HomeMy WebLinkAbout02 RHNA PC REPORT I
AGENDA REPORT ITEM #2
MEETING DATE: NOVEMBER 12, 2019
TO: PLANNING COMMISSION
FROM: COMMUNITY DEVELOPMENT DEPARTMENT
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT ALLOCATION
RECOMMENDATION:
That the Planning Commission receive and file the report.
DISCUSSION:
The following provides background and analysis of the Regional Housing Needs
Assessment (RHNA) allocation and how the allocation affects the City of Tustin. Staff
will continue to monitor the RHNA process and will provide updates to the Commission
as necessary.
Background
California State housing law requires that each city and county plan for existing and
future housing needs by mandating that there are sufficient sites and zoning identified in
the housing element of its General Plan to accommodate its RHNA allocation. The
upcoming 6th Cycle RHNA will cover the planning period from October 2021 through
October 2029. The RHNA allocation development process is underway, and the final
RHNA for the Southern California Association of Governments (SCAG) region will be
adopted by October 2020. SCAG is the agency responsible for the development of the
RHNA allocation methodology for six (6) counties in southern California (including
Orange, Los Angeles, Imperial, Riverside, San Bernardino and Ventura) in consultation
with the California Department of Housing and Community Development (HCD), which
is the agency that makes the final regional RHNA determination,
Pursuant to State housing law, the RHNA process follows four main steps:
1. Methodology: SCAG is responsible for developing a uniform methodology that is
used to distribute the overall regional determination among all of the cities and
counties within the region. A single methodology allows the regional determination to
be distributed in an equitable manner based on a certain set of factors throughout
the SCAG region. Cities provided local input to SCAG earlier this year, which
includes projections on population and housing to be used in the methodology.
Planning Commission Report
November 12, 2019
Page 2
2. Regional Determination: The regional determination is the RHNA (total number of
housing units to be produced) as determined by HCD, segmented by income levels
(very low, low, moderate, and above moderate) for each region's planning body
known as a council of governments. SCAG is the regional council of government for
the counties listed above.
3. Draft Jurisdictional RHNA Allocation: The draft jurisdictional RHNA allocation is a
jurisdiction's specific share of the overall "regional determination." The draft
jurisdictional RHNA allocation may be appealed.
4. Final RHNA Allocation: The final RHNA allocation is a jurisdiction's share of the
overall regional determination after the reallocation.of units from successful appeals.
The final RHNA allocation must be addressed 'in a jurisdiction's housing element,
which is a part of the General Plan.
Methodology
In August of this year, the SCAG Regional Council approved the release of three (3)
proposed draft methodology options for public comment. Public hearings were held to
allow SCAG staff to present the three (3) draft methodology options for public comment
and receive input on. those three -(3) draft options as well as suggestions for revisions
and alternatives.
SCAG received 248 comment letters on the three (3) proposed RHNA methodology
options. Forty-eight percent of the comments were submitted by-local jurisdictions and
subregions. Based on the comments received, SCAG staff developed a single RHNA
methodology process and introduced it at a workshop on Monday, September 23, 2019.
The proposed September 23, 2019 RHNA allocation methodology is the SCAG staff
recommended methodology.
Regional Determination
The City of Tustin received notice on or around August 22, 2019, from SCAG that HCD
transmitted their final RHNA Regional Determination of 1,344,740 total units among the
four (4) income categories for the SCAG region. For reference, the SCAG region
received a regional determination range of 409,060 — 438,030 for the previous RHNA
cycle in 2011, when Tustin received an allocation of 1,227 units.
On September 5, 2019, the SCAG Regional Council voted to file an objection with HCD
on the methodology utilized in developing the final RHNA regional determination.
SCAG staff believes that HCD did not follow State law in making its determination, and
that the 6'" Cycle RHNA number should be between 821,000 and 924,000 housing units.
According to SCAG:staff, HCD's determination does not reflect SCAG's Growth Forecast,
data inputs, or analysis which were developed during the consultation process between
HCD and SCAG. HCD responded to SCAG regarding the objection, and the final RHNA
Regional Determination was modified to 1,341,827 units, due to new cost burden data.
Planning Commission Report
November 12, 2019
Page 3
The 1,341 ,827 units of regional determination include:
• 559,267 housing units in the "above moderate" income category
• 223,957 housing units in the "moderate" income category
- 206,807 housing units in the "low" income category
• 351 ,796 housing units in the "very low" income category
Analysis
Proposed RHNA Methodology
The proposed staff recommended RHNA methodology includes projected housing need
and existing housing need components, with a social equity adjustment.
Step 1: The protected housing need component is equal to the local household growth
input for the 2021-2029 RHNA planning period, with adjustments made for vacancy
need and replacement housing need.
Future
need
Jownerl Jurisdiction
- -] Projected Housing
Futurer
vacancy Need
need,. .. ...
Step 2: The existing housing need component is based on household growth from 2030
to 2045, accessibility to jobs, and population within current and planned High Quality
Transit Areas (HQTAs). Fifty (50) percent of regional existing need is based on
household growth, twenty-five (25) percent is based on accessibility to jobs, and twenty-
five (25) percent is based on population within current and future HQTAs. The jobs
accessibility factor is based on the percentage of the region's jobs that are within a 30-
minute drive from a "median" traffic analysis zone in the city.
Regional Existing Need
Jurisdiction Existing Need
share of
growth thln
1 '
yHQTAs
Planning Commission Report
November 12, 2019
Page 4
Step 3: A minimum 150 percent social equity adjustment is applied to each
jurisdiction's total draft RHNA allocation, along with an additional percentage of up to
thirty (30) percent added in areas with significant populations that are defined as very
low or very high resource areas, to determine the distribution to the four (4) income
categories for each jurisdiction. For Tustin, the total adjustment is 150 percent.
Social equity adjustment
A`
(0-30%)
t.
On October 7, 2019, the SCAG RHNA Subcommittee (including the Orange County
representative) voted to send the proposed RHNA methodology to the SCAG
Community, Economic, and Human Development Committee (CEHD) for their
consideration, which held a special meeting on October 21, 2019. The CEHD
Committee voted unanimously to recommend to the SCAG Regional Council to submit
the draft RHNA methodology to HCD. There was some discussion at the CEHD
meeting regarding the reasoning for including 2030-2045 household growth in the
existing need calculation. Essentially, SCAG staff responded that the HCD draft RHNA
number is so large that the only way to meet the number regionally was to include all
growth out to 2045. SCAG staff believes that cities that are projecting significant growth
are doing so to accommodate current overcrowding and cost burden conditions.
The SCAG Regional Council was scheduled to consider the proposed RHNA
methodology on November 7, 2019. Details and an update will be verbally provided at
the November 12, 2019 Planning Commission meeting.
Estimated Draft RHNA Allocation for Tustin
The estimated RHNA number for Tustin is now 4,820 housing units, This number is one
of the highest in Orange County, because Tustin has significant planned growth and is
centrally located close to transit and jobs. There are only four (4) Orange County cities
with higher estimates than Tustin:
• Irvine: 20,774
• Anaheim: 17,412
• Fullerton: 7,507
• Garden Grove: 5,592
Planning Commission Report
November 12, 2019
Page 5
Social equity adjustment Jurisdiction Total RHNA Allocation
Jurisdiction Totalj
a i i ry
RHNAAllocation
-"rate
Above moderate
Based on the SCAG staff recommended RHNA methodology, the City of Tustin would
receive the following estimated draft RHNA allocation by income level:
Total Units 4,820
Very Low 1 ,241
Low 747
Moderate 804
Above Moderate 2.028
Staff has identified the following concerns regarding the proposed RHNA methodology:
The RHNA number of 4,820 housing units for the 2021-2029 RHNA planning
period is significantly greater than the City's anticipated 2021-2045 growth of
about 3,300 housing units (per Orange County Projections 2018).
Housing law will make it more difficult to identify previous available housing sites
in future Housing Elements, unless sites allow at least thirty (30) dwelling
units/acre and twenty (20) percent or greater affordable projects are allowed by
right.
o SCAG did not provide adequate time prior to the RHNA Subcommittee's October
meeting for jurisdictions to vet the transit and jobs accessibility factors.
A future bus rapid transit route along the entire Interstate 5 was included as high-
quality transit even though there may not be any stops within or adjacent to
Tustin.
o Although Tustin has inclusionary housing requirements in some areas of the City,
and the City's specific plan areas and other residentially zoned areas could
accommodate the total proposed RHNA number, it will be challenging to
demonstrate in the next housing element that at least forty-one (41) percent
(1,241+747 divided by 4,820) of these housing units will be affordable to those
with very low and low incomes.
Planning Commission Report
November 12, 2019
Page 6
Riverside County Proposed RHNA Methodology Option
On November 4, 2019, City staff was informed by the Orange County Council of
Governments Technical Advisory Committee and Center for Demographic Research
staff that elected officials from three (3) Riverside County jurisdictions had submitted a
letter (Attachment A) to the SCAG Regional Council that proposes a new RHNA
Methodology option that would place more emphasis on creating housing near High
Quality Transit Areas, jobs centers and areas with favorable socio-economic indices.
According to information provided by SCAG (Attachment B), if this new proposed RHNA
methodology were approved by the Regional Council, the City of Tustin would receive
an allocation of about 9,493 housing units, and thirteen (13) of the thirty-five (35)
jurisdictions in Orange County also would receive higher RHNA allocations. It is our
understanding that many elected officials from the other counties in the SCAG region
are in support of this optional methodology. It should be noted that the new potential
allocation is roughly equivalent to the number of housing units that were constructed in
Tustin in the past thirty (30) years, but the 6t' Cycle RHNA period spans about eight (8)
years, not thirty(30) years.
Implications of Insufficient RHNA Progress
When a jurisdiction has not made sufficient progress toward meeting its RHNA
allocation, the jurisdiction is subject to the provisions of Senate Bill (SB) 35. SB 35,
which became effective on January 1, 2018, requires cities and counties to streamline
the review and approval of certain affordable housing projects through a ministerial
process which does not allow public hearings. Only design review or public oversight is
allowed, and it must be objective and focused on assessing compliance with criteria
required for streamlined projects as well as objective design review of the project.
When a jurisdiction has made insufficient progress toward its lower income RHNA
allocation (very low and low-income units), the jurisdiction is subject to SB 35
streamlining for proposed developments with at least 50% affordability. If the jurisdiction
also has made insufficient progress toward its above moderate income RHNA
allocation, then it is subject to the more inclusive streamlining for developments with at
least 10% affordability. The City of Tustin is currently one of approximately 148
jurisdictions that is subject to SB 35 streamlining for proposed developments with at
least 50% affordability.
City of Tustin Involvement
City staff continues to monitor and participate in RHNA related meetings and hearings.
Staff also has provided technical review throughout the process and has briefed the City
Manager. Staff is also actively involved with the Orange County Council of
Governments (OCCOG), its member agencies, and the Center of Demographic
Research at California State University Fullerton to ensure that the raw data utilized in
the draft methodology is accurate and consistent with local jurisdictional input.
Planning Commission Report
November 12, 2019
Page 7
Given the impact that the RHNA will have on the City, the City has sent the two (2)
attached comment letters (Attachments C and D) to SCAG detailing our concerns with
the proposed methodology. The overarching theme being conveyed is that local input
needs to be the basis of the methodology in order to set realistic and achievable targets
for the region's housing needs.
Timeline and Next Steps
• November 7, 2019 - January 7, 2020: HCD reviews and comments on methodology.
• Winter 2020: SCAG provides each jurisdiction with their Draft RHNA allocation.
• Summer 2020: RHNA appeal period.
• October 2020: the SCAG Regional Council adopts the Final RHNA allocations.
• October 2021 : Jurisdictions must have their housing elements certified by HCD.
Scott Reekstin Elizabeth A. Binsack
Principal Planner Director of Community Development
Attachments:
A) Riverside County Letter dated November 1 , 2019
B) SCAG RHNA Calculator Excerpt
C) Letter dated June 4, 2019
D) Letter dated August 30, 2019
ATTACHMENT A
RIVERSIDE COUNTY LETTER
DATED NOVEMBER 1 , 2019
1
November 1, 2019
Honorable Bill Jahn
Southern California Association of Governments
Attn. SCAG Regional Council
900 Wilshire Blvd. Ste. 1700
Los Angeles, CA 90017
Subject: Recommended Regional Housing Needs Assessment(RHNA) Methodology and
Proposed
Dear President:
As representatives of Inland Southern California,we would like to thank you for the opportunity to comment
on the Southern California Association of Governments' (SCAG) recommended RHNA methodology. Our
sub-region is actively involved in the RHNA process and fully recognizes that this effort is an important
opportunity to make meaningful change to the supply of housing,which is essential to the long-term success
of our region and state. We also understand and accept the notion that each jurisdiction must commit to
responsible growth and must equally commit to addressing the housing crisis.
We are committed to doing our part, however we do not believe that the proposed methodology will create
results that are attainable or equitable.
We oppose the staff recommended methodology, as it sets SCAG and our jurisdictions up for failure. As
an example,the recommended methodology disproportionately allocates housing inland to cities and more
importantly unincorporated county areas with less jabs, 'infrastructure and the transit needed to
accommodate new housing within the eight-year RHNA horizon. In addition, these areas do not have the
development market necessary to accommodate the disproportionate volume of housing allocated, which
translates to housing that will not be constructed.This imbalance will result in a situation where SCAG and
the Southern California municipalities are not able to meet our housing goals and quite likely will face large
fines as part of the state-level movement to motivate housing production through legal action and financial
penalties.
SGAG has an obligation to do what it can to plan for as much housing as possible within the eight-year
cycle; failure to adopt an appropriate allocation exacerbates the housing crisis, and all of staffs efforts
become moot.The sheer volume of housing allocated to areas that lack adequate job volumes and transit
infrastructure perpetuates sprawl and increases the number of people driving to Los Angeles and Orange
County job centers. Not only does this impact the quality of life in the SCAG region,it also does not reflect
the state's GHG and VMT goals. For illustration,the approach is counter to the following state legislation:
® AB 32, which calls for statewide reductions in greenhouse gas emissions. Placing more housing in
inland locations will increase greenhouse gas emissions associated with transportation.
• SB 375 and SB 743 call for reductions in vehicle miles traveled (VMT),at the regional and project
levels. Placing more homes in inland counties will significantly increase regional VMT, as
compared to placing those houses in proximity to the existing jobs and transit.
We recognize the effort staff has put into creating a methodology that complies with housing and RHNA
law, and we understand that a completely new methodology is not realistic this late in the processes. But
we also do not believe that we have allowed ample time to consider alternatives.To realign the methodology
to better reflect HQTA and job centers, we respectfully request that SCAG staff present an alternative
approach to the Regional Council for consideration. This new alternative should allocate RHNA based on
the following changes:
Page 1 of 2
50%of the existing reed allocation to be based on ,high quality transit areas (HQTA's),
e 50%of the existing need allocation to be based on proximity to jobs centers, and
"Residual" units to be redistributed to the jurisdictions within the county they were generated,
instead of a regional-wide distribution.
We believe that this amended methodology will result in a distribution of units that is more attainable, and
more consistent with state legislation, sound regional planning and good public policy.
Respectfully,
William R."Rusty' Bailey, III
Mayor, City of Riverside
District 68 Representative, SCAG Regional Council
Kam' 44:Aue -
Karen S.Spiegel
Supervisor, County of Riverside
Riverside County Representative,SCAG Regional Council
Frank J. Navarro
Mayor,City of Colton
District 6 Representative, SCAG Regional Council
l
Toni Momberger
SCAG Energy and Environment Committee Member
Page 2 of 2
i
ATTACHMENT B
SCAG RHNA CALCULATOR EXCERPT
Draft Shares Comparison based on HCD determination of 1,341,827
Updated 11/4/2019
10/16/19 Proposed Methodology(Option 4) OPTION 6 Riv.
w,1 new regional total and HQTA revisions OPTION 5(10/7/19 Substitute Motion) County AHLA
city VLI LI MR AMIJ Total VLI LI MI AMl Total Totall Total
Whittier city 939 489 503 1,186 3,116 928 487 508 1,201 3,123 3,116 4,719'
Unincorporated Los Angeles Cc. 27,489 14,568 14,990 38,280 95,327 29,995 16,018 16,714 42,797 105,524 101,796 70,885
Aliso Viejo city 55 30 29 54 168 55 30 29 55 169 166 3,143
Anaheim city 3,811 2,407 2,939 8,254 17,412 3,758 2,39i--'2,961 8,339 17,450 17,412 27,554
'Brea city 334 195 199 441 1,170 330 194 201 447 1,172 1,170 3,635
Buena Park-city 1,297 816 950 2,325 5,387 1,561 990 1,168 2,868 6,586 10,518 6,330
Costa Mesa city1,083 661 765 1,800 4,309 1.525 936 1,100 2,596 6,159 11,086 11,179
_ - _... _ - -__ _.,_--
Cypresscity 270 153 145- 347 i- 915 450 258 246 592 1,545 3,553 3,168
Dana Point city 142 81 97 190 509 111 64 77 152 404 403 2,538
Fountain Valleycity 375 224 236 537 1,371 571 343 367 838 2,119 4,516 4,034
Fullerton city 1,841 1,137 1,290 3,238 7,507 2,271 1,413 1,626 4,093 9,403 15,495 10,173
Garden Grove city 1,232 823 937 2,600 5,592 1,835 1,235 1,426 3,967 8,462 17,775 13,807
Huntington Beach City 1,001 593 623 1,395 3,612 1,561 932 992 2,229 5,714 12,457 15,656
Irvine city 5,696 3,744 3,784 7,550 20,774 6,518 4,3174,424 8,853 24,112 30,786 23,977
La Habra city 194 117 130 363 803 191 116 131 367 805 803 3,340
La Palma city ba 4 4 8 22 6 4 4 8 22 22 1,026
Laguna Beach city 17 11 11 16 55 16 11 11 16 55 55 2,453
Laguna Hills city 311 192 192 382 1,077 308 192 194 - 387 1,080 I,077 2,218
Laguna Niguel city 53 30 33 65 181 52 30 34 65 181 181 4,534
Laguna Woods city 13 14 20 55 102 13-----14 20 56 102 102 838
Lake Forest city 188 106 108 226 628 185 105 109 229 629 628 5,725
Los Alamitos city 68 41 50 108 268 67 41, 51 109 268 268 1,064
Mission Viejo city 59 35 34 64 193 344 205 204 382 1,135 193 6,098
Newport Beach city 836 530 S95 791 2,751 1,049 670 763 1,018 3,500 5,850 10,814
Orange city 1,077 606 675 1,569 3,927 1,064 603 681 1,588 3,935 3,927 11,537
Placentia city 739 405 456 995 2,595 889 441 561 1,227 3,168 4,982 3,276
Rancho Santa Margarita city 56 32 33 60 181 55 32 33 60 181 181 2,890
San Clemente city 241 139 158 292 830 214 124 144 266 748 748 4,867
San Juan Capistrano city 276 176 186 431 1.068 192 123 132 307 755 753 2,572
Santa Ana city 592 363 523 1,609 3,087 583 361 526 1,624 3,094 3,087 29,972
Seal Beach city 38 30 35 79 182 38 29 35 80 182 182 1,726
y 1 .
Stanton city 145 231 685 1,228 164 144 232 691 1,231 1,228 2,973
Tustin city _ 1,241- 747- 804 2,028 4,820 1,603 972 1,0612 684 -"-6,320 9,493 6,6611
Villa Park city 12 8 8 11 39 12 8 8 11 40 39 422'
Westminster city 544 423 509 1,308 2,784 823 645 787 2,077 4,282 9,043 7,685
Yorba Linda city 66 39 39 63 207 65 39 39 64 207 207 4,434
Unincorporated Orange Co- 3,728 2,201 2,390 3,905 12,224 3,041 1,809 1,992 3,263 10,104 12,783 8,088
Banning city 628 380 548 1,718 3,275 312 190 276 874 I„654 1,654 1,085
Beaumont city 1,832 1,068 1,064 2,244 6,209 1,202 706 714 1,509 4,130 4,129 1,731
Blythe city 166 143 193 489 991 81 70 97 245 493 493 635
calimesa city 1,078 595 814 1,853 4,340 488 272 377 860 1,996 1,996 362
Canyon Lake city 64 35 36 57 192 42 23 24 38 128 128 442
i Cathedral City city 1,005 653 841 2,188 4,687 526 345 450 1,173 2,493 2,492 2,254'
Coachella city 2,012 1,933 2,628 8,551 15,124 1,015 982 1,354 4,419 7,770 7,768 1,589
Corona city 1,853 1,092 1,144 2,278 6,357 2,135 1,268 1,346 2,688 7,438 5,932 9,0541
Desert Hot Springs city 1,262 1,160 1,507 4,521 8,470 564 531 688 2,069 3,851 3,850 890
Eastvale City 913 533 500 451 2,397 1,086 638 608 549 2,880 2,1.88 3,209'.
Hemet city 1,612 1,444 2,300 7,284 12,640 807 729 1,177 3,737 6;450 6,449 2,949
Indian Wells city 132 91 102 105 431 128 89 101 104 421 403 560'
Indio city 2,706 1,753 1,958 5,218 11,635 1,738 1,135 1,285 3,435 7,594 7,745 3,582
Jurupa Valley City 11346 829 804 1,976 4,956 1,143 709 698 1,719 4,268 4,261 4,765
DRAFT-for illustrative purposes,Numbers are not rounded
Using SLAG RHNA Calculator 10/16/19
Note:Imperial Ventura would receive no redistribution per ICAC,so their residual was redistributed based on share of DOF 2019 population. 3 of 5
ATTACHMENT C
LETTER DATED JUNE 4, 2019
Community `Development Department TUSTIN
z a
June 4,2019
Honorable Peggy Huang,Chair
Community, Economic and Human Development Policy Committee
Regional Housing Needs Assessment Subcommittee p
Southern California Association of Governments
900 Wilshire Boulevard,.Suite 1700' 111STBUILDIG sY
UR FUTURE
Los Angeles, CA 90017 HONOR NO OUR PAST
RE: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) CONSULTATION PACKAGE TO THE
CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HCD) AND
PROPOSED RHNA METHODOLOGY COMPONENTS
Honorable Chair Huang and Honorable Committee Members,
The City of Tustin supports SCAG's ongoing, efforts to address California's critical housing needs and
appreciates the opportunity to provide comments on the Draft Regional Housing Needs Assessment
(RHNA) Consultation Package to the California Department of Housing and Community Development
(HCD)and the proposed RHNA methodology components.
As noted in a recent SCAG staff report to the.,RHNA Subcommittee,.the goals for the RHNA consultation
process with NCD include the following:
• Fallow the SCAG RTP/SCS growth forecasting, process, procedure, methodology, and results
including bottom up local review, comment and input.
• Provide the best outcomes for the SCAG regional housing needs assessment and:determination,
meet the requirements of the law, and use the best available statistics and technical
methodology.
• Research the appropriate factors and causes associated with existing housing needs.
0 Develop policy responses for a long-term robust stable supply of sites and zoning for housing
construction.
In light of these goals and the methodology approved in previous RHNA cycles, the City of Tustin has the
following comments and concerns regarding the proposed RHNA methodology for the 6`h Cycle:
• SCAG should propose to HCD a regional 6'' Cycle RHNA determination.of no more than 430,000
housing units, which is consistent with local input and already incorporates existing and projected
housing need,
® It is unclear how SCAG will address a possible inconsistency between the RHNA,determination and
the SCAG regional growth forecast and local input, which were used as a basis for the 2020
Regional Transportation Plan (RTP) that is currently in development. The SCAG region.potentially
could be planning for additional housing, without planning for the transportation network to
support the additional housing. If the RTP growth forecast is modified to reflect a RHNA
determination by MCD that is inconsistent with local input, the RTP growth forecast would not be
based on sound land use planning principles.
300 Centennial Way,Tustin, CA 92780 • la: (714).573-3 10c) o C;(714) 573-31 13 • W1%VW.tustinCa.01'g
Honorable Peggy Huang
June 4, 2019
Page 2
• Action on the proposed social equity adjustment and the 70/30 split for overall.population share
and population share in High Quality Transit Areas (HQTAs) should be taken after HCD provides
SCAG with the RHNA allocation. Jurisdictions are unable to assess the impact of these factors until
the regional housing need allocation is confirmed. Inaddition, basing existing housing need on a
jurisdiction's share of population and`the presence of HQTAs will result in many housing elements
being out of compliance with State law.
• SCAG should provide each jurisdiction with its calculation of the jurisdiction's share of the region's
population within HQTAs.
• Existing housing need and the threefactors required by State law: overcrowding, cost burden,and
healthy vacancy rate, should only be considered for possible inclusion in the disaggregation of the
regional total to the jurisdictional level, not as a separate calculation or additive to the regional
total;.otherwise double counting would occur.
The City of Tustin continues to be a leader in the production of workforce and market rate housing.
However, with the dissolution of redevelopment agencies the available funding for affordable housing
subsidies has diminished and cities and counties are struggling to meet their REINA targets. Hopefully,
recently enacted funding measures will spur the development of more affordable housing throughout
California and result in RHNA targets that.are more attainable.
In conjunction with newly adopted housing legislation, the creation of an artificially high RHNA
allocation that cannot realistically be implemented will make jurisdictions be subject to State mandates
that will thwart housing development.
The City of Tustin urges SLAG to propose a regional 6`h Cycle RHNA determination of no more than
430,000 housing units, because such a determination will reflect local input, be reasonable and equitable,
be consistent with SCAG's stated goals, and allow communities to have local control over housing
development.
Sincerely,
Elizabeth A. Binsack
Community Development Director
cc: Tustin City Council
Kome Ajise, SLAG Executive Director
Marnie Primmer, OCCOG Executive Director
Matthew S. West, City Manager
lustina Willkom,Assistant Community Development Director
Scott Reekstin, Principal Planner
ATTACHMENT D
LETTER DATED AUGUST 30, 2019
Community Development Department TUSTIN
,TREE
l � I
August.30,2019
1'
Mr. Ko me Ajise
Executive Director
HISTO x
Southern California Association of Governments BUILDING OUR FUTURE
900 Wilshire Boulevard, Suite 1700 HONORING OUR PAST
Los Angeles, CA.90017
RE: PROPOSED REGIONAL HOUSING NEEDS ASSESSMENT(RHNA)ALLOCATION METHODOLOGY
i
s
Dear Mr.Ajise: i
The City of Tustin supports SCAG's ongoing efforts to address California's critical housing needs and
appreciates the opportunity to provide comments on the Proposed Regional Housing Needs Assessment
(RHNA)Allocation Methodology.
The City of Tustin has the following comments and concerns regarding the Proposed RHNA Allocation 1
Methodology for the 6th RHNA Cycle: I
i
a SCAG should select a methodology which is consistent with local input that aircady incorporates
existing and projected housing need. SCAG has solicited input from all 197 local jurisdictions in the
SCAG region, including: population, housing, and employment projections; parcel level General
Plan land uses, existing 2016 land uses and zoning; and survey information on policies and best
practices for local planning. This local input has always been a foundational component of SCAG's
RHNA planning process, and ensures consistency between the RHNA and the Regional I
Transportation Plan (RTP)/Sustainable Communities Strategy(SCS). 1
It is unclear how SCAG will address a possible inconsistency between the RHNA determination and
the SCAG regional growth forecast and local input, which were used as a basis .for the 2020
RTP/SCS, known as Connect SoCal, that is currently in development: The SCAG region potentially
could be planning for additional housing, without planning for the transportation network to i
support the additional housing. If the RTP growth forecast is modified to reflect a RHNA
determination by HCD that is inconsistent with local input, the RTP growth forecast would not be
based on sound land use planning.principles. f
Of the three (3) methodology options developed and released for public review by SCAG,the.City j
of Tustin is most supportive of Option One. However, the City of Tustin is opposed to the
reassignment of Above Moderate Income units to the three lower-income categories. Above
Moderate Income housing units can be built without subsidies and are often developed in
conjunction with affordable housing units that can be financially supported by the higher-income
housing units. {
I
® If one (1) of the three (3) RHNA Allocation Methodology options being reviewed at this time is
revised or if a new methodology option is introduced based on the input received during the
public review period, the City of Tustin requests that additional review time of at least ten (10) i
days be provided to allow local jurisdictions the time to assess this new information prior to any
SCAG committee taking action on a preferred methodology.
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300 Centennial Way, Tustin, CA 92780 a P: (714) 573-3100 F: (714) 573-3113 0 www.tustinca.org
Mr. Ko me Ajise
August 30, 2019
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o The City of Tustin supports the technical comments provided by the Center for Demographic
Research at California State University, Fullerton, in their letter dated August 23,2019 (attached).
These technical comments are intended to improve the accuracy of the three (3) methodology '
options.
The City of Tustin continues to be a leader in the production of workforce and market rate housing. ,
However, with the dissolution of redevelopment agencies the available funding for affordable housing
subsidies has diminished and cities and counties are struggling to meet their RHNA targets. Hopefully, '
recently enacted funding measures will spur the development of more affordable housing throughout
California and result in RHNA targets that are more attainable.
The City of Tustin urges SCAG to adopt a RHNA Allocation methodology for the 6,h Cycle RHNA that
reflects local input, is :reasonable and equitable, is consistent with SCAG's stated goals, and allows
communities to have local control over housing development and have their housing elements certified by
the Department of Housing and Community Development (HCD). Not doing so may result in a RHNA
allocation that is not achievable and one that will jeopardize the region's ability to successfully address
California's housing crisis.
Sincerely,
Elizabeth A. Binsack
Community Development Director
cc: Tustin City Council
Ma'Ayn Johnson, SCAG
Marnie Primmer, OCCOG Executive Director
Deborah S. Diep, CDR Executive Director
Matthew S. West,City Manager
Justina Willkom,Assistant Community:Development Director
Scott Reekstin, Principal Planner
Attachment: August 23, 2019, Center for Demographic Research Letter
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