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15 <br />panel explained, its "holding does not cover <br />individuals who do have access to adequate temporary <br />shelter," such as individuals who "have the means to <br />pay for it" but decline to do so. Pet.App. 62a n.8. <br />Accordingly, to obtain an accurate count of <br />individuals for whom shelter must be made available, <br />local governments would have to somehow distinguish <br />between individuals who are sleeping outside by <br />necessity and those who are doing so by choice. There <br />is simply no feasible way to do this.10 <br />B. It Is Also Difficult To Assess the Number of <br />Available Shelter Beds <br />Continually measuring the availability of shelter <br />beds presents its own set of challenges. For one thing, <br />some shelters are run by private organizations, so <br />governments must engage in a complex coordination <br />effort to maintain accurate and up-to-date records of <br />vacancies at those shelters. <br />What is more, some shelters are limited to one <br />gender, so simply knowing that shelter beds are <br />available may not be sufficient. More generally, as <br />discussed in Part I of this brief, determining whether <br />a given shelter is "available" for a given individual is <br />a complex and fraught fact -intensive inquiry. <br />In addition, it is not clear what relationship a given <br />jurisdiction should strive to achieve between the <br />io The task is made even more difficult by the fact that <br />criminals often take up residence in homeless encampments in <br />order to hide among —and victimize —the genuinely homeless. <br />See, e.g., Lolita Lopez & Phil Dreschler, NBC Los Angeles, Gangs <br />of LA on Skid Row (Feb. 19, 2018), available at <br />https://www.nbelosangeles. com/news/local/Gangs-of-LA-on-Skid- <br />Row-474531353.html. <br />