HomeMy WebLinkAbout12 REGIONAL HOUSING NEEDS ASSESSMENT ALLOCATIONMEETING DATE
TO:
FROM:
SUBJECT:
u u.'
AGENDA REPOR
NOVEMBER 19, 2019
MATTHEW S. WEST, CITY MANAGER
COMMUNITY DEVELOPMENT DEPARTMENT
Agenda Item
12
Reviewed:
City Manager
Finance Director
N/A
REGIONAL HOUSING NEEDS ASSESSMENT ALLOCATION
California State housing law requires that each city and county plan for existing and future
housing needs. The Regional Housing Needs Assessment (RHNA) is the process that
prescribes the housing need for each jurisdiction. The California Department of Housing
and Community Development (HCD) is the agency that makes the final regional RHNA
determination, and the Southern California Association of Governments (SCAG) is the
regional agency responsible for the development of the RHNA allocation methodology
and the distribution of the RHNA allocation among the jurisdictions in six (6) Southern
California counties, including Orange County. On November 7, 2019, the SCAG Regional
Council approved a substitute motion for a draft modified RHNA allocation methodology
that results in a RHNA allocation for Tustin of about 9,493 housing units.
RECOMMENDATION:
That the City Council authorize the Mayor to send a letter to HCD objecting to the City's
disproportionate RHNA allocation and receive and file the report.
FISCAL IMPACT:
The fiscal impacts associated with the RHNA allocation implementation may be very far
reaching. The exact impact is not known at this time.
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 Council as
necessary.
City Council Report
RHNA Allocation
November 19, 2019
Page 2
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.
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 Al ' location: 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
City Council Report
RHNA Allocation
November 19, 2019
Page 3
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 6th
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.
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
SCAG Staff Proposed RHNA Methodology
The proposed SCAG staff recommended RHNA methodology includes projected
housing need and existing housing need components, with a social equity adjustment.
Step 1: The projected 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.
City Council Report
RHNA Allocation
November 19, 2019
Page 4
Future
vacancy
need
Jurisdiction
Jurisdiction's projected HH
(owner)
Jurisdiction's
growth
8
replacement
Projected
Housing
Future need
vacancy
need
(renter)
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
Mou.MNd paNA
2U3° -10x5
Jun zdictior ,
share of .. .
50% "Vowl, r
JiQTM tzo3o-ma ;
25%
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
Minimum � At`i=H Adjustment Tataf social equit
150%F 0-30%} adjustment
City Council Report
RHNA Allocation
November 19, 2019
Page 5
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.
Estimated Draft SCAG Staff Recommended RHNA Allocation for Tustin
The estimated RHNA number for Tustin based on SCAG staff's recommended
methodology was 4,820 housing units. This number was one of the highest in Orange
County, because Tustin has significant planned growth and is centrally located close to
transit and jobs. There were only four (4) Orange County cities with higher estimates
than Tustin:
• Irvine: 20,774
• Anaheim: 17,412
• Fullerton: 7,507
• Garden Grove: 5,592
Social equity adjustment Jurisdiction Total RHNA Allocation
F— Moderate
Above moderate---�
Based on the SCAG staff recommended RHNA methodology, the City of Tustin would
have received 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
City Council Report
RHNA Allocation
November 19, 2019
Page 6
Staff identified the following concerns regarding the proposed RHNA methodology that
was recommended by SCAG staff:
0 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).
0 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.
0 SCAG did not provide adequate time prior to the RHNA Subcommittee's October
meeting for jurisdictions to vet the transit and jobs accessibility factors.
0 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.
0 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.
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 HQTAs,
jobs centers and areas with favorable socio-economic indices.
SCAG Regional Council Action on RHNA Methodology
On November 7, 2019, the SCAG Regional Council voted 43-19 to approve the modified
RHNA methodology that was introduced by City of Riverside representative Mayor Rusty
Bailey through a substitute motion. All Orange County SCAG representatives voted in
opposition. The Regional Council directed SCAG staff to refine the allocation
methodology before forwarding the information to HCD.
City Council Report
RHNA Allocation
November 19, 2019
Page 7
The modified RHNA methodology approved by the SCAG Regional Council changes the
distribution from the SCAG staff recommendation and results in significantly higher
RHNA allocations for thirteen (13) of the thirty-five (35) jurisdictions in Orange County,
including Tustin. According to information provided by SCAG (Attachment B), Tustin
would receive a RHNA allocation of around 9,493 housing units. This allocation is
approximately double the size of the allocation under the methodology that was
recommended by SCAG staff. It also should be noted that the new modified draft
allocation is roughly equivalent to the number of housing units that were constructed in
Tustin in the past thirty (30) years, but the 6th Cycle RHNA period spans about eight (8)
years, not thirty (30) years.
HCD now has sixty (60) days to review and make comments on SCAG's draft RHNA
Allocation Methodology. The SCAG Regional Council will then vote to adopt a final
RHNA Allocation Methodology in early Spring of 2020.
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.
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
City Council Report
RHNA Allocation
November 19, 2019
Page 8
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 Ste
- November 7, 2019 - January 7, 2020: HCD reviews and comments on methodology.
• Early Spring 2020: SCAG provides each jurisdiction with their Draft RHNA allocation.
- Summer 2020: RHNA appeal period.
- October 2021: Jurisdictions must have their housing elements certified by HCD.
Scott Reekstin
Principal Planner
Attachments:
I W-1
Elizabeth A. Binsac
Community Development Director
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
Ul � I
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 jobs, infrastructure and th,e 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.
SCAG 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 staff's 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 I of 2
550 of; the existing need allocation Lo mbe based on high, quality transit areas (rOTA's),
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,
irlstead o, 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 ieoislatiron, sound regional planning and good public policy.
Respec Uliy,
yAr7-1
r'Yittir,;it �. `r`:,s�y Bailey, !il
rAlayor, City of,Rivelside
District 68 Representative, SCAG Regional Council
Karen S. Spiegel
Supervisor, County of Riverside
Riverside 1. ounty xe. nresQntarive, SCAU Regional Council
Frank J. Navarro
Mayor, City of Colt -on
District 6 Representative, SCAG Regional Council
Toni Momberger
SCAG Energy and Environnnent, rCo l nia e Member
Draft Shares Comparison based on HCD determination of 1,341,827
Updated 11/4/2019
DRAFT- for illustrative purposes, Numbers are not rounded
Using 5CAG RHNA Calculator 10/16/19
Note: Imperial Ventura would receive no redistribution perTCAC, so their residual was redistributed based on share of DOF 2019 population.
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10/16/19 Proposed Methodology (Option 4)
OPTION 6 Riv.
w/ new regional total and HQTA revisions
OPTION 5 (10/7/19 Substitute Motion)
County
AHLA
city
VLI
LI
MI
AMI
Total
VLI
LI
MI
AMI
Total
Tota)
Total
Whittier city _- _-_
- - --
939
489
503
1,186
3,116
928
487
508
1,201
3,123
3,116
4,719
-Unincorporated Los Angeles Co.
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
3 0
30
29
-- -- ---
55
-�
169
_ _
168
3,143=
-- - --
!Anaheimcity
3,811
2,407
2,939
8,254
17,412
3,758
2,961
8,339
17,450
17,412
27,554
Brea city
334
195
199
441
1,170
330
_2,3_92
194
201
447
1,172
1,170
3,6354
Buena Park city
1,297
816
950
2,325
5,387
1,561
990
1,168
2,868
6,588
10,518
6,3301
Costa Mesa city
1,083
661
765
1,800
4,309
1,525
938
1,100
2,596
6,159
-6
12,086
11,179
--
Cypress city
153
145
347
915
450
246
592
3,563
3,168'
DanaPointci
142
81
97
190
509
111
64
3
77
152
404
403
2,538
Fountain Valley city
375
224
236
537 --
1,371
571
34
367
838
2,119
4,516
4,0341
I Fullerton city-- _-
1,841
1,137
1,290
31238
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
1.1-Itint.ington 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
4,317
4,424
8,853
24,112
30,78623,977;
La Habra cit
_ _-_ Y _-
194
117
130
363
803
191
_
116
131
367
805
---803--
803
_
3,3404
La Palma city
6
-.----
4
4
8
22
6
4
4
8
2222
La unBeach citV
L _a
17
11
- - 11
-- 16
-
55
16
11
11
16 __...
_ - 55 -
_ - --- 5 - 5
-=Y
- 31
2,453
Laguna Hills city
311
192
192
382
1,077
- -
_
308
192
-
194
387
1,080
1,077
2,218
LLaguna Niguel city
53
30
33
65
181
52
30
34
65
181
181
4,5344
Laguna Woods city
13
14
20
55
102
13
14
20
56
102
102
838,
ILake Forest city --
---- - - -
188
106_
108
226_
628
185
105
109
229
629
628
5,7251
amitos city
68
41
50
108
268
67
41
51
--1088
268
268
1,064
Missi
city---------
59
35
34
_
344
20S
204
35
6,0981
Newport Beach
836
530
595
-791
- 2,751
1,0 9--
670
763
3,500
5,850
10,8141
(Orange city
1,077
606
675
1,569
3,927
1,064
603
681
1,588
3,935
3,927
11,5371
Placentia city
739
405
456
995
2,595
889
491
561
1,227
3,_168
4,982
3,276.
Rancho Santa Margarita city^
56
32
33
_ 60
181
55
32
33
60
181
181
218904
'San Clemente city
241
139
158
292
830
214
124
144
266
748
748
4,867
San Juan Capistrano city276
176
186
431
1,068
192
123
132
307
755
753
2,5721
Santa Ana city
592
363
523
1,609
3,087
583
367
526
1,624
3,094
3,087
29,972
Seal Beach city
38
30
35
79
182
38
29
35
80
182
182
1,7261
Stanton city
166
145
231
685
1,228
164
144
232
691
1,231
1,228
2,973
1 ustinnty
1,241
747
804
2,028
4,820
1,603
972
1,061
2,684
6,320
9,493
6,661
Villa Park city
12
8
8
i1
39
12
8
P,
11
40
39
422
1Westminstercity
423
509
1,308
2,784
823
645
787
2,027
4,282_
9,043
7,6851
CYorba Linda city
_544
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
8,6881
Banningcity628
380
548
1,718
3,275
312
190
278
874
1,654
1,654
1,085
Beaumont city
1,832
1,068
1,064
2,244
6,208
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
6351
�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
492'
�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
4Corona city
1,853
1,092
1,144
• 2,278
6,367
2,135
1,268
1,346
2,688
7,438
5,932
9,054
I Desert Hot Springs city
1,262
1,180
1,507
4,521
8,470
564
531
688
2,069
3,851
3,850
890
IEastvale City --
- ----
913
533
-
500
- -----
451
-----
2,397
1,086
-
638
608
-
549
-- -
2,880
- ---
2,188
--
3,2094
Hemet city
1,612
1,444
2,300
7,284
12,640
807
729
1,177
3,737
6,450
6,449
2,949
[11ndian Wellscity132
91
102
105
431
128
89
101
104
421
403
5604
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
1,346
829
804
1,976
4,956
1,143-
709
698
1,719
4,268
4,261-
4,7651
DRAFT- for illustrative purposes, Numbers are not rounded
Using 5CAG RHNA Calculator 10/16/19
Note: Imperial Ventura would receive no redistribution perTCAC, so their residual was redistributed based on share of DOF 2019 population.
3of5
'", � � � !! 1' ''
Con.,imunity D U,ve,k)p-ment Department
June 4, 2019
Honorable Peggy Huang, Chair
Con,impnity, Econo.rril(,and FlUrrlarl Development Policy Committee
Regional Housing Needs Assessrnmt Subcommittee
Scothern Califor.hio AsSbc.Yallon of Governments
90.0 Wilshire Boulevard, Suite 1700.
Los Angeles, CA 90017
BUILDING OUR FUTURE
I-tot4b.)UNG OUR PAST
RE: DRAFT REGIONAL HOUSING NEEDS !ASSESSMENT (RHNA) CONSVILTATION PACKAGE TO THE
CALIFORNIA DERARTME . NT OF HOUSING AND COMMUNITY DEVELOPMENT {HCD) AND
PIROPOSED RHNA METHODOLOGY compoNENTs
Honor,!blje Chair Huang and H,onofable Committee Members.,
The City of Tustin supports SCAG's ongoinig efforts to address California's critical housing needs and
appreciates the b.pp.o,rtunity to provide coni'merits on the Draft Regional Housing Needs Assessment
(RHNA) Consultation Package to the California Departown.t of HoosiriE and Com.munity Development
(HCl) and the proposed RHNA methodology components.
As noted its al recent SCA G staff report to the RHNA Subcormll[.ttoe, thegoalsfor-the. RHNA consultation
process with HCI) includethe following:
Follow the SCAG RTP ' /SCS growth forecasting process, procedure, methodology, and results
iftlUding bottom. up local review, comment acid ijip.ut.
Provide the best outcomes foe the SC reglonal how-frigneeds assessment and determination,
meet the requirements of the law, and use the hest available statistics and technical
methodology.
0. R,esearch the appropriate factors and causes associated with existing hou5ing needs.
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 RHN. A, method I alody for the & Cycle:
SLAG should propose to HCD a regional 6"1 Cycle RHNA.'doterminatiom Of no more than 430,000
housing units, which is consistent with local input and already incorporates existing and projected
housing need,
Itis unclear how SCAG will address a passible 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 curre.ndy in delvolopniqnt, The SCAG region potentially
could be planning for additional housing, without plannirig for the transportation network to
support the additional housing. If the R . W 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,
300 C-entennial Way, Ttmin, (.'.A 021-80 0 P: (.'/ H � '573-3) 1,01) 0 F: �'i H 1 5 71_� I 1_1 "01.g
I - ':1 n(-- I
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 HC.D.provides
SCAG with the RHNA allocation. Jurisdictions are unable to assess the impact of these factors until
the regional housing need allocation is confirryied. in addition, 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 three factors required by State law: overcrowding, cost burden, and
healthy vacancy rate, sl ould..only be considered for possible inclusion in the disaggregation of the
regional total to the judsdictional 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 loader 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 wfil 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 reallsticaily be implemented will make jurisdictions be subject to State mandates
that will thwart housing development,
The City of Tustin urges SCAG to propose a regional 6th 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
Korne Ajise, SCAG Executive Director'
Mamie Primmer, OCCOG Executive Director
Matthew S. West, City Manager
Justina Willkom, Assistant CoMf"I'lUnity Development Director
Scott Reekstin, Principal Planner
ATTACHMENT D
Commurfity Development
Department
August 30, 2019
Mr, Kome4jbe
Executive Director
Southern California AssobadonofGovernments
'90b Wilshire Boulevard, Suite 170QHONORING OUR PAST
Los Angeles, CA 900117
BUILDING OUR FuTuu.
RE: PROPOSED REGIONAL HOUSING NEEDS ASSESSMENT(RHWA) ALLOCATION METHODOLOGY
Dear Mr, Ajise:
The City ofTustin supports SC4G's ongoing efforts to address Califom�so��[b needs and
appreciates the opportunity to connme�zpg�e - iono|HPus|ng Needs^ Assessment
(RHNA) Allocation Methodology.
The City of Tustin and, concerns ��gardingthe Proposed RHNAAllocation
Methodology for the, 6'h RHNA Cycle:
* SCAG shold select a methodology which it consistent With JOCal ir[Put that alr,_idy incorporates
existing and projected housIng need, SCAG has solicited input from all 1W local jurisdictions in the
$CAG region, including: 'population housing, and emplcyment pr jections; parce
I level General
Plan land uses, existing �016 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
RHm* planning process, and ensures consistency between, the VMNA and the Reg , lona
Transportation Plan (RTP)/Sustainab|aComrnunitles�Strategy(SCS).
It 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 fat the 2020
RTP/SCS, known �as Connoct.SoCal! 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 HCD that is inconsistent with local input, the RTP growth forecast would not. be
ba.sed on sound land use. planning1principles,
Ofmethodology
of Tustin is mbst 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.
m Ifone (1)nfthe three (3)RHNAAllocation Methodology optionsbeing atthis ti�
me
revised or ifa new methodology option isintnoduzed based on the input received during the
public review period, the City of Tustin requests that additional review time of at least ten (1O)
days be provided to nUovv|oca| jurisdictions the time to assess this new information prior to any
SCAGcommittee taking action onapreferred methodology.
Mr. Kome4jise
August 3l2O19
Page
The City ofTustin supports the technical comments provided by the Center for Demographic
Research at California State University, Fullerton, in their letter dated August 23 2018 (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 thelrRH0A targets. Hopefully,
recently enacted funding measures will spur the development of more affordable housing thnzughoui
Ca|}fornia'and result in BHNAtargets that are more attainable.
The City of Tustin rgcsSCAG toadopt a RHNAA|locaton methodology for R8NAtha1
��n local �p��n� and equitable,isconsistent — SCAG's stated goals, and allows
communities tmhave local Control housing their housing elements certified by
the Department of Housing and community Development (H[D). Not doing az may result in RHNA
allocation that is not achievable and one that will jeopardize the region's ability to successfully address
California's housing crisis.
Elizabeth A, Binsock
Community Development Director
cc: Tustin City Council
M8Y\ynJ0hnsVn SCAB
ManniePrimmer, ,OCCOGExecutive Director
Deborah S.D| CDR Executive Director
Matthew S. West, City Manager
]ust|na VVU|horn^/ss|stant Community Development Director
ScottReekst|n, Principal Planner
Attachment: August 23, 2019, Center for Demographic Research Letter