Independent public-interest research · Tucson / Pima County
Research Findings
Current Research Status
Selected records reviewed November 7, 2026; other source dates remain attached to their findings. The 12 finding entries comprise 9 dated observations, 2 open comparisons and 1 resolved comparison (F-006).
What we know: The CDBG resource arithmetic reproduces, and the corrected PR-26 is available. The earlier mixed CDBG/CDBG-CV comparison is withdrawn. New records clarify the construction count, identify SAAF AVP-RRH’s reduction, and document financing, placement and adopted-transfer milestones. Read the November 7 update.
Still unanswered: The $1,284,589.71 formula-CDBG narrative difference needs a transaction-level explanation. Final reporting, financing, contracts, current availability and matched aggregate outcomes remain separate verification questions. Neither an open comparison nor a reported balance establishes missing money or assistance available today.
Additional November 7 review: exact voucher-payment checkpoints, Tucson House temporary occupancy, separate Amazon funding scopes and project-specific outcomes. Existing finding IDs and unresolved limits are retained.
November 8 County funding review: $8.7 million in allocations and $2,986,331 in PRICE agreement scopes. Actual County spending, executed agreements and outcomes remain open. Existing finding IDs are unchanged.
What published records document, what the project has
calculated, and what remains unanswered.
Public research release v0.6 · CDBG correction posted · Original targeted review November 3, 2026; source-specific dates apply · Not updated automatically
This is the stable finding register: dated observations and open or resolved comparisons, each retaining its F-ID. Use the Evidence Index to check sources and Research Updates to follow changes over time.
November 3, 2026 audit process update:
A targeted review of current research workbooks logged 17 review items, passed 12/12 selected arithmetic checks, and found no formula-error patterns in the scoped scan. It did not independently audit all source transactions or certify the final PY2025 CAPER.
Read the dated funding and evidence update.
How to Interpret These Findings
This page presents selected, source-linked observations,
not an official financial audit, a finding of wrongdoing,
or a live housing-availability service.
Source reviewed confirms a limited statement
in an agency publication, not implementation or an
independently audited outcome.
Financial categories and project-unit categories are not
additive unless their definitions and periods match.
Three evidence levels:
Source reviewed — an agency publication was examined for
the stated fact.
Workbook assessment — an internal comparison was
documented but not fully reproduced from primary records.
Open question — additional information is needed before
reaching a conclusion.
12 finding entries total: 9 dated agency-report observations, 2 open comparisons and 1 resolved comparison.
9Dated agency-report observations, including draft figures
2 open + 1 resolvedAccounting or construction-cohort comparisons; F-006 resolved
0Findings of wrongdoing or certified available funds
Documented Observations
Each observation specifies what a dated agency record
establishes. Figures in the PY2025 draft CAPER remain
draft figures, including those whose arithmetic
has been independently checked.
Source reviewedF-001 · CDBG · PY2026
City Approved a $1.5 Million CDBG Reallocation
The City's October 9 update reports that Mayor and Council
approved shifting $1.5 million in previously planned
CDBG funding within the FY2027/PY2026 Annual Action Plan.
The City reported moving the allocation from Community
Facilities to Decent Affordable Rental and Homeowner Housing,
including potential preservation or rehabilitation activities.
The housing category gains $1.5 million in planned capacity
while the facilities category loses the same amount.
Total CDBG resources do not increase.
Housing category: +$1,500,000
Facilities category: −$1,500,000
Net change in total CDBG funding from this reallocation: $0
What this does not prove
HUD implementation, unobligated cash, a new federal award,
completed rehabilitation, or housing openings.
November 7 source review: The October 6 Council action report, Resolution 24188 and Exhibit A document adoption of the $1.5 million transfer between CDBG categories, with no increase in total resources. The action report records a 7–0 vote. SRC-102 · SRC-103 · SRC-104
Source reviewedF-002 · PBV / HOME · 2025–2026
Amazon Flats: Construction Started; Vouchers Proposed
The City announced an April 17, 2026 groundbreaking
for a 59-apartment building. A December 2025 environmental
notice proposed using 39 project-based vouchers.
The earlier notice described $500,000 in HOME funds
and two HOME-designated units within the 59 planned apartments.
The City estimated completion in fall 2027.
Do not add 59 + 39 + 2.
These refer to overlapping apartment and subsidy categories,
not separate sets of homes.
Financing classification:
The City reported an overall development cost of approximately
$24.4 million. The earlier environmental notice identified
a proposed $500,000 HOME contribution and estimated
$6,645,600 in PBV assistance over 20 years.
These figures describe development cost, a proposed capital
source, and projected future rental assistance.
They do not establish a combined balance of
currently available housing funds.
What this does not prove
Construction completion, executed voucher contracts,
current applications, or vacant apartments.
November 7 follow-up: The April 8, 2026 EPHD action report records a 5–0 ratification of Amazon Flats’ financial closing. The closing package, precise closing date, signed HAP contract and occupancy remain unverified. SRC-113
Source reviewedF-003 · PBV / RAD · August 2026
Craycroft and Lee Street: Allocated Vouchers
The City's August 3, 2026 notice describes 74 existing
Craycroft Towers apartments and eight Lee Street Duplex
apartments, with 82 project-based vouchers allocated
over 15 years.
The notice identifies nine Rental Assistance Demonstration
(RAD) units and 65 Section 18 disposition units at Craycroft
Towers. Together, these classifications cover its 74
existing apartments. The notice also identifies four
HOME-assisted units within the project.
Understanding Section 18 versus Section 8:
Section 18 concerns the disposition of public housing
as part of a conversion or preservation transaction.
Section 8 is a separate rental-assistance authority,
including Project-Based Vouchers (PBVs).
The City reports an allocation of 82 Section 8 PBVs
for the combined Craycroft Towers (74 apartments) and
Lee Street Duplexes (8 apartments), over 15 years.
These figures describe overlapping units and program
classifications; they are not additional homes.
See the terminology guide.
The work concerns preservation and conversion of existing
housing, not construction of 82 new apartments.
An allocation is not proof that voucher contracts are
executed or that apartments are vacant.
What this does not prove
Executed assistance-payment agreements, completed
conversion, current occupancy, or 82 vacant apartments.
November 7 source review: Federal records show an environmental milestone and a submitted financing plan for the 82-unit preservation project. The RAD tracker reviewed November 7 lists “Financing Plan Submitted” without a closing date. Closing, proceeds and signed assistance contracts remain unverified. SRC-098 · SRC-099 · SRC-100
Citation correction: the previous link opened a different project’s review. The correct HUD document records 7015.16 certification on September 1, 2026. Read the citation correction and source limits.
Source reviewedF-004 · Housing delivery · 2025
Milagro on Oracle: Documented Housing Delivery
The City reports that this 63-unit affordable housing
development opened to residents in January 2025.
City announcements credit El Pueblo Housing Development
and Gorman & Company with developing this housing,
combining new construction and adaptive reuse
of two historic motor courts.
This is a documented positive housing-delivery milestone,
although the City announcement is not an independently
audited occupancy report.
What this does not prove
Current vacancies, present occupancy, resident income levels,
or remaining available subsidy.
The City announced a draft CAPER covering
July 1, 2025 through June 30, 2026,
with comments accepted September 1–17, 2026.
The 33-page draft indicates that certain CR-05,
CR-10, and CR-15 tables would be available
in the final report.
Their absence from the draft does not establish
that the City failed to file a final CAPER.
What remains unverified
The final CAPER, submission date, HUD receipt or acceptance,
and supporting appendices. Failure to locate a record
does not prove non-submission.
The PY2025 draft reports two separate HOME carryforward
figures, not a verified current subsidy balance.
Program income:
$534,792.63 received − $7,548.34 applied =
$527,244.29 carryforward.
Recaptured funds:
$373,430.46 received − $65,866.33 applied =
$307,564.13 carryforward.
Limits and uses
The draft states that program income supported
tenant-based rental assistance and recaptured funds
supported down-payment assistance.
Neither year-end figure proves currently unobligated
cash or eligibility for any particular household.
HOME matching credits are a separate noncash category.
The PY2025 draft lists nine open HOME activities
whose designated HOME-unit counts total 44.
The nine listed project amounts total
$5,470,000.
These are activity amounts, not independently confirmed
expenditures or a present grant balance.
What this does not prove
That 44 designated HOME units equal all apartments,
that units are currently occupied or available,
or that $5.47 million has been fully spent.
November 7 follow-up: County contract PO2500016491 uses the name “Amazon Flats” but identifies $749,625 for a 30-room motel-to-studio conversion, separate from the 59-apartment construction project. Published signature and covenant lines are blank; executed documents and completion evidence remain needed. SRC-112
Source reviewedF-012 · Housing preservation · October 2026
Tucson House: Renovation Milestone
On October 16, 2026, the City reported 24 renovated
apartments on Tucson House's 15th floor and stated
that 25 households would be moving into renovated housing.
The work involves rehabilitation of existing public
housing, not 24 newly constructed apartments.
The broader project concerns 358 apartments,
with further renovation milestones anticipated
through summer 2028.
The difference between 24 apartments and 25 households
requires clarification, not an assumption of error.
What this does not prove
That all 25 households already moved by October 16,
that these were newly admitted applicants,
or that apartments remain available for external referrals.
November 7 follow-up: The City permit page shows an October 15, 2026 application for TC-CFO-1026-00207. The register listed the permit as Issued when reviewed November 7 for temporary occupancy associated with Tucson House’s 15th-floor Level 4 renovation. The issue date remains unverified. The register lists a November 15, 2026 expiration. The October 20 PHA report says the renovation was 30% complete, the 15th floor was finished and residents were moving back. The October 16 announcement’s 24 apartments and 25 households remain unreconciled. Neither the permit register nor the later narrative verifies a completed move count, new admissions or current vacancies. The original certificate and any conditions or renewal still need verification. SRC-109 · SRC-110 · SRC-106
November 10 permit check: TC-CFO-1126-00224 for the 14th floor displayed Fees Paid. On November 7 it was observed as Submitted – Online. The application date remains November 6, 2026. These observations do not establish when the status changed, certificate issuance, occupancy or move-in. SRC-111
Open Comparisons
Not established findings of error:
The following comparisons raise questions about reporting
definitions, periods, and accounting populations.
They are not conclusions about missing funds or misconduct.
Open transaction reconciliationF-007 · formula CDBG · PY2024
What Still Needs Explaining in CDBG Spending?
Correction, November 6, 2026: The earlier $944,972.60 comparison mixed formula CDBG and CDBG-CV. OMB guidance establishes separate PR-26 reports, so that comparison is withdrawn as a comparable spending gap. The remaining formula-CDBG question is $1,284,589.71. Read the corrected review and sources.
The corrected PR-26 reports $4,717,936.37 in formula-CDBG expenditures. The City’s narrative reports $3,433,346.66, leaving a $1,284,589.71 arithmetic difference requiring a transaction-level explanation.
$4,717,936.37 − $3,433,346.66 = $1,284,589.71
OMB’s 2025 Compliance Supplement says standard PR-26 reports are restricted to annual formula grants; CDBG-CV has a separate PR-26. The rounded $4,717,936 summary-table figure agrees with the corrected PR-26. The narrative notes a draw after June 30, 2025, but the records reviewed do not establish which transactions explain the full difference.
The $102,106.09 adjustment is on line 30 in the public-service-limit calculation. Line 14’s total-expenditure adjustment is zero. It does not by itself resolve the narrative difference.
This is not a finding of missing funds, currently available assistance or a cost per housing outcome. CDBG-CV is reported separately.
The City's PY2024 CAPER, CR-15 (PDF page 13,
printed page 10), reports $4,717,936
in CDBG expenditures in its table. Its narrative
separately lists $3,433,346.66 for CDBG
and $339,616.74 for CDBG-CV.
CR-15 table compared with both narrative amounts:
$4,717,936.00 − $3,433,346.66 − $339,616.74 =
$944,972.60
Source correction (November 4, 2026): The corrected Tucson
PR-26 Financial Summary Report is included in the City's PY2024 CAPER
(PDF page 149, printed CAPER page 146), alongside the City's
$102,106.09 prior-year coding adjustment explanation on PDF page 148.
The corrected PR-26 directly reports $4,717,936.37
in total expenditures. Comparing it with only the standard
CDBG narrative (excluding CDBG-CV) produces $1,284,589.71
in arithmetic difference. The two measures are not yet established
as like-for-like accounting scopes.
Corrected PR-26 compared with standard CDBG narrative only:
$4,717,936.37 − $3,433,346.66 =
$1,284,589.71
These are different arithmetic comparisons,
not two verified measures of missing funds.
Even the $944,972.60 cross-presentation difference
may mix CDBG and CDBG-CV reporting scopes,
and cannot be treated as a reconciled accounting balance.
No available comparison establishes improper spending
or unrestricted funding.
Next verification
The corrected PR-26 has been located in the CAPER (PDF pages 148-150).
The outstanding tasks are to match CR-15 and narrative accounting scopes,
review IDIS activity-level draws and any separately dated report versions,
and explain the treatment of CDBG-CV.
Open draft-report comparisonF-008 · Housing production · PY2025
Different Construction-Unit Counts
The PY2025 draft CAPER describes 378 affordable
housing units as constructed on PDF page 3,
including 59 Amazon Flats apartments.
Page 5 states that Amazon Flats construction had begun,
while page 26 separately reports 483 units
of construction activity.
These statements may refer to different construction
stages or project populations. They do not establish
comparable completed or occupied unit totals.
Next verification
Obtain public project-level construction, completion and
occupancy-permit records, plus aggregate occupancy counts.
The 105-unit arithmetic difference is not evidence
of unreported or missing apartments.
November 7 source review: The draft’s 378-unit list includes 96 existing Casa del Pueblo apartments being rehabilitated. Current Lariat and Shasta permit records show continuing construction. The 378 figure is not a verified count of completed new homes; neither a revised completed-new-home total nor its relationship to 483 is verified. SRC-095 · SRC-096 · SRC-097
Resolved Comparisons
The arithmetic comparison below is resolved. Commitments, restrictions, later transactions and current availability remain separate questions.
Source arithmetic reproduced November 6, 2026F-006 · CDBG · PY2024
Program Income: Preventing Double Counting
The corrected PR-26 reports a $5,068,664 annual grant and $349,468 in program income. Together they equal the $5,418,132 current-resource subtotal.
$5,068,664 + $349,468 = $5,418,132
Program income must not be counted a second time. The full resource and ending-balance calculations also reproduce the report, without establishing money currently available for new work.
Next verification Identify commitments, restrictions and later transactions affecting the reported balance.
The following nine activities are identified on page 26
of the City's PY2025 draft CAPER.
HOME-designated units are not all apartments in a project.
Nine HOME Activities
Activity
HOME Units
Listed HOME Amount
Rincon Manor Apartments
2
$500,000
Corazon Del Pueblo
7
$280,000
Rodeo Addition
11
$440,000
Lariat Village
4
$1,000,000
Casa del Pueblo
11
$500,000
Amazon Flats
2
$500,000
Shasta Apartments
2
$500,000
Elstone II Houses
3
$750,000
Tucson House
2
$1,000,000
Arithmetic total
44
$5,470,000
Source: PY2025 public-comment draft CAPER, page 26.
Reported activity amounts are not necessarily amounts spent.
Construction-Count Crosswalk
The five project counts on page 3 of the
PY2025 draft CAPER total 378.
The reporting stage for each project requires separate
verification before treating these figures as
completed or occupied homes.
Draft CAPER's 378-Unit Breakdown
Project
Units
Lariat Village Apartments
120
Casa del Pueblo Apartments
96
Shasta Apartments
100
Elstone II Houses
3
Amazon Flats Apartments
59
Reported arithmetic total
378
Source: City PY2025 draft CAPER, PDF pages 3, 5, and 26.
The reported 483-unit construction category still requires
a project-level crosswalk.
November 7 classification check: Casa del Pueblo’s 96 units are existing apartments being rehabilitated; Lariat and Shasta remain under construction in the reviewed permit records. Subtracting 96 does not establish 282 completed new homes. SRC-095 · SRC-096 · SRC-097
Housing Delivery and Preservation
A development may be proposed, under construction,
completed, rehabilitated, occupied, or awaiting
voucher-contract implementation.
These are different outcomes and should not be
added into a single housing-production number.
Selected Tucson Housing Project Milestones
Property
Apartment Count
Documented Stage
Unverified
Milagro on Oracle
63
City-reported opening to residents, January 2025
Present occupancy and referral availability
Amazon Motel
30
Existing motel converted to supportive housing in 2025
Current occupancy and vacancies
Amazon Flats
59
Groundbreaking April 2026; anticipated fall 2027 completion
Completion, PBV contracts, lease-up
Craycroft / Lee Street
82 existing
Rehabilitation and voucher conversion
Agreement execution and occupancy transitions
Tucson House, 15th floor
24 renovated
Renovation milestone reported October 2026
Actual moves and applicant access
The listed units represent different stages and
project types. They must not be summed as net-new
housing or available vacancies.
Financial Reconciliation Register
The register below distinguishes each reported amount,
its accounting meaning, verification status,
and the evidence required to resolve remaining questions.
Different financial measures; not one available funding pool
Final sources and uses, commitments, PBV contracts
The PY2024 CDBG CR-15 table and narrative amounts are
from the City's published CAPER. The corrected PR-26 in that
CAPER (PDF page 149) directly reports $4,717,936.37 in total
expenditures; its comparability with the narrative remains unresolved.
Other PY2024 comparisons also draw on workbook extracts.
PY2025 HOME figures originate in the draft CAPER.
The Amazon Flats figures come from dated City notices
and announcements. None establishes unrestricted
funding currently available to applicants.
What We Need to Verify Next
Priority Verification Queue
Priority
Records Needed
Purpose
1
Final PY2025 CAPER, attachments and submission receipt
Verify final outcomes, funding and filing status
2
Located corrected PY2024 PR-26; reconcile CR-15/narrative scopes and activity details
Reconcile resource and expenditure measures
3
Amended PY2026 AAP and HUD/IDIS transactions
Trace the $1.5m CDBG reallocation into implementation
4
Public or appropriately redacted PBV agreements, aggregate occupancy counts and published referral rules
Separate allocated vouchers from applicant opportunities
5
Construction milestones and aggregate occupancy counts by project
Explain the 378-versus-483 reporting comparison
6
HOME project commitments, receipts, draws and balances
Trace restricted financial resources and unit designations
7
Aggregate Tucson House floor-turnover and household-move counts
Distinguish renovated apartments and household moves
Glossary and Research Identifiers
Definitions of housing programs, financial-reporting terms,
and the project's finding, question, and source identifiers
are maintained in the standalone
Glossary & Identifiers.
Every finding should be reproducible using a
document title, reporting period, source page,
quantitative inputs, and a documented interpretation.
Plans, awards, commitments, expenditures,
project costs, available cash, new apartments,
rehabilitated apartments, occupied apartments,
HOME-designated units, and PBV-supported units
are different measures.
This project documents legitimate agency achievements
and possible explanations alongside discrepancies.
An unresolved research question is not an allegation
of misconduct or noncompliance.
No private housing, medical, court, or personal
correspondence is published in this page.
Correction Policy
Material revisions will preserve the finding ID
and identify the previous wording, revised statement,
reason for the correction, supporting records,
and correction date.
Research Revision History
November 3, 2026, targeted review: Added a public summary of selected audit-workbook control checks, FY2027 planning classifications, the $0 net new CDBG award effect of the internal transfer, and outstanding CAPER/PR-26 verification. No new finding of wrongdoing or available housing assistance is asserted. See dated review note.
November 3, 2026, F-007 clarification:
Distinguished the $944,972.60 cross-presentation arithmetic
using both CDBG and CDBG-CV narratives from the $1,284,589.71
workbook comparison using only CDBG. Identified that the
original Tucson PR-26 was not located in the examined records.
Preserved both calculations without labeling either a verified
financial discrepancy.
November 2, 2026 clarification: Added an explanatory distinction between Section 18 public-housing disposition and Section 8 PBV assistance in F-003, with program terms and research identifiers subsequently moved to a standalone glossary. No housing-unit totals changed.
v0.5 · October 31, 2026:
Added the financial reconciliation register,
housing-project stage comparison, Tucson House finding,
and separate Amazon Flats financing measures.
Preserved findings F-001 through F-011 and added F-012.
v0.3:
Added Amazon Motel and reproducible HOME/construction
calculation tables, and strengthened distinction between
funding categories and housing-unit classifications.
v0.2:
Clarified Craycroft's existing apartments,
Milagro developer attribution, HOME carryforwards,
and construction-reporting differences.
v0.1:
Established the initial source-reviewed observations
and provisional reconciliation questions.
Review boundary:
Research is based on selected City announcements,
the 33-page PY2025 public-comment draft CAPER,
and research workbooks reviewed through November 3, 2026.
Source-specific verification dates and the scope of newer checks are stated separately.
It does not certify the final CAPER,
independently audit every workbook cell,
verify current vacancies, or establish
unrestricted available funds.
