Required by the U.S. Department of Housing and Urban Development (HUD), the Consolidated Annual Performance and Evaluation Report (CAPER) provides detailed financial and beneficiary information explaining how the City of Tulsa is carrying out its housing and community development strategies, projects, and activities, outlined in the 2020-2024 Consolidated Plan.

This year-end report summarizes the results of activities that have taken place during PY 2022. It provides information for HUD and citizens of the City of Tulsa to review funded programs and evaluate performance against established goals.

The HUD Community Development Committee (HUD CDC) identified community goals and priorities utilizing public input.  Based on this information, interested agencies submitted proposals to meet these objectives. Proposals for funding were received and per City ordinance the proposals were reviewed and scored by five reviewers. The HUD CDC reviewed the scoring and made funding recommendations to the Mayor for approval. As a result, the City Council and Mayor approved 38 activities to be awarded HUD funds.

Utilizing Community Development Block Grant (CDBG), HOME Investment Partnership (HOME), Emergency Solutions Grant (ESG) and Housing Opportunities for Persons with AIDS (HOPWA) funds, the City of Tulsa selected activities to promote Decent Housing, Create Suitable Living Environments and Economic Opportunities.

The City of Tulsa expended a total of $6,670,992 to:

• Serve 9,735 people through public service activities;
• Provide HOPWA services including STRMU, TBRA and Permanent Housing Placement to 370 persons with AIDS
• Assist 268 persons with Homeless Prevention activities
• Provide emergency shelter to 831 people;
• Create or retain 92 FTE jobs;
• Assist 33 businesses;
• Rehabilitate 147 homeowner homes and 12 rental units;
• Constructed 16 new rental units;  
• Assist 9 first time homebuyers;
• Rehabilitate 1 public facilities that will serve 4,860 low- and moderate-income citizens; and
• Demolish 24 substandard structures.

The City also continued to expend additional funding received through the Coronavirus Aid Relief and Economic Security Act (CARES Act) during PY22. A total of $3,383,170 of CARES Act funding was expended from July 1, 2022, through June 30, 2023.

Twelve projects funded with CDBG-CV and 11 projects funded with ESG-CV expended funding during the project year to:

• Serve 3,058 people through public service activities;
• Assist 154 persons with Homeless Prevention activities;
• Provided ongoing assistance to 332 households (514 Persons) with Rapid Rehousing activities
• Provide emergency shelter to 2,614 people;

The City has been allocated $6,477,826 in HOME-ARP Funds. To receive access to the this funding, the City of Tulsa had to develop and submit a HOME-ARP Allocation Plan for HUD’s approval. On April 10, 2023, the HOME-ARP Allocation Plan was approved. The HOME-ARP Allocation Plan describes the activities that the City of Tulsa will undertake to reduce homelessness and increase housing stability within the City of Tulsa. Grants Administration has allocated 76.5% of the HOME-ARP funding to be used to create affordable rental housing units in Tulsa, with 8.5% used for HOME-ARP Supportive Services for those who are housed in these HOME-ARP units. Grants Administration anticipates allocations will be approved and projects underway by the summer of 2024.

Progress the jurisdiction has made in carrying out its strategic plan and its action plan.  91.520(a)

The City of Tulsa expended $10,054,162 in HUD funds during PY 2022.

CDBG expenditures totaled $4,647,284; CDBG-CV expenditures totaled $1,534,668.

ESG expenditures totaled $333,678; ESG-CV expenditures totaled $1,848,492.

HOME expenditures totaled $881,255.44.

HOPWA expenditures totaled $809,285.

During PY22 the City continued to work towards accomplishing the five-year goals set out in the consolidated plan. Many organization that had developed safety protocols to continue to serve clientele during the height of the pandemic were continuing to use these practices during PY22. Public facility and housing projects continued to experience delays related to materials/supply shortage and higher costs and HUD Environmental Review issues. One public facility project was cancelled due to the delay of the Environmental Reviews while another PY22 sidewalks projects is on hold until clearance is provided by the Tribal State Historic Preservation Office.

Homeowner Rehabilitation Programs continued to see high costs for work required at each home, due to the current economic climate resulting in fewer homes completed than estimated in the Annual Action Plan. During PY22 160 homes received emergency repairs, with an average of $4,072 spent per home. An additional five homes received rehabilitation services through a HOME homeowner Rehabilitation Loan program.

One CHDO HOME rehabilitation project was funded during PY22, Country Oaks, and seeks to rehabilitate 6 affordable rental units. Another HOME rehabilitation was funded during PY22, Belle Arms & Southwind Apartments, and seeks to rehabilitate 22 affordable rental units. One Rehabilitation project of a multi-family rental development, Terrace View Apartments, is currently underway and projected to result in 22 rehabilitated HOME units by the first quarter of 2024. One Rehabilitation project funded in PY20, Baltimore Apartments, a multi-family rental project was completed in the last quarter of 2022. One CHDO Development project, Whittier Heights, funded in PY17 and another one, Whittier Villas, funded in PY16, both for seniors, were completed in PY22. In PY20, a CHDO was funded to construct and sell two Single-Family housing units in the development, Buena Vida. To further the impact of affordable housing creation in the Buena Vida development, additional funds in PY20 were awarded to the CHDO’s parent organization to construct and sell five Single-Family housing units. Both of these projects are projected to be completed in the last quarter of 2024, creating seven single-family homes to sell to eligible homeowners whose income is no more than 80% of the Tulsa Area Median Income.

Two first-time home buyer Down Payment Assistance (DPA) programs expended funds during the program year. Tulsa Habitat for Humanity assisted 6 households with DPA funding (allocated in PY19) during PY22. In PY22, Housing Partners of Tulsa, Inc. projected to assist 25 households through their DPA program. In early 2023, Tulsa Housing Authority made the decision to disband Housing Partners of Tulsa. At the time this decision was made 3 households had been assisted with DPA funding. The final DPA was closed in late November 2022.  HOME and CDBG funds not expended will be reallocated in PY24.

Ongoing COVID-19 reduced capacity restrictions and changes to one local shelter policies, resulted in the ESG funds used to provide shelter operations and services serving fewer people than estimated in the Annual Action Plan. The shelter in question changed their overnight walking-clients policy, to continue to house most vulnerable homeless populations and to create a more stable living environment while they are waiting on permanent housing.  

CDBG CARES Act funding was used for several public service activities, providing services such as job training, emergency shelter, education services and legal aid to 3,058 persons. ESG CARES Act funding continued to be used for emergency shelter and homelessness prevention activities, serving 2,615 persons. An additional 332 households received ongoing assistance through ESG CARES CT funding allocated to rapid-rehousing programs.  

Expenditures By Grant

Comparison of the proposed versus actual outcomes for each outcome measure submitted with the consolidated plan and explain, if applicable, why progress was not made toward meeting goals and objectives.  91.520(g)

Categories, priority levels, funding sources and amounts, outcomes/objectives, goal outcome indicators, units of measure, targets, actual outcomes/outputs, and percentage completed for each of the grantee’s program year goals.

Table 1 - Accomplishments – Program Year & Strategic Plan to Date

Assess how the jurisdiction’s use of funds, particularly CDBG, addresses the priorities and specific objectives identified in the plan, giving special attention to the highest priority activities identified.

The City of Tulsa identified seven priorities in its Consolidated Plan. These priorities are: 1) Housing Acquisition, Construction and Rehabilitation 2) Essential Services (Public Services), 3) Homeless/Special Populations, 4) Economic Development, 5) Public Facilities and Infrastructure Improvements, 6) Housing Subsidies/Assistance, and 7) Demolition of Substandard Buildings. All activities tie to one of HUD’s specific performance objectives of Creating Suitable Living Environments, Providing Decent Housing, or Creating Economic Opportunities. During Program Year 2022 the City of Tulsa expended $5,933,252.32 of PY 2022 funds, carryover funds and revolving loan funds, on activities and projects excluding general administration and Homeless Management Information System (HMIS) data collection. Twenty-seven activities expended $2,328,698 to support Decent Housing, nineteen activities expended $1,331,067 to Create Suitable Living Environments, and two activities expended $3,302,698 to Create Economic Opportunities.

In CARES Act funding, the City of Tulsa expended $3,262,116 on activities and projects excluding general administration and Homeless Management Information System (HMIS) data collection. Seven activities expended $721,032 to support Decent Housing, and seventeen activities expended $2,541,084 to create Suitable Living Environments.

Describe the families assisted (including the racial and ethnic status of families assisted). 91.520(a)

Table 2 – Table of assistance to racial and ethnic populations by source of funds

Narrative

Table 2 data does not include all race types reported in IDIS and therefore does not represent the total families served. A table showing the total people served will be included in the final CAPER.

Identify the resources made available

Table 3 – Resources Made Available

Narrative

The expected amount available in Table 3 is the amount included in the PY 2022 Annual Action Plan.

CARES Act funding for CDBG and ESG, are also being reported. Amendments to the PY19 Annual Action Plan included these additional resources.

The CDBG-CV allocation was $4,972,954, of which $1,534,678 was expended during the PY22 program year and the ESG-CV allocation is $5,151,657, of which $1,848,492 was expended during the PY22 program year.

Identify the geographic distribution and location of investments

Table 4 – Identify the geographic distribution and location of investments

Narrative
Previously the majority of low and moderate income (LMI) census tracts had been located in the north quadrant of the city and this area was targeted during the last Consolidated Plan. New census data, gathered during the development of the Consolidated Plan, showed a sharp rise in the number of LMI census tracts throughout the city as a whole and this is the basis for targeting specific geographical locations within the jurisdiction. In the development of the Consolidated Plan, two target areas were defined and approved. Along these two bus route corridors, there is a high level of poverty and unemployment, but also areas available where new investments and revitalization can occur. With the exception of a small portion of the Peoria Bus Rapid Transit Route target area, all are identified as LMI census tracts.

Of all the HUD funds expended during this program year, approximately 3%, were spent on activities that were identified to serve beneficiaries located within the designated target areas. This figure does not include CDBG Public Service activities, ESG activities and HOPWA activities that provided services to all eligible Tulsa citizens, such as emergency shelter and crisis management services. 

Leveraging

Explain how federal funds leveraged additional resources (private, state and local funds), including a description of how matching requirements were satisfied, as well as how any publicly owned land or property located within the jurisdiction that were used to address the needs identified in the plan.

The federal, state, and local resources available to address the needs identified in the plan included federal formula grant funds under CDBG, ESG, HOME, and HOPWA. The local Continuum of Care (CoC) also awarded grant funds under the competitive McKinney-Vento Homeless Assistance Act. These funds were leveraged with the City's general funds, ESG match dollars, various state and county sources, local nonprofit resources, and private foundation grants.

Public service projects concentrated efforts to address the needs of families, children, and youth in high risk populations, consistent with the identified priority needs. Use of CDBG and ESG funds leveraged other nonprofit resources and private foundation funds to assist low-income persons.

Physical expansion and/or improvement projects used a combination of funds including, but not limited to, CDBG, city general funds, nonprofit fundraising, and private foundation funds to enhance selected projects. 

Since matching funds are not required for CDBG, the City Council considered projects that included leveraged funds to support CDBG dollars. For the projects selected for funding, over $17 million of leveraged resources enhanced the use of CDBG dollars.

HOME Match: The sources of matching contributions for HOME funds were from non-federal contributions and the City. The City requires subrecipients, housing developers, and CHDOs to provide up to a 25% match. The match liability for the City of Tulsa was reduced to 0% again this year. Banked match is available if grant recipients are not able to generate the required match. The City had $9.8 million in excess match at the beginning of the program year on July 1, 2022. After the match contributions were received and the liability deducted, the City has a match balance of $9.8 million.

Emergency Solutions Grant Match: The jurisdiction fulfilled the ESG requirement of a matching contribution equal to the grant program funds. Each organization provided matching funds equal to the amount of funds expended. This stipulation is included in each written agreement. Documentation of match is required when each subrecipient submits a request for funds. The City of Tulsa provided in-kind administrative expenditures, as necessary, to match administrative funds received.

With the implementation of HUD waivers available for ESG-CV, projects and administrative expenditures were not required to provide matching funds equal to the amount of funds expended.

The City did not identify any publicly owned land and property that could be used to address the needs identified for PY 2022.

Table 5 – Fiscal Year Summary - HOME Match Report

Table 6 – Match Contribution for the Federal Fiscal Year

HOME MBE/WBE report

Table 7 – Program Income

Table 8 – Minority Business and Women Business Enterprises

Table 9 – Minority Owners of Rental Property

Table 10 – Relocation and Real Property Acquisition

Evaluation of the jurisdiction's progress in providing affordable housing, including the number and types of families served, the number of extremely low-income, low-income, moderate-income, and middle-income persons served.

Table 11 – Number of Households

Table 12 – Number of Households Supported

Discuss the difference between goals and outcomes and problems encountered in meeting these goals.

Typical of HOME-funded housing development is that outcomes are not produced in the same program year as funds are awarded.

In PY20 Mental Health Association Oklahoma (MHAOK) was awarded $255,133 in HOME funds for rehabilitation of a 16-unit multi-family rental project, Baltimore Apartments. This project completion did not occur by the end of the program year but is expected to be complete in September 2022. MHAOK was also allocated $892,828 in PY21 for the major rehabilitation of the multi-family rental development, Terrace View Apartments. Terrace View’s performance period is July 1, 2021 through March 31, 2024 and will result in 22 Home-assisted units

Vintage Housing was allocated a total of $1,626,868 in HOME funds for construction of a 52-unit elderly independent living rental complex, Whittier Heights. Funds were awarded in PY17, but they did not receive anticipated funding from LIHTCs. They applied again in 2019 with success. The City also allocated PY18 CHDO reserve funding to this project since no CHDO-eligible project was funded in PY18 and additional funds in PY19. This project got underway in November 2020, and project completion occurred in fall 2022. This project is located adjacent to the smaller 6-unit rental apartment development, Whittier Villas, for which Vintage was awarded with $624,000 of PY16 off-cycle funds during PY17. Zoning issues, Infrastructure development, General Contractor changes, coronavirus pandemic issues including increased material costs stalled project progress. The City was granted a waiver from HUD to extend the time allowed to complete this project.  Whittier Villa’s project completion occurred on in early 2023.

In PY20, the Community Housing Development Organization (CHDO), Habitat Housing, Inc. DBA Boomtown Development Co. was awarded $275,000 for constructing and selling two Single-Family housing units in the development, Buena Vida. Additionally, in PY20, Tulsa Habitat for Humanity, Inc. DBA Green Country Habitat for Humanity was awarded $618,625 for constructing and selling five Single-Family housing units in the Buena Vida development. The period performance for both of these projects will end June 30, 2024, and will produce a total of seven single-family homes to sell to eligible homeowners whose income is no more than 80% of the Tulsa Area Median Income.

Housing Partners of Tulsa, Inc. (HPT) used $4,351 in CDBG project delivery funds and $26,700 in HOME funds to assist 3 households to purchase their first home. Tulsa Habitat also used $48,127 in PY19 HOME funds to assist 4 households to purchase their first home.

The City of Tulsa Working in Neighborhoods Department (WIN) utilized both HOME and CDBG funds to provided homeowner rehabilitation programs. The CDBG Homeowner Repair program served 137 homeowners, providing necessary safety and sanitary improvements. The HOME Homeowner Rehabilitation Loan Program provided substantial rehabilitation to houses for 5 homeowners.

Additional energy conservation rehabilitation was provided by a CDBG-funded subrecipient program. The Area Council for Community Action assisted 5 homeowners. The change to allow maximum assistance for roof repairs up to $7,500 for lead-free housing has enabled them to more easily meet their goals.

Family Safety Center, Inc, used ESG funds to provide Homeless Prevention assistance to 63 persons and Salvation Army added 205.

ESG CARES Act funds were used to provide Homelessness Prevention assistance to 154 persons, and ongoing rapid rehousing assistance to 332 households.

For information see the attached draft ESG and ESG-CV.

Discuss how these outcomes will impact future annual action plans.

Once completed projects currently under construction will add more affordable housing units in the Tulsa area. One of the biggest delays for major projects is caused by the time it takes to secure all the necessary financing before the projects can get underway. Additionally, minor rehabilitation projects have resulted in an increased cost per home which has affected the number of households served, exacerbated by the shortage of available qualified contractors. The city continues to try and find ways to help increase the availability of quality affordable housing over the next several years. In March 2023, Tulsa’s first independent study of Tulsa’s housing crisis, conducted by Development Strategies and Homebase, was published and prepared for Housing Solutions and was supported by the City of Tulsa and will be a beneficial study to consider in the creation of future annual action plans. An Affordable Housing Trust Fund was established in February 2021 and is aligned with the City’s Affordable Housing Strategy to endeavor to create an economically thriving, inclusive community with quality housing opportunities for all residents.

Include the number of extremely low-income, low-income, and moderate-income persons served by each activity where information on income by family size is required to determine the eligibility of the activity.

Table 13 – Number of Persons Served

Narrative

On March 1, 2023, Tulsa’s first independent study of Tulsa’s housing crisis, conducted by Development Strategies and Homebase, was published and prepared for Housing Solutions: https://www.housingsolutionstulsa.org/tulsa-housing-study/. This study was supported by the City of Tulsa, Partner Tulsa, Downtown Tulsa Partnership and Tulsa Housing Authority. This study summarized the following:

1. Housing is needed in Tulsa across the affordability spectrum
2. There is no single solution or strategy that will make it possible to meet demand
3. More than half of housing demand is for units at or below 100% average median income.
4. Meeting demand will not solved all of Tulsa’s housing challenges.

The total 10-year demand broken down by affordability in areas that HUD funding could help address is as follows:

• Extremely Low Income (<30% AMI or <$20,000)- 2,160 units
• Very Low Income (30% AMI to 50% AMI or $20,000 to $30,000)- 1,790 units
• Low Income (50% to 80$ AMI or $33,000 to $54,000)- 2,290 units

Additional activities to address the need for decent, affordable housing have been funded during PY23.

Evaluate the jurisdiction’s progress in meeting its specific objectives for reducing and ending homelessness through:

Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs

Street outreach programs for unsheltered persons were not funded with PY23 entitlement funds. A portion of ESG-CV funding was provided to two agencies to provide street outreach activities during the program year. One agency served the entire population with the other focusing on unsheltered youths. The Housing Solutions’ outreach program operates using a Housing First approach with an emphasis on services that support self-sufficiency, such as obtaining vital records, accesses to resources such as health care, transportation, and applicable public benefits (e.g. Social Security, SNAP, housing vouchers, Veteran benefits), while trying to find creative solutions to connect them to housing resources.

A total of 1,115 unsheltered persons received street outreach services during the program year through programs funded by ESG-CV dollars.

In addition to the efforts of the funded agencies there are also outreach programs organized locally by the Tulsa City, faith-based organizations and other non-profit organizations. Housing Solutions works with other local organizations to coordinate street outreach for person living in unsheltered situations across Tulsa County. All ESG and CoC-funded outreach programs utilize the local Coordinated Entry System to assess and prioritize participants for housing placement. In addition, the outreach teams come together each year to perform the Point-in-Time count survey of the unsheltered population. One survey question asks each person what services are currently needed. The top three responses provided by the unsheltered population this year were housing and shelter, health services, and case management.

Addressing the emergency shelter and transitional housing needs of homeless persons

A portion of the Emergency Solutions Grant (ESG) funds were utilized by the City of Tulsa for shelter operations and/or services at Domestic Violence Intervention Services (DVIS), Tulsa Day Center (TDC), Legal Aid Services of Oklahoma, and Youth Services of Tulsa (YST). In addition, CDBG funds were provided to DVIS, TDC, Salvation Army, and YST to provide services, counseling, case management, and basic needs to those experiencing homelessness or those at risk of homelessness.

During the program period, the ESG-funded DVIS shelter provided shelter to 60 persons. Clients unable to be served were referred to other area shelters. The CDBG-funded Court Advocacy Program provided services to 473 survivors of domestic and sexual violence. Due to the nature of the client’s situation no exit data was collected.

TDC provided shelter and essential services to homeless persons by using ESG funds for operational expenses. During the program year 449 unduplicated clients stayed in the night shelter. Ongoing COVID-19 restrictions and a change in Tulsa Day Center policy resulted in a lower number of individuals served during the program year than estimated. Tulsa Day Center updated their overnight-walking policy to continue to house most vulnerable homeless populations and to create a more stable living environment while they are waiting on permanent housing. Individuals not only have access to shelter but also to various services including food and clothing, case management, laundry, shower and restroom facilities, medical services, bus tokens and access to telephones and the internet. TDC also used CDBG funds for salary costs for the free nurses’ clinic located in the shelter. The clinic provided medical services to 2,671 persons during the program year, exceeding the projected goal of 1,600. As a result of the services provided, 418 emergency room visits were averted.

YST utilized ESG funds to operate Oklahoma’s largest shelter for adolescents. In PY 2022, the shelter served a total of 152 adolescent youth. The shelter program now has a full-time counselor at the shelter to address the increasing emotional/mental health challenges of the youth staying at the shelter. They also offer on-site psychiatric services through the OSU Health Sciences Center, Department of Psychiatry and Behavior Sciences. During the year 57 (37%) of the youth exited the shelter to transitional or permanent housing. The CDBG-funded Transitional Living Program was able to serve 95 youth, with 31% successfully completing the program and 100% housed by the end of the program year. 93% Clients exiting the program continued to live successfully on their own at six months, with 22% engaged in job training or school and 63% employed. Of the remain program participants 48% were still receiving program services at the end of the project year.        

The ESG-funded Homeless Legal Assistance Program operated by Legal Aid Services of Oklahoma (LASO) assisted a total of 170 persons, of which 43 were people were assisted in applying for or appealing denials of Social Security benefits. Nine people received monthly income from the Social Security Administration for an average monthly amount of $771.18 and eight people received backpay awards in the total amount of $126,704.51 due to LASO’s assistance. LASO was able to advise 51 people about replacing missing identification papers and able to obtain 30 birth certificates for those persons thus removing barriers to employment and housing. An additional 20 people received legal assistance with tax issues, consumer debt issues and family law matters.

The Salvation Army Center of Hope (COH) provided a total of 88,228 nights of lodging and 329, 176 meals to those seeking emergency shelter, along with case management to 2,696 guests. The CDBG funds were used for costs associated with food and security guards.

ESG-CV funds were used to provide emergency shelter operating costs which served a total of 2,614 persons.

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are:  likely to become homeless after being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions);  and,  receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs.

In an effort to prevent homelessness, the City of Tulsa and the Continuum of Care focus on five primary preventative services offered by various provider organizations including:

• Mortgage /Rental assistance;
• Utility assistance;
• Eviction prevention;
• Counseling/advocacy;
• Mediation;
• Housing Stability Services; and
• Legal assistance

The Landlord Tenant Resource Center (LTRC), a division of the CoC lead agency, Housing Solutions, continued its efforts to make homelessness rare, brief, and non-recurring within our community by offering access to resources and education related to eviction diversion and prevention. The LTRC focuses on stopping homelessness before it begins by working to provide supports and information that may help community members stay safe and stably housed. Highlights from this work include: (1) the Tulsa's Eviction Diversion Program called the Social Services Hub (Hub). Opened in 2021, the HUB operates in conjunction with the Tulsa County Forcible Entry Docket aka Eviction Docket. Open Monday-Thursday from 1:00pm-4:30pm at Iron Gate, the Hub has served over 3,968 unique individuals during the program year, (2) Holding "onsite" events at the request of our community landlords to bring our mobile unit, staff, and resources to meet the tenants and landlords where they are at (landlords can request this service using a link on our website) (3) Participating in community-wide events like the Expungement Expo, Tulsa PRIDE, and the newly launched Just Home program events, and (4) Producing plain language resources in both English and Spanish to inform our landlords and tenants about the availability of resources/programs, rights and responsibilities education, and court navigation.

PY22 ESG and ESG-CV funds were used by Family Safety Center and Salvation Army for Homelessness Prevention services.  ESG funds assisted 268 persons, and ESG-CV funds provided assistance to an additional in 134 people.

Tulsa CARES (TC) provided housing services in the form of short-term rent, mortgage and utility assistance, tenant-based rental assistance, permanent housing placement and supportive services with HOPWA funds as outlined in the HOPWA CAPER which can be found in the appendix (See Section 4 – Additional Reports).

The Community Service Council (CSC) also operates the 2-1-1 Help Line providing referrals to multiple organizations that provide services to help people remain housed. No grant funds were awarded to this agency during PY22.

Publicly funded institutions and systems of care are overseen by the State of Oklahoma. Discharge policies and practices are managed by the designated State agency.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again

YST used CDBG funds to partially fund a transitional housing program that served 95 unaccompanied youth ages 17-22. 31% successfully completing the program and 100% of those remained housed by the end of the program year. 93% Clients exiting the program continued to live successfully on their own at six months, with 22% engaged in job training or school and 63% employed. Ongoing long-term assistance through YST rapid rehousing program funding with ESG-CV dollars, help 14 youth stay housed.   

ESG-CV funds were also used by Tulsa Day Center and Mental Health Association OK through Rapid Rehousing Programs which help to continue assisting 332 households during the program year.

Actions taken to address the needs of public housing

No PY 2022 funds were allocated to projects directly relating to addressing public housing needs. Funds were allocated to the City of Tulsa Engineering Department to provided infrastructure improvements as part of the ongoing Tulsa Housing Authority River West project. River West, funded through the HUD Choice neighborhood program. Additional information on this project is provided below.

Actions taken to encourage public housing residents to become more involved in management and participate in homeownership

THA operated Community Centers at all its public housing apartment communities. Each center was staffed by THA Social Service Coordinators (SSC) that assisted all residents in connecting with partnering agencies and organizations in achieving their individual health, educational and employment goals to ultimately break the cycle of generational poverty. Personal barriers that prevent self-sufficiency may include clothing, transportation, childcare and chronic health conditions. Once those barriers are addressed, the SSC assists residents in connecting with partner agencies and organizations to obtain a high school diploma/GED, technical training, higher education or whatever may be necessary to help the residents become self-sufficient.

THA staffed two Family Service Coordinators with funding received under a ROSS Family Service Coordinator grant that provided case management services at six public housing family communities.  These Family Service Coordinators completed a needs assessment on all participants in the program and goals were set according to each individual resident’s needs.  The Family Service Coordinators provided additional job placement assistance, counseling, group networking, and outreach to community resources. Both Family Service Coordinators worked closely with local agencies to bring programs and services to the community sites. Monthly meetings were held to assess progress and assist with any barriers in reaching the participant's stated goals.  As an incentive, the Family Self-Sufficiency (FSS) Program opened an escrow account for each participant. As the family's income increased, contributions were made to the escrow account on their behalf.  Once the family is determined to be "Self-Sufficient" by meeting their goals and other program requirements, the money in the escrow account will be paid to the participant.  No conditions are imposed on the use of the money, but the family is encouraged to pursue homeownership.  Information regarding local Homebuyer Education Programs is provided to the family.

Residents of THA communities were actively involved in the planning and development of programs for their communities.  The Resident Associations met monthly to discuss concerns as well as plan events and activities for their communities.  Each Association has a set of by-laws that have been voted on and approved by the members that outline how their association will operate.  Training that includes job duties, parliamentarian procedures, communication and financial bookkeeping were provided to all Resident Association officers.

In 2018, THA was awarded a $30mm U.S. Department of Housing and Urban Development’s Choice Neighborhoods Implementation Grant that will leverage other public and private funds to revitalize Riverview Park Apartments, a THA public housing property, and Brightwaters Apartments, a HUD subsidized Section 8 property, along with investing in improvements to West Tulsa Park, establishing a neighborhood grocery store, and piloting new programs with local agencies to strengthen resident and community growth within health and wellness, employment and self-sufficiency and educational attainment. The Choice Program provides one-on-one case management for all 390 families in Riverview and Brightwaters for the entirety of the grant period as well as increased mobility counseling as families are relocated during construction to ensure their ability to return to the new units, using their first right to return. Phase I, II, and III are complete and lease. Phase IV remains under construction, and Phase V and VI were initiated during the program year. The project is scheduled to be completed in September 2024.

In 2018, THA received approval to proceed with a portfolio wide conversion through the Rental Assistance Demonstration (RAD), transferring fee simple ownership of the 13 public housing properties from HUD to THA via the RAD project-based rental assistance program. Residents are engaged throughout the conversation process to provide information on the new structure, provide input on any planned renovations and to understand the choice mobility voucher option that is made available to them one year after conversion. THA has continued work on the RADS conversions during the program year.

In 2019, THA completed comprehensive, community led master planning for the redevelopment of Comanche Park Apartments. The THA Board of Commissioners approved the final plan in November 2019, with redevelopment calling for the replacement of the existing 271 subsidized units with over 400 mixed-income apartments across a range of housing types; neighborhood sized retail/commercial spaces; a centralized park space and overall improvements to site connectivity and infrastructure. Through this new planned mixed-income community, residents were engaged in identifying both houses and non-housing uses, as well as were vocal in ensuring the development included opportunities for home ownership. With such input, the final phase will include 8 single family homes made available both for existing and new residents, partnering with the homebuyer program provided through Housing Partners of Tulsa. In February 2022, THA, in partnership with the City, submitted an application for a FY21 Choice Neighborhoods Implementation Grant, and was announced as a finalist for that grant on May 25, 2022. In September 2022, THA were one of four communities selected approved for funding. THA will receive $50m in Choice neighborhoods that form part of a $190m multi-year investment to transform and area of Tulsa  in much need of quality affordable housing. Demolition of the existing property commenced in May 2023.

Actions taken to provide assistance to troubled PHAs

The Housing Authority of the City of Tulsa is not designated as troubled.

Actions taken to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment. 91.220 (j); 91.320 (i)

The Tulsa Planning Office continue to implement and amend the Zoning Code, which came into effect on January 1, 2016.  The Zoning Code supports diverse, affordable housing opportunities including various lot size options for single-family homes and the introduction of new housing types such as mixed-use buildings, cottage homes, patio homes and multi-unit houses. These housing types are allowed in certain districts and can introduce density and affordability, while remaining compatible with nearby single-family neighborhoods.

After a 15-month process of development and community input, citywide changes to the zoning code and the new Neighborhood Infill Overlay (Section 20.080 of the Tulsa Zoning Code) took effect in December 2021. Both sets of amendments aim to reduce barriers to housing options. The regulations and boundaries of the Neighborhood Infill Overlay were developed by a staff working group and refined from input received during meetings with neighborhood residents, local builders, licensed architects, and various City officials.

The overlay allows up to six dwelling units to be constructed on a single residential lot by right, plus accessory dwelling units. The building types allowed include: duplex, multi-unit house (triplex, quadplex), townhouse, cottage court, and apartment/condo. The overlay also reduces minimum lot sizes, reduces parking requirements by 50%, reduces minimum open space requirements, and reduces minimum street, side, and rear setback and lot width requirements to fit the predominant narrow lot pattern of these older neighborhoods, which will make these lots buildable by right for the first time in more than 50 years. Eliminating the need to seek special permission to construct these housing types will reduce uncertainty for builders, and is anticipated to increase the development of affordable housing options. Neighborhoods and city councilors in other parts of Tulsa have already inquired about expanding the overlay or implementing similar measures to encourage this type of development in their areas of the city.

Citywide changes to the zoning code also focus on lot and building regulations, reducing the lot area requirements for duplexes and cottage house developments, lot widths for duplexes and townhouses, and the required street setback in Residential-Multifamily zoning districts. Both the overlay and citywide changes stem from recommendations in a 2020 housing study and strategy.

Additional steps to facilitate the development of affordable missing middle housing are in the exploration stage, including the potential development of a program that offers pre-approved building plans for certain housing types, which would reduce uncertainty, architectural fees, and processing time for permits for home builders, while ensuring predictability and compatibility for neighborhood residents.

The Tulsa Planning Office is also leading the update to the City of Tulsa’s comprehensive plan, planitulsa.  Recommendations from the City of Tulsa’s Affordable Housing Strategy are being incorporated into planitulsa, and are being combined with input from the general public and subject matter experts about how Tulsa can build and maintain strong neighborhoods. The recommendations will set the stage for modifications to regulatory documents associated with development activities in the city, such as the Zoning Code, Subdivision Regulations, and Building Codes. Further insight into potential regulatory limitations will be gathered through a series of roundtable discussions with organizations that work through the permitting processes of the City as they develop properties. These insights will inform recommendations to make the permitting process more consistent, transparent, and predictable.

On March 1, 2023, Tulsa’s first independent study of Tulsa’s housing crisis, conducted by Development Strategies and Homebase, was published and prepared for Housing Solutions: https://www.housingsolutionstulsa.org/tulsa-housing-study/. This study was supported by the City of Tulsa, Partner Tulsa, Downtown Tulsa Partnership and Tulsa Housing Authority. This study summarized the following:

1. Housing is needed in Tulsa across the affordability spectrum
2. There is no single solution or strategy that will make it possible to meet demand
3. More than half of housing demand is for units at or below 100% average median income.
4. Meeting demand will not solved all of Tulsa’s housing challenges.

The total 10-year demand broken down by affordability in areas that HUD funding could help address is as follows:

• Extremely Low Income (<30% AMI or <$20,000)- 2,160 units
• Very Low Income (30% AMI to 50% AMI or $20,000 to $30,000)- 1,790 units
• Low Income (50% to 80$ AMI or $33,000 to $54,000)- 2,290 units

Actions taken to address obstacles to meeting underserved needs.  91.220(k); 91.320(j)

In PY 2022, the City of Tulsa provided funds to 29 external agencies and 2 city departments to conduct 39 activities. By awarding funds to a variety of agencies and multiple activities, the City assisted in addressing obstacles to meet the underserved needs of the community. In addition, Tulsa CARES utilized HOPWA funds to support people with HIV/AIDS.

CDBG funds were used to provide public service activities to 9,365 persons. These activities served children and youth, battered persons, and abused and neglected children. The funds also assisted people with transportation needs, employment/training programs, and health services. ESG funds were used for Homelessness Prevention assistance was provided to 268 persons, and Shelter and Services were utilized by 831 persons. HOPWA funds served a total of 380 people, with housing assistance and/or support services.

Three public facilities and improvement projects received funding during PY22, one project was cancelled. The two remaining projects included new sidewalks installation in a low-income neighborhood and improvements to an early childhood education facility. Both projects were delayed due to issues with the HUD Environmental review Tribal Historic Preservation Clearance. Projects are expected to be completed during PY23.

Through an economic development activity for small business loans, 92 FTE jobs were created or retained, and 18 businesses were assisted. 91 of the jobs created or retained were filled by low- and moderate-income persons. Through an economic development activity for micro-enterprises 33 businesses were assisted during the program year.

Additionally, CDBG funds were utilized to demolish 24 dilapidated structures.

Actions taken to reduce lead-based paint hazards. 91.220(k); 91.320(j)

All programs that provided rehabilitation to owner-occupied homes inspected each house built prior to 1978 for lead-based paint (LBP) hazards using a Certified LBP inspector or risk assessor. In homes where an inspection confirmed the presence of LBP (or it was presumed), all contractors were required to implement safe work practices during the rehabilitation work in accordance with HUD’s Lead-Safe Housing Rule.  The City’s Working in Neighborhood Department prequalified contractors to work on HUD-funded projects and all were trained in lead-safe work practices. 

Grants Administration includes additional measures to ensure specific grant-funded activities comply with LBP regulations. Additional language is included in subrecipient agreements for projects where rehabilitation work occurs, requiring subrecipients to produce documentation of LBP testing prior to any work commencing. Additionally, Grants Administration’s Construction Checklist used for grant-funded construction and housing projects includes a check for LBP compliance. 

Environmental Health Services Division at the Tulsa City County Health Department (TCCHD) continued operating the Lead Hazard Control Program, which was launched in October 2020. This program identified lead-based paint in homes throughout Tulsa County. The Lead Hazard Control Program’s (LHCP) goal is to create healthy living conditions for children under the age of 6 through a HUD grant. TCCHD’s outreach includes lead testing and home inspections, Safe and Healthy Homes education, tenant rights, and promoting lead testing in children. The City is helping advance the LHCP in three keyways: 1) Working in Neighborhoods (WIN) is assisting TCCHD by referring citizens who contact them about housing rehabilitation to this new program; 2) the Mayor’s Office is helping to advertise LHCP by including it as a component in the Goldstar Landlord Program; and 3) the City has assisted in planning numerous education events to increase awareness of housing safety.

Actions taken to reduce the number of poverty-level families. 91.220(k); 91.320(j)

To attempt to break the cycle of poverty for the City's youth, the City continued to fund education programs and provide after school programs and transitional living programs for youth. In addition, educational needs and employment training of low-income parents were also addressed with CDBG funding. Other programs offered mentoring to people released from prison and assistance to victims of abuse. Services to help homeless individuals on a path to self-sufficiency were also conducted during the program year.

The City received CARES Act funding from various sources which was used in a variety of ways to help address the needs of citizens and businesses as a result of the coronavirus pandemic. The Mayor formed a Coronavirus Relief Fund Working Group to ensure the various sources of funds were allocated to address critical needs and to eliminate duplication. Staff from Grants Administration participated in this group to ensure the CDBG and ESG CARES Act funding was allocated to areas of need based on eligible use of the funds. In PY22 the City expended over 2.5m in CARES act funding through 17 projects aimed at providing suitable living environments.

The Tulsa Housing Authority’s Family Self-Sufficiency (FSS) Program also provided resources to assist families toward becoming self-sufficient.  Interested residents participate in the program to establish goals, such as employment or homeownership. An escrow account is established for each participant and money is added to this fund when they meet their goals and program requirements.   Once families meet their goals they are encouraged to use the escrow funds to pursue homeownership. 

Actions taken to develop institutional structure. 91.220(k); 91.320(j)

Program Year 2022 goals and priorities were set with input from the public, non-profit organizations and the City’s HUD Community Development Committee. In October grant applicants were informed of the City’s goals, priorities and target areas. Once funding was awarded, the HUD Community Development Committee (CDC) continued to review the performance of projects and programs during the year. 

The City of Tulsa utilized City departments as well as non-profit organizations, community and faith-based organizations, developers, and social service agencies to carry out projects for the second year of the City’s five-year plan. Multiple philanthropic organizations throughout the City also provide funding to the same projects/programs funded with HUD grant dollars. These leveraged dollars allowed our grant recipients to continue or expand their programs during the year. 

Assisting low- and moderate-income persons, especially the unemployed, is critical to the economic success of the City of Tulsa; therefore the City funded programs that assist such persons in becoming economically self-sufficient through skills training and workforce development services. The City of Tulsa also addressed economic opportunities by providing funding to a Community Development Financial Institution (CDFI) to provide loans to businesses normally excluded from the economic mainstream so that jobs would be created through the development, stabilization and expansion of small businesses. 

To ensure continued compliance with the HEARTH Act, Grants Administration (GA) worked closely with the city’s Continuum of Care and Emergency Solutions grant recipients serving the homeless. Tulsa’s Project Sponsor for the HOPWA grant, Tulsa CARES, completed an expansion of their facility three years ago using private funds. This enables them to continue to offer more services through collaboration with other organizations and clients have better access to public transportation.

Actions taken to enhance coordination between public and private housing and social service agencies. 91.220(k); 91.320(j)

Tulsa benefits from a strong and cohesive coalition of local government officials, service providers, lenders, and volunteers.  These various groups coordinate effectively to avoid duplication of services and facilitate a delivery system which meets the needs of Tulsa's various populations.  

The City continued its public outreach effort to educate and engage the public regarding HUD Grants and televised all HUD Community Development Committee meetings.

Coordination and integration of ESG-funded activities with other programs is being implemented through the Tulsa Continuum of Care’s 5-Year Strategic Plan. This plan provides a strategic, community-wide system to prevent and end homelessness in the Tulsa County geographic area. The Tulsa CoC and City of Tulsa coordinated a crisis response for 104 residents at an apartment complex who were all at-risk of homelessness. The city was forced to close the apartment complex because the owner(s) failed to address the uninhabitable living conditions.

The Landlord Tenant Resource Center (LTRC), a division of the CoC lead agency, Housing Solutions, continued its efforts to offer access to resources and education related to eviction diversion and prevention. Highlights from this work include: 1) Launch and facilitate Tulsa's Eviction Diversion Program, the Social Services Hub (Hub) which served over 4,000 tenants and 170 landlords since opening in August 2021; 2) Hold events to bring a mobile unit, staff, and resources to meet with tenants and landlords onsite; 3) Participate in community-wide events; and (4) Provide plain language resources in both English and Spanish to landlords and tenants about resources, programs, rights and responsibilities education, and court navigation.

During PY22 the City awarded approximately 6.5m of funding received through The Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program, authorized by the American Rescue Plan Act, to local non-profits service providers to help develop capacity.

Identify actions taken to overcome the effects of any impediments identified in the jurisdictions analysis of impediments to fair housing choice.  91.520(a)

To be included in the final CAPER

Describe the standards and procedures used to monitor activities carried out in furtherance of the plan and used to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements

All funded projects and agencies were assigned a risk factor rating to identify which projects were to be monitored on-site during the year.  This assessment rates risk based upon the type of project, compliance issues, complexity of the project, and known capacity of the agency.   Agencies with a high risk rating were selected for formal onsite monitoring as well as those programs not monitored recently.  GA utilizes the HUD CPD Monitoring Handbook as its standard and guideline for each formal monitoring visit.   Desk monitoring of all HUD-funded programs and projects were conducted throughout the year to ensure compliance with regulations and agreement requirements.   Physical projects are inspected on a periodic basis until completion to confirm construction/rehabilitation projects are progressing and funds are being spent as planned. 

For new HOME rental projects, on-site inspections occur throughout the project and the first on-site monitoring occurs within 12 months after project completion.  Because of the 2013 HOME Final Rule, unless a rental project is considered a high-risk property, HOME monitoring schedules have been adjusted to ensure these on-site monitoring visits for rental properties still under the period of affordability are conducted at least every three years. The Rental Annual Reporting requirements included in each rental written agreement does ensure that the properties have a desk monitoring review yearly and that they remain financially viable and are operated/managed according to the HOME requirements. 

It is the policy of the City of Tulsa to encourage the use of minority or woman owned businesses in contracting opportunities.  As part of HUD’s grant requirements and written agreements, agencies performing construction and rehabilitation projects are encouraged to hire Section 3 residents and/or utilize Section 3 businesses and WMBE businesses when contracting or subcontracting. 

Citizen Participation Plan 91.105(d); 91.115(d)

Describe the efforts to provide citizens with reasonable notice and an opportunity to comment on performance reports.

In accordance with the Citizen Participation Plan, the City of Tulsa posted notices in the Tulsa World at least 14 days in advance of public hearings.  In addition, notice was posted on the City’s website and social media sites. The draft CAPER will be available for comment form September 9^th 2023 – September 23, 2023.

PY 2022 HUD ESG Caper

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