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Court vacates HUD NOFO; county says CoC application submitted and ready to adapt

Clackamas County Board of Commissioners · August 11, 2026
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Summary

Clackamas County submitted a consolidated Continuum of Care application totaling about $8.6 million; staff told commissioners a district court vacated HUD's NOFO for procedural reasons, and the county remains prepared to resubmit or respond when HUD reissues guidance. Staff noted a required local match of about $2.1 million including county general funds.

Clackamas County staff told commissioners the county's consolidated FY2026 Continuum of Care application — a locally coordinated submission of competitive and renewal projects totaling about $8.6 million — was submitted on schedule, but that a federal district court subsequently vacated HUD's NOFO.

Vahid Brown, deputy director of Housing and Community Development, explained the court found HUD had changed program priorities without the required administrative public-comment process; the change earmarked about $1.3 billion for transitional housing and supportive-services-only programming. "On Friday last week, a district court vacated HUD's notice of funding opportunity for this year," Brown said. He added the county had incorporated those priorities into its local scoring and is prepared to adjust if HUD reissues guidance.

Brown outlined that the local match requirement totaled about $2.1 million, of which $115,742 was identified as county general funds while the balance would come from other federal, state and local sources. Commissioners pressed staff on whether the vacatur puts county programs at risk; staff said they expected to maintain program continuity and that HUD and high-performing Continuums of Care have a record of avoiding significant funding losses.