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 Program Year (PY) 2024. 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 36 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 $7,787,122.97 in annual entitlement funding to:

• Serve 10,479 people through public service activities
• Provide HOPWA services including STRMU, TBRA and Permanent Housing Placement to 137 persons with AIDS
• Assist 27 persons with Homeless Prevention activities
• Provide emergency shelter to 855 people
• Assist 358 persons with Street Outreach activities
• Create or retain 58 FTE jobs
• Rehabilitate 117 homeowner homes
• Assist 31 first time homebuyers
• Rehabilitate 2 public facilities that will serve 2,636 low- and moderate-income citizens
• Demolish 18 substandard structures

The City of Tulsa also continued to expend additional funding received through the Coronavirus Aid Relief and Economic Security Act (CARES Act) during PY24. A total of $269,250.16 of CARES Act funding was expended from July 1, 2024, through June 30, 2025.

One project funded with CDBG-CV expended funding during the project year to:

• Serve 63 people through public service activities.

The City has been allocated $6,487,524 in HOME-ARP Funds. To receive access to 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 76.4% of the HOME-ARP funding to be used to create affordable rental housing units in Tulsa, with 8.6% used for HOME-ARP Supportive Services for those who are housed in these HOME-ARP units. Grants Administration has selected a partner to implement the HOME-ARP project, Tulsa Housing Authority (THA), and anticipates that allocations will be approved and projects underway by late 2025.

There have been delays in the implementation of the HOME-ARP project due to a myriad of circumstances including:

1. The City's pilot permitting program.
2. Difficulty in securing required funding for total project costs.
3. THA's audit backlog.
4. Environmental review setbacks.

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

The City of Tulsa expended $8,016,863.14 in HUD funds during PY24.

CDBG expenditures totaled $4,838,920.18; CDBG-CV expenditures totaled $269,250.16.

ESG expenditures totaled $241,001.14.

HOME expenditures totaled $1,923,707.33.

HOPWA expenditures totaled $783,494.32.

During PY24 the City continued to work towards accomplishing the five-year goals set out in the consolidated plan. Public facility and housing projects continued to experience delays related to materials/supply shortage and higher costs and HUD Environmental Review issues.

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 PY24, 112 homes received emergency repairs, with an average of $6,275 per home. An additional five homes received rehabilitation services through a HOME Homeowner Rehabilitation Loan program.

One CHDO HOME rehabilitation project was funded an additional $1,000,000 in PY23 for the initially funded PY22 project: Country Oaks. Country Oaks seeks to rehabilitate 11 affordable rental units and construction started in Fall 2024. Another HOME rehabilitation was funded during PY22, Belle Arms & Southwind Apartments, and seeks to rehabilitate 22 affordable rental units and construction started in the Summer of 2025. One Rehabilitation project of a multi-family rental development, Terrace View Apartments, completed interior construction in March 2024 and exterior construction in April 2024 and resulted in 22 rehabilitated HOME units. Construction was completed in the final quarter of 2024.  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. Buena Vida has created seven single-family homes to sell to eligible homeowners whose income is no more than 80% of the Tulsa Area Median Income. Both projects have made sufficient progress, and construction was completed on the homes at various times from April 2024-June 2024. At the end of Program Year 2024, reporting requirements and final reimbursement were pending on Both Buena Vida projects, full project completion is projected for the late summer 2025.

One first-time home buyers Down Payment Assistance (DPA) program expended funds during the program year. Tulsa Habitat for Humanity assisted 31 households with DPA funding during Program Year 2024, utilizing $330,000. 5 of the households assisted will be counted in Program Year 2025's report.

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 are tied to one of HUD’s specific performance objectives of Creating Suitable Living Environments, Providing Decent Housing, or Creating Economic Opportunities. During Program Year 2024 the City of Tulsa expended $7,039,362,86 of PY 2024 funds, carryover funds and revolving loan funds, on activities and projects excluding general administration and Homeless Management Information System (HMIS) data collection. Eleven activities expended $3,830,666.68 to support Decent Housing, twenty-five activities expended $1,270,172.52 to Create Suitable Living Environments, and one activity expended $1,938,523.66 to Create Economic Opportunities.

In CARES Act funding, the City of Tulsa expended $256,762.27 on activities and projects excluding general administration and Homeless Management Information System (HMIS) data collection. One activity expended $256,762.27 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 doesn’t include all race types reported in IDIS and therefore does not represent the total families served. A table showing the total number of people served during PY24 is included below. See Appendix Section 4 for additional reports for each individual grant.  

The following table shows the total PY24 racial data (not including sidewalks and the Choice Neighborhoods Program).

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 2024 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 $269,250.16 was expended during the PY24 program year.

Additional data on investments and resources by geographic area will be available in the CAPER final draft.

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. 

Additional information on CDBG and HOME matching will be included in the CAPER final draft.

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.

The City did not identify any publicly owned land and property that could be used to address the needs identified for PY 2024.

Additional Match Contribution Data will be available in the CAPER final draft.

HOME MBE/WBE report

No Program Income was incurred during the Program Year.

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.

MHAOK was allocated $892,828 in PY21 for the major rehabilitation of the multi-family rental development, Terrace View Apartments. Terrace View’s performance period was July 1, 2021, through July 31, 2024, and resulted in 22 HOME-assisted units. Construction was accomplished, reporting requirement completed, and project funds fully drawn in PY 2024. Project marked as completed in PY 2025 and will be counted in next year's CAPER.

In PY20, Tulsa Habitat for Humanity DBA Green Country Habitat for Humanity was awarded $618,625 for constructing and selling five Single-Family housing units in the development, Buena Vida. In combination with their parent company, Boomtown, Buena Vida has created seven single-family homes to sell to eligible homeowners whose income is no more than 80% of the Tulsa Area Median Income. Construction was completed at various times from April 2024 - June 2024. At the end of Program Year 2024, reporting requirements and final reimbursements were pending on both Buena Vida projects and full project completion is projected for the last quarter of 2025. Green Country's contract was extended through December 31, 2025, with their final draw being held until Section 3 requirements are completed. Boomtown's two units have not yet been sold, so their project is not marked as completed.

Tulsa Habitat for Humanity also used $330,000 in HOME funds and assisted 31 households in purchasing their first home. 5 of households that were assisted with the $330,000 will be counted in Program Year 2025's report due to when their projects were completed.

The City of Tulsa's Housing Department utilized both HOME and CDBG funds to provide homeowner rehabilitation programs. The CDBG Homeowner Repair program served 112 homeowners, providing necessary safety and sanitary improvements. The HOME Homeowner Rehabilitation Loan Program provided substantial rehabilitation to houses for 5 homeowners.

Family Safety Center, Inc, used PY23 ESG funds to provide Homeless Prevention assistance to 4 persons. The previously allocated PY24 funds were returned due to difficulty finding income qualified households in the specific subset of the population. The returned funds were reallocated to another program providing Homlessness Prevention.

Additional ESG Reporting will be available in the CAPER final draft.

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 of Tulsa 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 community with quality housing opportunities for all residents. In April 2024, The Mayor/Council Housing, Homelessness, and Mental Health (3H) Task Force has released its Path to Home recommendations, which include four goals and 33 actions to address community needs, where Housing Production and Preservation is the first goal. In September of 2024, the 3H Task Force was involved in discussions around the development of priority needs for the 2025-2029 HUD Consolidated Plan to ensure alignment with Path to Home recommendations and Tulsa Housing Strategy.

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 summarizes 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 solve 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 PY24.

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

One street outreach program for unsheltered persons was funded with PY24 entitlement funds. 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 358 unsheltered persons were assisted with street outreach services during PY24 funded with ESG funds.

In addition to the efforts of the funded agency there are also outreach programs organized locally by faith-based organizations and other non-profit organizations. Housing Solutions works with other local organizations to coordinate street outreach for people 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 Tulsa Day Center (TDC), Legal Aid Services of Oklahoma, and Youth Services of Tulsa (YST). In addition, CDBG funds were provided to TDC and YST to provide services, counseling, case management, and basic needs to those experiencing homelessness or those at risk of homelessness.

TDC provided shelter and essential services to homeless persons by using ESG funds for operational expenses. During the program year 370 unduplicated clients stayed in the night shelter. In addition to shelter, 5,552 Individuals also had access 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 1,727 unduplicated persons during the program year, exceeding the projected goal of 1,072. As a result of the services provided, 344 emergency room visits were averted.

YST utilized ESG funds to operate Oklahoma’s largest shelter for adolescents. In PY 2024, the shelter served a total of 240 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 215 (90%) of the youth exited the shelter to transitional or permanent housing. The CDBG-funded Transitional Living Program was able to serve 124 youth, with 57% successfully completing the program and 90% housed by the end of the program year. Eighty-one percent of Clients exiting the program continued to live successfully on their own at six months, with 38% engaged in job training or school and 65% employed. Of the remaining program participants 57% were still receiving 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 247 persons, of which 13 people were assisted in applying for or appealing denials of Social Security benefits receiving monthly income from the Social Security Administration for an average monthly amount of $943.00 and receiving backpay awards in the total amount of $18,000 due to LASO’s assistance. LASO was able to advise 79 people about replacing missing identification papers and able to obtain 77 birth certificates for those persons thus removing barriers to employment and housing.

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.

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 support 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 also known as the Eviction Docket. Open Monday-Thursday from 1:00pm-4:30pm at Iron Gate, the Hub has served 4,460 unique individuals during the program year.

(2) Holding "onsite" events at the request of community landlords to bring the mobile unit, staff, and resources to meet the tenants and landlords where they are.

(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 landlords and tenants about the availability of resources/programs, rights and responsibilities education, and court navigation.

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 Tulsa Area United Way (TAUW) 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 PY24. However, for PY25, their 2-1-1 program was approved to receive $25,000.

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 124 unaccompanied youth ages 17-22. 57% successfully completing the program and 100% of those remained housed by the end of the program year. Eighty-one percent of Clients exiting the program continued to live successfully on their own at six months, with 38% engaged in job training or school and 65% employed. Of the remaining program participants 57% were still receiving services at the end of the project year.  

Actions taken to address the needs of public housing

While no PY 2024 funds were allocated to projects directly relating to addressing public housing needs, funds were allocated to City of Tulsa's Public Works Department to provide needed infrastructure improvements as part of the ongoing Tulsa Housing Authority Comanche Park project. This is a large-scale project funded through HUD's Choice Neighborhood Implementation program. More information 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 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 and our SSC’s have strengthened their partnerships within the community.  We have several MOUs with partners such as Family and Childre’s Services, The Foodbank of Eastern Oklahoma, and Amplify Tulsa.  The SSCs work very closely with the Tulsa County Library, Lilyfield, Oklahoma Caring Foundation, Tulsa Health Department, CREOKS, Goodwill, Tulsa County Health Department, Food on the Move, YMCA, and Tulsa Responds just to name a few.  

Residents of THA communities were actively involved in the planning and development of programs for their communities.  The Resident Associations meet 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 was provided to all Resident Association officers.

In 2018, THA was awarded a $30M 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 Neighborhood 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. Phases I, II, III, IV, and V are complete and leased. Phase VI, construction is completed, and leasing is in progress.  The project is scheduled for completion in September 2024 and case management will continue for all residents of River West.  

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 housing 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. In February 2022, THA, in partnership with the City of Tulsa, 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 was one of four communities selected approved for funding. THA received $50M in Choice Neighborhood Initiative funding that forms part of a $190M multi-year investment to transform an area of Tulsa in critical need of quality affordable housing. The project also received a commitment of over $2M in City of Tulsa SLFRF funding. Demolition of the existing property commenced in May 2023 and case management started February 2022 and is continuing for the Comanche Park residents who have been moved off site. Currently, the project is in Stage 7 of its timeline, which includes Phase III of tenant relocation and initiation lease-up of Phase I construction.

Actions taken to aid 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 continues to implement and amend the Zoning Code, which came into effect on January 1, 2016. The Zoning Code supports a variety of 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 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 summarizes 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 solve 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 2024, the City of Tulsa provided funds to 24 external agencies and 3 city departments to conduct 36 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 10,226 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 92 persons, and Shelter and Services were utilized by 855 persons. HOPWA funds served a total of 337 people, with housing assistance and/or support services.

Two public facilities and improvement projects received funding during PY24. One project was completed and one is ongoing. Projects are expected to be completed in 2026.

Through an economic development activity for small business loans, 58 FTE jobs were created or retained, and 12 businesses were assisted. 45 of the jobs created or retained were filled by low- and moderate-income persons.

Additionally, CDBG funds were utilized to demolish 18 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 Housing Department prequalified contractors to work on HUD-funded projects and all were trained in lead-safe work practices. The City’s Housing Department also utilizes a third party for testing prior to beginning any work for their rehabilitation programs. These measures have been effective in reducing the amount of Lead in households.

Grants Administration includes measures to ensure specific grant-funded activities comply with LBP regulations. 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 identifies lead-based paint in homes throughout Tulsa County. TCCHD closed out their first Lead-Based Paint Hazard Control grant, spending over $1 million in funding. In 4 years, TCCHD conducted 181 lead-based paint inspections. This response shows the continued need for a Lead Hazard Control Program in our community. TCCHD completed 25 lead abatements in homes at an average cost of $32,450 each. The program replaced many broken wooden sash windows with energy efficient windows in low-income homes. In October 2024, TCCHD received a $2,973,984 grant renewal. Their goal is to complete 140 lead-based paint inspections, and 70 abatements based on a $32,000 average per house.

Additionally, TCCHD participates in numerous community events every year to educate families on the importance of testing young children for lead levels in blood.

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 of Tulsa received CARES Act funding from various sources which was used in a variety of ways to help address the needs of citizens and businesses because 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 CARES Act funding was allocated to areas of need based on eligible use of the funds. In PY24 the City expended $269,250.16 on CARES act funding through 1 project aimed at creating 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 2024 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 of Tulsa 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 four 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 of Tulsa 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 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 14,260 tenants and 182 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 PY24, local non-profits service providers expended over $5.5M in Coronavirus State and Local Fiscal Recovery Funds (SLFRF) awarded by the City of Tulsa. These projects are aimed at providing support to communities and persons disproportionately impacted by the COVID-19 pandemic. A full reporting on PY24 SLFRF activities can be found on the City's website: https://www.cityoftulsa.org/covidrelief.

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

The City’s designated department for fair housing is located the Mayor’s Office (MORE). During PY 2024 there were two housing-related complaints received by MORE. These were resolved with mediations. Of the two complaints that were mediated, one complaint was with the Tulsa Housing Authority (THA), one was with the City of Tulsa’s Housing Department.

The U.S. Department of Housing and Urban Development Fair Housing and Equal Opportunity (FHEO) received seven fair housing complaints in Tulsa during PY24. Four of those complaints have been closed. One was settled successfully, two were withdrawn by complainant after resolution, and one complainant failed to cooperate. Three cases remain open.

The City of Tulsa partners with the Tulsa Area Fair Housing Partnership (“TAFHP”) to provide outreach activities for the public, home buyers/renters, and realtors/landlords. TAFHP continued to provide outreach activities throughout the program year. In April of 2025, a Fair Housing Summit was held. Also, in April of 2025, a Housing Education Seminar was hosted by the Tulsa Area Fair Housing Partnership. In June 2025, a Freedom Through Wealth Seminar was held. These events were free and open to the public.

MORE collaborated with various external partners for an outreach/resource event assisting potentially displaced residents.

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 was 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. The 2025 HOME Final Rule reduces the burden by adding monitoring flexibilities for small-scale housing projects to help streamline procedures. 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 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 W/MBE 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 was available for public comment from September 4th, 2025 – September 19th, 2025.

Specify the nature of, and reasons for, any changes in the jurisdiction’s program objectives and indications of how the jurisdiction would change its programs as a result of its experiences.

The City of Tulsa did not make any changes to the CDBG program objectives during the year. The City monitored the expenditure of CDBG funds throughout the year to ensure that projects awarded funds, either during this year or from prior periods, were completed and dollars expended.

As per Ordinance 23362, agencies that did not expend all awarded funds were asked to provide certain documentation to carry over funds into the next program year. Instances where sufficient documentation was not provided resulted in funds being recaptured and reprogrammed by the City.

Does this jurisdiction have any open Brownfields Economic Development Initiative (BEDI) grants?

This program is no longer active.

Include the results of on-site inspections of affordable rental housing assisted under the program to determine compliance with housing codes and other applicable regulations

Please list those projects that should have been inspected on-site this program year based upon the schedule in §92.504(d). Indicate which of these were inspected and a summary of issues that were detected during the inspection. For those that were not inspected, please indicate the reason and how you will remedy the situation.

All HOME rental projects subject to the affordability period were monitored during the program year. Since annual onsite monitoring is no longer required per the 2013 HOME Final Rule, projects with no findings or concerns form the previous onsite monitoring are identified as low risk and scheduled for an onsite monitoring in a two or three-year cycle. Annual monitoring includes finances, occupancy, marketing, property condition, and management reports which are submitted each year according to the established rental monitoring schedule. There are currently 22 developments under the period of affordability, 13 are multi-family and 9 are for seniors.

Onsite monitoring at all developments involved:

• A review of tenant files of the HOME-assisted units to verify compliance with:
  • Income calculations and documentation according to HUD’s Part 5 income determinations and HUD’s applicable income limits for Tulsa
  • Leases and rent charges to verify the appropriate HOME rental rates and utility allowances as approved by GA and in compliance with HOME rental rate limits and utility allowances
• An inspection of HOME-assisted units to ensure compliance with Tulsa’s local codes
• Overall inspection of complex exterior, surroundings, and common areas.

There are a series of onsite monitoring visits that are scheduled to take place in PY25. The following is a summary of the onsite monitoring conducted in PY24:

Tulsa Housing Authority (THA) THA has a total of 164 HOME units, containing elderly and multi-family properties. Each multi-family property contains the following number of HOME units: Latimer Phase I (28), Haskell Phase II (17), Newton Phase II (56), Osage North Phase IV (49), and Nogales Phase V (14). GA staff conducted onsite monitoring April 28-30, 2025. All annual reports were reviewed to ensure the operations of the rental development complied with HOME regulations and GA policies. A few items needed corrections/revisions and GA staff are working with THA on resolution. No future monitoring is scheduled due to the expiration of Affordability Periods for these properties.

Provide an assessment of the jurisdiction's affirmative marketing actions for HOME units. 92.351(b)

GA includes in its grant administration policies that all housing projects include an Affirmative Fair Housing Marketing Plan (AFHMP) that follows the Affirmative Fair Housing Policy established by GA. These plans are required with each application for a housing project and must be updated periodically until land use restrictions on the property have expired. Yearly rental reporting requirements include a review of the most recent AFHMP for each property location and a narrative to report on the outcome of the marketing and outreach efforts and any changes that will be made for the following year. The Tulsa Area Fair Housing Partnership (TAFHP) members play a big part in the education, awareness, and outreach efforts in the city. Subrecipients and local housing developers are among the members of this organization and help carry out the TAFHP plans.

Data on the amount and use of program income for projects, including the number of projects and owner and tenant characteristics

Program income was not incurred this program year.  

Describe other actions taken to foster and maintain affordable housing.  91.220(k) (STATES ONLY: Including the coordination of LIHTC with the development of affordable housing).  91.320(j)

Not applicable

Identify the number of individuals assisted and the types of assistance provided

Table for report on the one-year goals for the number of households provided housing using HOPWA activities for: short-term rent, mortgage, and utility assistance payments to prevent homelessness of the individual or family; tenant-based rental assistance; and units provided in housing facilities developed, leased, or operated with HOPWA funds.

Table 14 – HOPWA Number of Households Served

Narrative

The Tulsa CARES Housing Program has successfully administered the Housing Opportunities for Persons with AIDS (HOPWA) program since 1995. The housing program is designed to work collaboratively with other programs and service providers to identify and develop short- and long-term strategies for meeting the needs of low-income people living with HIV/AIDS and their families. Overarching housing program client goals include: 1) to establish or better maintain a stable living environment for program clients, 2) to improve access to HIV treatment and other health care support, and 3) to prevent homelessness among households living with HIV/AIDS. The actual numbers listed above do not account for duplications. More details regarding the PY 2024 HOPWA funded Housing Program goals are provided in the HOPWA CAPER located in the attachments.

Qualitative Efforts – Number of Activities by Program

Qualitative Efforts – Number of Activities by Program, continued

One HOME activity required Section 3 reporting during this program year, Terrace View. Seventeen (17) Section 3 workers were utilized, of which fourteen (14) were Targeted Section 3 workers. 10.7% of overall labor hours were performed by Section 3 workers.

One CDBG activity requiring Section 3 reporting, six (6) Section 3 workers were utilized, which equated to 100% of the overall labor hours worked.

ESG Supplement to the CAPER in the SAGE HMIS Reporting Repository

For Paperwork Reduction Act

1. Recipient Information

Basic Grant Information

ESG Contact Name

ESG Contact Address

ESG Secondary Contact

2. Reporting Period—All Recipients Complete

3a. Subrecipient Form – Complete one form for each subrecipient

The Following information is now collected using HUD’s Sage HMIS Reporting Repository.

4. Persons Served

4a. Complete for Homelessness Prevention Activities

Table 15 – Household Information for Homeless Prevention Activities

4b. Complete for Rapid Re-Housing Activities

Table 16 – Household Information for Rapid Re-Housing Activities

4c. Complete for Shelter

Table 17 – Shelter Information

4d. Street Outreach

Table 18 – Household Information for Street Outreach

4e. Totals for all Persons Served with ESG

Table 19– Household Information for Persons Served with ESG

5. Gender—Complete for All Activities

Table 20 - Gender Information

6. Age—Complete for All Activities

Table 191 – Age Information

7. Special Populations Served—Complete for All Activities

Number of Persons in Households

Table 202 – Special Population Served

The Following information is now collected using HUD’s Sage HMIS Reporting Repository.

8. Shelter Utilization

Table 23 – Shelter Capacity

9. Project Outcomes Data measured under the performance standards developed in consultation with the CoC(s)

A. Emergency Shelter - Percentage of households exiting from emergency shelter into transitional or permanent housing (excluding youth and DV shelters): 12%

B. Prevention & Rapid Rehousing - Percentage of clients who remained in permanent housing within six (6) months following the last receipt of assistance: 95%

The Following information is now collected using HUD’s Sage HMIS Reporting Repository.
See Section 4 – Additional Reports

11. Expenditures

11a. ESG Expenditures for Homelessness Prevention

Table 214 – ESG Expenditures for Homelessness Prevention

11b. ESG Expenditures for Rapid Re-Housing

75Table 25 – ESG Expenditures for Rapid Re-Housing

11c. ESG Expenditures for Emergency Shelter

Table 22 – ESG Expenditures for Emergency Shelter

11d. Other Grant Expenditures

Table 23 - Other Grant Expenditures

11e. Total ESG Grant Funds

Table 24 - Total ESG Funds Expended

11f. Match Source

Table 259 - Other Funds Expended on Eligible ESG Activities

11g. Total

Table 30 - Total Amount of Funds Expended on ESG Activities