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Orange County homelessness commission fast-tracks letter urging HUD/ congressional action after HUD pauses NOFO
Summary
The Commission to Address Homelessness voted to add an urgency item directing staff to draft a letter to the Board of Supervisors urging full funding and congressional outreach after HUD removed its COC NOFO amid litigation and major funding-rule changes.
The Orange County Commission to Address Homelessness voted to add an urgency item and asked staff to draft a letter to the Board of Supervisors calling for immediate congressional engagement and for HUD to honor funding expectations after the agency removed its 2025 Continuum of Care (COC) Notice of Funding Opportunity (NOFO) from public view.
Doug Rapp, the countys lead staff on care coordination, told commissioners the NOFO released on Nov. 13 included two unexpected changes: a proposed cap on how much COC grant funding can be used for permanent housing and a sharp reduction in the proportion of each jurisdictions renewal grants placed into "tier 1" (historically about 90% of funds) to roughly 30%. He said the countys COC receives about $33.5 million annually and that roughly $28 million (about 89%) has been used for permanent housing under current practice. Rapp said those shifts, if finalized, could reduce the number of Orange County households newly provided with permanent housing; locally, staff estimated the change could affect approximately 1,100 households who have been served through COC-funded permanent housing programs.
Rapp also described litigation in which about 20 states and multiple organizations challenged the NOFO; he said HUD removed the document from its website during court proceedings and indicated to a federal judge it would revise and re-release the NOFO. That pause, Rapp said, complicates renewal timelines for the county because the COCs funding is made up of many separately timed grants, some with renewals due very soon (he cited a grant with a Dec. 31 expiration).
Commissioners pressed staff on contingency planning, communication to clients and housing providers, and how the county would seek extra time to adapt its programs. "We need time to plan," Rapp said, noting the county is preparing contingency measures and urging commissioners to contact members of Congress about local impacts.
Commissioner (speaker 12) moved that the commission find the situation urgent, amend the agenda by two-thirds to allow immediate consideration, and instruct staff to draft a letter supporting full funding of the NOFO and urging the Board of Supervisors to press congressional and federal leaders. Commissioner Morris seconded the motion; the chair called for a voice vote and the motion carried. Commissioners discussed mechanics for the letters approval, whether all commissioners could sign, and the advisory limits of the commissions authority to act on behalf of the Board.
The commission directed staff to circulate a draft letter consistent with widely used templates, to identify who may sign, and to prepare to present the matter at the next Board of Supervisors meeting. Several commissioners emphasized that outside groups and individual signatures could add persuasive weight. The commission did not purport to bind the Board but sought to transmit its advisory position quickly so county leadership could amplify local impacts to HUD and Congress.
Next steps: staff will circulate a draft letter to commissioners and coordinate with the chair and the countys legislative team to prepare for the upcoming board meeting and congressional outreach.
