Hypothermia season has just begun, meaning that D.C. is now legally required to make shelter available and that its annual winter shelter plan is now in effect.

The Interagency Council on Homelessness (ICH) issued this year’s winter plan last week, just before the first alert of the season went out late Sunday. The winter plan outlines how the city will protect people experiencing homelessness during the hypothermia season, which typically begins in early November and ends in late March.

ICH was behind schedule in completing the plan this year, voting to approve the plan in October, well past the statutory deadline of Sept. 1.

Kate Coventry, senior policy analyst at the DC Fiscal Policy Institute and voting member of ICH, said staff vacancies — which have since been filled — contributed to the plan’s delay. But she said that the city is still able to provide services before the annual plan is approved.

“I don’t think there’s any worries about the delay in the plan affecting service provision,” Coventry said.

ICH did not immediately respond to a request for comment. In the plan, it attributes the delay to the ongoing pandemic.

“Due to the public health emergency and its impact on homeless service system operations, the ICH recommended taking an additional month to ensure all know changes could be discussed with partners prior to finalizing the plan,” the plan reads.

Coventry said something she and other ICH members are monitoring is whether there would be enough capacity in single shelters. She said there are not as many openings this year as in previous years, but that it’s hard to tell whether there would be a shortage as hypothermia season has just begun.

In a departure from previous years, the District will not be using seasonal shelters, according to the plan. The District will instead rely on year-round low barrier shelters, as well as overflow shelters when year-round shelters are at or near capacity.

The DC Department of Human Services (DHS) projects that single adults will be occupying anywhere from just over 1,600 to more than 1,700 beds from this month until March 2023, similar to the demand from the last hypothermia season.

This year, the plan says DHS is preparing for an increase of families seeking shelter, though noting that it is difficult to predict just how many families will experience homelessness this year.

An increase would follow what has been a continued drop in demand from families since the 2019-2020 hypothermia season, when there were more than 500 families in shelters each month. In the latest hypothermia season, more than 150 families were in shelter on the last day of each prior month.

In addition to the ongoing pandemic, the city will have to grapple with additional challenges in meeting shelter demand, including the influx of migrants into D.C. and a rise in evictions. Monkeypox could also present challenges in sheltering residents safely.