Great Falls city commissioners voted unanimously Tuesday night to adopt both a five-year “master plan” and a new one-year “action plan,” which together are meant to guide the city though its distribution of $1.08 million in federal Housing and Urban Development grants.

That sentence alone is more than enough to make the average reader yawn, but its only the tip of the iceberg when it comes to federal appropriations and understanding what the city of Great Falls can and cannot do with the millions of federal dollars it’s been given to address the pandemic, homelessness, urban blight, and affordable housing. These issues have recently come to the forefront as the city searches for new ways to address public concerns over an emergency homeless encampment that’s taken root in the parking lot of the First United Methodist Church near the Downtown Historic District.

Last month the city of Great Falls filed a complaint in District Court alleging that the Methodist Church encampment was in violation of city zoning ordinances, and demanding the church remove the tents and camping arrangements from the area. That complaint is still in litigation.

Learn more about the First United Methodist Church's emergency homeless shelter

Tuesday’s public hearing began with Great Falls Director of Planning and Community Development, Craig Raymond, attempting to slice through the Gordian Knot of federal appropriations gobbledygook. He noted that that the $1.08 million the city expects to receive comes from two separate but strategically aligned programs of the Housing and Urban Development Department (HUD). The city of Great Falls has participated in both the Community Development Block Grant program (CDBG) and the Home Investment Partnership program (HOME) for decades and relies upon these annual federal disbursements to help fund affordable housing and urban renewal projects.

“Every year the amount changes slightly, but this year the city will receive $764,295 in CDBG (Community Development Block Grant) funds and we will also receive $319,759 in HOME funds (Home Investment Partnership),” Raymond explained.

The CDBG and HOME programs both originate from the same federal agency (HUD), but each program has its own set of separate requirements and qualifications to obtain funding.

“One requirement CDBG and HOME share is that the municipality applying for them must develop both a five-year Consolidated Plan as well as Annual Action Plans that lay out in detail how the grants will be used,” Raymond explained. “The Consolidated Plan is a five-year ‘master plan’ that lays out the types of efforts and projects that the city intends to focus on over the next five years. It is intended to be broad in focus but specific enough to chart the course.

“The Annual Action Plan is essentially a much more detailed direction for the coming one-year period that’s supposed to reflect the ‘how to’ of the master plan.”

Tuesday’s vote was to approve both the Consolidated Plan and the 2022 Annual Action Plan, along with amendments that will allow the city greater latitude to allocate funds to acquire and rehabilitate distressed properties in Great Falls to address affordable housing issues.

But that’s only the beginning of a saga that also includes $4 million in special federal funding meant to address economic recovery after COVID as well as homelessness in Great Falls. Just how these funds are eventually allocated has been placed into sharper public focus given an increasing shortage of affordable housing in the city, compounded by a very visible encampment of homeless people near the city center.

“Since the adoption of the plan, circumstances surrounding housing demand have significantly accelerated,” Raymond told the Commission. “The proposed amendment to the five-year Consolidated Plan is the addition of activities specifically intended to target affordable housing opportunities and the elimination of blight in the community. Staff will be placing a high interest and priority on homelessness services through the public services category. We will also be very active in affordable housing, housing rehabilitation, fair housing, economic development, and public facilities.”

CDBG and HOME funds are, by statute, specifically targeted toward sustainable, long-term community improvement projects to aid low to moderate income neighborhoods and to develop more affordable housing. The money is not intended for the establishment of emergency homeless shelters; yet the topic of homelessness rose to the top of Commission debate on Tuesday.

“We have $1 million plus dollars – looking at the emergency fund for these homeless shelters,” noted Judith Mortenson, an opponent to passage of the Consolidated Plan. “How is this emergency funding and these shelters we are proposing going to actually solve the problem rather than just mitigate people who want to come in and find whatever benefits they can at the hands of the taxpayers of Great Falls?”

Mortenson’s reference was to a separate federal grant of $1.03 million, specifically targeted toward addressing homelessness and affordable housing. To make things even more confusing, the HOME COVID Funds grant (HOME/CF) originates from the Department of Housing and Urban Development (HUD) just like all the others do, but carries with it an entirely different set of priorities and limitations. The Great Falls City Commission approved a set of priorities for the $1.03 million in HOME/CR funds last February. That plan did not include a funding priority for emergency homeless shelters.

“I don’t see where this housing proposal actually solves much of that problem,” Mortenson continued. “There are many people in Great Falls who are having difficulty with housing who do not qualify. How is this solving the problem and what do you see going forward?”

It’s an important question; but the answer is fraught with complexities. First, its important to realize that the city of Great Falls does not have complete control over how the federal grants are spent. In fact, the city acts more like a pass-through organization than a direct participant in the application of the grants.

“There seems to be a misconception sometimes that the city of Great Falls is directly involved in addressing the homeless situation, the poverty situation, the lack of housing by directly expending funds. We do not,” Great Falls City Commissioner Rick Tryon said. “What the city of Great Falls does is provide those funds through CDBG and some special allocations such as HOME/CF to provide to community partners and nonprofits who then use that money as a sub-recipient of the grant process to address those issues.”

In short, there is not a big pot of money the federal government keeps filled to the brim that the city can use for any program it chooses.

Raymond said regular CDBG and HOME funding has played a hugely important role in combating issues of homelessness in Great Falls, but these efforts don’t always show up on a concise housing balance sheet.

“The CDBG and HOME programs identify homelessness in many facets, specifically through public services,” Raymond said. “We have funded different organizations that help combat the typical things people who are experiencing homelessness, or who are at risk of losing their homes will deal with, whether it be alcohol or drug related support services, meals-on-wheels - a number of different things we have helped fund to help people out of homelessness. We’ve done an awful lot with other types of affordable housing through the CDBG and HOME programs.”

Federal guidelines for the various grant programs are detailed and specific. Step over a line on how the grant money was spent and the city risks losing them altogether – especially when it comes to funding an unapproved project like an emergency homeless shelter.

“The world of emergency shelters is plagued with a lot of difficulties besides just opening a door,” said Great Falls Mayor Bob Kelly. “For one thing we have not seen an organization come forward with the infrastructure capable of executing an emergency shelter. That’s one of main reasons we haven’t seen a request for it.”

“If we’re going to give an organization $1 million to stand up an emergency shelter, we have to be really damn confident that they’re going to do so, and that they’ll be able to sustain it for at least 10 years,” Raymond said of the city’s obligation when it comes to HOME/CF grants. “You have to assure the federal government that they (the service organization) have the capability to sustain this thing for a minimum of 10 years and if they don’t, you’re potentially at risk of having to pay that $1 million back to the federal government. So, you really have to pay attention and you better do it right.”

Commissioner Tryon noted that one of the express conditions of the $1.03 million HOME/CR grant was that it could only be used for “non-congregate housing,” a stipulation that excludes several emergency homeless shelter alternatives.

“It means it can’t be group housing where you open up one room, put cots in there and everyone lives in the same place,” Tryon explained. “Non-congregate would have to be as an individual or as a family. It has to have some privacy involved. That’s where the Pallet housing idea comes from.”

“Pallet housing” is a reference to the Seattle based company “Pallet” which constructs small, two-person sleeping cabins with lockable doors that can be erected easily in a day. Many west coast communities have turned to Pallet homes to construct secure temporary villages for the homeless.

“They almost look like an ice fishing shack you’d find in Minnesota or something,” Raymond said.

At this point the Great Falls City Commission has not received a specific proposal to build pallet homes, nor one to establish some alternative type of non-congregate emergency shelter for the homeless. A large majority of the federal grant money the city currently has at its disposal is not eligible for that type of use.

“The efforts being made by some of the agencies are for long-term sustainable housing and not necessarily for emergency shelters,” Kelly said. “The situation going on at the church here in town – there are people there who are trying to do good things and they’re trying to be organized, but at this point there’s not the skill set involved or the infrastructure, or even the IRS status for some of these grants to be put out to do this type of emergency shelter work.

“Our community partners have requested a variety of projects to address homelessness, but as far as a low-barrier or no-barrier shelter – that is a very difficult thing to stand up. I for one would look forward to any organization that wants to try to propose that to come forward, because there’s obviously a need for it here in our community.”

In a side conversation with the Tribune, Commissioner Tryon pointed out that the city commission lacks a clear definition of even what the term “homelessness” means or who it applies to.

“Do you mean widows and orphans who have no other option other than to live outside somewhere or under a bridge, or do you mean people who voluntarily choose to live at a tent encampment in a parking lot … because they don’t want to live by rules, and they don’t want to live under any kind of structured environment?” Tryon asked.

“There are some people that want us all to think that every single one of the people who is homeless in Great Falls is homeless by no choice of their own. I don’t believe that. On the other hand, there are some people who are literally living in their car because they have no choice, they have nowhere to go. I don’t know how to quantify that.”

Tryon also said the city is ill equipped to take the lead in managing or administrating an emergency homeless shelter.

“We don’t have the resources to do that,” he said. “The money that we would allocate would have to be for somebody that has a long-term plan … who would be able to take that money and build a dozen or so pallet housing units, but then they would have to have a place to put it. They’d have to have a way to manage it. There would have to be some kind of administrative and management plan in place long-term, and nobody’s come forward to do that.”

What the appropriate role for the city to take in addressing homelessness and affordable housing has yet to be fully determined. The answer to that question rests heavily upon determining how much latitude the city of Great Falls actually has, given that nearly all the available funding has very specific federal stipulations attached to it.