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HomeMy WebLinkAbout09 AUTHORIZE APPEAL OF DRAFT ALLOCATION TO TUSTIN OF REGIONAL HOUSING NEEDS ASSESSMENT BY THE SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 a 9 Agenda Item AGENDA REPORT Reviewed: ?'yl5Zll City Manager Finance Director N/A MEETING DATE: OCTOBER 20, 2020 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: MATTHEW S. WEST, CITY MANAGER SUBJECT: AUTHORIZE APPEAL OF DRAFT ALLOCATION TO TUSTIN OF REGIONAL HOUSING NEEDS ASSESSMENT BY THE SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS SUMMARY: Consider authorizing an appeal to the Southern California Association of Governments ("SCAG") of Tustin's allocated portion of the draft Regional Housing Needs Assessment ("RHNA"). RECOMMENDATIONS: 1. Authorize the appeal of Tustin's RHNA allocation; and 2. Authorize staff to respond to any appeal of another agency's RHNA allocation that could result in an increase in the RHNA allocation to Tustin; and 3. Authorize the City Manager to execute all forms and documents required or appropriate to support the appeal and response(s). FINANCIAL IMPACT: The draft RHNA allocation as currently proposed would require significant expenditures of City resources in dollar amounts that are presently unknown to plan for and implement the required allocations, particularly for planning and construction of infrastructure that would be needed to support the increased levels of development. The costs of the infrastructure are likely to be in the millions of dollars, and such expenditures may be offset to some extent by fees chargeable to the developers or occupants of the additional development. The cost of appealing the draft allocation is unknown but likely will be less than $50,000. BACKGROUND AND DISCUSSION: TUSTIN'S COMMITMENT TO ADDRESSING CRITICAL HOUSING NEEDS The City of Tustin is committed to addressing California's critical housing needs and is a leader in building affordable housing and housing for those of all socioeconomic levels. A listing of the many existing affordable home communities and emergency and transitional DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Appeal of Regional Housing Needs Assessment Allocation October 20, 2020 Page 2 housing facilities in Tustin is attached (as part of the letter dated December 12, 2019). With housing development within the City's former redevelopment areas and the major master- planned communities of Tustin Ranch and Tustin Legacy, approximately 9,000 single and multiple family homes have been built in Tustin over the past thirty (30) years. However, many other cities statewide have done little or nothing to address their own local affordable housing needs without significant consequences, while the City of Tustin is facing the possibility of an artificially large RHNA allocation primarily because of an alternative methodology that over-emphasizes proximity to transit facilities and employment centers. WHAT IS RHNA? The Regional Housing Needs Assessment (RHNA) is mandated by State Housing Law as part of the periodic process of updating the City's housing element in its General Plan. The RHNA quantifies need (as determined by the State and SCAG, not by the City) for housing within the City during specified planning periods. The first step in the RHNA process involves the State making estimates of the housing need in each region of the State, broken down by income groups, for the upcoming eight year period from October, 2021 — October, 2029. The California Department of Housing and Community Development ("HCD") has determined the overall housing need for the Southern California region for the upcoming 8-year planning period to be a very large number: 1,341,827 units. In turn, SCAG has taken that number and, using a methodology the SCAG Board adopted and HCD later approved, proposed allocations of those units to each city and county in the region, including to Tustin. SCAG'S PROPOSED RHNA ALLOCATION FOR TUSTIN On September 4, 2020, SCAG sent Tustin its draft allocation (see Attachment 1). SCAG's planned allocation to Tustin is as follows: Total units: 6,765, broken down as follows': Very-Low Income units: 1,720 Low Income units: 1,043 Moderate Income units: 1,129 Above-Moderate Income (Market) units: 2,873 These figures would represent a dramatic increase in the number of residential units that, if not reduced, will increase significantly the number of residential units that the City must allow for in its next Housing Element update, and in turn, the amount of residential development that may be anticipated over the next decade. Some believe that the allocation to Tustin and 1 SCAG wrote that its allocations are based in part on Local Housing Data applicable specifically to Tustin that can be viewed at the following link: htti3://scaa.ca.aov/i3roarams/Documents/LHD/Tustin HE 0820.i3df DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Appeal of Regional Housing Needs Assessment Allocation October 20, 2020 Page 3 to other Orange County jurisdictions is an unrealistically high RHNA allocation number that each City must plan for in its next Housing Element update. Potential direct and indirect impacts of the proposed allocations could include, but are not limited to, the following: - Increase in the number of allowed residential units in the City; - Increases in maximum allowed densities of residential development in some areas of the City; - Changes in Tustin's Zoning Code to allow residential development in areas where it is not currently permitted, perhaps including mixed use developments in some areas; - Increases in the number of vehicles and traffic; - Increases in the utilization of public resources such as parks, recreation facilities; - Increases in demand for utilities like water, wastewater, electricity, gas, etc.; - Increases in the demand for public services, i.e. police, fire, city services, etc.; and - Impacts to the City's school system. THE CITY'S PRIOR EFFORTS TO OPPOSE THE LARGE ALLOCATION City staff has been actively engaged in State and SCAG RHNA proceedings in a continuing effort to reduce the potential impact of such a large RHNA allocation on Tustin. In June, 2019, the City's Community Development Director directed a letter to SCAG recommending that SCAG propose to HCD a RHNA Cycle determination of no more than 430,000 housing units for the Southern California region, and commenting on the proposed RHNA methodology components that were proposed at that time. (See Attachment 2.) On August 30, 2019, the City followed up with a letter to the Executive Director of SCAG commenting on the methodology options that SCAG had developed, and urged SCAG to adopt a RHNA allocation that reflects local input, is reasonable and equitable, and allows local communities to have local control over housing development. (See Attachment 3.). Additionally, on November 7, 2019, Councilmember Chuck Puckett, in his capacity as a Regional Councilman, attended the SCAG Regional Council meeting at which the proposed allocation methodology was considered. Councilmember Puckett objected that the methodology is not equitable and urged that Tustin is already doing its part in contributing to affordable and inclusionary housing, and that other cities larger than Tustin and located near DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Appeal of Regional Housing Needs Assessment Allocation October 20, 2020 Page 4 transit and job centers would be assigned lower RHNA allocations. Councilmember Puckett stated that the RHNA numbers must be equitable such that all jurisdictions must share the responsibility to address the state's housing needs. And on December 10, 2019, Mayor Bernstein dispatched a letter to the Director of State HCD objecting to the Regional Housing Needs Assessment (RHNA) allocation methodology approved by SCAG, and objecting to the disproportionate draft RHNA allocation planned for the City of Tustin. (See Attachment 4.) Despite these and many other efforts by Tustin and most other local jurisdictions in Orange County, the State HCD approved the allocation methodology that was adopted by SCAG. As a result, the disproportionate allocations are poised for final approval in the next few months. And the deadline to appeal the proposed allocations is quickly approaching. DEADLINE FOR SCAG APPEAL TO BE FILED The deadline for the City to file an appeal based upon application of SCAG's methodology, local planning factors or changed circumstances is Monday, October 26, 2020 at 5:00 p.m. SCAG indicates that it expects the final RHNA allocations (after all appeals are resolved) to be issued in February 2021. RESPONDING TO OTHER AGENCIES' APPEALS It should be noted that, after all appeals are resolved, 1,341,827 units will still be allocated to cities and counties throughout the Southern California region. As a result, in the event other jurisdictions in Southern California successfully challenge the allocations to their city/county, any units that are removed from those jurisdiction's allocations would then be allocated to other jurisdictions in the region — potentially causing an additional an allocation to Tustin. For this reason, staff recommends that the City Council authorize (but not require) City Staff to respond to appeals filed on behalf of other jurisdiction(s) that could result in an additional RHNA allocation to Tustin. CAN SCAG'S ALLOCATIONS BE CHALLENGED IN COURT? Probably not. When legal challenges of prior RHNA allocations were filed in court, the courts determined that, under the law as written, SCAG's allocation process may only be appealed administratively within SCAG itself, not in court. So unless the law is changed, a court challenge of SCAG's allocations appears to be unavailable. For all of these reasons, staff recommends that the City Council direct staff to appeal of Tustin's RHNA allocation, authorize staff to respond to any appeal of another agency's RHNA allocation that could result in an increase in the RHNA allocation to Tustin; and authorize the City Manager to execute all forms and documents required or appropriate to support the appeal and response(s). DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Appeal of Regional Housing Needs Assessment Allocation October 20, 2020 Page 5 ATTACHMENTS: 1. September 4, 2020 RHNA Allocation letter from SCAG 2. June 4, 2019 Letter from Tustin to SCAG 3. August 30, 2019 Letter from Tustin to SCAG 4. December 12, 2019 Letter from Mayor to HCD RELATED REFERENCE MATERIALS: 1. For an FAQ published by SCAG about the RHNA appeal process go to: http://scag.ca.gov/programs/Documents/RHNA/RHNAAppealsFAQ.i)df 2. For an FAQ prepared by SCAG about the RHNA process generally, go to: http://scag.ca.gov/programs/Documents/RHNA/RHNA-2019factsheet.r)df 3. For an HCD overview of the RHNA and Housing Element process, go to: https://www.hcd.ca.gov/community-development/housing-element/index.shtmi (click on "Background") ATTAr LAMENT 1 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 ■ ME���� September 4, 2020 SCAGTM Matthew S. West 1WVATIiJG FOR A BETTER TOMORRN, City of Tustin 300 Centennial Way SOUTHERN CALIFORNIA Tustin CA 92780-3767 ASSOCIATION OF GOVERNMENTS goo Wilshire Blvd.,Ste.1700 Los Angeles,CA 90017 Subject: 6th Cycle Draft Regional Housing Needs Assessment :{213}236-1800 www.scag.ca.gov (RHNA) Allocation for City of Tustin and appeals timeline notice. REGIONAL COUNCIL OFFICERS Dear Mr. Matthew S. West: President Rex Richardson,Long Beach Pursuant to Government Code Section 65584 et seq., the Southern First Vice President Clint Lorimore,Eastvale California Association of Governments (SCAG) is required to allocate the Second Vice President region's housing need as determined by the California Department of Jan Harnik,Riverside County Housing and Community Development (HCD) to all local jurisdictions in Transportation Commission the SCAG region. For the 6th Cycle of RHNA, which covers the planning Immediate Past President Bill Jahn,Big Bear Lake period from 2021 to 2029, HCD has determined our regional housing need to be 1,341,827 units. COMMITTEE CHAIRS Executive/Administration After extensive public input and review by HCD, on March 5, 2020, Rex Richardson,Long Beach SCAG's Regional Council adopted the final RHNA Methodology which, in Community,Economic& coordination with final Connect SoCal adopted on September 3, 2020, Human Development results in Draft RHNA Allocations for all local jurisdictions. Please note Jorge Marquez,Covina that receipt of this letter containing the Draft RHNA Allocations begins Energy&Environment David Pollock,Moorpark the appeals timeline. The Draft RHNA allocation shall be deemed Transportation received on September 11, 2020. Cheryl Viegas-Walker,EI Centro The Draft 6th Cycle RHNA Allocation for the City of Tustin is 6765 total units, consisting of: Very-low income units: 1720 Low income units: 1043 Moderate income units: 1129 Above-moderate income units: 2873 The deadline to electronically file an appeal of your 6th cycle Draft RHNA Allocation is 5:00pm on October 26, 2020 (details attached). The hearing on the RHNA allocation appeals is scheduled to begin on or about December 10, 2020. Following the conclusion of the appeals process, the Final RHNA Allocations are anticipated to be issued in Page 1 1 of 2 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 February 2021. Local jurisdictions' housing element updates are due to HCD by October 2021. We appreciate your collaboration and input during this process. Additional information including underlying data can be found on SCAG's RHNA website at www.scag.ca.gov/rhna. If you have additional questions or concerns, please direct them to housing@scag.ca.gov so they can receive priority attention. Sincerely, ' S.-,Z- Kome Ajise Executive Director Attachments: SCAG Region 6t" Cycle Draft RHNA Allocations SCAG 6t" Cycle RHNA Appeals Procedures Page 12 of 2 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 SCAG 6TH CYCLE DRAFT RHNA ALLOCATION BASED ON FINAL RHNA METHODOLOGY&FINAL CONNECT SOCAL 9/3/20 ALLOCATION BY COUNTY Above Very-low Moderate moderate Total income Low income income income Imperial 15,956 4,659 2,352 2,194 6,751 Los Angeles 813,082 217,565 123,171 131,532 340,814 Orange 183,430 46,295 29,176 32,482 75,477 Riverside 167,177 41,943 26,450 29,146 69,638 San Bernardino 137,786 35,575 21,855 24,087 56,269 Ventura 24,396 5,759 3,803 4,516 10,318 TOTAL 1,341,827 351,796 206,807 223,957 559,267 ALLOCATION BY LOCAL JURISDICTION Above- Very-low Moderate moderate County Total income Low income income income Adelanto city San Bernardino 3756 394 565 650 2147 Agoura Hills city Los Angeles 318 127 72 55 64 Alhambra city Los Angeles 6808 1769 1033 1077 2929 Aliso Viejo city Orange 1193 389 214 205 385 Anaheim city Orange 17411 3757 2391 2939 8324 Apple Valley town San Bernardino 4280 1083 599 745 1853 Arcadia city Los Angeles 3206 1099 569 604 934 Artesia city Los Angeles 1067 311 168 128 460 Avalon city Los Angeles 27 8 5 3 11 Azusa city Los Angeles 2646 759 367 382 1138 Baldwin Park city Los Angeles 1996 574 275 262 885 Banning city Riverside 1668 316 192 279 881 SCAG,September 2020 Page 1 of 5 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 SCAG 6TH CYCLE DRAFT RHNA ALLOCATION BASED ON RC-APPROVED FINAL RHNA METHODOLOGY ALLOCATION BY LOCAL JURISDICTION Above- Very-low Moderate moderate County Total income Low income income income Barstow city San Bernardino 1516 172 227 299 818 Beaumont city Riverside 4202 1226 720 722 1534 Bell city Los Angeles 228 43 23 29 133 Bell Gardens city Los Angeles 501 99 29 72 301 Bellflower city Los Angeles 3726 1012 487 552 1675 Beverly Hills city Los Angeles 3096 1005 678 601 812 Big Bear Lake city San Bernardino 212 50 33 37 92 Blythe city Riverside 493 82 71 96 244 Bradbury city Los Angeles 41 16 9 9 7 Brawley city Imperial 1423 398 210 202 613 Brea city Orange 2360 667 393 402 898 Buena Park city Orange 8899 2114 1340 1570 3875 Burbank city Los Angeles 8751 2546 1415 1406 3384 Calabasas city Los Angeles 353 131 71 70 81 Calexico city Imperial 4856 1276 653 612 2315 Calimesa city Riverside 2013 494 275 378 866 Calipatria city Imperial 151 36 21 16 78 Camarillo city Ventura 1373 352 244 270 507 Canyon Lake city Riverside 128 43 24 24 37 Carson city Los Angeles 5605 1766 911 873 2055 Cathedral City city Riverside 2542 538 352 456 1196 Cerritos city Los Angeles 1903 678 344 331 550 Chino city San Bernardino 6961 2107 1281 1201 2372 Chino Hills city San Bernardino 3720 1384 819 787 730 Claremont city Los Angeles 1707 554 309 297 547 Coachella city Riverside 7867 1030 997 1364 4476 Colton city San Bernardino 5420 1314 666 904 2536 Commerce city Los Angeles 246 55 22 38 131 Compton city Los Angeles 1001 235 121 130 515 Corona city Riverside 6075 1748 1038 1094 2195 Costa Mesa city Orange 11733 2912 1790 2084 4947 Covina city Los Angeles 1905 612 267 281 745 Cudahy city Los Angeles 392 80 36 53 223 Culver City city Los Angeles 3333 1105 603 559 1066 Cypress city Orange 3927 1147 656 622 1502 Dana Point city Orange 530 147 84 101 198 Desert Hot Springs city Riverside 3865 568 534 687 2076 Diamond Bar city Los Angeles 2516 842 433 436 805 Downey city Los Angeles 6510 2074 944 913 2579 Duarte city Los Angeles 886 268 144 137 337 Eastvale City Riverside 3022 1142 671 634 575 EI Centro city Imperial 3433 998 489 461 1485 EI Monte city Los Angeles 8481 1792 851 1230 4608 EI Segundo city Los Angeles 491 189 88 83 131 Fillmore city Ventura 413 72 61 72 208 Fontana city San Bernardino 17477 5096 2943 3029 6409 Fountain Valley city Orange 4827 1304 784 832 1907 SCAG,September 2020 Page 2 of 5 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 SCAG 6TH CYCLE DRAFT RHNA ALLOCATION BASED ON RC-APPROVED FINAL RHNA METHODOLOGY ALLOCATION BY LOCAL JURISDICTION Above- Very-low Moderate moderate County Total income Low income income income Fullerton city Orange 13180 3190 1985 2267 5738 Garden Grove city Orange 19122 4155 2795 3204 8968 Gardena city Los Angeles 5721 1481 759 892 2589 Glendale city Los Angeles 13393 3430 2158 2244 5561 Glendora city Los Angeles 2270 733 385 387 765 Grand Terrace city San Bernardino 628 188 92 106 242 Hawaiian Gardens city Los Angeles 331 61 44 46 180 Hawthorne city Los Angeles 1731 444 204 249 834 Hemet city Riverside 6450 810 730 1171 3739 Hermosa Beach city Los Angeles 556 231 127 105 93 Hesperia city San Bernardino 8135 1916 1228 1406 3585 Hidden Hills city Los Angeles 40 17 8 9 6 Highland city San Bernardino 2508 618 408 470 1012 Holtville city Imperial 171 41 33 26 71 Huntington Beach city Orange 13337 3652 2179 2303 5203 Huntington Park city Los Angeles 1601 263 196 242 900 Imperial city Imperial 1597 702 345 294 256 Indian Wells city Riverside 382 117 81 91 93 Indio city Riverside 7793 1788 1167 1312 3526 Industry city Los Angeles 17 6 4 2 5 Inglewood city Los Angeles 7422 1808 953 1110 3551 Irvine city Orange 23554 6379 4225 4299 8651 Irwindale city Los Angeles 118 36 11 16 55 Jurupa Valley City Riverside 4485 1204 747 729 1805 La Canada Flintridge city Los Angeles 610 251 135 139 85 La Habra city Orange 803 192 116 130 365 La Habra Heights city Los Angeles 172 78 35 31 28 La Mirada city Los Angeles 1957 633 341 319 664 La Palma city Orange 800 223 140 137 300 La Puente city Los Angeles 1924 542 275 274 833 La Quinta city Riverside 1526 419 268 296 543 La Verne city Los Angeles 1343 413 238 223 469 Laguna Beach city Orange 393 117 80 79 117 Laguna Hills city Orange 1980 566 353 353 708 Laguna Niguel city Orange 1204 347 201 223 433 Laguna Woods city Orange 993 126 135 191 541 Lake Elsinore city Riverside 6666 1874 1097 1131 2564 Lake Forest city Orange 3228 954 541 558 1175 Lakewood city Los Angeles 3914 1293 636 652 1333 Lancaster city Los Angeles 9002 2218 1192 1325 4267 Lawndale city Los Angeles 2491 730 310 370 1081 Loma Linda city San Bernardino 2048 522 311 352 863 Lomita city Los Angeles 827 238 124 127 338 Long Beach city Los Angeles 26440 7123 4038 4149 11130 Los Alamitos city Orange 767 193 118 145 311 Los Angeles city Los Angeles 455577 115680 68593 74936 196368 Lynwood city Los Angeles 1555 376 139 235 805 SCAG,September 2020 Page 3 of 5 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 SCAG 6TH CYCLE DRAFT RHNA ALLOCATION BASED ON RC-APPROVED FINAL RHNA METHODOLOGY ALLOCATION BY LOCAL JURISDICTION Above- Very-low Moderate moderate County Total income Low income income income Malibu city Los Angeles 78 27 19 17 15 Manhattan Beach city Los Angeles 773 322 164 155 132 Maywood city Los Angeles 363 54 47 55 207 Menifee city Riverside 6594 1756 1049 1104 2685 Mission Viejo city Orange 2211 672 400 396 743 Monrovia city Los Angeles 1665 518 261 253 633 Montclair city San Bernardino 2586 696 382 398 1110 Montebello city Los Angeles 5174 1311 705 775 2383 Monterey Park city Los Angeles 5245 1321 820 846 2258 Moorpark city Ventura 1288 377 233 245 433 Moreno Valley city Riverside 13596 3769 2047 2161 5619 Murrieta city Riverside 3034 1006 581 543 904 Needles city San Bernardino 87 10 11 16 50 Newport Beach city Orange 4834 1453 928 1048 1405 Norco city Riverside 454 145 85 82 142 Norwalk city Los Angeles 5022 1542 757 657 2066 Ojai city Ventura 53 13 9 10 21 Ontario city San Bernardino 20805 5625 3279 3322 8579 Orange city Orange 3927 1064 603 676 1584 Oxnard city Ventura 8528 1835 1068 1535 4090 Palm Desert city Riverside 2783 673 459 460 1191 Palm Springs city Riverside 2552 544 407 461 1140 Palmdale city Los Angeles 6625 1773 933 1002 2917 Palos Verdes Estates city Los Angeles 198 82 44 47 25 Paramount city Los Angeles 362 91 43 48 180 Pasadena city Los Angeles 9408 2740 1659 1562 3447 Perris city Riverside 7786 2025 1124 1271 3366 Pico Rivera city Los Angeles 3939 1149 562 572 1656 Placentia city Orange 4365 1228 679 769 1689 Pomona city Los Angeles 10534 2792 1336 1507 4899 Port Hueneme city Ventura 125 26 16 18 65 Rancho Cucamonga city San Bernardino 10501 3237 1916 2033 3315 Rancho Mirage city Riverside 1741 429 317 327 668 Rancho Palos Verdes city Los Angeles 638 253 139 125 121 Rancho Santa Margarita city Orange 680 209 120 125 226 Redlands city San Bernardino 3507 964 614 650 1279 Redondo Beach city Los Angeles 2483 933 507 489 554 Rialto city San Bernardino 8252 2212 1203 1368 3469 Riverside city Riverside 18415 4849 3057 3133 7376 Rolling Hills city Los Angeles 45 20 9 11 5 Rolling Hills Estates city Los Angeles 191 82 42 38 29 Rosemead city Los Angeles 4601 1151 636 685 2129 San Bernardino city San Bernardino 8104 1411 1095 1445 4153 San Buenaventura (Ventura)city Ventura 5300 1184 863 948 2305 San Clemente city Orange 978 281 163 187 347 San Dimas city Los Angeles 1245 383 219 206 437 San Fernando city Los Angeles 1791 460 273 283 775 SCAG,September 2020 Page 4 of 5 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 SCAG 6TH CYCLE DRAFT RHNA ALLOCATION BASED ON RC-APPROVED FINAL RHNA METHODOLOGY ALLOCATION BY LOCAL JURISDICTION Above- Very-low Moderate moderate County Total income Low income income income San Gabriel city Los Angeles 3017 844 415 465 1293 San Jacinto city Riverside 3385 798 464 559 1564 San Juan Capistrano city Orange 1051 269 172 183 427 San Marino city Los Angeles 397 149 91 91 66 Santa Ana city Orange 3087 584 361 522 1620 Santa Clarita city Los Angeles 10008 3389 1730 1668 3221 Santa Fe Springs city Los Angeles 950 252 159 152 387 Santa Monica city Los Angeles 8873 2787 1668 1698 2720 Santa Paula city Ventura 656 102 99 121 334 Seal Beach city Orange 1239 257 201 238 543 Sierra Madre city Los Angeles 204 79 39 35 51 Signal Hill city Los Angeles 516 160 78 90 188 Simi Valley city Ventura 2786 747 492 517 1030 South EI Monte city Los Angeles 576 131 64 70 311 South Gate city Los Angeles 8263 2131 991 1171 3970 South Pasadena city Los Angeles 2062 755 397 333 577 Stanton city Orange 1227 164 144 231 688 Temecula city Riverside 4183 1355 799 777 1252 Temple City city Los Angeles 2182 628 350 369 835 Thousand Oaks city Ventura 2615 733 493 531 858 Torrance city Los Angeles 4928 1617 845 851 1615 Tustin city Orange 6765 1720 1043 1129 2873 Twentynine Palms city San Bernardino 1044 230 127 184 503 Unincorporated Imperial Co. Imperial 4292 1200 595 579 1918 Unincorporated Los Angeles Co. Los Angeles 89842 25582 13661 14151 36448 Unincorporated Orange Co. Orange 10381 3131 1862 2035 3353 Unincorporated Riverside Co. Riverside 40768 10399 6648 7371 16350 Unincorporated San Bernardino Co. San Bernardino 8813 2174 1357 1520 3762 Unincorporated Ventura Co. Ventura 1259 318 225 249 467 Upland city San Bernardino 5673 1580 957 1011 2125 Vernon city Los Angeles 9 5 4 0 0 Victorville city San Bernardino 8146 1731 1134 1500 3781 Villa Park city Orange 296 93 60 61 82 Walnut city Los Angeles 1292 426 225 231 410 West Covina city Los Angeles 5334 1649 848 863 1974 West Hollywood city Los Angeles 3924 1063 687 681 1493 Westlake Village city Los Angeles 142 58 29 32 23 Westminster city Orange 9737 1876 1470 1781 4610 Westmorland city Imperial 33 8 6 4 15 Whittier city Los Angeles 3431 1022 536 555 1318 Wildomar city Riverside 2709 796 449 433 1031 Yorba Linda city Orange 2411 763 450 457 741 Yucaipa city San Bernardino 2859 706 492 509 1152 Yucca Valley town San Bernardino 748 155 116 145 332 SCAG,September 2020 Page 5 of 5 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Al IAUHMENT 2 Community Development Department TUSTIN TREES lune.4, 2019 7 i "xi rd it j Honorable Peggy Huang,Chair Community, Economic and Human Development Policy Committee Regional Housing Need s,Assessment Subcommittee -� Southern California Association of Governments _ 900 Wilshire Boulevard, Suite 1700 ��ISTQ Los Angeles, CA 90017 BUILDING OUR FUTURE g HONURINGOUR PAST RE: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) CONSULTATION PACKAGE TO THE CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HED) 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 Horsing 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,HCD include the following: • Follow 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 Jaw, and use the best available statistics and technical methodology. Research the appropriate factors and causes associated with existing housing 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 RHNkmetho_dology for the 6`h Cycle: + SCAG should propose to HCD a regional 6'h 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. • Itis 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 HCD 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 9 ll; (7 1,J) 573-3100 o F; (714) 573.-3i l3 a wc«v.tustinca.orn DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Honorable Peggy Huang Lune 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. In addition, basing existing housing need on & 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 itscalculation 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, 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 RHNA targets. Hopefully, recently enactedfunding 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 SCAG to proposer a regional 6''' 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. i Sincerely, Elizabeth A. Binsack Community Development Director cc: Tustin City Council (Come Ajise,SCAG Executive Director Marnie Primmer, OCCOG Executive'Director Matthew S. West, City Manager lustina Wilikom,Assistant Community-Development Director Scott Reekstin, Principal Planner DocuSign Envelope ID: F05413575-41 FA-4146-132A7-9301724375c_2 ' /TENT 3 Community Development Department TuSTIN }} TREES F Z 7 O August 30, 2019 Mr, I<ome Ajise Executive Director H[570RY 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 Dear Mr.Ajise: 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 Methodology for the 6t" RHNA Cycle: SCAG should select a methodology which is consistent with local input that already 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 Transportation Plan (RTP)/Sustainable Communities Strategy(SCS). 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 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. • Of the three (3) methodology options developed and released for public review by SCAG, the City 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. • 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) 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. 300 Centennial Way, Tustin, CA 92780 • P: (714) 573-3100 9 F: (714) 573-31 13 • www.tustinca.orc, DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr. Kome Ajise August 30, 2019 Page 2 • 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 6th 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 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Center for Demographic Research Sponsors: August 23,2019 California State Mr. Kome Ajise University,Fullerton Executive Director County of Orange Southern California Association of Governments 900 Wilshire Blvd., Suite 1700 Municipal Water Los Angeles, CA 90017 District of SENT VIA EMAIL: housing@scag.ca.gov Orange County SUBJECT: PROPOSED REGIONAL HOUSING NEEDS ASSESSMENT(RHNA) Orange County Council of ALLOCATION METHODOLOGY Governments Dear Mr. Ajise: Orange County Sanitation District The Center for Demographic Research(CDR)at Cal State Fullerton has reviewed the Proposed Regional Housing Needs Assessment(RHNA)Allocation Methodology and its Data Appendix. Orange County We recognize all of the work SCAG staff has done to produce these reports and the extensive Transportation work with local agencies during the development process. Further, CDR extends our thanks for Authority SCAG's close coordination with us on behalf of Orange County jurisdictions to ensure that the Orange County 2018 Orange County Projections(OCA), Orange County's growth forecast, were utilized. Water District I would also like to express our appreciation for the ongoing coordination regarding the Southern California upcoming updates and corrections to the RHNA calculator. Though a new version of the RHNA Association of calculator is forthcoming, some of the draft comments in the matrix below are indicated as Governments pending after feedback from SCAG staff that these are expected to be included in the next iteration of the calculator, I would also like to acknowledge that comments 3 and 4 in the matrix Transportation below were prepared prior to the issuance of the draft regional number from HCD. As the Corridor Agencies income shares provided by HCD to not appear to include a redistribution of the above moderate income category,please also take these comments into consideration for any subsequent RHNA Contributing Partner: cycles. Orange County We support SCAG's approach to developing an equitable methodology by releasing multiple Local Agency Formation Commission potential methodologies for public review and comment. After a detailed review of each available option, we ask for your consideration and response to the following: 1. We support the comments provided separately by the Orange County Council of Governments: + Local input should underpin the selected RHNA methodology allocation option • Support for local input as the floor for any RHNA allocation of projected need + Allow time for peer review of new factors or methodologies • Adopt a methodology after HCD provides the regional determination • Align the definition of HQTAs with Cap and Trade for RHNA purposes • Opposition to the reallocation of Above Moderate units Utilize share of growth for household population not total population growth • Remove land areas not compatible with residential uses from density calculation • Allow for vetting and corrections to CIRB units permitted data 2. Technical comments on the Proposed RHNA Allocation Methodology, Data Appendix, and the RHNA Calculator in Table 1 matrix below. 3. Suggested language changes to the Proposed RHNA Allocation Methodology in the redline version attached to this letter(Attachment Q. 1121 N.State College Blvd.,Suite 238,Fullerton,C:k 92831-3014(657)278-3009 1`ax(657)278-5091 viww.fuilerton.edu/cdr/ DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr.Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 2 of 9 i Table I.Comments on Proposed RHNA Allocation Methodologies&Data Appendix Tables Topic&Page Question/Comment Reference All I. Provide a tracked changes document based on the changes made since publication of the documents for the public comment period. 2. Please see Attachment 3 for a redline version of the Proposed RHNA Allocation Methodology pages 1-53 for text corrections,clarifications and suggestions, Page 8,Option 1, 3. Redistribution of Existing Need Above Moderate units is not consistent with the 6rh cycle Step Id methodology of assigning total regional need to regions throughout the state. On page 8 of the Proposed RHNA Allocation Methodology,Step ld discusses the redistribution of the Above Moderate housing units for existing need to the three lower-income categories.Using SCAG's RHNA calculator,with a sample regional allocation of 659,144 units,Option 1 redistributes approximately 63,807 Above Moderate units into the three lower- income categories across the region,about 9.7%of the sample regional allocation total and 42.4%of the existing need total of 150,589,As seen in Table A below,lines 1, 2,and 8 show the differences in the percent shares by income category before and after the proposed redistribution of the Above Moderate units.This makes it impossible to match the allocations and percent shares by income category provided by HCD unless HCD factors the redistribution into its regional determination for SCAG before a decision on a methodology is made by the RHNA subcommittee,CEHD or Regional Council . Table A;Differences in Methods for Redistribution of Existing Need Above Moderate income Category Above Very Low Low Moderate Moderate Proportional Share: Income Income Income Income I Option 1 original 110%social equity adjustment 25.4% 15.5% 16.8% 42.4% 2 Option 1 after redistribution of above moderate units(proportional share) 44.1% 26.9% 29.1%n 0.0% 3 Difference:Redistributed—original 110% -+-18.7% -11.4% +12.3% -42.4% 4 Option 1 original 110%social equity adjustment 38,242 23,311 25,229 63,807 5 Option 1 after redistribution of above moderate units(proportional share) 66,390 40,437 43,771 0 6 Difference: Redistributed—original 110% +28,148 +17,126 +18.542 -63,807 Equal Share: 7 Option I original 110%social equity adjustment 25.4% 15.5% 16.8% 42.4% 8 Option 1 after redistribution of above moderate units(using equal share) 39.5% 29.6% 30.9% 0.0% 9 Difference:Redistributed—original 110% +14.1% +14.1% +14.1% 424% to Option l original I10%social equity adjustment 38,242 23,311 25,229 63,807 11 Option 1 after redistribution of above moderate units(using equal share) 59,533 40,437 43,771 0 12 Difference:Redistributed—original l 10% +21,291 +17,126 +18,542 -63,807 In order to utilize this redistribution methodology,HCD would have to be informed of the proposed redistribution methodology,accept the idea of redistribution,and provide either a range for each of the income categories in numbers and percent shares for the SCAG total regional allocation or pre-determine the social equity adjustments and pre-calculate the redistribution of the Above Moderate category to provide specific regional numbers and shares. To date,HCD has provided specific numbers and percent shares for each of the four income categories for each the I I agencies it has already provided total regional allocations to for the DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr. Ajise 8/23/2919 Proposed RHNA Methodology Comment Letter Page 3 of 9 Topic&Page Question/Comment Reference 6"RHNA cycle(http://www.hcd.ca.p-ov/community-development/housing_- element/index.shtm l). Providing SLAG income category ranges would be inconsistent with the methodology and regional assignments for the 11 regions in the state that have already received their regional allocations from HCD for the 611 cycle.Using either of the two methods described above, regional ranges or specific numbers and percentages that include redistribution of the Above Moderate units,could also set a precedent for the nine subsequent regions still waiting for their 6'h cycle allocations and fitture RHNA cycles for all 21 regions. 4. Redistributing the Above Moderate units to the three lower-income categories further increases the burden of those jurisdictions that are already impacted and have higher shares of lower-income units by assigning more units into the three lower-income categories. Using the relative share of the lower income categories to redistribute the Above Moderate units increases the burden for those jurisdictions that currently have higher concentrations of lower-income units. Lines 3 and 6 in Table A above show that an additional 28,000 very low and 17,000 low income units would be redistributed throughout the region. This includes those jurisdictions that are already impacted, lower-income communities. If redistribution of the Above Moderate units is decided to be done by SCAG's elected officials and committees,at the very least to attempt to lessen the effect of further impacting local jurisdictions, apply an equal share to each of the three tate og ries to lessen the impact on those jurisdictions that already have higher concentrations of lower-income housing. Lines 3 and 9 in Table A above show that the impact to those jurisdictions already burdened would be lessened by using an equal share to redistribute the Above Moderate units if the SCAG elected officials choose to do so. For example,if the Above Moderate total is 60 units and needs to be redistributed to the three lower-income categories,divide 60 by 3 —20 and assign 20 units to each of the three lower-income categories. Page 8, 5. "For example, in Los Angeles County 63 percent of all households live within an HQTA, paragraph 3 with 72 percent of the County's very low income households living within an HQTA while only 56 percent of above moderate income households do." ---Please add a table showing all shares for all counties for all data points listed in paragraph. Page 20, 6. "At the jurisdictional level, between 2012 and 2017 the jabs..." paragraph 2 ---Please explain in the report why this specific time increment reported. Page 28, 7. "The AFFH survey accompanied the required local planning factor survey and that was paragraph 2 sent to all SLAG jurisdictions in mid-March 2019 with a posted due date of May 30,2019" ---Wasn't the initial deadline for input April 30? Page 32,Jobs 8. "...enough affordable housing in high resources areas," Housing Fit ---Please provide the definition of`high resource areas' in the methodology document. paragraph 1 Page 37, Step 1 b 9. "The 20 percent of the regional existing housing need will be distributed based on a jurisdiction's share of 2016 regional population within an existing(2016) HQTA." ---Please clarify if the 2019 DOF population was developed at the SCAG TAZ level and is being used or if the RTP TAZ/Iocal input data for year 2016 was used. Page 43, Step 2a I0. "...the share of regional household growth for the jurisdictions, e.g,., for years 2020-2030, is calculated and applied to the RHNA regional household growth" ---Is this share of growth prorated to 2021-2029?If so,add text from Option 3. All tables in 11. Add table ID numbers to each table. RHNA Technical 12. Add in pagination for each table,e.g. I of 5. Appendix DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr,Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 4 of 9 Topic&Page Question/Comment Reference Share of 2019 13. Add note that says"HQTAs may include permanently protected open space identified by state Population in 2016 and/or federal agencies." HQTAs,54-58 Number of 14. Why is SCAG looking at only the last two cycles of RHNA for permit activity?Why not go Residential Units further back if it is to address the existing need/backlog? Permitted,CIRB 15. Show calculations for how permits per 1,000 pop are calculated. and SCAG Local Profiles, 59-82 Social Equity 16. Add formula page to show how 110%and 1.50%social equity adjustments are calculated. Adjustments Existing/110%11 50%, 88-93 Projected 17. "Source:Local Input from SCAG jurisdictions for Connect SoCal/2020 RTP/SCS, Household October X92018" Growth-Local Input for Connect SoCal 99-103 Local Population 18. "Source:Local Input from SCAG jurisdictions for Connect SoCal/2020 RTP/SCS, and Household October X92018" Growth 2020- 2045,Connect Socal 110-113 Vacant Units by 19. If SCAG chooses to use the strict U.S.Census Bureau definitions for renter and owner vacancy Tenure and Type, rates(defined below),for the most accurate data possible,SCAG should use the raw,unrounded American data from tables DP04 and B25004 to calculate the tenured(owner&renter)vacancy rates by Community jurisdiction for use in the healthy market vacancy rate adjustments. Survey 2013- U.S.Census Bureau defines the following: 2017 5-year https:!lwww2.census.gov/programs-surveys/acs/tech_doos/subject definitions!2017_ACSSubjectDefinitions.pdf7 Estimates Homeowner Vacancy Rate--The homeowner vacancy rate is the proportion of the 114-117 homeowner inventory that is vacant"for sale."It is computed by dividing the number of vacant units"for sale only"by the sum of the owner-occupied units,vacant units that are Options 1 &3 "for sale only,"and vacant units that have been sold but not yet occupied,and then multiplying by 100.This measure is rounded to the nearest tenth. Rental Vacancy Rate—The rental vacancy rate is the proportion of the rental inventory that is vacant"for rent."It is computed by dividing the number of vacant units"for rent"by the sum of the renter-occupied units,vacant units that are"for rent," and vacant units that have been rented but not yet occupied,and then multiplying by 100.This measure is rounded to the nearest tenth. To calculate owner and renter vacancy rates,the U.S,Census Bureau reports the raw data in two separate tables:DP04 and B25004. DP04 includes the following: • Total housing units • Occupied housing units(Households) • Vacant units • Total vacancy rate • Number of owner-occupied units(owner households)[for owner vacancy rate] • Number of renter-occupied housing units(renter households)[for renter vacancy rate] • Owner vacancy rate-rounded to tenths • Renter vacancy rate-rounded to tenths B25004 reports the number of vacant units by the seven vacancy types: I. For rent[for renter vacancy rate] 2. Rented,not occupied 3. For Sale only for owner vacancy rate DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr.Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 5 of 9 Topic&Page Question/Comment Reference 4. Sold,not occupied 5. For seasonal,recreational,or occasional use 6. For migrant workers 7. Other vacant Currently,SCAG is only using the rounded-to-tenths owner and renter vacancy rates from DP04 for the healthy market vacancy rate adjustments at the jurisdictional level.For example,in order to calculate the regional tenured vacancy rates for the HCD consultation package(June 6,2019 CEHD agenda packet), SCAG imputed the renter and owner units from a single table's rounded data(DP04)rather than calculating the actual rates from raw data in two separate tables(DP04 and B25004).Table B below illustrates the differences when using imputed and rounded vs. raw,unrounded data to calculate the regional tenured vacancy rates.Though small differences in percentages are seen in the tenured vacancy rates,when applied to the regional totals of hundreds of thousands of housing units shown in Table C,the resulting differences when using imputed and rounded data vs.raw, unrounded data can be sizeable. Table B:Tenured Vacancy Rates for SCAG Region from Different Source Tables Owner Renter i Vacancy Rate Vacancy Rate i Only 1-year DP04(requires imputation using rounded data) 1.1015% 3.2756% Only 5-year DP04(requires imputation using rounded data) 1.2018% 3.5850% All 5-year data (Tables DP04&B25004,raw,unrounded) 1.2443% 3.61.82% Sources:U.S,Census Bureau American Community Survey 2017 1-year and 2013-2017 5-year estimates Using the occupied units by tenure from the June 6,2019 CEHD HCD Consultation Package's Table 1 on page 16,Table C below shows the magnitude of the differences when using imputed/rounded data vs.the raw,unrounded data outputs from Table B to calculate the regional healthy market vacancy rate adjustments by tenure.When comparing the raw, unrounded data to the imputed!rounded data,the raw,unrounded data are 19.3%to 23.0%lower than using the imputed rates.Recognizing that 1-year and 5-year data are inherently different and will produce different results,Table C also shows the differences between the 5-year raw vs. 5-year imputed data. Table C:Differences in Healthy Market Vacancy Rate Adjustments at the SCAG Regional Level by Tenure,U.S.Census Bureau American Community Survey(ACS) Total Differences with Projected Need Vacancy Table 1* Owner Renter Adjustments Number I Percent SCAG Total 311,821* 282,916* 594,737* 1 1- ear ACS-on DP04* 1,247* 4,866* 6,113* 0 0.0% 2 5-year ACS-only DP04 797 3,909 4,707 1,406 -23.0% 1 3 5- ear ACS DP04&B25004 930 4,003 4,933 1,180) -19.3% I Existing Need Owner Renter Number Percent I SCAG Total 3,184,473* 2,889,288* 6,073,761* 4 1- ear ACS-only DP04* 12,738* 49,696* 62.434* 0 0.0% 5 5-year ACS-only DP04 8,141 39,924 48,066 (14,368) -23.0% 6 5-year ACS DP04&B25004 9,498 40,882 50,380 12,054 -19.3% *SCAG's calculations reported in June 6,2019 CEHD Agenda Packet's HCD Consultation Package,Table 1,p. 16 Sources:U.S.Census Bureau American Community Survey 2017 1-year and 2013-2017 5-year estimates, Tables DP04&B25004 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr.Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 6 of 9 Topic&Page Question/Comment Reference E 20. Since the raw data is available,in order to use the most accurate data possible during the RHNA process,unrounded vacancy rates for each jurisdiction should be calculated by using both tables DP04 and B25004 for use in the healthy market vacancy rate adjustments. 21. Please include the table in Attachment 1 in the RHNA Data Appendix,which shows the raw data inputs,calculations and results of the owner and renter vacancy rates using both tables DP04 and B25004. Vacant Units by 22. Consider using all,or more than two,of the seven categories of vacant units to calculate the Tenure and Type, tenured vacancy rates. American Community The U,S.Census Bureau American Community Survey{ACS)2017 5-year estimates report Survey 2013- 6,470,403 housing units in the SCAG region with 5,970,784 occupied housing units 2017 5-year (households)and 499,619 vacant units.The total vacancy rate for the region is 7.7% Estimates (6,470,403 1499,619).As mentioned above on page 4,the Census Bureau divides vacant units 114-117 into seven different categories. See Attachment 2 for Census definitions of all vacant unit types. Options 1 &3 Though all seven categories are used to calculate a jurisdiction's total vacancy rate,to calculate the tenured(owner&renter)vacancy rates,the Census Bureau only uses two of the seven types of vacant units. California statute does not specify how to calculate the homeowner and renter vacancy rates,nor does it require Census Bureau definitions to be used, it only specifies that the healthy market vacancy rate for renters is 5.0%, Five of the seven categories of vacant units,totaling 353,517 units,are not included in the calculation of owner and renter vacancy rates using the Census Bureau definitions(above on page 4),Thus,any RHNA methodology that utilizes the strict Census owner and renter vacancy rates will underestimate the tenured vacancy rates and actual number of vacant units for each jurisdiction.As a result,the region as a whole,and each of the t97 jurisdictions,will be assigned a higher RHNA allocation, for example,as seen in Table D below on page 7,Imperial County has a total of 1.2,000 vacant housing units(ACS 2017 5-year estimates)but only two categories of those vacant units(829 and 548=1,377)are used in the formula to calculate the owner and renter vacancy rates.That means that 10,623 vacant units are not being credited to Imperial County jurisdictions in the RHNA's healthy market vacancy rate adjustments.As a result,the owner vacancy rate is 2.1%, the renter vacancy rate is 4.0%,while the total vacancy rate for imperial County is 21.0%. As a further example,Orange County has a total of 56,725 vacant housing units(ACS 2017 5- year estimates)but only two categories of those vacant units(14,542 and 5,037= 19,579)are used to calculate the owner and renter vacancy rates.That means that 37,146 vacant units are not being credited to Orange County jurisdictions in the RHNA's healthy market vacancy rate adjustments due to this underestimation. These same strict definitions were used to calculate the regional vacancy rates as explained above(Item 20),for the consultation package sent by SCAG to HCD with the ultimate effect that the region was not credited with all the vacant units by ignoring five of the seven types of vacant units,thus underestimating the current vacant housing stock. 23. Consider using all,or more than two,of vacant unit categories in the tenured vacancy rates. • Rented,not occupied • Sold,not occupied • For seasonal,recreational,or occasional use • For migrant workers • Other vacant DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr. Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 7 of 9 Topic&Page Question/Comment Reference Table D: Types of Vacant Units,ACS 2013-2017 5-year estimates,Table B25004 Los San Imperial Angeles Orange Riverside Bernardino Ventura SCAG For rent 829 59,605 14,542 14,961 13,167 3,569 106,673 Rented,not occupied 338 16,188 4,294 2,153 2,848 477 26,298 For sale only 548 16,067 5,037 9,264 7,088 1,425 39,429 Sold,not occupied 88 9,393 4,274 3,726 3,397 943 21,821 For seasonal, recreational,or occasional use 3,028 32,662 17,727 64,887 43,155 5,672 167,131 For migrant workers 92 97 162 551 111 187 1,200 Other vacant 7,0771 77,693 10,689 19,438 18,492 3,678 137,067 Total Vacant housing units 12,000 211,705 56,725 114,980 88,258 15,951 499,619 Total vacant units used in vacancy calculation 1,377 75,672 19,579 24,225 20,255 4,994 146,102 Total vacant units not being credited to jurisdictions 10,623 136,033 37,146 90,755 68,003 10,957 353,517 Table E:Total and Tenured Vacancy Rates,ACS 2013-2017 5-year estimates,Table DP04 Los San Imperial Angeles Orange Riverside Bernardino Ventura SCAG Total Housing Units 57,198 3,506,903 1,081,701 826,704 711.900 285,997 6,470,403 Total Vacancy Rate 21.0% 6.0% 5.2% 13,9% 12.4% 5.6% 7.7% Homeowner vacancy rate (Rounded) 2.1% 1.0% 0.8% 1.9% 1.9% 0.8% Rental vacancy rate (Rounded) 4.0-/, 3.2% 3.2% 5.6% 4.9% 3.5% Sources:U.S.Census Bureau American Community Survey 2013-2017 5-year estimates,Tables DP04& B25004 Overcrowding 24. Add ACS source table number B25014 table 118-121 Cost-Burdened 25. Add ACS source table rnunber B25070 table 122-126 Industry 26. Add ACS source table number Affiliation by 27. Add second line to title or note at bottom of page"Number of residents employed in Residence table jurisdiction by industry" 127-130 Industry 28. Add ACS source table number Affiliation by 29. Add second line to title or note at bottom of page"Number of jobs in jurisdiction by Workplace,ACS industry" 2012-2016 5- year Estimates 131-134 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr.Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 8 of 9 Topic&Page Question/Comment Reference RHNA 30. Indicate in notes at bottom of table what the four categories of the survey represent and Methodology dates for each. Survey Response Summary, Spring 2019 288-293 RHNA Data 31. If HCD approves the removal of growth on tribal lands in unincorporated county areas, Appendix,p. 99- specifically Unincorporated Riverside&San Bernardino Counties,please: 103; 110-113 & a. Indicate these changes to population and household numbers in the Proposed RHNA RHNA Methodology Data Appendix tables: Calculator i. Projected Household Growth-Local Input for Connect SoCal ii. Local Population and Household Growth 2020-2045,Connect SoCal b. Indicate these changes to population and household numbers in the RHNA Calculator RHNA data worksheet columns: i. POP20,POP30,POP35,&POP45 ii, HH2O,HH30&HH45 RHNA 32, In the RHNA Calculator RENA_data worksheet,please add 2035 Households for all Calculator jurisdictions,which is needed to determine which increment of population growth share should be used for Option 3 and for general reference. RHNA Data 33. Please correct Households 2045 in either the RHNA Calculator or the Proposed RHNA Appendix,p, 99- Methodology Data Appendix Tables:Local Population and Household Growth 2020-2045, 103; 110-113 & Connect SoCal and Projected Household Growth—Local Input for Connect SoCal as 196 of RHNA 197 jurisdictions' data does not match. Calculator PENDING RHNA Data 34. In the RHNA Calculator RHNA—data worksheet,for columnsNI(H. QTAPOPI6)&N Appendix,p. 54- (PCT_HQTAPOP 16),please correct the sorting in either the Proposed RHNA Methodology 58&RHNA Data Appendix Table: Share of 2019 Population in 2016 HQTAs or the RHNA Calculator for Calculator the following cities: • Bell Gardens (PENDING) . Bellflower • La Habra • La Mirada • La Puente • La Verne • Laguna Niguel • Lakewood • Lancaster RHNA 35. Please correct the tenure rates by tenure in the RHNA Calculator RHNA data worksheet for the Calculator following jurisdictions,as it is unlikely all have the same share of owner and renter units: • Unincorporated Los Angeles (PENDING) • Unincorporated Orange • Unincorporated Riverside • Unincorporated Ventura RHNA 36. In the RHNA Calculator RHNA—data worksheet,Option 1 uses a total of 150,577 for existing Calculator need by using this formula: a. Placeholder HCD regional total housing allocation(659,144)-projected household growth(468,428)-vacancy adjustments for projected need(14,580)-replacement need for projected growth(25,559)= 150,577, b, The calculator is using the total number of replacement need of 25,559 for the projected need calculations,but the 25,559 is the existing need replacement number per Table 1 in the June 6,2019 CEHD HCD consultation package. The projected replacement need number should be smaller,near 2,500 as seen in Table 1 in the HCD package. DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr. Ajise 8/23/2019 Proposed RHNA Methodology Comment Letter Page 9 of 9 Topic&Page Question/Comment Reference RHNA 37. In the RHNA Calculator RHNA_data worksheet,for Option 1,columns BC,BD,and BE divide Calculator the above moderate category into three equal shares,whereas the methodology on page 8 talks about using the relative share of the three lower-income categories.Please correct the formulas to match the methodology on page 8. RHNA 38. With the newly-issued draft regional total from HCD of 1,344,740,SCAG may choose to Calculator update the calculator with only the option of 1,334,740 or a simple formula that utilizes the share of growth for 2020-2045. If SCAG chooses to retain the flexibility of the calculator inputs,please update Option 3's calculations to utilize if/then statements so the formulas are referencing the appropriate time increment(2020-2030,2020-2035,or 2020-2045)based on the amount of household growth as is described on page 15 of the Proposed RHNA Methodology. The RHNA Calculator is currently set up to only use the growth increment of 2020-2045,which is not how the methodology is described on page 15 of the Proposed RHNA Methodology document. RHNA 39. The formulas in the RHNA calculator currently"force-fit"the results to match an exact regional Methodologies& number.The expectation is that the final RHNA methodology and calculations would do the RHNA same.If this is the case,please revise the appropriate narrative to clarify that existing need wiI l Calculator be the remainder of the regional determination after the projected need is determined,as utilizing a different progression would result in a different determination for each local jurisdiction. RHNA Data 40. Please republish the Proposed RHNA Allocation Methodology Technical Data Appendix and Appendix& RHNA calculator after corrections are made. RKNA Calculator Again, we thank you for your time and consideration of the comments above, If you have any questions, please do not hesitate to contact me. Sincerely, Deborah S. Diep Director, Center for Demographic Research Attachments: 1. Housing Tenure Vacancy Rates by SCAG Jurisdiction 2. U.S. Census Bureau Definitions of Types of Vacant Units 3. Tracked changes version of Methodology document(incl. Word version) Email CC: CDR Management Oversight Committee CDR Technical Advisory Committee OCCOG Board of Directors OCCOG TAC Sarah Jepsen, SCAG Ma'Ayn Johnson, SCAG Ping Chang, SCAG Kevin Kane, SCAG Marnic Primmer, OCCOG Ruby Zaman, CDR ATTAr-unni=NT 4 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Office of the City Council • December 12, 2019 01 Mr. Doug McCauley, Director California Department of Housing and Community Development 2020 West El Camino Avenue Sacramento, CA 95833 RE: REGIONAL HOUSING NEEDS ASSESSMENT(RHNA)ALLOCATION METHODOLOGY Dear Mr. McCauley: On behalf of the Tustin City Council, I would like to express our serious concerns regarding the action taken by the Southern California Association of Governments (SCAG) Regional Council on November 7, 2019, to approve, through a substitute motion and a 43-19 vote, an alternative Regional Housing Needs Assessment (RHNA) allocation methodology;and our objection to the disproportionate draft RHNA allocation for the City of Tustin. This alternative RHNA allocation methodology will result in a dramatic increase in the RHNA allocation for most Orange County cities, while substantially decreasing the RHNA allocations for many Riverside and San Bernardino County cities. In fact, the allocation for the City of Tustin would be approximately 6,853 housing units over the eight- year 6h Cycle RHNA period. As you are aware, the alterative RHNA allocation methodology had not been analyzed by SCAG staff prior to the November 7, 2019, vote and was not consistent with the RHNA allocation methodology that was supported by SCAG staff, provided to all SCAG member jurisdictions for review, and approved by the SCAG RHNA Subcommittee and the SCAG Community, Economic, and Human Development Committee. The City of Tustin is committed to addressing California's critical housing needs and is a leader in building affordable housing and housing for those of all socioeconomic levels. A listing of the many existing affordable home communities and emergency and transitional housing facilities in Tustin is attached to this letter. With housing development within the City's former redevelopment areas and the major master-planned communities of Tustin Ranch and Tustin Legacy, approximately 9,000 single and multiple family homes have been built in Tustin over the past thirty (30) years. However, many other cities statewide have done little or nothing to address their own local affordable housing needs without significant consequences,while the City of Tustin is facing the possibility of an artificially large RHNA allocation primarily because of an alternative methodology that over-emphasizes proximity to transit facilities and employment centers. The RHNA allocation methodology should be equitable and reflect local input that incorporates population,housing, and employment projections. This local input has always been a foundational component of SCAG's RHNA planning process and ensures consistency between the RHNA and the Regional Transportation Plan (RTP)/Sustainable Communities Strategy(SCS). It is also concerning how SCAG addresses the inconsistency between the regional 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. The SCAG region potentially could be planning for additional housing without planning for the transportation network to support the additional housing. And if the RTP growth forecast is modified to reflect the regional RHNA Mayor Dr. Allan Bernstein e Mayor Pro Tem Letitia Clark • Charles E. "Chuck" Puckett - Barry W. Cooper • Austin Lombard 300 Centennial Way,Tustin, CA 92780 0 www.tustinca.org DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 Mr. Doug McCauley December 12, 2019 Page 2 determination by HCD that is inconsistent with local input, the RTP growth forecast would not be based on sound land use planning principles. Although the City of Tustin believes that the regional allocation of approximately 1.3 million housing units for the SCAG region is unattainable, this total allocation determined by HCD should be more equitably allocated among jurisdictions if the goal is to encourage the development of more housing throughout the region. Therefore, the City of Tustin respectfully requests that the California Department of Housing and Community Development reject the SCAG RHNA allocation methodology that was adopted by the SCAG Regional Council on November 7, 2019, and take all possible steps within its authority to ensure that the final RHNA methodology adopted by SCAG complies with State law, results in more reasonable RHNA allocations for Change County cities, and is not based on political motives. 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 had urged SCAG to adopt an 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 an RHNA allocation that is not achievable and one that will jeopardize the region's ability to successfully address California's housing crisis. Sincerely, ozaet� Dr. Allan Bernstein Mayor cc: Tustin City Council Kome Ajise, SCAG Jonathon T. Hughes, SCAG 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: Affordable Housing Communities and Emergency/Transitional Housing Facilities DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 AFFORDABLE HOUSING COMMUNITIES Community Name Number of Tenant Type Affordable Units Tustin Gardens 101 Elderly Kenyon Pointe 71 Family Westchester Park(Orange Gardens) 150 Family Flanders Pointe 49 Family i Rancho Alisal 72 Family Rancho Maderas 54 Family Rancho Tierra 51 Family Coventry Court 153 Senior Tustin Grove 22 Family Ambrose Lane 5 Family Heritage Place 54 Senior Chatham Village(Hampton Square) 210 Family Tustin Field I 78 Family Tustin Field Il 40 Family Arbor Walk 10 Family i Cambridge Lane 50 Family Camden Place 63 Family Clarendon 42 Family i I St.Anton 225 Family Amalfi Apartments 37 Family t Habitat for Humanity 2 Family TOTAL 1,538 DocuSign Envelope ID: F05413575-41 FA-4146-B2A7-9301724375C2 EMERGENCY AND TRANSITIONAL HOUSING FACILITIES I Project Name Number of Tenant Type beds or housing units { Sheepfold -- — — 6 Women and children I i i Laurel House 6 Youth 3 Village of Hope 387 Family Tustin Family Campus 90 Family Salvation Army at Tustin Field I 6 units Family i Human Options at Columbus Grove 6 units Familv Orange Coast Interfaith Shelter 6 units Family City Emergency Shelter 80 Men and Women Veterans Outpost 26 beds Veterans and their families i i i J J 1 i 3 3