AB 1708 amends California’s Homeless Housing, Assistance, and Prevention (HHAP) program by forcing continuums of care (CoCs) that receive round 7 funds to set aside and distribute portions of those funds to “smaller jurisdictions” — defined as cities with populations under 300,000 — under a new eligibility and application process. The bill also adds an Article governing round 8 that requires regional homelessness plans to describe programs run by smaller jurisdictions, analyze how round 8 and other funding streams can support those programs, and permits regions to allocate part of round 8 dollars to those cities.
The law creates concrete gates and transparency requirements: smaller cities must meet specific eligibility conditions before they can receive HHAP funding; CoCs must run a public, documented application process (including an initial 30-day window for eligible smaller-city applicants for round 7) and prioritize awards that involve partnerships. For practitioners, this redirects some regional HHAP flows toward smaller cities while adding new compliance, outreach, and administrative duties for both regions and local governments.
At a Glance
What It Does
The bill requires CoCs awarded round 7 HHAP funds to allocate funding to cities with populations under 300,000 and to accept smaller-city applications under a prescribed timeline and prioritization scheme. It separately requires round 8 regional plans to document smaller-city programs, analyze funding alignment, and permits regions to allocate a portion of round 8 funding to those jurisdictions.
Who It Affects
Directly affects continuums of care that administer HHAP regionally, California cities under 300,000 residents, and local housing planning officials required to maintain compliant housing elements and encampment policies. Nonprofits and inter-city partnerships that deliver homeless services will be affected through new eligibility incentives and award priorities.
Why It Matters
The measure institutionalizes a route for smaller cities to compete for state homelessness dollars rather than relying only on county or large-city distributions, potentially shifting funding flows and local program design. It also raises operational demands: CoCs must run targeted outreach, create transparent application processes, and justify allocations in regional plans.
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What This Bill Actually Does
AB 1708 creates two connected tracks: a round 7 distribution rule that forces CoCs to carve out funding access for smaller cities, and a round 8 planning framework that makes the roles and needs of smaller cities a required element of regional homelessness plans. The bill defines “smaller jurisdiction” as a city with fewer than 300,000 residents and then places explicit conditions on which of those cities can receive HHAP support.
For round 7, the bill requires each CoC that receives eligible funding to accept applications from smaller jurisdictions during an initial period in which only qualifying small cities may apply. The CoC must evaluate those applications under existing round 7 rules, and it must prioritize requests in which the small city proposes to work with a nonprofit, another small city, or other private partners.
If money remains after awards to smaller cities, the CoC can then consider applications from other eligible entities.To be eligible, a smaller jurisdiction must demonstrate they will participate in and comply with the regionally coordinated homelessness action plan, have a compliant housing element, adopt a local encampment policy consistent with administration guidance, and show how prior programs and spending have furthered regional HHAP objectives. The bill also requires the smaller jurisdiction to hold a public hearing on the regional plan, post plan documents online at least 30 days before that hearing, and adopt a resolution directing the mayor to sign the region’s memorandum of understanding.The round 8 provisions require regional plans to include a description of programs and interventions led by smaller jurisdictions, documented outreach to those cities, and an analysis of how round 8 and other funding streams can support identified projects.
A region may set a target percentage for funding to support smaller jurisdictions but must evaluate that target’s feasibility and publish a transparent application process with timelines, evaluation criteria, and decision formulas.
The Five Things You Need to Know
Smaller jurisdiction is defined as a city with a population under 300,000.
To qualify for smaller-jurisdiction HHAP awards, a city must have a compliant housing element and an adopted local encampment policy consistent with administration guidance.
For round 7, CoCs must open an initial 30-day application window that accepts only eligible smaller-city applications.
Continuums must prioritize awards where the smaller jurisdiction proposes to use funds in partnership with a nonprofit, another small city, or other private organization eligible for HHAP.
Round 8 regional plans must include documented outreach to smaller jurisdictions and an analysis of how round 8 and other funding sources can sustain or expand programs those cities identify.
Section-by-Section Breakdown
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Legislative findings on smaller jurisdictions and prior HHAP rounds
The bill’s findings summarize the Legislature’s view that smaller cities have a role in regional homelessness responses and note the distribution pattern used in a prior round (percentages for CoCs, large cities, and counties). Practically, these findings justify the policy shift: they frame smaller cities as under-recognized actors whose projects should be surfaced and financed through HHAP.
Round 7 — mandatory allocation to smaller jurisdictions and application rules
Section 50246 requires any continuum of care receiving round 7 funding to allocate funds to smaller jurisdictions and sets an application procedure: an exclusive 30-day initial period for eligible small cities, evaluation under existing round 7 rules, prioritization for proposals that partner with nonprofits or other small jurisdictions, and a fallback process if funds remain. The section also sets the city-level eligibility checklist and public hearing/notice steps that a city must complete before receiving awards.
Round 8 — planning requirements and optional allocation pathway
The new Article 4 requires round 8 regionally coordinated homelessness action plans to document programs provided by smaller jurisdictions, evidence of coordinated outreach and engagement, and an analysis of how local, state, federal, and round 8 funds could support those programs. Regions gain explicit authority to allocate a portion of round 8 funding to smaller jurisdictions but must create transparent application processes and evaluate the feasibility of any target funding percentage against regional priorities and resources.
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Explore Housing in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Cities under 300,000 residents — gain a defined pathway to apply for HHAP dollars and explicit eligibility rules that can unlock state funds for locally designed projects.
- Regional planners and CoCs — receive structured requirements to surface smaller-city needs, which can improve regional project pipelines and coordination with local partners.
- Nonprofit service providers and intercity partnerships — are incentivized through award prioritization to form or deepen partnerships with small cities, potentially increasing funds directed to collaborative models.
- People experiencing homelessness in smaller cities — stand to benefit from more locally tailored services and funding that supports expansion or continuation of existing projects.
Who Bears the Cost
- Continuums of care — must run targeted outreach, administer the exclusive 30‑day small-city application window, apply prioritization rules, and document transparent decision formulas, increasing administrative work and reporting needs.
- Smaller cities that lack compliant housing elements or an encampment policy — must invest staff time and political capital to update housing elements, adopt encampment policies, and hold required public hearings before they can access funds.
- Local governments generally — face added procedural steps (posting plans online, adopting resolutions, signing MOUs) that require legal review and clerical support.
- State agencies and oversight bodies — will likely absorb additional monitoring duties to ensure regions meet the new planning, outreach, and transparency standards.
Key Issues
The Core Tension
The bill’s central tension is between targeted inclusion and practical readiness: it aims to broaden access to HHAP dollars by obligating regions to fund smaller cities, but it conditions that access on planning and policy readiness that many small jurisdictions lack — so the effort to expand eligibility may end up steering funds to the better-resourced small cities, or creating new administrative bottlenecks for regions and state implementers.
The bill attempts to thread two objectives that can pull in opposite directions: it wants funds to flow to under-recognized smaller cities while preserving regional allocation discretion. Requiring CoCs to run an initial, small‑city-only application window and to prioritize partnership-based proposals channels money to cities that are already organized or partnered; less-resourced cities without established nonprofit partners may lose out despite being eligible.
The eligibility conditions — a compliant housing element and an encampment policy “consistent with administration guidance” — are sensible accountability measures but effectively exclude jurisdictions that lack planning capacity or face political constraints, turning policy access into a function of local regulatory readiness.
Implementation details are also under-specified in ways that matter. The statute allows regions to evaluate the feasibility of a “target percentage” for smaller-city funding but does not describe how to set or enforce such targets, how to prevent double-dipping with other state or federal grants, or how to weight competing regional priorities.
The phrase “consistent with administration guidance” imports uncertainty: differing administrative interpretations could produce uneven eligibility gates across regions. Finally, prioritizing partnerships shifts grantmaking toward collaborative projects, which may be efficient but can favor established nonprofits and neighboring cities with prior relationships over standalone local initiatives.
Operationally, CoCs will need to reconcile these new duties with existing round rules, staffing constraints, and data gaps (population cutoffs, housing-element compliance timing). Regions and cities will want explicit templates for the transparent application process, clear criteria for the “evaluation” step, and guidance on acceptable encampment policy content to avoid legal or political disputes.
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