HomeMy WebLinkAboutItem 12c - SGVCG's Whitepaper on Los Angeles Homeless Service Authority Reform
DATE: March 16, 2021
TO: Honorable Mayor and City Council
FROM: Sara Somogyi, Director of Recreation and Community Services
By: Ashley Marston, Recreation Coordinator
SUBJECT: ADOPT RESOLUTION NO. 7354 APPROVING THE SAN GABRIEL VALLEY
COUNCIL OF GOVERNMENT'S WHITEPAPER ON LOS ANGELES
HOMELESS SERVICE AUTHORITY REFORM
Recommendation: Approve
SUMMARY
With epidemic homelessness throughout Los Angeles County and challenges within the
current homelessness service system, the San Gabriel Valley Council of Government
(“SGVCOG”) authored a Whitepaper to advocate for reformations within the current system
to increase representation and autonomy for smaller cities, as well as provide an alternative
option to pursue independent control of homelessness funds. To set as foundation to better
address homelessness within the San Gabriel Valley and the County as a whole, it is
recommended that the City Council adopt Resolution No. 7354 approving the San Gabriel
Valley Council of Government's Whitepaper on Los Angeles Homeless Service Authority
Reform.
BACKGROUND
The current homelessness service structure is a complex system with many overlapping
administrations including Los Angeles County, City of Los Angeles, the Los Angeles
Homeless Services Authority (“LAHSA”), and the administration of Measure H. LAHSA is
governed by an appointed, ten-member Commission that convenes monthly. Its members
consist of five members appointed by the Mayor and City Council of City of Los Angeles and
one member appointed by each member of Board of Supervisors.
In response to the Countywide homelessness crisis and challenges within the current
homelessness services system, the Los Angeles County Board of Supervisors approved a
motion on September 1, 2020, seeking to explore changes to the structure and function of
LAHSA and highlighting the need to examine the system as a whole. A similar motion was
Resolution No. 7354 approving the SGVCOG’s Whitepaper on LAHSA Reform
March 16, 2021
Page 2 of 3
approved by the City of Los Angeles City Council and LAHSA itself convened an Ad Hoc
Committee on Governance to consider parallel concerns. Subsequent events, including the
election of three new Los Angeles City Councilmembers and the announced retirement of
the Director of the County Homeless Initiative, have further set the stage for reform.
The SGVCOG is a joint powers authority that supports regional issues and implements
regional programs. The SGVCOG includes the 31 cities and unincorporated areas of Los
Angeles County Supervisorial Districts one, four, and five, representing 20% of the
population of Los Angeles County. In response to the County’s expressed desire for
improvement to the current homelessness system, the SGVCOG convened a working group
to draft a Whitepaper to ensure the San Gabriel Valley had a leading voice in the reform
efforts. This working group, consisting of representative from Arcadia and ten other cities,
met five times from September to November 2020.
The SGVCOG City Manager’s Steering Committee, the Homelessness Committee, and the
Executive Committee reviewed the Whitepaper at their respective meetings in November
and December. All three committees recommended that the Governing Board approve the
Whitepaper; the Governing Board adopted the paper in January 2021.
DISCUSSION
The purpose of this Whitepaper is to address the systemic problems with the current
homelessness response system, identify comprehensive solutions, confirm the San Gabriel
Valley’s commitment to best practices and programs, and demonstrate our desire to lead
the region to a more effective, County-wide coordinated strategy to combat homelessness.
Specifically, the paper identifies several problems with the current system, including a lack
of collaborative relationship with smaller cities, a lack of funding for locally based and
supported initiatives and programs, and poor communication and lack of transparency. To
address these problems, the Whitepaper proposes potential solutions to the current system
including increasing representation and autonomy for smaller cities, as well as leaving the
door open to pursue independent control of homelessness funds if these strategies are
unsuccessful at sufficiently resolving the stated concerns.
Adopting Resolution No. 7354 in support the Whitepaper would demonstrate Arcadia’s
commitment to have the San Gabriel Valley and its perspective cities hold a more vocal role
in mitigating homelessness in Los Angeles County.
ENVIRONMENTAL ANALYSIS
The proposed action does not constitute a project under the California Environmental
Quality Act (“CEQA”), and it can be seen with certainty that it will have no impact on the
environment. As such, this matter is exempt under CEQA.
Resolution No. 7354 approving the SGVCOG’s Whitepaper on LAHSA Reform
March 16, 2021
Page 3 of 3
FISCAL IMPACT
There is no fiscal impact as a result of the adoption of Resolution No. 7354.
RECOMMENDATION
It is recommended that the City Council determine that this action does not constitute a
project and is therefore, exempt under, the California Environmental Quality Act (“CEQA”);
adopt Resolution No. 7354 approving the San Gabriel Valley Council of Government's
Whitepaper on Los Angeles Homeless Service Authority Reform.
Attachments: Exhibit “A” – San Gabriel Valley Council of Government's Whitepaper on Los
Angeles Homeless Service Authority Reform
Exhibit “B” – Resolution No. 7354
Exhibit “A”
United We Stand:
Supporting a comprehensive, coordinated structure and strategy to meet
the homelessness crisis in Los Angeles County
A White Paper
Prepared and Adopted
by the San Gabriel Valley Council of Governments
January 21, 2021
Page 1 of 30
Table of Contents
INTRODUCTION 2
EXECUTIVE SUMMARY 3
BACKGROUND 6
PROBLEMS WITH THE CURRENT SYSTEM 11
POTENTIAL SOLUTIONS 18
DEMONSTRATING COMMITMENT TO QUALITY PROGRAMS AND SERVICES 29
CONCLUSION 30
Page 2 of 30
INTRODUCTION
The ever-worsening homeless crisis is a growing threat to the wellbeing, prosperity and quality of
life of our region. It is likely only to intensify due to the ongoing COVID-19 pandemic. The gravity
and urgency of the crisis requires a comprehensive, coordinated, Countywide structure and
strategy to end the shame of tens of thousands of people living on our streets.
Acknowledging this crisis and the problems with the current homelessness services system, the
Los Angeles County Board of Supervisors approved a motion, “Exploring New Governance
Models to Improve Accountability and Oversight of Homeless Funds” on September 1, 2020. This
motion focused on the structure and function of Los Angeles Housing Services Authority
(LAHSA) but highlighted the need to examine the system as a whole. Meanwhile, LAHSA itself
has convened an Ad Hoc Committee on Governance to consider similar concerns.
While we support the efforts of the County, LAHSA and the City of Los Angeles to seek a more
effective coordinating structure, we believe it is critical to directly involve the remaining 87 cities
that make up the County. These cities represent 60% of the County’s population, nearly 40% of
the population of those experiencing homelessness and are the source of the majority of the tax
revenue for Measure H.
Municipalities in the San Gabriel Valley are committed to be leaders in the fight to combat
homelessness. We have the need and the desire to serve the most vulnerable in our communities
and to maximize local ideas, resources, and programs to this end. The San Gabriel Valley Council
of Governments (SGVCOG) and its member cities developed this white paper to demonstrate our
commitment to creating a more coordinated, effective homelessness services system which is
capable of solving our homelessness crisis.
As demonstrated in our Homeless Report (Attachment A), we bring tangible resources to the table.
Our city governments, non-profits, faith communities, healthcare providers, businesses, civic
organizations and volunteers are already actively engaged in meeting this crisis. We already have
boots on the ground working every day on all aspects of this challenge. What we lack is
participation in a focused, flexible and responsive Countywide structure to coordinate strategy,
services and funding to effectively address the causes and solutions for homelessness.
In this white paper, we lay out the background and our perspective on the shortcomings of the
current approach to homelessness across LA County. We lay out a range of potential solutions.
Our concerns are substantive and we believe our alternatives are realistic. We believe that failure
is not an option.
The cities of the San Gabriel Valley pledge to work with the County of Los Angeles, the City of
Los Angeles, our sister communities and the myriad of private, non-profit, academic, philanthropic
and civic institutions across the County to mobilize an effective, efficient and equitable response
to the homelessness crisis.
Page 3 of 30
EXECUTIVE SUMMARY
The SGVCOG is a joint powers authority that supports regional issues and implements regional
programs. The SGVCOG includes the 31 cities and unincorporated areas of Los Angeles County
Supervisorial Districts 1, 4, and 5, representing 20% of the population of Los Angeles County.
The 2020 Homeless Count identified 4,555 people experiencing homelessness in the San Gabriel
Valley. This represents an increase of 47% over the last five years. With the inclusion of the
separate count within the separate Pasadena Continuum of Care, the homeless population of the
San Gabriel Valley represents nearly 10% of the Countywide total.
Of those counted in 2020, two-thirds were unsheltered with the majority of those staying in
vehicles (59.8%) and the remainder (40.2%) on the streets. One third were sheltered. People of
color represent 75% of those experiencing homelessness
The SGVCOG cities are actively engaged in providing homelessness services and work with
LAHSA, LA County Homeless Initiative, LA County Department of Mental Health, LA County
Sheriff’s Department, and various other State and County departments, nonprofits, service
providers, and other municipalities. The cities of Claremont, Pomona, and La Verne are also served
by Tri-City Mental Health.
Most San Gabriel Valley cities have adopted formal homelessness response plans and others are
currently developing them. Several cities have used Measure H implementation funding to offer
Housing Navigation services to their communities. In 2018, the City of Pomona opened a 200-bed
interim housing facility, contributing much of the capital funding themselves. The region has
strong networks of outreach efforts, shelters, housing assistance programs and a range of public,
non-profit and faith-based social services. Finally, twenty-one SGVCOG member cities have
joined the San Gabriel Valley Regional Housing Trust (SGVRHT) that is financing the planning
and construction of affordable housing, including permanent supportive housing for homeless
individuals and families.
Problems with the Current System:
● Lack of Collaborative Relationship with Smaller Cities: LAHSA and the broader
County homeless services delivery system do not engage with SGV cities as partners. Yet
our cities are on the front line when residents have complaints or concerns about
homelessness. Without effective collaboration from LAHSA or the County, cities are
largely left on their own to address the needs of their homeless residents. At worst, this can
lead to duplicative efforts with LAHSA that are a waste of precious resources. County and
LAHSA programs would be more effective if they built on the close relationship that city
governments have with their communities and their knowledge of local conditions. To do
this, there must be an effort to understand the specific needs of these small communities
and collaborate with jurisdictions to implement these more targeted approaches.
Communication and transparency need to be improved to build trust and collaboration.
● Lack of Funding for Locally-Based and Supported Initiatives and Programs: Cities
throughout the County have constrained funding to address a wide range of issues,
including homelessness, transportation, public safety, parks, and stormwater. Under the
Page 4 of 30
current system, when cities propose an innovative solution, it does not appear to be taken
seriously unless it can be applied County-wide. Funding for locally-based and locally-
supported initiatives and programs can leverage Measure H funding for greater impact.
Other countywide tax measures, including Measure W (Water), Measure A (Parks),
Measure M (Transportation), Measure R (Transportation), have all included a “local
return” component that have allowed cities to implement projects and programs customized
to local needs.
● Poor Communication and Lack of Transparency: If one thing is clear about the
homelessness crisis in LA County, it is that it’s not clear who is accountable. The roles,
missions and responsibilities of County government, the County’s Homeless Initiative and
LAHSA and individual cities overlap or leave gaps. Currently, cities struggle to access
information about programs, do not have direct access to appropriate contacts that can
answer questions and respond to concerns. There is a lack of timely and accurate shared
data about people experiencing homelessness served in their communities. When cities are
able to find appropriate contacts, it can be difficult to get clear and concise direction from
LAHSA and the County. At times, staff receive different answers from different people,
creating confusion and making program implementation more difficult. Further
complicating these issues is that cities often interact with LAHSA in both its capacity as
an administrator of funding and as a direct service provider though its outreach teams.
Potential Solutions:
● Increasing Representation Within the Current System: LAHSA was created nearly
three decades ago as a joint structure for the County and the City of Los Angeles to
administer funding for homeless programs, primarily from the Federal government. Much
has changed since then, including the passage of Measure H and the increased role of the
State government in funding homeless programs. The nature and distribution of
homelessness has also fundamentally changed. There is widespread recognition that
greater clarity, coordination and innovation is necessary to effectively deal with the
growing homelessness crisis. Many options have been proposed for restructuring the
governance of homeless strategy, funding, programs and policies. Among the models are
restructuring LAHSA to act as the primary entity for expanded countywide coordination.
These include using the Metro board as a model; adding representatives from all the
Service Planning Areas or the Councils of Government; and a new model implemented in
King County (Seattle) that has a bifurcated board structure to direct policy and operations
and includes representation from elected officials, experts and people with lived
experience.
● More Autonomy Within the Current System: Even without restructuring governance,
there can be improvements within the current system by granting greater autonomy on
programming and funding within each Service Planning Area and with the cities they
cover.
The white paper proposes additional proposals for improving the delivery of services to reduce
homelessness. Finally, it poses the option that in the absence of consensus on a comprehensive
coordinated strategy and structure to effectively address the growing crisis, the San Gabriel Valley
is prepared to accept independent responsibility for administering our own Continuum of Care. Of
Page 5 of 30
course, this would require an appropriate allocation of resources. We are hopeful we can work
together, collaboratively, to improve the current system.
Page 6 of 30
BACKGROUND
The San Gabriel Valley Council of Governments (SGVCOG) is a regional government planning
agency that aims to maximize the quality of life in the San Gabriel Valley. We are a joint powers
authority that consists of 31 incorporated cities, unincorporated communities in Los Angeles
County Supervisorial Districts 1, 4, and 5, and three San Gabriel Valley Municipal Water Districts.
The SGVCOG works on issues of importance to its member agencies, including homelessness,
transportation, the environment, and water, and seeks to address these regionally.
The SGVCOG is the largest and most diverse sub-regional council of governments in Los Angeles
County. The San Gabriel Valley encompasses nearly 400 square miles and has more than two
million residents of thirty-one cities that are represented by 161 councilmembers. In comparison,
the City of Los Angeles, with a population of four million, is represented by fifteen
councilmembers. This allows councilmembers in San Gabriel Valley cities to be closely in tune
with the concerns of their constituents and to shape local policy accordingly.
Our communities each have a unique character and history and often face unique challenges that
they have varying resources to address. Our member cities’ populations range from 1,008 in the
City of Industry and 1,084 in the City of Bradbury to 117,000 in the City of El Monte and 156,000
in the City of Pomona.
Page 7 of 30
It’s a diverse region: of the residents in the San Gabriel Valley, 44.7% identify as Hispanic or
Latino; 25.7% as Asian; 24.8% as white non-Hispanic; 2.4% as Black; and 2.4% as Native
American, Alaskan Native, Native Hawaiian, or another race.
At the time of the 2010 Census, 61% of residents in the San Gabriel Valley lived in owner-occupied
housing, while 39% lived in rental housing units.
While our member cities have unique needs and resources, our communities also face many of the
same challenges and have developed a unified voice to maximize resources, achieve sustainable
solutions, and advocate for regional and member interests to improve the quality of life in the San
Gabriel Valley.
Scope of Homelessness
In January 2020, the Greater Los Angeles Point-in-Time (PIT) Count determined there were 4,555
people experiencing homelessness within the SPA 3, the boundaries of which closely mirror those
of the SGVCOG. The number of people experiencing homelessness in the San Gabriel Valley has
steadily increased since 2015, when 3,093 people were identified through the PIT Count.
Just as our cities have varying populations, needs, and resources, our communities experience
varying levels of homelessness. The 2020 Point-In-Time Count determined there was a range of
homelessness in each of our cities - from 0 people experiencing homelessness (PEH) in some
communities to 723 people experiencing homelessness in another, with a median of 68 PEH in
each SGV city.
Of the people experiencing homelessness within the San Gabriel Valley who were captured
through the PIT Count, the majority are unsheltered: 66.5% were unsheltered, with 59.8% of those
staying in vehicles (59.8%) and the remaining (40.2%) staying outdoors on the streets, in parks, or
in tents. 33.5% were sheltered, sleeping in emergency shelters or transitional housing.
Other key concerns from the region’s 2020 Point-in-Time Count data of concern to our region
include the following:
Page 8 of 30
● People experiencing chronic homelessness rose 40%
● Number of seniors 62 and over experiencing homelessness rose 13%, 68.7% of whom are
unsheltered
● People of color represent 75% of those experiencing homelessness
Our cities recognize the complex vulnerabilities many of those living on the street in the San
Gabriel Valley face, with 28% living with serious mental illness and 33% having a substance use
disorder. We seek to prioritize the expansion of the mental health and substance abuse services
these individuals need to rebuild their lives.
Our region also has deep concern with the impacts of the COVID-19 pandemic on housing stability
and homelessness. The 2020 PIT count data predates the pandemic, and the full effects on
homelessness in the region remain to be seen.
While the PIT count data provides one metric for measurement, it does not capture the full breadth
of homelessness in the region. The PIT count records the presence of homelessness on just a few
nights supplemented with metrics and formulas that are extrapolated to determine the PIT count,
which can produce significant over-counts and under-counts. The PIT count data also does not
account for those persons experiencing homelessness (PEH) that may not reside permanently in
the region but may travel and spend time here.
Regional Homelessness Response
As the homeless population has risen over the last 5 years, so too has the amount of San Gabriel
Valley resources allocated to policies and programs to respond to the regional homelessness crisis.
The cities of the SGVCOG are strongly committed to providing homelessness services and have
supplemented the programs and funding administered by LAHSA and the County to provide
additional resources to PEH in their communities. Nineteen cities have developed homelessness
response plans, with five more cities currently developing plans to be approved by their City
Councils in the coming months. The SGVCOG received an influx of $5.625 million from the State
Budget in FY 2020, and the majority of those funds have been allocated to these cities to implement
their homeless plans. With additional funding supported by the County’s Measure H Innovation
Fund - which provided approximately $1.5 million to the San Gabriel Valley - in total, 22 cities
are utilizing these funds to implement prevention, diversion, rapid rehousing programs, and other
pilot programs aimed at reducing homelessness in the San Gabriel Valley. This funding has
supplemented funding that some communities received from Measure H implementation grants,
which they also used to provide additional housing navigation services to their communities.
Recently, during spring and summer 2020, 11 cities participated in the SGVCOG’s hygiene
program (funded by the County) to provide people experiencing homelessness increased access to
hygiene services during the pandemic and to mitigate the spread of COVID-19 in our unhoused
neighbors.
These programs often fill key gaps in the larger homeless services system. For example, there is
currently a serious lack of funding for rapid rehousing in the San Gabriel Valley, with CES
programs often unable to take new clients after the first few months of the fiscal year. With the
funding sources listed above, the SGVCOG and its member cities are able to provide additional
case management and housing navigation and rapid rehousing slots - as well as targeted outreach
Page 9 of 30
and incentives to landlords to increase the supply of available units - to provide more resources to
house our homeless population.
Even with limited staff, cities have also allocated staff resources to ensure that their city can
respond to homelessness. Cities’ homelessness response falls within a variety of city departments,
often working in coordination with one another. Cities’ homelessness response teams are staffed
in different departments, with some in the City Manager’s Offices, some in departments of
community/neighborhood/human services, housing departments, economic development
departments, police departments, and fire departments. Our cities work with LAHSA, the LA
County Homeless Initiative, LA County Department of Mental Health, LA County Sheriff’s
Department, and various other State and County departments, nonprofits, service providers, and
other municipalities. The cities of Claremont, Pomona, and La Verne are also served by Tri-City
Mental Health.
Our region is committed to providing shelter to those experiencing homelessness and developing
affordable housing to stop the inflow into homelessness. In 2018, the City of Pomona opened a
200-bed interim housing facility, contributing much of the capital funding themselves. The region
has strong networks of churches, one of which provides shelter for families, and another of which
provides winter shelter locations, in addition to those operated at County parks each year. Smaller
scale programs offer transitional housing to youth or families, or residential treatment for
substance use disorder. The cities of Baldwin Park and Pomona operate housing authorities to offer
rental assistance to qualifying families and individuals through a Housing Choice Voucher
Program (HCV). Our cities have engaged in advocacy to use surplus and underutilized public
properties to meet the needs of those with mental illness. In 2020, the SGVCOG also started the
San Gabriel Valley Regional Housing Trust (SGVRHT) - which has been joined by twenty-one
SGVCOG member cities to date - to fund and finance the planning and construction of homeless
housing, and extremely-low, very-low, and low-income housing projects. Already, the SGVRHT
has issued funding letters of commitment to projects that would provide more than 100 housing
units o for the region, 30% of which would serve extremely-low income households or homeless
residents.
White Paper Development Process
To inform the white paper, the SGVCOG engaged its thirty-one member cities and formed a
working group of representatives from the following 11 cities: Arcadia, Baldwin Park, Claremont,
Duarte, Glendora, Montebello, Monterey Park, Pomona, San Dimas, South El Monte, and South
Pasadena. Stakeholders included City Managers, Assistant City Managers, Directors of
Community/Neighborhood/Human Services, Public Safety Outreach Coordinators, and Police
Chiefs. During a three-month period from September to November 2020, the working group met
five times.
The white paper was developed through a multi-phase process. The first component included
information gathering and assessment to understand the problems with the existing homelessness
response system, as well as our region’s current resources and programs. Subsequent meetings
each focused on one section of the white paper.
Page 10 of 30
The white paper was reviewed by the SGVCOG’s City Manager’s Steering Committee,
Homelessness Committee (made up of elected officials and staff from 10 of our member cities and
one LA County Supervisorial District), and ultimately approved by the SGVCOG Governing
Board.
The purpose of this white paper is to address the systemic problems with the current homelessness
response system, identify comprehensive solutions, confirm our commitment to best practices and
programs, and demonstrate our desire to lead the region to a more effective, County-wide
coordinated strategy to combat homelessness. While the white paper includes a strong focus on
recommendations for reform at LAHSA, it also acknowledges and discusses other challenges
within the LA County homeless services system, including administration and distribution of
Measure H funds and the implementation of other County programs. This approach has allowed
us to look more comprehensively – and make broader recommendations – on the County’s entire
homeless services system.
The white paper does this by approaching the following topics:
● Exploring the causes and impacts of systemic problems with the current homelessness
response system, especially as they relate to smaller cities;
● Identifying comprehensive solutions; and
● Confirming the San Gabriel Valley’s commitment to best practices and programs and to
affirming a willingness to lead the region to a more effective, County-wide coordinated
strategy to combat homelessness.
Page 11 of 30
PROBLEMS WITH THE CURRENT SYSTEM
To identify solutions, it is important to have a good understanding of the existing problems. To
that end, the first section of this white paper articulates these obstacles, provides examples of how
this impacts service delivery to PEH, and identifies potential root causes. These problems prevent
the SGVCOG’s cities, the County, and LAHSA from most effectively assisting and housing people
experiencing homelessness (PEH) and prevent homelessness.
The SGVCOG has identified the following specific problems and their impacts, which will be
discussed in more detail below:
● Lack of Collaborative Relationship with Smaller Cities
● Poor Communication and Lack of Transparency
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
Lack of Collaborative Relationship with Smaller Cities
In general, LAHSA and the broader County homeless services delivery system often do not
effectively collaborate with cities. While the County provides opportunities for consultation on
Measure H funding priorities, that input has limited impact on the ultimate decision-making. Cities
do not feel informed of programs before they are implemented and, at times, it appears that cities
are viewed as obstacles rather than partners.
In small cities, the relationship between residents and the city is much closer than in larger
jurisdictions (e.g. County of Los Angeles; City of Los Angeles). Cities’ councils and staff are on
the front line in addressing homelessness and responding to residents, and they are expected to
address issues. This means that programs that are much more localized and responsive to city-
specific conditions. With limited support from and collaboration with LAHSA or the County, cities
are largely left on their own to address the needs of their homeless residents. At worst, this can
lead to duplicative efforts with LAHSA that are a waste of precious resources.
Examples
Specific examples of this lack of collaboration between LAHSA, the County, and the cities are as
follows:
● Project Roomkey: During the recent initial rollout of Project Roomkey, cities were not
consulted or informed as potential project sites were identified and pursued. This approach
not only created the impression that cities were being deliberately excluded from the
discussion but also likely created more opposition, as cities were not able to properly
prepare for the launch of Project Roomkey in their communities. Neither staff nor
councilmembers had adequate information on the program implementation and had many
questions that were unanswered, such as the following:
● What additional city services/resources (if any) would need to be provided to those
sites?
● Would cities receive transient occupancy tax on the occupied rooms?
● Who would be housed in these Project Roomkey sites?
● Would homeless residents from their communities have first priority?
● Where would Project Roomkey residents go after sites were decommissioned?
Page 12 of 30
Instead, the County’s and LAHSA’s efforts moved forward without the cities’ engagement,
leaving councilmembers and residents concerned and frustrated by the lack of up-front
information and engagement. It was difficult to overcome this initial lack of collaboration:
even as LAHSA and the County attempted to engage cities as Project Roomkey advanced,
there was still distrust and uncertainty about the program and its implementation. With a
collaborative approach, questions could have been discussed and addressed prior to project
launch which would have led to a more successful launch of the Project Roomkey program.
● Point-in-Time Count: Cities have often raised the issue that the LAHSA Homeless Count
methodology produces a PIT count which is substantially different from a city’s
understanding of its homeless count, based on its knowledge of its homeless populations.
This has in the past included either a substantial undercount or overcount. For example,
from 2019 to 2020, the City of Baldwin Park experienced a 100% increase in its homeless
count, to 555. This number seemed improbable given Baldwin Park’s size, efforts related
to address homelessness locally, and observations of staff. To that end, Baldwin Park City
staff spent significant time and effort to identify the reason for the significant increase and
raised these concerns to LAHSA. However, no action was taken and City staff were left
unable to provide an adequate explanation to the community. Baldwin Park’s experience
is consistent with the experience of other San Gabriel Valley communities. When cities
have raised these concerns and presented specific corrections to the official count, no action
has been taken.
City staff are deeply knowledgeable about their communities, and, in some instances, may
have collected data throughout the year. LAHSA and the County should collaborate with
cities on this data, in order to make better decisions and better direct resources and services
to specific areas. This is extremely important from both a political and technical level. City
level counts are also highly significant to each community’s perception of progress made
against homelessness. A PIT count is less accurate at smaller geographies, so it’s important
to fully vet and understand the data and analyze the reasons for significant changes,
especially to assess if the significant change is the result of an error. Input from and
meaningful collaboration with cities could resolve these serious discrepancies.
Key Cause: Lack of Representation
The SGVCOG believes that these issues may arise from the fact that LAHSA only represents the
City of Los Angeles and the County of Los Angeles, and only representatives from the City and
County of Los Angeles are seated on the LAHSA Commission. There are 84 other cities in the
County that are also part of the LA Continuum of Care that do not have representation at the level
where the most impactful decisions about homelessness are made. Instead, cities are considered as
one of many stakeholders within the process, rather than as an independent partner that is also
responsible for providing services to its residents. County Departments that provide numerous
services to PEH have a seat at the table in discussions on how to address homelessness. However,
departments that provide services to PEH in the other 84 cities are not a recognized part of these
discussions. Without a seat at the table, it is impossible for true collaboration with all cities.
The SGVCOG recognizes that collaboration is challenging in a region so large and diverse, with
thirty-one jurisdictions in the San Gabriel Valley, each with its own council members, ordinances,
programs, and staff. However, it is critical to providing the most effective services and resources
to our unhoused residents. San Gabriel Valley cities have a shared goal of ending homelessness,
Page 13 of 30
and each city implements the approach that is most responsive to the needs of all of its community
members and is based on the resources available, historical knowledge of their communities, and
previous experiences.
LAHSA programs could benefit from the close relationship that cities have with their communities
and their knowledge of local conditions. To do this, there must be an effort to understand the
specific needs of these small communities and collaborate with jurisdictions to implement these
more targeted approaches.
Lack of Funding for Locally-Based and Supported Initiatives and Programs
Cities have had limited access to funding that can be used to develop and implement programs that
would best serve their communities. This is despite the fact that County residents passed Measure
H, voting to tax themselves to provide additional resources to address homelessness. Other tax
measures - Measure W (Water), Measure A (Parks), Measure M (Transportation), Measure R
(Transportation) - have all included a “local return” component that have allowed cities to
implement these unique programs. In each of these instances, the “local return” is only one
component of the funding allocation, and there is still significant funding that is allocated towards
regional projects and programs.
Local return is missing from Measure H. Instead, Measure H funding is managed by the County,
where cities participate merely as minor stakeholders amongst a group of other stakeholders. This
mindset has been demonstrated in the various stakeholder meetings used to develop the Measure
H Approved Strategies to Combat Homelessness. At these meetings, the majority of
representatives have been from County departments or the homeless services system, with very
limited representation from cities.
As a result, cities have had limited access to funding that could be used to develop and implement
programs that would best serve their communities. This has severely limited cities’ flexibility or
creativity to create programs that uniquely serve their own communities. Moreover, even when
cities propose an innovative solution, it does not appear to be taken seriously unless it can be
applied County-wide.
Examples
Specific examples demonstrating the lack of locally-available funding are as follows:
● Burdensome Funding Requirements: When Measure H funding from the County is
provided, it comes with numerous restrictions. When cities received grants for the
implementation of their homeless plans, the County placed restrictions on how the funding
could be used and provided cities with little ability to reprogram funds. This left funding
that could have supported PEH unused because cities could not use the funds as originally
intended but also could not reprogram it. Funding also cannot be used for law enforcement,
even if the funding is not used for enforcement activities. Funding also has program
standards which small cities are not equipped to provide, such as retaining Licensed
Clinical Social Worker (LCSW) level staff. This is especially problematic given that many
small cities cannot support enough city staffing to adequately address homelessness issues.
Finally, LAHSA appears to apply Federal restrictions to the Measure H, locally-generated
Page 14 of 30
funds. These overly-burdensome requirements do not increase the transparency or
effectiveness of the use of funds - they merely increase the time and capacity required by
cities and LAHSA to administer and implement the funds.
● Prohibition on Funding for Law Enforcement Implementation: In some communities,
police or fire departments are the first responders to PEH in their communities and, as such,
lead cities’ homeless response efforts. With limited resources, cities must use the resources
that they have in order to make an impact. Moreover, police officers are on the streets in
their communities and often know their local homeless populations. However, with
LAHSA’s and the County’s restrictions, cities that engage their law enforcement to
implement homeless programs are precluded from many resources that could support their
efforts to address homelessness. They do not have access to data; they have limited access
to the county-wide resources that are intended to serve the whole County. Law enforcement
has been prevented from communicating directly with the SPA 3 outreach coordinator,
even though a strong prior relationship existed. While partnerships with LAHSA’s
Homeless Engagement Teams (HET) have been made, these teams don’t have the
resources to adequately communicate and build partnerships with each city. Departments
have specialized staff and trained mental health personnel that respond to the homeless
within their communities and help to place PEH into housing. For example, in Monterey
Park, where the Police Department leads homeless outreach efforts and where several
Project Roomkey sites were located, officers were able to house several individuals in
temporary Project Roomkey housing. Monterey Park officers worked closely with their
assigned County Mental Health team to provide mental health services to those PEH in
need.
With LAHSA’s and the County’s restrictions, cities that engage their law enforcement to
implement homeless programs are precluded from many resources that could support their
efforts to address homelessness. These blanket determinations prohibiting engagement
with law enforcement have hampered efforts to address homelessness in those
communities. PEH would be better served by improving coordination and identifying
opportunities to fund those innovative and unique programs, even if they fall within law
enforcement agencies. In the longer-term, PEH would also be well-served by efforts to
develop and implement a mental health-first response, rather than enforcement, first
response. The SGVCOG is currently undertaking an effort to incorporate these services on
a regional level. However, even as this effort advances, law enforcement will play a role
and, to most effectively provide services to PEH, they should be provided with access to
the data and services to do so effectively.
Key Cause: Lack of Understanding of Cities
The 31 independent cities in the San Gabriel Valley - and an additional 54 other independent cities
also in the LA Continuum of Care - are each unique, and operate differently from the City and
County of Los Angeles. Cities have unique and diverse stakeholders and different programs,
procedures, and policies to serve these stakeholders. Neither LAHSA nor the County Homeless
Initiative appears to understand this diversity or to value the diversity and information that cities
do bring to the table. As discussed previously, cities have an intimate knowledge of their
communities, as well as their homeless populations. The overall homeless services system would
benefit greatly if LAHSA and the Homeless Initiative made a more concerted effort to understand
Page 15 of 30
the diversity of individual cities and worked with them to support more localized homelessness
programs, rather than try to apply a one-size-fits-all approach across the entire County.
City government is the most effective level of government where residents, service providers, faith
communities, businesses, and non-profit organizations can work together to develop solutions that
work best for their communities. Acknowledging this fact would allow for more opportunities to
identify and implement unique solutions.
Poor Communication and Lack of Transparency
As alluded to previously, there is poor communication between LAHSA, the County, and cities.
Cities have no centralized point of contact at LAHSA or the County, nor do they have access to
appropriate contacts that can answer questions about programs, respond to concerns, and provide
data about PEH served in their communities. Further complicating these issues is that cities often
interact with LAHSA in both its capacity as an administrator of funding and as a direct service
provider though its outreach teams.
When cities are able to find appropriate contacts, it can be difficult to get clear and concise
direction from LAHSA and the County. At times, staff receive different answers from different
people, creating confusion and making program implementation more difficult. It often seems that
information is being withheld from cities, creating the appearance of a lack of transparency.
Examples
Specific examples of this lack of communication and transparency are as follows:
● Data Sharing: HMIS is the critical component of data sharing in the County’s homeless
services system. However, staff are often denied access. In some instances, HMIS access
is denied because city staff are members of law enforcement, or, in some cases, simply
work closely with law enforcement. Cities are working to use HMIS as a part of an effort
to better coordinate their services with the broader system, to share knowledge of
individual clients’ whereabouts, and to better target city resources and avoid duplication.
Without HMIS access, cities are hindered from embracing the principles of the Coordinated
Entry System (CES) - intended to be a no-wrong door, county-wide system - while at the
same time being encouraged to follow the CES process. It has led to numerous instances
of cities working with a particular person experiencing homelessness, only to learn later
that they had a case manager elsewhere actively looking for them, or that a service provider
was working with someone actively receiving services from a city program. Alternatively,
when clients working with a city are later connected to services, their new provider does
not have the context which could have been already entered into HMIS. Though cities
attempt to facilitate information sharing through individual communications, this is much
less efficient or effective. There likely are legitimate issues related to privacy; however,
LAHSA has not partnered with cities to attempt to overcome these issues. With genuine
collaboration and communication, LAHSA could learn from other contexts in which cities
or law enforcement have access to sensitive information and apply these best practices to
HMIS and other data.
Page 16 of 30
Without full access to data and information-sharing systems, work done by cities or smaller
community-based providers (either separately or in coordination with cities) is not
effectively coordinated within the system. As a result, services remain fractured. Even as
new initiatives, such as Housing Central Command, aim to unify diverse resources, smaller
cities or independent public housing authorities are not included. The need for improved
communication is especially critical when cities are impacted by homelessness in areas
outside of their jurisdiction. Cities have few options related to homelessness in County
parks or Caltrans property within or near their borders, or in unincorporated County which
borders the city, and which may not even be in the same SPA.
● Undermining Public Support for and Success of Measure H: Beyond the impact on
PEH, these problems jeopardize the success of Measure H and challenge the goodwill of
residents that want to see progress in addressing homeless in their communities. San
Gabriel Valley cities receive numerous complaints regarding the lack of progress made
surrounding homelessness, despite the promises of Measure H. Cities, shut off from
influencing the services delivery system, cannot assist in a meaningful way. Cities that do
not have their own housing navigators - funded using separate funding - or existing
relationships with CES providers or outreach teams can only themselves access services
for their homeless residents by using the Homeless Outreach Portal (LA-HOP), which can
only commit to a response within days. Alternatively, cities can direct their residents to use
the same process to request services. If and when an outreach team arrives days later - at
which time the PEH may or may not still be there in need of services - nothing appears to
change. Then, when programs like Project Roomkey are launched in a community and are
not preceded by community engagement, city staff and elected officials are the ones
responsible for addressing community complaints. Because they are provided little or no
information - and are not in control of the programs, they have little to offer. Community
members who wish to serve their homeless neighbors have comparatively few options to
get involved. This sours future support in communities for any measure to extend homeless
services funding, putting in jeopardy the future of Measure H, as well as the system we
have all worked so hard to build.
Key Cause: Lack of Trust
It appears that LAHSA and the County do not trust the cities’ partnership in addressing
homelessness. They do not appear to trust cities’ ability to develop and administer programs
responsibly, nor do they appear to trust cities to appropriately use the data to serve their homeless
populations. LAHSA and the County have focused on creating an overarching system and
establishing best practices but have not actively involved the cities in this process. As a result, an
understanding of local context and situation is not included.
Our cities truly are willing partners in the fight against homelessness and having more
communication with and trust in cities to develop and implement programs that are responsive to
the local communities will lead to a stronger system. Currently, nonexistent and/or slow
communication prevents the timely resolution of problems, creates confusion, and, ultimately
makes program implementation more difficult. It undermines the intended approach of CES and
the County homeless system to have a no-wrong door approach and ensure that PEH receive
services as quickly and efficiently as possible.
Page 17 of 30
Cities have developed - and want to continue to develop - their own programs that serve their
communities, and they want these programs to be recognized as legitimate components of the
County’s homeless services system.
Page 18 of 30
POTENTIAL SOLUTIONS
The SGVCOG believes there are multiple alternatives that would address the issues discussed in
detail in the previous section. The SGVCOG believes these alternatives would strengthen the
County’s overall homeless services delivery system. These alternatives would be more responsive
to the partners in small cities around the County and allow for more robust collaboration and
coordination between all partners participating in the fight to end homelessness in LA County.
Our proposed solutions include both recommendations to improve the system at a high level as
well as smaller-scale adjustments to be made concurrently. While most of these recommendations
focus on LAHSA, we recognize that many would instead require changes to the policies of the
County and its respective departments. In particular, our recommendations 1b, 2b, 2c, 2d, 2e, 3a,
and 3c are just as applicable to the County system as to LAHSA. All fall into one of the following
categories:
● Increasing Representation Within the Current System
● More Autonomy Within the Current System
● Additional Improvements to the Current System
● Independent Control
Our hope is that it will be possible to resolve the issues identified without necessitating a wholesale
overhaul of the current system or the creation of new entities. We believe that starting from scratch
in that way is only in the best interest of all involved if sufficient alternatives cannot be agreed
upon. To that end, it is our intent to only advocate for the options in the “Independent Control”
category after first attempting to find an agreeable resolution to our concerns from among the other
categories.
Increasing Representation Within the Current System
Recommendation 1a: Increase Representation and Seats on the LAHSA Commission
The SGVCOG believes that, within the current system, there must be increased representation for
jurisdictions besides the City and County of Los Angeles. Seats should be added to the LAHSA
Commission, to provide a voice to and increase knowledge of other areas of the region and smaller
cities.
The SGVCOG proposes that jurisdictions other than the City of Los Angeles and the County of
Los Angeles should have representation that is equal to that of the City and the County. Four
potential approaches are summarized in Table 1, below.
Page 19 of 30
Model Representation Structure
Add Council of Government
(COG) Based
Representation
● 5 seats for the City of Los Angeles
● 5 seats for the County of Los Angeles
● 5 seats allocated to COGs according to their population,
excluding portions in the City of Los Angeles and
unincorporated County. That could be divided potentially as
follows:
● San Gabriel Valley COG (approx. 2 million people)
● Gateway Cities COG (approx. 2 million people)
● South Bay Cities COG (approx. 1.3 million people)
● Westside Cities COG and the Las Virgenes/Malibu COG
(Combined) (approx. 500,000 people)
● San Fernando COG, Arroyo Verdugo COG, and North Los
Angeles County COG (Combined) (approx. 1.35 million
people)
Los Angeles County
Metropolitan Transportation
Authority (Metro) board
● 5 seats for the City of Los Angeles
● 5 seats for the County of Los Angeles
● 5 seats selected by the City Selection Committee
Add Service Planning Area
(SPA) Based Representation
● 5 seats for the City of Los Angeles
● 5 seats for the County of Los Angeles
● 5 seats allocated to all 8 SPAs according to their population,
excluding portions in the City of Los Angeles and
unincorporated County. That could be divided potentially as
follows:
● SPAs 1 and 2 (Combined) (approx. 1.3 million people)
● SPA 3 (approx. 2 million people)
● SPAs 4 and 5 (Combined) (approx. 550,000 people)
● SPA 7 (approx. 2 million people)
● SPAs 6 and 8 (Combined) (approx. 1.8 million people)
King County (Seattle)
Regional Homelessness
Authority
● A Governing Committee
● One seat for the Mayor of Los Angeles, three seats for LA
Councilmembers
● Five seats for the Supervisors
● Five seats for elected officials representing the other 87
cities
● Two seats representing people with lived experience with
homelessness
● An Implementation Board of twelve members with specialized
skills and experience appointed by the County, the City of Los
Angeles and the smaller cities in the County.
Table 1.
Summary of Possible Governance Structures.
Page 20 of 30
Many problems identified stem from the fact that LAHSA does not represent the other 84 cities in
LA County that are also members of the LA CoC and behaves accordingly. While this solution
does not solve other specific problems immediately, it allows for appropriate representation to
ensure issues in all categories can be addressed over time. It takes the existing structure and
improves it incrementally, preventing the disruption associated with building out a new system.
Because small cities would have direct authority within the LAHSA structure, LAHSA staff would
start to appropriately prioritize their needs, and those cities would have advocates within LAHSA
they could call upon as specific situations arise. It also would provide cities with trusted insight
into how decisions are being made.
Issue(s) Addressed
● Lack of Collaborative Relationship with Smaller Cities
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
● Poor Communication and Lack of Transparency.
Key Considerations
We recommend an option that provides representation directly to COGs so that the representatives
can be more fully accountable to the diverse interests of cities within those regions, rather than
only the city they represent. If such alternatives are chosen, the portions of each COG or SPA
which are composed of the City of Los Angeles or unincorporated County should not be considered
for population weighting purposes, and those entities should recuse themselves from the selection
of representatives. Otherwise, this will continue to provide them with disproportionate influence
over the homeless services system. Where a seat is to be shared by multiple COG’s or SPA’s, they
could be provided with the option of jointly selecting their representative or rotating who makes
the selection. Additionally, policies would need to be created surrounding cities which are not
members of any COG or are members of multiple COG’s.
This change must still be accompanied by a shift in perspective by LAHSA to view cities and their
commissioners as full partners and to endeavor to understand how cities function. Because small
cities would not be able to collectively enact any change on their own even with five votes, cities
would need to feel assured that the voices of their new commissioners would be listened to.
Critically, this would not resolve cities’ concerns as to funding allocations and other decisions
related to homelessness made by the County, which must be addressed separately.
Recommendation 1b: Increase Small City Representation on Stakeholder Groups
The SGVCOG requests that LAHSA and the County commit to providing seats dedicated to small
cities on advisory bodies, ad hoc committees, and/or stakeholder groups whenever they are formed.
The County Homeless Initiative and County Departments should make frequent use of such groups
when making decisions which affect the entire County. This will allow for important, otherwise
overlooked considerations to be raised from the beginning and provide cities with influence in
more areas.
Specifically, the County should form a standing advisory group comprised of cities to provide
input on funding decisions. This will better ensure equitable distribution of Measure H funding to
regions and jurisdictions around the County.
Page 21 of 30
Issue(s) Addressed
● Lack of Collaborative Relationship with Smaller Cities
Key Considerations
A thoughtful process would need to be developed to determine which entities select these
representatives. Those selected would need to bring the perspective of small cities as a group, but
it is also necessary for each region to advocate for their distinct needs. Whenever possible,
representation from multiple areas should be provided. We also recommend adding additional
seats to such bodies for people with lived experience with homelessness.
More Autonomy Within the Current System
Recommendation 2a: Modify LAHSA’s Mission to Acknowledge its Services to All Cities
The SGVCOG recommends modifications to LAHSA’s mission to specify that it represents and
services all 85 cities that are members of the LA CoC, to clarify responsibilities, and to provide
more responsibilities to the cities. This would include, for example, committing to always consult
cities for input on siting locations and for developing overall strategy in each area. By including
the need to be accountable to smaller cities in its mission, LAHSA staff would better grasp the
importance of understanding the priorities and structures of all member cities. By requiring that
LAHSA obtain early input from cities on matters which affect them, strategies will be better
tailored to local needs and foreseeable problems would be averted.
Issue(s) Addressed
● Lack of Collaborative Relationship with Smaller Cities
Key Considerations
Modifications to written policy must be accompanied by good faith collaboration. Because any
outline of responsibilities will not be able to capture all circumstances, it will be important to
develop strong relationships and active lines of communication to address each new situation.
Recommendation 2b: Incorporate City Input into Program Design
Cities should be given the opportunity to provide input on program design and on the development
of Requests for Proposals (RFPs) and Scopes of Required Services, as well as a process to request
exemptions from certain requirements. This should also include public funding related to
homelessness administered through any County department. This would allow for the removal of
barriers to small cities or small providers being awarded funding through the LAHSA RFP process
or otherwise. These changes could include, but not be limited to:
● Allowing for programs to target a catchment area approved by the cities but smaller than
the whole SPA.
● Removing requirements related to having Licensed Clinical Social Worker level staff.
● Removing prohibitions on funding law enforcement.
This would better facilitate cities being directly awarded funding and to support smaller scale
programs by trusted community providers. Both cities and smaller-scale community providers are
sometimes unable to meet the program requirements that LAHSA and/or the County require,
which unreasonably restricts funding to larger social services providers with the expansive
Page 22 of 30
infrastructure necessary to meet these program requirements. It would allow cities who operate
their local homeless services through or in close coordination with their police departments to
continue these programs, taking advantage of the knowledge that police departments have of their
communities. It would allow cities to prioritize the use of surplus or underutilized public properties
in innovative ways.
While homelessness is a regional issue, the SPA is too broad a catchment area for providing
services and housing to PEH in a region as large and diverse as the San Gabriel Valley. This
requirement could prevent PEH from receiving services in their own communities. For many in
our region, PEH may be unable to receive services in their community, separating them from those
who speak their language or from foods from their community of origin. This undermines our
shared goals related to cultural competency. Our communities may be understanding of serving
some PEH from neighboring cities, but requiring the acceptance of referrals from the entire SPA
can displace PEH from their established communities, which serves neither housed nor unhoused
residents of the San Gabriel Valley. Allowing cities to collaboratively determine a local catchment
area of 2-5 cities solves these problems while allowing for flexibility.
Issue(s) Addressed
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
Key Considerations
This process would need to be ongoing and allow for flexibility as new programs are designed or
new problems are identified.
Recommendation 2c: Create No-Wrong Door Communication Approach with Cities
LAHSA and the County should provide a “no wrong door” style central point of contact for cities
who would be empowered to determine answers to new, city-specific problems. LAHSA and the
County would develop better, formal mechanisms within their own structures for engaging with
cities as stakeholders and incorporating their input when making decisions.
This would solve a variety of issues related to a collaborative relationship and responsiveness to
questions or needs. It would create a mechanism for solutions to novel problems to be developed
in a timely manner. This point of contact could be tasked with ensuring there is always outreach
to cities when a new program may be located in their jurisdiction.
Issue(s) Addressed
● Poor Communication and Lack of Transparency
● Lack of Collaborative Relationship with Smaller Cities
Key Considerations
A key element to this solution is that the contact would have the ability to prioritize these issues
within LAHSA and facilitate decision making. Providing a single point of contact without this
ability only solves a small portion of the problem.
Recommendation 2d: Make Funding and Programming Decisions at the SPA-level
Funding and programming decisions should be made at the SPA-level rather than at the County-
level, incorporating meaningful input and engagement from stakeholders in each SPA. This could
Page 23 of 30
include distinct allocations foreach Measure H strategy to each SPA and/or SPA-specific RFPs.
This could also include allowing SPAs to determine the most impactful ways of allocating funding
and implementing programs at the SPA-level, for example developing catchment areas for the
purposes of providing services to PEH. This could resolve issues of a mismatch between the
strategies for programs and funding determined for each sub-region at the County level and their
actual needs. This could also allow for SPAs to develop a more thoughtful approach to providing
services and housing for PEH
Issue(s) Addressed
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
Key Considerations
A thoughtful engagement of SPA-level stakeholders would be needed to make these decisions.
Recommendation 2e: Increase Measure H Allocations to Cities and COGs
The County should increase the Measure H allocation to cities and COGs, with a dedicated
minimum funding level for each year.
Ensuring a consistent local return will bring Measure H more in line with other County sales tax
measures. It would help to address a variety of concerns which were raised with respect to local
control and needs. Creating more locally-controlled programs allows for more responsiveness to
community concerns and improves public perception about the impact made by Measure H.
Issue(s) Addressed
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
● Lack of Collaborative Relationship with Smaller Cities
Key Considerations
The use of previous allocations of funding to COGs demonstrated their ability to use this funding
effectively to create city-specific programs while also maximizing opportunities to build regional
partnerships and economies of scale. By providing dedicated funding on an ongoing basis, it will
become possible to create long-term programs.
Recommendation 2f: Collect Input on the PIT Methodology from Cities Prior to Finalizing
LAHSA should provide an opportunity for input from each City on the data and methodology used
to calculate their city level PIT count before it is finalized, as may be possible within HUD
guidelines. This can include input on the correct multiplier to use for the number of individuals
per car, tent, or makeshift structure, as well as ensuring the census includes a count of areas within
each city with disproportionately high or low concentrations of unsheltered individuals.
This lowers the likelihood of an official overcount or undercount which is at odds with the
observations of those who know the city well. It prevents fluctuations from year to year related
more to how the count was conducted than changes in reality. It will allow for better data related
to the geographic distribution of the homeless population within SPA 3 to inform program
targeting decisions.
Page 24 of 30
Issue(s) Addressed
● Lack of Collaborative Relationship with Smaller Cities
Key Considerations
Cities can provide valuable information about their homeless population both when planning for
the PIT count and when functioning as a check against inaccurate data or conclusions afterwards.
Additional Improvements to the Current System
Recommendation 3a: Increase Flexibility in Implementing Programs
LAHSA and the County should provide increased flexibility in implementing programs. Overall,
there should be more flexibility, whether through modifications to existing program types or the
option of proposing new ones. This could include, for example, funding more, smaller programs
rather than fewer, larger programs, or the funding of creative programs proposed by cities. LAHSA
should not set minimum numbers of PEH to be served by proposed programs and should not
restrict the number of providers to be awarded in each SPA. Program funding levels should be set
to make smaller programs feasible. This would allow for more access centers, interim housing
programs, winter shelters, safe parking sites, and rapid rehousing providers. Currently, the limited
number of these programs in each SPA hinders program access by PEH, prevents access to funds
by smaller providers, and leads to greater neighborhood pushback as compared to the same funds
split across more programs. Program implementation should acknowledge the resources and needs
across the region. For example, there should be a greater priority placed on expanding resources
for those that suffer with mental health and substance abuse challenges. Program implementation
should focus on identifying opportunities to use and expand existing programs and facilities,
including vacant, government-owned buildings, to better provide the services these individuals
need to rebuild their lives.
This will allow for versions of programs which fit better into communities or otherwise better meet
local needs. Using the same amount of funding for smaller programs allows for better geographic
distribution, lowers neighborhood impact, and facilitates the participation of smaller providers.
For example, in the 2020 Access Centers RFP, in which LAHSA added more funding overall to
SPA 3 but did not increase the number of sites. The funding available would have been sufficient
to fund two or three smaller programs capable of carrying out the full scope of required services.
The current approach leaves most of the region without any nearby access center.
Issue(s) Addressed
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
Key Considerations
This should be addressed both through the creation of the “menu” of programs available to be
implemented, but also within RFP documents themselves. RFPs should be less specific in
mandating, for example, how many programs will be selected per SPA, and should state more
generally the goals that programs must meet, allowing for some discretion in the proposal itself.
Page 25 of 30
Recommendation 3b: Allow Cities to Access HMIS
LAHSA should create a streamlined way for cities to access HMIS and collaborating to resolve
any legitimate privacy concerns. LAHSA should provide a clear process for beginning HMIS
participation, and standard policies related to privacy concerns cities are likely to face.
This will allow cities to participate in HMIS who do not currently do so either because of lack of
a clear avenue to gain access, or because they are prohibited from doing so. Where privacy
concerns must be addressed, a collaborative process could result in cities adopting the appropriate
policies to resolve them.
Issue(s) Addressed
● Poor Communication and Lack of Transparency
Key Considerations
This should include a clear mechanism to produce city level data and reports to best take advantage
of increased HMIS use.
Recommendation 3c: Better Integrate Law Enforcement into Homeless Response
LAHSA and the County should better incorporate homeless outreach within law enforcement. This
could be based on the existing model operated by the Department of Mental Health (DMH) with
local law enforcement. For example, Monterey Park has a DMH psychiatric social worker assigned
to their police department. This person works in conjunction with their officers who focus on
homeless outreach. This clinician is mandated to follow the County’s privacy and program
standards and policies, but this individual is integrated with this local city team. LAHSA could
utilize a similar model, assigning an outreach worker to each independent city or to groups of cities
depending on their size and/or PIT count. This integration could better tailor outreach to specific
community needs.
This will allow the homeless services system to take advantage of the knowledge local law
enforcement has of their city. It will reduce fragmentation between the larger system and the work
currently taking place in cities who operate their homelessness programs through their police
departments.
Issue(s) Addressed
● Poor Communication and Lack of Transparency
● Lack of Collaborative Relationship with Smaller Cities
Key Considerations
The appropriate points of contact and areas for integration will vary by city depending on their law
enforcement structure or methods of operating homeless services within their city.
Recommendation 3d: Expand Participation in Housing Central Command
LAHSA and the County should expand participation in Housing Central Command by smaller
cities and independent public housing authorities (PHAs) once it expands beyond its pilot phase.
This would better streamline the use of these entity’s resources to address homelessness in their
communities.
Page 26 of 30
Issue(s) Addressed
● Poor Communication and Lack of Transparency
Key Considerations
PHAs have different policies and differing approaches to homelessness which may influence their
relationship to Housing Central Command.
Independent Control
Should all attempts to reform or restructure LAHSA fail or be determined to be infeasible, the San
Gabriel Valley could pursue the creation or expansion of an entity or entities independent of
LAHSA to administer and manage Measure H and other funding. This could include:
● Administration of the majority of funds and programs directly through the COGs
● Forming new homeless services authorities to serve each sub-region.
● Forming a new homeless services authority to serve the County minus the City of LA
● Administration of the majority of funds and programs directly through each city.
Such an entity or entities could, with the necessary approvals, join the Pasadena, Glendale, or Long
Beach Continuums of Care (CoC) or create independent CoCs.
Managing funding independently would allow cities to solve all or most of the problems we have
identified. Because such an overhaul comes with downsides in terms of disruption of the current
system, we hope that these problems can be resolved through other means. However, we view
these options as effective solutions to prioritize if other methods fail.
These smaller entities also may be better equipped to act as the fiscal agent to administer funds, as
LAHSA struggles to do. Smaller entities could provide more timely payments to providers and
cities and be responsive to fiscal questions.
Issue(s) Addressed
● Lack of Collaborative Relationship with Smaller Cities
● Lack of Funding for Locally-Based and Supported Initiatives and Programs
● Poor Communication and Lack of Transparency
Key Considerations
The governance structure of any new entity created would need to be thoughtful to ensure problems
of representation are not duplicated and that the needs of all member cities are taken into account.
Additionally, Measure H funding would need to be allocated to the respective entities
proportionally, either by PIT count, population, or amount of sales taxes collected within their
borders. The costs associated with these options should be borne by new or existing County
funding.
Page 27 of 30
Recommendation Collaboration
with Smaller
Cities
Funding for
Local
Programs
Communication
and
Transparency
Additional LAHSA Commission seats
for smaller cities
X X X
Dedicated seats for smaller cities on
advisory bodies, ad hoc committees,
and/or stakeholder groups.
X
Expansion/clarification of LAHSA’s
mission and responsibilities to specify
that it represents and serves all 88 cities.
X
Formally incorporate cities’ input into
program design, RFPS, and SOWS and
allow cities to be exempted from certain
RFP requirements
X
Provide a “no wrong door” style central
point of contact for cities who would be
empowered to determine answers to new,
city-specific problems.
X X
Making funding and programming
decisions at the SPA-level rather than
Countywide.
X
Increasing the Measure H allocation to
cities and COG’s, with a dedicated
minimum annual funding level.
X X
Providing an opportunity for input from
each City on the data and methodology
used to calculate their city level PIT count
before it is finalized.
X
Increased flexibility in implementing
programs.
X
Streamline access for cities to HMIS,
collaborating to resolve any legitimate
privacy concerns.
X
Better incorporating homeless outreach
within law enforcement.
X X
Page 28 of 30
Participation in Housing Central
Command by smaller cities and
independent public housing authorities.
X
The selection of an entity or entities
independent of LAHSA to manage
Measure H and other funding.
X X X
Table 2.
Summary of Proposed Recommendations.
Page 29 of 30
DEMONSTRATING COMMITMENT TO QUALITY PROGRAMS AND SERVICES
The San Gabriel Valley is committed to continuing to pursue philosophies which lead to quality
programs and services and align with nationally recognized best practices. Our existing practices
and plans demonstrate this, and we intend to deepen our commitment to them as our work expands.
This demonstrates that funding will be used effectively as the San Gabriel Valley is provided with
more autonomy as our recommended solutions are put into effect. While this may look different
depending on the level of autonomy provided, these principles will guide the work to combat
homelessness in the San Gabriel Valley regardless.
Pursuing Best Practices
All programs in the San Gabriel Valley will follow nationally and regionally recognized best
practices, such as those mandated by HUD or recommended by the National Alliance to End
Homelessness. These include, but are not limited to, Housing First, Harm Reduction, Trauma-
informed Care, Cultural Competency, and a focus on equity, including racial equity and a
distribution of funds and services among subpopulations.
Our programs will be operated in accordance with program standards, facilities standards, and
performance targets substantially similar to those currently in use by LAHSA. They will follow
best practices in terms of caseload ratios and the use of interventions such as motivational
interviewing. With respect to unsheltered homelessness in our communities, cities will follow a
public health approach which prioritizes services over enforcement as recommended by LAHSA’s
Principles and Practices for Local Responses to Unsheltered Homelessness. PEH served in our
communities will benefit from non-discrimination, equal access, and grievance policies similar to
those currently in use. Overall, funds which cities or the COG control will be put to use according
to the Measure H strategies.
In order to support the implementation of these philosophies, staff at individual cities who focus
on homelessness will provide education on the importance of these best practices to their city
councils, particularly to councilmembers who may sit on the LAHSA commission or other boards
which oversee homeless services.
CES Participation and Regional Services
Programs in the San Gabriel Valley will participate in the Coordinated Entry System and operate
from a regional perspective. Our work will continue to prioritize administering the VI-SPDAT in
all programs and entering all participants into CES. City or COG funded programs will require
collaboration with CES providers through case conferencing and other venues. Any permanent
housing we control will be allocated according to LA County CES prioritization policies. Our
programs will participate in HMIS and use it to the fullest extent possible. The only exception to
this would be where prohibited by LAHSA, as outlined in the “problems” section of this paper.
Site based programs, such as interim housing, will be structured to serve a portion of the region.
Many of our cities already address homelessness in cohorts of neighboring cities. As locally-
controlled homelessness programming expands, the remaining cities can form themselves into
self-selected cohorts of two to five cities each. These cohorts will form the basis of the catchment
Page 30 of 30
area that each site based program would serve, rather than the entire SPA, and eligibility criteria
would include having contact with an outreach team while in that area or otherwise having ties to
a member city. In this way, local programs will have a regional approach while serving PEH from
the communities where the sites are located.
Use of Local Resources and Control
Our communities commit to using local resources and control to effectively expand the homeless
services delivery system. Once the above-mentioned cohorts of cities are formed, we will work to
site interim housing beds in each one. By doing so, interim housing options will be available to
PEH anywhere in the SPA, resolving a key limitation of this approach. The number of beds within
each catchment area will be in accordance with targets to be determined at a later time, for
example, 10% of each area’s PIT count.
It will be important for member cities to maintain a level of control over beds in their catchment
area. This could include the targeting of specific encampments, the use of preference lists, or a set-
aside of beds to be filled specifically by city referral. This will not preclude the integration of
interim housing into CES, such as by using eligibility criteria related to acuity or housing match
status.
Our communities will also support the siting of permanent supportive housing within our
communities. We will prioritize using surplus land for homeless services and affordable housing
and are actively working to identify parcels for this purpose. We will also prioritize leveraging
funding such as CDBG and the Regional Housing Trust to support regional goals. Our cities will
prioritize the use of surplus or underutilized public properties, particularly to address the needs of
those with mental illness or substance use disorder.
CONCLUSION
The challenges and recommendations emphasized in the sections above highlight the opportunity
for all stakeholders in the County of Los Angeles to come together and build a comprehensive,
coordinated, Countywide structure and strategy to end the shame of tens of thousands of people
living on our streets. Business-as-usual will not solve this problem, so all County stakeholders
must rise to face this challenge. The SGVCOG looks forward to actively participating in the
formation of a better and more responsive homeless services system for all.