideration (Attachment “E”). Staff will provide a presentation of the matrix, which identifies six eligible activities. The matrix details each activity's pros and cons and determines how they can further city policies. Staff Recommendations: 1. While the LACDA is encouraging local cities to allocate its PLHA funds to their Expanded Eviction Defense Program, staff does not recommend this because: • There is no quantifiable way to show that the City’s PLHA funds will directly help Temple City residents; and • There are more efficient ways to use the City’s PHLA funds that better align with local housing policies. Council may wish to consider funding the Expanded Eviction Defense Program next year, especially if this need is identified in the City’s soon-to-be-completed Homeless City Council October 6, 2020 Page 3 of 3 Plan. 2. Staff recommends using this year’s PLHA funding on Matrix Activity No. 2, which establishes a loan or grant program to create up to 12 affordable junior accessory dwelling units. The initiative also: • Helps the City meet its regional housing needs assessment (RHNA) goals; and • Is consistent with strategies identified in the General Plan to reduce impacts on single-family neighborhoods. As an alternative recommendation, Council is encouraged to consider Matrix Activity No. 5, which funds accessibility modifications in lower-income, owner- occupied housing. While it does not help the City meet its RHNA goals, it would: • Provide additional funding for the City’s existing handyworker and home rehabilitation grant program, which has a large waiting list; and • Yield an additional 12 handyworker grants or three housing rehabilitation loans for this fiscal year. CITY STRATEGIC GOALS: Actions contained in this report align with the following strategic goals: quality of life and good governance. FISCAL IMPACT: Annual funding is limited to a five-percent administration fee. For this fiscal year, that amount is $6,240.75. The use of subsequent year funding allocations will require Council review and approval. ATTACHMENTS: A. Resolution No. 20-5492 B. Expanded Eviction Defense Program C. Confirmation Letter D. Eligible PLHA Funding Activities E. Matrix of Eligible and City-Specific Initiatives RESOLUTION 20-5492 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TEMPLE CITY APPROVING PARTICIPATION IN THE LOS ANGELES URBAN COUNTY PERMANENT LOCAL HOUSING ALLOCATION PROGRAM BY AUTHORIZING THE MAYOR (OR DESIGNEE) TO SIGN A CONTRACT FOR FUNDING FOR THIS PROGRAM FROM THE COUNTY OF LOS ANGELES WHEREAS, Senate Bill 2, enacted in 2017 and codified in Government Code section 27388.1 and Health and Safety Cody section 50470, provided a funding source (Permanent Local Housing Allocation) to all local governments in California to help cities and counties implement plans to increase the affordable housing stock; and WHEREAS, as a result, the City of Temple City will receive $124,815 for fiscal year 2020-2021; and WHEREAS, the City of Temple City would be able to use these funds (PLHA funds) for certain eligible activities defined by the California Department of Housing and Community Development; and WHEREAS, the PHLA funds would be administered by the Los Angeles County Development Authority; and WHEREAS, the City of Temple City desires to participate in the Los Angeles Urban County Permanent Local Housing Allocation (PLHA) Program for the period beginning January 2021; and WHEREAS, the City authorizes the execution of a contract with the County of Los Angeles to receive said PLHA funds. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Temple City as follows: SECTION 1. The City Council approves eligible, city-specific initiatives to be implemented using PLHA funds for fiscal year 2020-2021, which are identified in Exhibit 1. SECTION 2. The City Council authorizes the Mayor (or designee) to execute any and all documents necessary for participation in the Los Angeles Urban County PLHA Program on behalf of the City of Temple City. SECTION 4. This Resolution shall take effect immediately upon its adoption by the City Council SECTION 3. The Secretary shall certify to the adoption of this Resolution. APPROVED AND ADOPTED on this 6th day of October, 2020. Tom Chavez, Mayor DRAFT ATTACHMENT A Resolution No. 20-5492 Page 2 of 2 I hereby certify that the foregoing Resolution was adopted by the City Council of the City of Temple City at a meeting held on the 6th of October, 2020, by the following vote: ATTEST:APPROVED AS TO FORM: Peggy Kuo, City Clerk Gregory Murphy, City Attorney YES:Councilmember- NO:Councilmember- ABSENT:Councilmember- ABSTAIN:Councilmember- ATTEST: Peggy Kuo, City ClerkDRAFT ATTACHMENT A Resolution No. 20-5492 Page 2 of 2 EXHIBIT 1 PROPOSED ACTIVITY OR ACTIVITIES FOR THE STATE PERMANENT LOCAL HOUSING ALLOCATION PROGRAM City Name ________________________ Date _________________ Name and Descrip2on of the Eligible Ac2vity or Ac2vi2es the City would like to Implement Using PLHA funds: Budget (s) Proposed for Ac2vity or Ac2vi2es: Per2nent Facts and Informa2on about the Priority Need for this Ac2vity or Ac2vi2es in your City: SubmiJed to LACDA By: _________________________ Date: ___________________ Title: _________________________________________ DRAFT ATTACHMENT A 1 Permanent Housing Local Allocation Plan 2019-2023 302 (c)(4) Plan Eligible Applicant Type Entitlement Local Government Recipient of PLHA Formula Allocation County of Los Angeles Approximate PLHA Formula Allocation Amount $11,025,126 Approximate PLHA Formula Five-Year Allocation Amount $66,150,756 §302(c)(4)(A) Describe the manner in which allocated funds will be used for eligible activities. The County of Los Angeles will use PLHA formula allocation funds to deliver homelessness prevention services under its Expanded Eviction Defense Program (EDP), to be launched in the last quarter of calendar year 2020: 1) limited and full scope legal representation; 2) short- term (90 day) rental assistance; 3) program navigation and case management; and 4) tenant legal clinics/"Know-Your-Rights" workshops. The primary goal of the County’s EDP is to provide low-income renters making up to 30% of the Area Median Income (AMI) and at-risk of becoming homeless due to a pending eviction case with free services and resources to aid them in maintaining and stabilizing their rental housing before, during, and after undergoing formal eviction proceedings—and thus, preventing the multitude of negative outcomes associated with evictions and disruptive displacements. PLHA funds would be used to provide free comprehensive legal services, case management, and short-term rental assistance to ensure low-income renters have the resources at their disposal to stabilize their housing and avoid becoming homeless due to a financial hardship. In addition, PLHA funds would be used to provide tenant/legal education to communities that are at high risk for displacement due to the number of low-income and rent burdened households, among other key socio-economic indicators for tenant vulnerability. §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). The County of Los Angeles will prioritize investments that increase the supply of housing for households with income at or below 60% of AMI by using PHLA funds to provide critical homelessness prevention services to low income households making up to 30% of the AMI. ATTACHMENT B 2 §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. The Plan is consistent with the programs set forth in the 2014-2021 Los Angeles County Housing Element because it aligns with and supports three key policies that drive several of the programs outlined in the Housing Element: 1) provide financial assistance and ensure that necessary supportive services are provided to assist low and moderate income households and those with special needs to attain and maintain affordable housing (Policy 4.1); 2) enforce laws against illegal acts of housing discrimination (Policy 8.2); and 3) ensure collaboration among County departments and other agencies in the delivery of housing and related services (Policy 9.1). The County's EDP supports Policy 4.1 via its short-term rental assistance component that will provide up to three months of financial assistance to households that need aid to stabilize their housing; Policy 8.2 via limited scope and full scope legal representation that will be provided to low income renters undergoing an eviction case as a result of landlord intimidation or retaliation; and Policy 9.1 via collaborations with the Los Angeles County Development Authority and various community-based organizations and legal service providers to implementation the eligible activities that will be funded by the PLHA. Lastly, the County's Plan aligns with and complements the following programs set forth in the Housing Element: 1) Program 10, First 5 LA Supportive Housing for Homeless Families Fund; 2) Program 24, Fair Housing Program; and 3) Program 30, Housing Element Annual Report. §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)(E)(i) Provide a description of how allocated funds will be used for the proposed Activity. The County's proposed plan will dedicate 100% of allocated PLHA funds to implement two core components of the County's EDP: 1) legal services, which includes limited and full scope legal representation 2) short-term rental assistance 3) program navigation & case management 4) Tenant legal clinics/workshops ATTACHMENT B 3 Proposed PLHA Activity 2019-2023 302(c)(4)(E) Permanent§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 §302(c)(4)(E)(ii) Projected Number of Households Served 0 800 4800 4800 4800 §302(c)(4)(E)(ii) Unmet share of the RHNA at AMI Level n/a n/a n/a n/a n/a 30%30%30% Type of Activity for Persons Experiencing or At Risk of Homelessness PermanentPermanentPermanent§302(c)(4)(E)(ii) Area Median Income Level Served 30% §302(c)(4)(E)(i) Percentage of Funds Allocated for the Proposed Activity 100%100%100%100% Funding Allocation Year 2019 2020 2021 2022 2023 15200 0 TOTAL ATTACHMENT B 4 §302(c)(4)(E)(iii) A description of major steps/actions and a proposed schedule for the implementation and completion of the Activity. September 10, 2019-L.A. County Board of Supervisors directs the Department of Consumer and Business Affairs (DCBA) to develop an implementation and evaluation plan for an Expanded Eviction Defense Program (EDP) March 4, 2020-Board of Supervisors declares State of Emergency in Los Angeles County due to the COVID-19 pandemic June 2020-DCBA, in partnership with non-profit legal service providers and community based organizations, to launch a countywide, 6-month Emergency Eviction Prevention Program in response to the COVID-19 emergency. This program will provide limited legal services, in addition to general and targeted tenant outreach and education, to address the immediate short-term needs of County residents during the COVID-19 emergency. This emergency program will fill a service gap while the long-term Expanded Eviction Defense Program ramps up for launch in November of 2020. November 2020-expected disbursement of PLHA funds November 2020-Begin year two delivery of PLHA funded activities, which include comprehensive legal services, including full scope legal representation, short-term rental assistance, case management/program navigation, and tenant clinics/workshops December 2020-Expiration of countywide Emergency Eviction Prevention Program. Residents in need of full scope legal services, rental assistance, and case management will be folded into the Expanded Eviction Defense Program. January 2021-Begin year three implementation PLHA funded EDP activities January 2022-Begin year four implementation of PLHA funded EDP activities January 2023-Begin year five implementation of the PLHA funded EDP activities December 2023-End of five-year PLHA funded EDP activities ATTACHMENT B ATTACHMENT C ATTACHMENT C PERMANENT LOCAL HOUSING ALLOCATION (PLHA) LIST OF ELIGIBLE ACTIVITIES Eligible activities for the formula allocations are: 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. 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. 3.Matching portions of funds placed into Local or Regional Housing Trust Funds. 4.Matching portions of funds available through the Low- and Moderate-Income Housing Asset Fund pursuant to subdivision (d) of HSC Section 34176. 5.Capitalized Reserves for Services connected to the preservation and creation of new permanent supportive housing. 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. A.This activity may include sub-awards to administrative entities as defined in HSC Section 50490(a)(1-3) that were awarded the CESH program or HEAP funds for rental assistance to continue assistance to these households. B.Applicants must provide rapid rehousing, rental assistance, navigation centers, emergency shelter, and transitional housing activities in a manner consistent with the Housing First practices described in 25 CCR, Section 8409, subdivision (b)(1)-(6) and in compliance with WIC Section 8225(b)(8). An applicant allocated funds for the new construction, rehabilitation, and preservation of permanent supportive housing shall incorporate the core components of Housing First, as provided in WIC Section 8255, subdivision (b). 7.Accessibility modifications in lower-income owner-occupied housing. 8.Efforts to acquire and rehabilitate foreclosed or vacant homes and apartments. 9.Homeownership opportunities, including, but not limited to, down payment assistance. 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. ATTACHMENT D ATTACHMENT B Permanent Local Housing Allocation 2020 Total Urban County Entitlement $11,025,126 Less Administration (5%)$551,256 Total 2020-2021 to be Allocated $10,473,870 City Population 2015 Poverty 2015 Overcrwding 205 Factor Allocation AGOURA HILLS 20,697 1194 65 0.004345193 $45,511 ARCADIA 57,564 5486 735 0.017424818 $182,505 AVALON 3,777 539 313 0.002380354 $24,932 AZUSA 48,033 7569 1,758 0.023293918 $243,977 BELL 35,998 9947 2,394 0.027934862 $292,586 BELL GARDENS 42,842 11935 3,556 0.035962885 $376,671 BEVERLY HILLS 34,663 3100 317 0.009723729 $101,845 CALABASAS 24,075 1897 62 0.005785489 $60,596 CLAREMONT 35,762 2591 300 0.009000859 $94,274 COMMERCE 13,017 2052 724 0.007213434 $75,553 COVINA 48,587 5245 1,042 0.017183349 $179,976 CUDAHY 24,138 7527 1,922 0.021198893 $222,034 CULVER CITY 39,469 3491 803 0.012618399 $132,163 DIAMOND BAR 56,471 3919 322 0.013396981 $140,318 DUARTE 21,769 3313 535 0.009425774 $98,724 EL SEGUNDO 16,929 1224 208 0.004496691 $47,098 HAWAIIAN GARDENS 14,475 4426 806 0.011318428 $118,548 HIDDEN HILLS 1,557 76 2 0.000295148 $3,091 HERMOSA BEACH 19,747 783 79 0.003660287 $38,337 IRWINDALE 1,426 178 31 0.000542803 $5,685 LA CANADA-FLINTRIDGE 20526 518 129 0.003520497 $36,873 LA HABRA HEIGHTS 5,425 186 39 0.001023701 $10,722 LA MIRADA 49,182 3453 1,257 0.015277139 $160,011 LA PUENTE 40,496 5853 1,911 0.020385377 $213,514 LA VERNE 31,920 2576 352 0.008744464 $91,588 LAWNDALE 33,231 5915 1,639 0.018693836 $195,797 LOMITA 20,622 3009 479 0.008629249 $90,382 MALIBU 12,856 1339 95 0.003815106 $39,959 MANHATTAN BEACH 35,603 1416 90 0.006415414 $67,194 MAYWOOD 27,739 8284 2,405 0.024512447 $256,740 MONROVIA 37,164 3738 685 0.012315745 $128,994 RANCHO PALOS VERDES 42,464 1799 277 0.008437302 $88,371 ROLLING HILLS ESTS 8188 444 43 0.001738249 $18,206 SAN DIMAS 34,073 2283 223 0.008062317 $84,444 SAN FERNANDO 24,296 4563 947 0.013120635 $137,424 SAN GABRIEL 40,198 5492 1,402 0.017948713 $187,992 SAN MARINO 13,353 740 108 0.002996815 $31,388 SANTA FE SPRINGS 17,162 2153 660 0.007591641 $79,514 SIERRA MADRE 11,084 636 62 0.002420530 $25,352 SIGNAL HILL 11,332 2041 515 0.006251968 $65,482 SOUTH EL MONTE 20,483 4200 995 0.012318315 $129,020 SOUTH PASADENA 25,999 2025 319 0.007127353 $74,651 TEMPLE CITY 36,079 3414 745 0.011916778 $124,815 WALNUT 29,970 1999 223 0.007175079 $75,151 WEST HOLLYWOOD 35,332 5408 311 0.013320883 $139,521 WESTLAKE VILLAGE 8,471 512 16 0.001775713 $18,599 TOTAL PARTICIPATING CITIES 1,234,244 150,488 31,901 0.482737559 $5,056,130 Supervisorial Districts (Unincorporated Area only) * I.262483 52,187 13,007 0.156276164 $1,636,816 II.253210 64,961 12,653 0.173593546 $1,818,196 III.21,410 1,826 60 0.005377334 $56,321 IV.223783 24,416 6,599 0.086079046 $901,581 V.279396 31,613 4,587 0.095936351 $1,004,825 TOTAL DISTRICTS 1,040,282 175,002 36,907 0.517262441 $5,417,739 TOTAL ALLOCATIONS 2,274,526 325,490 68,808 100% $10,473,870 * Supervisorial District boundary updated after 2011 adopted reapportionment borders; the population numbers are based on 2011- 2015 ACS Data All Participating Cities $5,056,130 All Supervisorial Districts $5,417,739 County Administration $551,256 TOTAL URBAN COUNTY DISTRIBUTION $11,025,126 ATTACHMENT D Permanent Local Housing Allocation Funds Possible Programs for Fiscal Year 2020-2021 ELIGIBLE ACTIVITY PROS CONS ALIGNMENT WITH LOCAL POLICIES STAFF RECOMMENDATION No. 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. Can possibly be used to redevelop the former Chamber of Commerce site at 9050 E. Las Tunas Drive. May be expensive to fund. No previous Council direction on the site’s redevelopment. Future PLHA funding may be insufficient to make a project “pencil out.” This has not been included in the Housing Element’s list of existing programs. Not recommended. For Consideration: If Council wants to redevelop the property into affordable housing, it would be best to join San Gabriel Valley Regional Housing Trust. Participation would allow for the possible allocation of regional housing funds. No. 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. Is consistent with the General Plan’s strategy to reduce impacts on single-family neighborhoods. Would be a good way to increase affordable housing throughout the city. Helps with RHNA numbers. Could focus funding on low- to moderate-income seniors. Allows affordable housing to be spread out, instead of concentrated to one area. Staff-intensive; would require much Council policy to establish the program. Creates additional density in single-family zoned areas. Is consistent with the Housing Element, i.e., Category 2, Program 8: Second Unit Ordinance. Recommended. For Consideration: The City would need to hire a consultant to monitor affordability covenants. The program could possibly produce 8-12 net new junior ADU units with individual $10K-$15K grant/loans. ATTACHMENT E ELIGIBLE ACTIVITY PROS CONS ALIGNMENT WITH LOCAL POLICIES STAFF RECOMMENDATION No. 3: Matching portions of funds placed into local or regional housing trust funds. N/A N/A This has not been included in the Housing Element’s list of existing programs. Not recommended. For Consideration: Council would need to first approve membership in the San Gabriel Valley Regional Housing Trust. A staff report outlining membership options and responsibilities will be presented on Nov. 3. No. 4: Assisting persons who are experiencing or at risk of homelessness, including, but not limited to, p roviding 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. Funds can be used for homeless prevention initiatives and homeless plan strategies (e.g., case management, etc.). No existing guiding policy. Does not help with RHNA numbers. Is consistent with the Housing Element, i.e., Program 5: Rental Assistance (for Existing Cost Burdened Households). Not recommended. For Consideration: LACDA has created the Eviction Defense program. It would be more prudent to opt-in to their program rather than creating a program ourselves. Reconsider this as an option after the City’s Homeless Plan is adopted. No. 5: Accessibility modifications in lower-income, owner-occupied housing. Leverages the City’s existing CDBG handyworker grant program. Does not help with RHNA numbers. Is consistent with the Housing Element, i.e., Program 12: Reasonable Accommodation. Recommended alternative. For Consideration: There is a large waiting list for the City’s handyworker grant program; additional funding would help meet demand. ATTACHMENT E ELIGIBLE ACTIVITY PROS CONS ALIGNMENT WITH LOCAL POLICIES STAFF RECOMMENDATION No. 6: Homeownership opportunities including, but not limited to, down payment assistance. Addresses the reality that it’s difficult for younger people (or young families) to buy homes in Temple City. Limited availability of loans/grants (acting as second mortgages) because of locally- high real estate prices. Is a staff intensive program, i.e., program development and the monitoring of affordability covenants. Does not help with RHNA numbers. Is consistent with the Housing Element, i.e., Program 6: Home Ownership Program for Lower-Income Households. Not recommended. For Consideration: This program is not the most efficient use of funds given it may only assist two or three households. ATTACHMENT E