HomeMy WebLinkAbout02 RHNA WorkshopITEM #2
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DATE: MAY 22, 2007 Inter C 0 m ~`sT~?
PLANNING COMMISSION
TO:
FROM: COMMUNITY DEVELOPMENT DEPARTMENT
SUBJECT: HOUSING ELEMENT AND
REGIONAL HOUSING NEEDS ASSESSMENT UPDATE
RECOMMENDATION
That the Planning Commission receive and file this report.
BACKGROUND AND DISCUSSION
Regional Housing Needs Assessment
State law requires that jurisdictions provide their fair share of regional housing needs. The
State of California Department of Housing and Community Development (HCD) is
mandated to determine the state-wide housing need. In cooperation with HCD, local
governments and councils of government (COGs) are charged with making a
determination of their city's or region's existing and projected housing need as a share of
the state-wide housing need. This process is called the Regional Housing Needs
Assessment (RHNA) and is summarized in Attachment A to this report. The Planning
period for the current Regional Housing Needs Assessment (RHNA) prepared by the
Southern California Association of Governments (SCAG) is for an eight-year period from
2006 to 2014.
After the last state mandated Regional Housing Needs Assessment (RHNA) cycle, the
SCAG Regional Council asked that actions be taken to streamline the process to make it
less contentious and cumbersome and more relevant to local planning. These actions led
to the recent adoption of the RHNA Pilot Program through the passage of Senate Bill No.
12. The author and sponsors of SB 12 noted that the RHNA Pilot Program features three
core principles:
• One integrated forecast for housing, transportation, and air quality.
• Protection and enhancement of the local input process.
• One round of appeals maintained as a process safety valve.
Timeline
The following timeline highlights the most pertinent actions that have been taken in the last
twelve (12) months and/or are scheduled to occur in the next two months by the City of
Tustin and the Southern California Association of Governments with respect to RHNA.
Planning Commission Report
Regional Housing Needs Assessment
Housing Element Update
May 22, 2007
Page 2
Date Action
June 15, 2006 Tustin provides written comments to SCAG regarding proposed
RHNA Pilot Pro ram.
July 6, 2006 Tustin provides written comments to SCAG regarding proposed
RHNA Pilot Pro ram.
Jul 12, 2006 SCAG ublicl releases Pro osed RHNA Pilot Pro'ect Lan ua e.
July 17, 2006 Tustin provides written comments to SCAG regarding proposed
RHNA Pilot Pro ram.
Au ust 3, 2006 SCAG ublicl releases revised RHNA Pilot Pro~ect Lan ua e.
August 15, 2006 Tustin provides written comments to SCAG regarding proposed
RHNA Pilot Pro ram.
November 2, 2006 SCAG releases draft RHNA numbers.
November 7, 2006 Tustin staff participates in Orange County Subregional Workshop
and rovides RHNA related comments.
November 16, 2006 SCAG staff discussed RHNA methodology at the Orange County
Council of Governments Board meetin .
November 27, 2006 Tustin provides written comments to SCAG disputing the draft
re lacement need of 1,076 housin units.
December 11, 2006 Tustin provides written comments to SCAG requesting that the
draft re lacement be ad'usted.
January 11, 2007 SCAG issues a letter to Tustin agreeing to removed the
replacement need associated with the demolition of military
housin from the final RHNA construction need calculation.
January 11, 2007 Tustin provides written comments to SCAG regarding the
increase in the RHNA allocations for nine Oran a Count cities.
February 1, 2007 SCAG Regional Council approves Final RHNA Methodology and
Draft RHNA Allocation Plan.
February 1, 2007 Tustin staff met with SCAG staff and staff from eight other Orange
Count cities.
Februa 9, 2007 SCAG issues a letter to Tustin re ardin OCP and RHNA.
Februa 26, 2007 SCAG staff meets with Tustin staff.
March 15, 2007 Tustin submits its a eal/revision re uest to SCAG.
A ril 10, 2007 Senate Bill 12 is a roved and si ned into law b the Governor.
April 25, 2007 RHNA Appeals Board holds appeal hearing for Tustin appeal.
Mayor Pro Tem Amante testifies before the RHNA Appeals Board
and urges them to consider our request to reduce the RHNA
allocation for the City of Tustin. The Appeals Board considers the
re uest and continues the matter to A ril 26, 2007
April 26, 2007 RHNA Appeals Board holds continued appeal hearing and
a roves a reduction of 985 allocated housin units for Tustin.
May 14, 2007 RHNA Appeals Board approves written decisions on RHNA
a eats and re uests.
July 12, 2007 SCAG Regional Council to consider adoption of the Final Housing
Need Allocation Plan.
Planning Commission Report
Regional Housing Needs Assessment
Housing Element Update
May 22, 2007
Page 3
September 4, 2007 Deadline for final adoption of the Final Housing Need Allocation
Plan by HCD.
The SCAG Regional Council is expected to adopt the Final Housing Need Allocation Plan at
their meeting on July 12, 2007. The adopted RHNA allocation for the City of Tustin is a
critical component of our General Plan Housing Element update, which is mandated by State
law to be completed by June 30, 2008.
Housing Element
The availability of housing for every family is addressed by the California Government
Code requirement that each city adopt a Housing Element as a mandatory part of its
General Plan. The purpose of the Housing Element is to address the housing needs of all
economic segments, while considering the economic, environmental, and fiscal factors and
community goals set forth in the General Plan. The preparation of the City's Housing
Element is guided by, and must conform to, Section 65580 et. al. of the California
Government Code. The implementation period for the next Housing Element cycle is July
2008 to 2013.
To complete the Housing Element, each city needs to identify its projection and
quantification of existing and projected housing needs for all income groups. This
projection and quantification is part of the Regional Housing Needs Assessment (RHNA)
described in the RHNA discussion above.
The following are the required components of the Housing Element:
A. Housing Needs Assessment
• Analysis of population trends in Tustin in relation to regional trends
• Analysis of employment trends in Tustin in relation to regional trends
• Projection and quantification of Tustin's existing and projected housing needs for
all income groups
• Analysis and documentation of Tustin's housing characteristics including the
following:
a. Level of housing cost compafed to ability to pay
b. Overcrowding
c. Housing stock condition
• An inventory of land suitable for residential development including vacant sites
and redevelopment potentials; and relation of zoning, public facilities and
services to these sites
• Analysis of existing and potential governmental constraints upon the
maintenance, improvement, or development of housing for all income levels
• Analysis of special housing need: disabled, elderly, large families, female-
headed households, farm workers
• Analysis concerning the needs of homeless individuals and families in Tustin
Planning Commission Report
Regional Housing Needs Assessment
Housing Element Update
May 22, 2007
Page 4
• Analysis of opportunities for energy conservation with respect to residential
development
B. Goals and Policies
• Identification of Tustin's goals, quantified objectives and policies relative to
maintenance, improvement, and development of housing including:
a. Housing supply/housing opportunities
b. Maintenance and conservation
c. Environmental Sensitivity
d. Housing Element Implementation Program
e. Five year quantified objectives 2008-2013
f. Identify affordable housing resources
g. Housing programs
C. Implementation Programs
• Identify adequate sites which will be made available through appropriate action
with required public services and facilities for a variety of housing types for all
income levels
• Assist in the development of adequate housing to meet the needs of low and
moderate income households
• Identify and when appropriate and possible remove governmental constraints to
the maintenance, improvement, and development of housing
• Conserve and improve the condition of the existing and affordable housing stock
• Promote housing opportunities for all persons
• Identify programs to address the potential conservation of assisted housing
developments to market rate units
The Tustin Housing Element also includes the identification of strategies and programs
that focus on:
• Housing affordability
• Rehabilitating substandard housing
• Meeting the existing demand for new housing
• Conserving the existing affordable housing stock
The City is required to complete and obtain approval of the Housing Element from the
State Department of Housing and Community Development for review by June 30, 2008.
Staff has recently prepared a Request for Proposal (RFP) to contract a consultant for
preparing the City's 2008 to 2013 Housing Element.
Planning Commission Report
Regional Housing Needs Assessment
Housing Element Update
May 22, 2007
Page 5
Preparation of the Housing Element is anticipated to follow the following schedule:
Receipt of Proposals
Consultant Interviews
Consultant Selection/Award of Contract
Begin Contract
Review Screencheck
Submit to HCD
Adoption by City Council
HCD Certification
June 21, 2007
early July, 2007
late July, 2007
August, 2007
November, 2007
February, 2008
April, 2008
June 30, 2008
~~o-t~
Scott Reekstin
Senior Planner
~~~ ~~ o~.~~~-~iG~
Elizabeth A. Binsack
Director of Community Development
Attachments:
~~
Minoo Ashabi
Associate Planner
A -Regional Housing Needs Assessment Pilot Program FAQ
B -Correspondence (Letters from the City of Tustin to SCAG dated June 15, 2006; July 6,
2006; July 17, 2006; August 15, 2006; November 27, 2006; December 11, 2006;
January 11, 2007; Letters from SCAG to the City of Tustin dated January 11, 2007;
February 9, 2007; City of Tustin to SCAG dated March 15, 2007)
C - Draft RHNA, dated November 2, 2006
D - Appeal/revision request and SCAG staff report
S:\Cdd\PCREPORT2007\RHNA HE Update May 2007 .doc
ATTACHMENT A
Regional Housing Needs Assessment
Pilot Program FAQ
State law requires that jurisdictions provide their
"fair share" of regional housing needs. Local
governments and Councils of Government
(COGs) are charged with determining existing
and future need, together with the California
Department of Housing and Community Devel-
opment. SCAG prepares the Regional Housing
Needs Assessment (RHNA) for the six-county
territory it represents. The last assessment covered
the period January 1998 through June 2005.
The SCAG Regional
Council approved a
Pilot Program that
would modify existing
law and streamline
the RHNA process.
7. When Is the
next RHNA due
and what period
will it cover?
It is due June 30, 2007,
covering the period 2008 through 2014.
2 What about housing that has
been built since the end of the last
RHNA cy~de? Wlll cities be ~credited~
for housing built between the last
cycle and the start of the new one?
Yes, local jurisdictions wiN be able to take "credits'
for actual construction activvities in the 3-year
gap period (2005-2008) that are above the
growth forecasted far that period, and- apply
those credits to the housing needs forecasted
for the period between 2008 and 2014.
3. Haw can cities that are built-out
be required to provide more housing
when land is not available? There is
little support for rezoning vital
commerciaUlndustrial lands deemed
critical to continued economic viabilityl,
Cities are responsible for creating opportunities to
meet their housing needs. There are various tools
to meet these requirements, including, but not
limited to, the conversion of
existing units or rezoning.
4r How will an
over~concentration of
low-income housing
be avoided?
Neither existing law nor the
Pilot Program allow the fur-
therconcentration of lower
income households in
jurisdictions that house
more than their "fair share.° The Regionat Council
will establish a policy to decrease new allocated
housing need in areas that already have a high
concentration.
5. X11 the process allow the use
of local zoning and land ordinances
as the basis of local input? Combining
housing and transportafilon forecasts
seems to place restrictions on local
jurisdictions.
Transportation, housing, and employment
forecasts for the future rely heavily on local
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
23
6. Why are urine tying the RHNA
process together with the RTP
process? RH1VA is a needs-based
program while the RTP is land-use
based.
The Pilot Program ensures an integrated long-
range growth forecast. It links together hous-
ing, transportation, and air quality planning,
allowing jurisdictions to plan for transportation
and housing simultaneously and plan more
efficiently for future growth. Past practices in
which cities created one forecast for transpor-
tation and one for housing will be avoided.
7. Does tits integrated approach
far our 2007 growth forecast process
change the Compass Blueprint from
a voluntary program to a mandatory
one?
No, it is a regional policy that. the Compass
Program remains a voluntary program. ; `
Implementation of the Compass Blueprint
focuses on providing planning tools and
consulting services to local governments that
voluntarily apply for assistance. The services
offered are aimed at assisting cities and
counties implement local plans and policies
that are consistent with regional goals.
August 2006
The Commission on State Mandates has ruled
that COGs are not eligible to seek reimbursement.
Attempts to pass a state budget appropriation have
failed, although efforts are still underway to receive
some form of state funding in addition to California
Blueprint funds.
Federal transportation funds can only be used
for the growth forecast portion of the process.
To finance funding shortfalls, SCAG can
access its General Fund and/or assess fees.
SCAG's Regional Council is opposed to a fee
assessment.
9. Why does the Pilot Program
seek to limit the RHNA appeals
process to one appeaYl
The Pilot Program includes a streamlined appeals
process that is better suited to a complex multi-
county region than the existing state law. The
existing law permitted an endless round of
appeals in which jurisdictions would be unable
to complete their housing requirements in time.
Permitting only one round of appeals allows for a
comprehensive regional review of appeals based
on the AB 2158 factors and allows jurisdictions to
progress towards their housing goals in a
streamlined and efficient manner.
for more information contact soumcrtiv ca.aatxw
Joe Carreras
Program Manager
818 West 7th St. 12th Fi.
Los Angeles, CA 9001?
213-236-1856
carreras@scag.ca.gov AssOCiAnOM of
GOVEttNMBNTS
~4
planning as expressed in General Plans, 8. How wlill the vlnDrk to complete
Capital Improvement Programs, and actual the ~~ prOCeSS ~ ~~~
growth trends in the city, county, and region.
ATTACHMENT B
Correspondence
C~ice of the City Council
June 15, 2008
Rk:hard Dixon, Vice Chairperson
RegionaVSubrepbnal Relations Task Force
Soulhem California Associaton of Governrnenb
818 W. 7th Street, 12th floor
Loa Anpebs, CA 90017
300 Centennial Way
Tustin, CA 92780
www.tustirK;a.org
(714) 573-3010
FAX (714)836-1602
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) PILOT DO1° ~
PROGRAM.
Dear tJt. Dbton:
On behaN d,the City of Tustin, I wish to express our concerns regarding the
Regbrisl Housing Needs Assessment Plot Program proposed by Ilse Stwthem
Calttorrtia Association of Govemmerna. N approved through State lepislatbn, tltis
pool Program would implement several signHicarn reviskms to the existing
Regbnal Housing Needs Assessment Program for the SCAG repbn and would
allocate the devebpntern of housing to SCAG Compass Blueprlrn 2% Strategy
Arena.
The CNy of Tustin b not opposed to Improving the Regbnsl Housing Needs
Assessment process; However, we are opposed to the foNowinp aspects of 111e
proposed pilot program:
1 • The program reduces local land use control,
Rather than being based on bcal Input, the RHNA numbers would bs
based an SCAG'e 2% Strategy. which was understood to' be voluntary
and was not adopted by bcel jurtsdictbns.~ In addition, the program that
is currerny proposed does not aNow appeals.
2. The program Ices fhe RHNA wRh the RTP (Regbnai Transportation Plan)
and. hence. the OCP (Orange County projections).
Tying the RHNA wNh the RTP and OCP M problematic because
jurisdicibns may underestimate housing, popufatbn, and empbymertt
projections N those projections wIN be used for regbnal housing needs
purposes. RHNA is a needs based program, while the RTP and OCP are
land•use based. This fundamental difference underscores the need to
keep the processes separate.
City of Tustin
Tncp walyr NpM
~rgor rre Tow
la 9aiv
c~na~.,
Taryr Kaw~sNmw
CourKrmemp~,
~«.r Amos.
tinatneme.r
274
Richard Dlxon,lACe Chairperson
RegionaVSubregional Relations Task Force
June 15,2006
Page 2
3. Theprogram requires jurisdictions to plan fora 20-year housing supply and zone for a
10-year housing supplyA pfaming horizon o1 ten or twenty years is ideal for general
plann(ng purpos s but does not provide for market or demographk; shtRs over the long
term which wou~ strongly influence the RHNA process. Furthermore. the general plan
and zoning era required to be consistent pursuant to State law. It is unclear es to taw
this can be reconcled with the proposed program.
4. The program may increase RHNA allocations to cities with large 2~G strategy areas.
Tire proposed pAot program may piece an unfair burden on devebpad dues with tranaR
cantata and corridors because RHNA ntxrrbets would be albcated withh 2% strategy
areas. Ttw SCAB 2% strategy proposes to cxmcsntrals re~lonal growth within inf•
areas to around metro centers; dty callers. rail trarwit stops. bus rapid transR corridors.
airports, ports. irxiustrlal centers. and priority residential k-dpl areas.
5. lTh~e pater ~ Is undear about the details pertaining 1o trades and transfers among
The trading and transferring of RHNA allocations among jurisdidions would be
permitted, but the administration and allowable trequency o1 these trades ie not specified
in the pikrt program. Furthermore, the prohibition of trades among subregions
contradida the regbnal growth visbning process.
For these reasons, we oppose the RHNA PNd Program aa•~ is cuneMy proposed. H you have
any questions, please cooled ms or Elizabeth Binsadc, Community Devebpmerd Director, at
(714) 573-3031.
ti~'KMy~
ib Davert
Mayor
cc: Tustin City CouncB
Orange County Courrcq of Governments
Mark Plsano
275
J~~,r6.~06 City of Tustin
3n0 Centennial `Nay
The Honorable Yvonne B. Burke, President Tustin. CA 92780
Sotrthem California Associatbn of Governments cvww.tustinca.orcJ
818 W. 7* Street, 12° ibor ;;tar 573.3010
Los Angeles, CA 90017 FAX Iota) 838-tfi02
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT PILOT PROGRAM
Dear President Burke: oa.p o„~„
rdror
On behaq of the Cky of Tustin, i wish to express our concerns regarding the T"`~' w«"r ~
Regional Housing Needs Assessrnera Pilot Program proposed by the Southern °i1iyOf hoTem
CaMomia Association of Govemrnertts. N approved through State legislation, this ~ eAn.
Allot program would knplemeM several signilicark revisbns to the existing CO1"0*"'"'~•~
Regbnai Housing Needs Assessment Program for the SCAG region and would ronr Kaww.ti,,,.
~b~te the devebpment of housing to SCAG Compass Blueprint 2•A. Strategy ~,o.~
The Cky of Tustin first provided comments to SCAG r co„nn~""'"O"
Program in a kilter dated June 15, 2006 ear ~ the Proposed Pitt
R bnatlSub ( ~). to the SLAG
eg regbnal Relatbns Task Force. Although SCAG stall provided
written responses to our oontmerrta, the responses were somewhat vague, and in
some cases, misleading.
The City d Tustin is not opposed to improving the Regbrtal Housing Needs
Assessment process. Hewever, we are opposed to the tollowirg aspects of 1M
Proposed Pitt prograrrr:
1. The program reduces local Iand use control.
Rather then being based on bcal Input, the RHNA numbers would be
based on SCAG's 2•,f. Strategy. SCAG staff has acknowledged that the
2'K Strategy is a vokrrttary Program, but continues to recommend that the
RHNA Pibt Progrem bs Ynlced to the Strategy.
2. The program ties the RHNA with the RTP (Regional Transportation Pian)
and, hence, the OCP (Orange County Projections),
Tying the RHNA with the RTP and OCP is problematic because
jurisdictions may underestimate housing, population, and empbyment
projecibns it those projecfions wig be used for regional housing needs
purposes. RHNA is a needs-based program, while the RTP and OCP are
land-use based. This fundamental difference underscores the need to
keep the processes separate.
272
Yvonne B. Burke, President
Juy s, Zoos
Page 2
3. The program requires jurisdictions to plan fora 20-year housing supply and zone for a
10-year housing suppy.
A planning horizon of ten or twenty years is ideal for general planning purposes but does
not provkfe for market or demographk shifts over the long term which would strongly
influence the RHNA process. Furthem~ore, the general plan and zoning are required 14
be consistent pursuant to State law. K is unclear as to how this can be rec~ncAed with
the proposed program.
4. The program may Increase RHNA aAocations to cities with large 2°Y. strategy areas
The proposed pibt program may place an uMair burden on developed cities with transit
tamers and corridors because. RHNA numbers would be allocated wkhin 2'K strategy
areas. The SCAG 2% strategy proposes to ooncerwate regional grawlh wkhin IrMN
areas in around metro cerMers, city camera, raN transk stops, bus rapid transk corridors,
airports, ports, induetrlal cerrtera, and priority residential In-fAl erase.
5. The program is unclear about the details pertaining to trades and transfers artang
jurisdictions.
Ths trading and transferring of RHNA allocations among jurisdictlons is perrNtted by
existing law, but the administration and akowable lrequerwy of these trades should be
specNied in the pill program. Furtherrrwre, the prohibition d trades anwng subregions
coMradids the regional growth visioning process
For these reasons, we oppose the RHNA PAot Program as k is currently proposed. H you have
any questions. please contact me or Elizabeth Binsack, Coriurxrnity Developmerrt Director. at
(714) 573-3031. '
Mayor
ca t~(3ommuNty, Economic 6 Human Development Committee
Tustin Cky Coundl
Orange County CounGl of Governments
WAliam A Huston
Doug Hdland
Elzabeth A. Binsack
Scott Reekstin
Ariachmerri: June 15, 2006 Letter
a ~coaow~.~n-u rua Ropam twr a aG6 RC.doe
273
-' . .i t J .
~'! ~, rtil 1
July 17.3006
.. :.. -.
The Nonurabk~ Yvonrn• B. Burke, President
Southern California Association of Governments
8l8 W. 7'a Sucet, 12'" floor
L.os Angeles, CA 90017
~~'
..nM.
SUBJECT: ItECIONAI. HOL'SiNG NEEDS ASSESSA~VT P1LOT '•~r ''! r,. - ~.~:
1)carPresidcnt Burke: ; _ ,::,;':~."
On behalf. of the City of Tustin. 1 wish ro expn.•wt raa canccrna regarding the ~ °,
Southern California Aseoriatiun of Governments (SCAG) Proposed Regiotal .
Hcxtsing N~~cJs Assessment (RHNA) Pilot Project Language that SCAG publicly
n:lcascd on July 13, 3086 (anachod).
The City of Tustin has provided comments to SCAG rcgartfing the proposed Pilot
Project in letter dated June l6, 2006, and July 6, 3006 (attached), Because the
July 12, 3006, rcvisinns do not address our concerns, the comments contained in
(hose two letter still apply.
Aa we have stated previously, the City of 'Tustin is rat opposed to improving the
Regional Housing Needs Assessment process. However, we remain particularly
opposed to the proposed use of SCAG': 29tr Strategy as a basis for the allocation
of RHNA numbest, and the proposed limit of are appeal per jurisdiction,
'fherrforc, we recommend that the words "and other strategic" be de'Ictcd fmm
Section 65584.02.5(e) of the proposed language. We also urge SCAG to revise
thr pmposed language such thrt appeals may be filed relating to any adjustments
made pursuant to subdivision Ig) of Government Cade Section 65584.05.
If these recnmmentled changes are not made, cities with large 276 Strategy Areas
will receive a disprupunionrte RHNA alla:ation and may underestimate housing,
populati~m, and rmpbymcnt numbers used in xubrcgional projections to offset the
impact of the 276 Strategy. Cities could also receive allocatians that could not be
appealed.
270
The Honorable Yvonne B. Burke, President
Southern California Association of Governments
Juiy 17, 2~
Page Two
For these reasons, we oppose the proposed July 12, 2006, language for the RHNA Pilot Project.
if you have any questions, please contact me or Elizabeth Binsack, Community Development
Director, :u (714) 573-3031.
sincerely,
i
Dou aver-
May
cc Mark Pisarw, SCA(3
Tustin Ciry Council
Orange County Council of Governments
William A. Huston
Doug Holland
Elizabeth A. Binsack
Scott Reekatin .
Attachment:: SCAG Proposed RHNA Pilot Project Language
July 6, 2006 Letter, '
June 15, 2006 Letter
a:~CDbrenM~sl4aVtNNA Pib~ lio0ew I~ur 3 b aC.AUdoe
271
,.
.~
August 15, 2006 • = ~ . ~ _ .. •
The Honorable Yvonne B. Burke, President
Southern Calfornia Association of Governments
818 W. 7r' Street, 12"' floor
Los Angeles, CA 90017
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT PILOT
PROJECT :. ~.,,:
:. .
Dear Preskierri Burke: •~: ~~:•t. - •<r,.,
On behalf of the Cpy of Tustin, 1 wish to express our concerns regarding. ~ .~""
the Southern California Association d Govemmenta (SCAG) Proposed
Regional Housing Needs Assessment (RHNA) Pilot Project Language that
SCAG pubpcy released on August 3, 200!3 (ariached). '"
The City of Tustin has provided comments to SCAG regarding the ~ .•
proposed Pilot Project in leriers dated June 18, 2006, Juy 6, 2008, and
Juy 17, 2008 (attached). Because tl~e August 3, 2008, revisions do not
address all of our previous concerns, some of the comments contained in
those three letters slip appy.
As vae have stated previously, the City of Tustin is particutary opposed to
tying the RHNA with the Regional Transportation Plan (RTP) and pmttirq
the number of appeals to one appeal per jurisdiction.
Therefore, we recommend that SCAG revise the proposed language such
that the .RTP and regional demographic projections are kept separate trom
the RHNA process and such that appeals may be tiled relating to any
adjustments made pursuant to subdivision (g) of Government Code
Section 65584.05. The revisions to proposed .Section 65584.02.5(8)
should include the removal of the reference to consistency with the
Regional Transportation Plan and an explanation of the objective criteria
to be used to determine the Housing Need Allocation Plans' consistency
with the objectives of the proposed Section 65584.02.5.
If these recommended changes are not made, cities may underestimate
housing,. populaCbn, and employment numbers used iri subregional
projections to offset the impact on the RHNA allocation. Cities could also
receive allocations that could not be appealed.
268
The Honorable Yvonne B. Burke, President
Southern Cafrfornia Association of Governments
August 15, 2006
Page Two
The City of Tustin is also concerned about the severe time constraints associated with
participating in the housing allocation process and preparing fts~ housing element by the
current June 30, 2008, deadline. We request that SCAG propose a two-year extension
of the housing element deadline to June 30.2010.
For these reasons, we oppose the proposed August 3, 2006, language for the RHNA
Pilot Project and urge that amendments be incorporated into the proposed language. H
you have any . questans, please contact me or Elizabeth Binsadc, Community
Development Director, at (714) 573-3031.
Mark Pisano, SLAG
Tustin City CouncY
Orange County Counc~'1 of Governments
William A. Huston
Doug Holland
Elizabeth A. Binsadr
Scott Reeksttn
Attadtments: SCAG Proposed RHNA Pilot Project Language
July 17.2006, Letter
Juy 6.2006. Letter
June 15, 2006, Letter
8:~toones~ns,ww,,vM.r-Mr.~o,..~.o,. asc~..s
269
November 27, 2006
•~; _;1
The Honorable Yvonne B. Burke, President
Southern Calflomia Association of Govemments
818 W. 7~ Street; 12° floor
Los Angeles, CA 90017
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT
METHODOLOt3Y
4
Dear President Burke:
On behalf of the City of Tustin, 1 wish to express our concerns regarding
the Southem Califomia Association of Governments (SCAG) Proposed
Regional Housing Needs Assessment (RHNA) Methodology as K pertains
to replacement housing need.
:,.;
~~ x;.r;t.,..,,,~,
'Mn~r .a•o "a.r
. L' SYA
.. '
According to the draft Regional Housing Needs Assessment methodology
and numbers released by SCAG on November 2, 2008, the Cily of Tustin
has been assigned a draft replacement need of 1,067 housing units. TMs
number equals the number of housing units demolished in the City of
Tustin from 1997-2005 and includes 985 military housing units that have
been demolished at the closed Marine Corps Air Station Tustin.
The 985 military housing units were vacated over a period of time, with
527 units vacant in January t998 and aU of the units vacant as of base
cbsure on July 1, 1999. The 985 military housing units were later
demolished, and the demolitions were reported to the California
Department of Flnance.
In the last RHNA cycle, the 985 military housing units were inappropriately
counted as vacant units. Although the C8y of Tustin was assured by
SCAG staff that the vacancy rate would be adjusted, our only option was
to appeal the vacancy rate determination and the appeal was repeatedly
denied by SCAG. Afterward, SCAG staff acknowledged that the higher
vacancy rate was erroneously included and that the number wo41d be
remed'~ed; however, the correction never came to fruition.
The 985 demolished military housing units should not be included in the
cak:uiaiion of replacement need in the current RHNA cycle, but should be
given special consideration by SCAG because these units were available
266
The Honorable Yvonne B. Burke, President
November 27, 2006
Page 2
only to military personnel and their famil'les and were never available for occupancy by
the general public and theretore were not a part d the City's general housing market. In
tact, pursuant to ttte MCAS Tustin Redevelopment Plan which was adopted through
Ordinance No. 1276 by the Tustin City Council on June 16, 2003,1he mlitary housing
units at MCAS Tustin are not subject to the replacement housing requirements per the
California Health and Safety Code Section 33413 et seq. Since the adopted
Redevelopment Plan recognizes these units as unique and the Redevelopment Plan
was based on Stets law, SCAG should also recognize these special circumstances.
Based on this sound reasoning, we urge .SCAG to adjust the replacement needs
methodology aocordngly for military housing units and to not defer file consideration •d
this matter to the RHNA appeals process. Furthermore, we ask SCAG to provide the
actual axurate RHNA numbers to jurisdictions prior to any approval action on the
RHNA methodology. The distribution d the actual assigned numbers wig enable eaci~
jurisdiction to properly assess the impact of the methodology on their corrxrwnity.
As currently proposed, the RHNA methodok>gy~ assigns a disproportitxoata housing
need to Tustin as h relates to replacement housing. This disproportion should be
eliminated and not distributed to other jurisdictions in the region.
if you have any questions regarding our comments, please contact me or Egzabeth
Binsack, Community Development Director, at (714) 573-3031.
Si erey,
Doug rt
Mayor
ca Mark Pisano, SCAG
Ma'Ayn Johnson, SCAB
Tustin City Cour>cY
Orange County CouncY d Governments
W~Qam A. Huston
Doug Holland
ENzabeth A. Binsadc
Justine WMkom
Scori Aeekstin
267
..
,~,,_. , .
• ~t.:~. ..Jl.
,_ ~ ~_ _ ~• HIG.
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t~ity ~~f T+~stin
:ctw t:~nwauu:N Vl:ry
fu::un LA 9X7:!6
December 11, 2006 ~ la.y''~.~ pl
r'nx 7t.+.F~a.~strz
Hasan Iklvate, Director f.au Bawr
t,v,y,x
Planning and Potlry DepaAment
Soutltem Catiftxnia Association d Governments ~ ""t' "
818 W. 7w Street, 12~'tl0or tAaya trio Tan
Los Angeles, CA 90017 p~ Davarl
Cotrw,a161snrfror
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT METHODOLOGY
T,,,,t, K,.r;,t,~~
Dear Alr.~lbm~elta: Cumx3 6Aambrr'
'
At the Orange County Courrcll d Governments Board d Diedors meeting on ~ JknP.atmur'
~'`~'~""~ t'r'""~"
November 18, 2008, we disalssed the Regional Ftousktg Needs Assessment
~+h~oOY~ Dur+rq our conversation, you indk~ted that you would ensure
that the demolished military tausk>tg unit at former MCAg, Tustin an not
inducted in tl~e calculatbn d replacement housing need for the City d Tttstlrt.
Our reasons supporting the removal d the 98.5 demdished military houak~g
ur>its horn the replacement need cakulatton wen provided h a feller from '
former Tustin Mayor Doug Davert to Southern CalKomis Association d
Govemmenis (SCAG) President Yvonne Burka dated November 27, 2008
and •
,
can be summarized as togows:
• The 98S demolished n4litary houskg units 'wen avagable oNy. to
rnilriary persomd and thstr famiYes .and wen never ava8abie for
occupancy by the penxal publk and ihenfora were not a part d the
'
Cify
s general housing maAutl.
Pursuant b the MCAS Tustin Redevebpment Plan adopted by the
TusBn City Councq, the military housing units at MCAS Tustin are not
subject to fhe replacenent housing requirements per the CalNomis
HeaHh and Safely Code Section 33413 d seq. Since the adopted
Redevelopment Plan recognizes these units as unique and the
Redevelopment Plan was based on State law, SCAG should also
recognae these spedal dreumstances.
We specifically request that for the above reasons, SCAG adjust the draA
replacement need accordingly and provide a footnote in aN written SCAG
publications containing the replacement need numbers that demolished miitary
units shall not be included in the replacement need calculation. 1 would greatly
appreaate a written response tram you that Iha aforementioned wtll txcta' prior
to•the next Regional Courx~7 meeting.
264
Hasan Iktuata, Director
Planning and PoCuy Department
Southern CaGtornia Association d Governments
December 11, 2008
Pags 2
H you have any questions regarding this mafter, please contact me or Eizabeth Binsadc,
Community Development Director, at (714) 573-3031.
Sincerely,
_..'" , .
,. .
Lail Born
Mayor
ce: Mark Ptsano, SCA(3
Ma'Ayn Jotwtson, SCAG
Tustti City Council
orarpa County Coundl of Govertrnerrb
Wlllarn A: Huston
Dap Holland
Elzabeth A. einsadr
Justtr-a WIIMrom
Scott Reekstln
265
•_ -. ;,
January 11, 2007 _ 1 , ~ : ~ ' •:
,,
The Honorrble Yvonne B. Burke, president
Southern California Association of Governments
818 W. 7° Street, 12° floor
Los Angeles, CA 90017 _
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT
METHODOLOGY
Dear President Bnnc~ .. _ : ,~,2
. : ,.
On behalf of the City of Tustin, I wish to esprcas s significant cotteern we have regarding the ' ", :'^ "''':
Southern Glifomia Associatioa of Governmetrt: (SCA(;) proposed.Regionat Housing Needs ~` -~, N°
Assessarem (RHNA) Methodology. . ; ., ~..-
It is our understanding .that the drrfl RHNA allaestions for nine (9)' Orange County cities,
including Tustin, have been proposed to be increased because the numbers of housing units that. ~ • • • ..
arc projected to be eonctructed in those cities exceed the September 2006 dtaR RHNA -
allocatiorts. r , ,
.. ..•. .
This unjurii~abk substantial increase in the Ciry's RHNA allocation will place an undue
burden on the City of Tustin as additions! resources and incentives would be required to enabk
developers to feasibly construct the additional housing units in the very low, low, and moderate
income categories.
The City of Tustin urges the Southern Glitamia Association of Govemmertts to eonsidv an
altemarive methodobgy whereby cities that project significant housing growth arc not required
to provide more bowing is the very bw, low, and moderate income categories thw would be
required by the California Depsttrneat of Housing sad Community Devebpmgnt based an
regional housing need. As currently proposed, the RI~IA ,methodology would assign a
disp-opptiatmte atfordabk housing need to Tustin that should be diatinated. .
if you have any queatiorts regarding our cotruitents, please cornea rrc or Eli?abetlt.Birtsack.
Community Development Director, at (714)573-3031.
074.
L.ou Bone
Mayor
e J,tark Pisano. SCAG
Ms'Apt Johnson. SCAG
Tootles Ciry Council
Orange County Council of GOrttnmeMt
Wil6aot A. Hustm
Doug Hoaatd
Elizabeth A. Blmack
Jmtim Willkom
StptReekuin
263
SOUTHERN CALIFORNIA
ASSOCIATION of January 11, 2007
GOVERNMENTS
Main OMce
818 West Seventh Street Hon. Lou Bone, Mayor
City of Tustin
uth Floor 300 Centennial Way
Los Angeles. CaPfornfa Tustin, CA 92780
90017.3435
' a""361°0D In accordance with State law and cr the r uest of the Ci of Tustin and the
1uul~a~-,us ~ P aq tY
Orange County Council of Governments (OCCOG), the Southern California
,~„~,,,~,~, Association of Governments (SCAG) agrees to remove the replacement units
associated with demolition of military housing from the final Rl•INA
,'"',,,~;,,,~ "^"~°~~.~ construction need calculation for the City of Tustin. This action reflects the
s.'a.airiGw-•slaieWalwrale loss of the military base housing due t0 the close of the Tustin Marine Corps
4N1+ el.i, lAr cart . Iraleyr cal
-allaal~,wwal,l.,llw.,., Air Station and its change of land use.
~ u..i~ area rotor, r...l
rr.xy.,wrerrlar...
,~~, ~ Please feel fret to call me or Joseph Caaeras, RHNA Program manager, at
~~~ ~~~ 213-236-1856 if you have further questions.
,dl tay111t I.,w .,rlr Grra w
~ . soi awn u lrl,. wyw .
aayar cwt. IraaaN~: Gw Irlak
~ ~rtar.w.1~r,,,,~ w~a
• WrY 41L brwj • tlk saran la
MPw • Way' Gal lu Aryan . Hal
~~~ wW~~; Sincerely,
r~ayrw~.lael ~~ ~w
,aav • M /talra,,nlo Rolla • Ala
IAr, lw Anplu . IoW -+IIL lw --~~It1
Grb Y ArNIM, i~ir M~Iin~iq l!_J~V" _\.\/1 -
1aA1.4Frgrb•kaSpn,W,Ya•Iti - .
lmlrly,aalrr.Millgr, pMlw7
~ ~ c wM ~ ~ w Hasan Ikhrata, Director
al,.w . xa,,. Waar. t r. r.Mla . Planning and Policy Department ~ -
~~'`"~" SCAG -
aw•lrr{re, haYl.4l UeaRMY1M
•~Ww.AWrM•hWrfW. ~ .. .
Haltlnpia InrA . leie Dil/R Maryal ,
lyMa R•~ Wagli4 iaea•/a14w1,
t^a~e~M'+~,lalt NalNeraiq
IMrIDI tath7L liY f4lrrlr • Irlaa
1&tlnln Maur auy . 4r. lwnMtr.
-rlr Gtlwrd rM . ~
,M MI..rNa. (rNlf ~- UaMI sill r:c:
nl+t~+.,ra:"llaw.l~..r..c.n,'w`c.r Lynn Harris, Manager of Community Development
Fwa•Rr1w111.saarlll~Wl,r.~ Frank Wen
~Illllw•oriatlllAaaal,arlr ,Growth Forecasting Program Manager
'"0n11pn"~0"i"i Joseph Can•eras, RHNA Program
.~ ~ w~w aalriw~.,,
lw~(mo,f~wryy ~rNYa
GwaYY~IW+I~
r 4rngr,riryl Doc#131036v1
i''aaa4A1is~ 1/16/2007
ItNI,
262
SOUTHERN (:ALIFORNIA
ASSOCIATION Of
GOVERNMENTS
Main Offiu
818 West Seventh Street
12d1 Floor
Los AngeU!s, CaUfomA
90017-3435
t(213)236.1800
E u1]) 236•IEtIS
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14M-
February 9, 2007
Honorable Lou Bone
Mayor
City of Tustin
300 Centennial Way
Tustin, CA 92780
RE: Tustin's letters of November 27 and December 11, 2006; Distribution
of Draft Regional Housing Need Assessment Allocation Pian for 2006-
2014
Dear Hon. Lou Bone:
Thank you for your written comments on the Southern California
Association of Governments' (SCAG) ongoing Regional Housing Needs
Assessment (RHNA) and Integrated Growth Forecast planning processes.
Please be advised that the SCAG Regional Council approved, on
February 1, 2007, a final allocation methodology and Draft RHNA
Allocation Plan ('Plan"} for jurisdictions within the SCAG region for the
planning period of 2006-2014.
As you are aware, state housing law requires that SCAG prepare a
housing need allocation for each of the cities and counties in the region
based upon the State Department of Housing and Community
Development's (HCD) determination of regional housing need.. As its
household growth estimate is the starting point for the allocation, the
Integrated Growth Forecast supports this RHNA effort. Encbsed please
find a CD-ROM containing PDF files of the Plan. The Plan as well as a
description of the final allocation methodology are also available on
SCAG's RHNA webpage (http://scag.ca.gov/Housing/fina.htm).
SCAG has been accepting public comments on both the RHNA and
Integrated Growth Forecast for the past several months. Input from local
jurisdictions such as Tustin is a key element in the RHNA and forecasting
processes.
The comments in your city's November 27 and December 11 letters
concerning bcal factors affecting RHNA methodology have been
considered in the preparation of the draft RHNA allocation and Integrated
Growth Forecast. SCAG staff also worked closely with Orange County
Council of Governments (OCCOG), city and county planning directors and
managers, and the Center for Demographic Research (CDR) to evaluate
local input regarding regional housing need and methodology.
The CDR Orange County Projection 2006 (OCP06) was adopted by the
OCCOG Board of Directors on November 30, 2007, and reflected
collective input provided by individual jurisdictions. SCAG staff analyzed
the OCP06 and found it to be consistent with the Integrated Growth
Forecast. Thus, Tustin's allocation incorporates the local concerns
260
expressed by your jurisdiction. In addition, we met with speritically
impacted Orange County jurisdictions following the approval of the Draft
RHNA allocation plan on February 1 to discuss the issue of allocation by
income. We will continue to work with Tustin to resolve this issue and
ensure an appropriate resolution.
The RHNA allocat'wn is integral to the preparation of the Housing Element
of Tustin's General Plan. Please note that the Department of Housing and
Community Development (HCD), in a November 30, 2006 letter to SCAG
(available on SCAG's website), has determined that, "In updating their
housing elements, local governments may credit by applicable income
category housing units added since January 2006 'For further infom~ation
and guidance on how this applies to your jurisdiction's Housing Element,
contact HCD at 916-323-3177.
The ongoing RHNA process includes the following milestones:
February 1, 2007 Regional CouncA apprrnred Draft RHNA Allocation Plan,
February 15, 2007 Earffest date ~rkdictlorts may fAe revision requests
and/or appeals to the Draft RHNA Allocation plan.
March 16, 2007 Deadline for jurisdictions to file requests and/or appeals
to the Draft RHNA Allocation Plan.
June 7, 2007 SCAG issues a proposed Final RHNA Allocation Plan.
July 5, 2007 PubAc hearing to adopt the Final RHNA Allocation Plan
and submittal to hICD.
June 30, 2006 Statutory deadAne for jurisdictions within SCAG region to
submit updated Housing El~rteMs to HCD.
Thank ytiu for your partiapation in this important endeavor. Please visit
SCAG's RHNA website (http://scag.ca.govMousing/rhna.htm) or feel free
to contact Regional Planner Ma'Ayn Johnson at 213-236-1975 or Joe
Cameras, RHNA Program Manager at 213-236-1856 if you have any
questions
Sincerey,
Joe Cameras
RHNA Program Manager
AttaGrnenC CAROM ~. Draft Regional Flouring Needs Assessment ARocelion Plan
261
Office of the City Council
March 15, 2007
The Honorable Yvonne B. Burke, President
Southern California Association d Goverrrnertts
818 VY. 7'" Street, 12'" floor
Los Angeles. CA 90017
SUBJECT: REGIONAL HOUSiWG NEEDS
REVISION REOUt'8T
City of Tustin
30o Centenrrial way
TustM, CA 92780
www.tust'xica.org
(714j.573.30t0
FAX (714) 838-1602
ASSESSMENT ApPEAU
Dear President Burk:
On behalf d tlts City d Tustln, I am submitting the attached Appeal and/or.
Revision Request far Mte Fourth Cyde d the. Regional Housing Needs
Assesarrtertt (RHNA).
The basis for this appeal is that SCAG fa8ed to delemtine tits Cily bf Tuattrt's
share d the regional housing need in accordance with Qte informalton described
in the established abcatlon rrtethodobgy.
The methodology requires that the RHNA be based on SCAG's Integrated
Growth Forecast, not on s subregional forecast However. it ie ots.
understanding that SLAG utigzed the Orange Cauny Projecfbns {OCP) 2008 as
the Integrated Growth Forecast for tits Orange County suttregbn and thersfans
did not fellow the methodology established and approved by SCACi tar ttte
RHNA.
1ou eon.
,iw/y Anrr~
bhya Pro Twn
~+o oov..t
ca!nN rr.mea
cony Knrntyn~
Cound rtarmer
Jlm Ppmor
coi..oa M~mbor
wttae the utNizattot- of OCP 2008 may bs very approprtaa ~~ regbnsl growth
forAcaat(rtg Purposes. t1s uae in ttte RHNA may have jeopardized the vaNdily of .
Cis entiro RHNA process because jurisdictions may haw urtdsrestlrrtabd their .
houstrtg, population, and employment Protections with Ste trrtderstandirp that
those,projectbrts also ttrould be used for regbnal housing needs purpoass.
The reauq d usirg OCP 2008 is that Orange County cobs that have protected
robust housing growltt have been arbitrarily assigned a relaWey higher
altocatton than cities that have projected little a no housing growth. Far
example, the City d Tust(n was assigned a RHNA rxrrrtbar d .3,344 t>atsing
units, whereas another Orange County cHy un'fh a sGglttly greater population Than
Tustin was assigned a RHIJA number d ony 39 housing tattle. The other utys
RHNA number is low because the albcation is based entirey on Its cortservatiye
protected housing growth from 2008 to 2014 rather than ob the projected housing
needs d the community, the availability d vacant land, or other factors
established in Ute SLAG methodology.
The RHNA number for the City d Tustin is the (rfllt largest in Orange County, gat
the City's population ranks fotateeMh in the County. Under the proposed RHNA,
258
Honorable Yvonne B. Burke, PresWeM
March 15, 2007
Page 2
the City d Tustin is being required to take more than ifs fair share of the regional
housing need solely because tt is accommodating a large share of the region's
houskg growth within our community. This requirem8nt is unfair and illogical
and should be remedied.
As evidenced by the attached letters dated between June 15, 2008, and January
11, 2007, the City d Tustin is fundamentally opposed to a RHtVA that is supply-
based rather than needs-tom and does not agree with a9 aspeds.d SCAG's
approved RHNA Methodobgy. .
During the development d the preliminary RHtVA, k appears that SCAG adhered
to its methodology when K assigned a prelfmhary RHNA rxunber b Tustln In
Septert~er d 2008. The CNy d Tustln disagreed with the appNcatlort d Uie
replsoemerrt need factor to demdishad mitllary housing units st former Marine
Corps Ak Station, Tustin, and in a letter dated January 11, 2007, received a
oonMnatlon trorn SCAG that the replacement unNs associated wltl~ the .
demolkion d rNlriary hons(ng woukt be removed from the final RHNA
constnrctlon need calwlatlon for, the pty d Tustln. Thus, SLAG fOpowed Ms
methodology, rectified the issue d replacement need for mBitary dousing units,
and then departed from this methodology when K applied OCP 2008 to the'
RHNA.
The Cdy d Tustln submits this appeal and/or revision iequest and asks for
reconskieration t>y the SCAG Appeals Board.
K you ha~ro any questions regardkg our appeaVreviskxi roquest, phase contact,
me ar Erizabeth Binsadc, CommunMy DevebpmeM Okodor, at p14) 573-3031.
Sincere ,
~~
Lou Bone
Mayor
cc: Mark Pisano, SCAG
Ma'Ayn Johnson, SCAG
Tustln City Coundl
Orange County Council d Govemmerns
William A. Huston
Doug Hdland
17izabeth A. Binsadr
Justlna Willkom
Scott Reekstln
Ariachments: Appeal request form
Letters dated between June 15, 2006 and January 11, 2007
S~Ri1NA eoo.r l.rr n lcwGeoc
259
ATTACHMENT C
Draft RHNA dated November 2, 2006
Attachment A: Analysis of Preliminary Regional Housing Needs (2005-2014) Based on RHNA Subcommittee
Reeommendatlons: Household Growth (2005-2014) + Replacement Needs (1897-2005) + Vacancy Needs
.`..
p
~U ~U U
COUNTY NEWSR
HoueMOld
OraMtt
CrtY (2008d0U) Total
Replacement
NeeM:
20052014 Owner
Vacaney
Rap
R3%)
Renal
Vannay
Rate (3%)
Cansw
Ovmenhlp
Rap (%)
Total
Vaeanry ,
Nestle "^W
Onnps Orergs County SeN BNdI dty 133 84 2.3% 5.0% 78.4% 16":1~.
Orange Orengs County Spnbn dty 1,425 12 23% 5.0% 48.9% 55 ~„~~
Orengs Onnpe County Twtln tlty 1,370 1,067 23% 5.0% 49.8% 93 3;
Onrpe Oange County VIBe park dty 27 2 2.3% 5.0% 97.1% 1 ,.~*
Orange Onrpe County Wealminspr dry 377 20 2.3% 5.0% 60.2% 14'
Orange Orerge County Yabe Untla tlty 1,594 52 2.3% 5.0% 84.7% 48
Omgs Oange County UnNCdporapd 24,148 235 2.3% 5.096 79.2% 721 ~" ~ ~ 1
RNersitle Weapm Rlvenitle Couneil G t9amlrq dty 2,528 67 2.3% 5.0% 72
0% r
82 t
Rlvareltla Weepm RNenlda Coundl OI Bwunrmt dty 7,221 22 2.3% 5.0% .
56
0% y
2877
RN
ld . ,
~
ere
e Wespm Rkrorslds Courual Oi Cadmeee dty 2,887 8 2.3% 5.0% 63.0% 77
••
Rlverelde Weetem RhrersWe Cound Q Canyon take dtY 242 1 2.3% 5.0% 88.1% 7,_
RlwraWe Wostsm Riverside Coundl G Corona dty 2,867 91 2.3% S.IYy. 87.5% 98
RlwraWe Western RWersWe Coundl Q Hemet dry 17,843 31 2.3% 5.0% 64.6% 80,9,.:
Rlversltle Weuem Rlvenltls Coundl OI Uke Elskrors dry 4,512 78 2.3% 5.0% 64.6% 155 `:
RNerekp Weatem Rivenitle Coundl G Moreno Valley dty 7,288 89 2.3% 5.0% 71.1% 238 3.~.
Rlvarekp Western RNenWe Coundl G MuMep dty 9,433 27 2.3% 5.0% 79.7% 279 i+); ~
Rlvarelde Western RNerelde Coundl Oi Norw dry 953 21 2.3% 5.0% 82.3% 25 ,_ s ~'.
Wvenltle Wespm RhronkN Coundl DI Palle dy 4,BBS 21 2.3% 5.0% 66.1% 751
Riverside Weepm Rlvanlde Coundl Ol Rlvenke dty 78,248 279 2.3% 5.0% 56.8% 597'x.
Rwerslds Wespm RNSnitle Coundl Oi San Jadnp dty 2,841 24 2.3% 5.0% 71.0% 88 ' .
RNendds Wsapm RNerslde Coundl Oi Tartlewla dty 4,503 14 2.3% 5.0% 73.4% 141 ~
Rlwreids Wespm RNenkp Councn Oi Unlnoorponted 47,715 292 2.3% S.0% 78.8% 1455'
Rlvenlde Coadlefla Valley Aseoclaton ~ Blythe dry 1,012 150 2.3% 5.0% Sfi.9% 42-,.
.
Rlverdds Coachage Valley Auodapn • Cathedral Gty dry 8,489 199 2.3% 5.0% 85.2% 225 ~
RNerelds Coaehe4 Valley Aseodeton ~ COaNre9a dty 1,888 18 2.3% 5.0% 60.9% 60
RNenlde Coadls0a Valley Assodatan ~ Desert ybt Spdrps dty 4,414 35 2.3% S.g96 47.2% 173
RNerokle Coachena Valley Assodalon • Intllan WNIs dty 552 14 2.3% 5.0% 88.8% 15'
Rlvarelde Cosd»ga Vansy Aaaoeleton ~ Indb dty 1,907 3 2.3% 5.0% 58.2% 178 .
Rlvenlds Coadtana Valley Atwtliaton ~ U Ouklfa dty 3,775 88 2.3% 5.0% 81.5% 94 f
,
Rivemkte Coacheda VaINy Afeodaton ~ palm Desert dry 4,500 55 2.3% 5.0% 85.9% 15/'~ e
Rlvenrlds CoachNh Valley betldattln • Palm Springs dty 2,099 28 2.3% 5.0% 60.8% 74 ~' x
Rlvendlk Coachella Valley Aaeodaton ~ Rands Mlregs dty 3,197 78 2.3% 5.0% 83.0% 93
Rlwrekle Coatlxlla Valley AasodNOn~ Urtlncaporated 9,899 87 2.3% 5.0% 78.8% 30267:., •
D:1gm1rtp071rhna071pptac 101906.x1s
November 2, 2006
CEHD Committee
Page 1- 6
ATTACHMENT D
Appeal/revision request and SCAG staff report
Fourth Cycle Regional Housing Needs Assessment Appeal Request
Date parch 15. 2007
Coun isuere ion Orange Count
ry N y ]odad;ction: City of Tustin
Conran: Elizabeth Binsack PnooeNiE,n.u: 714.573.3031/ebinsack[ltue+inca.org
APPEAL AUTHORIZED BY: PLEASE CIRCLE BELOW:
Name: loU Bone Citiet Clmir of
MaYut Admioiatrarive Gty County Other
Olfiea Manages Board of
BASFS FOR.APPSAL (County) S°~"~
® RHNA Methodobgy
^ AB 2158 FaeOors (Sa Govematew Code See. ~S5B4.tlA (d))
D Foisting err Protected lob-Houciug Balwce
^ Iafraswetate Coatrniap for Additional Development •
^ The Availabliity of Lard Snitabk fa Urban DevebPmenr a for t:opversion m Res&kadal Use
D Lards Protected from Llrbaa Developraertt uodv 8uiaiog Feded a State tarograras
. ^ Couoty Pdkies b Preserve Prins Agricnlaaal Load
O t>istribwbn of Howehdd Grosvtlr aoome for Purpoaea of Comparobk Regional Traoaporutioo Plow
^ Motet Qtmand fa tiapiag •
D County~q Agreemem b Direct Omwth toword Ineocpontod Arse of county
^ l.ws of Units Comaiord in Assisted Housio~ Developrneots
D I•B~b Howiog Cwt Badeea
^ Houriag Needs of Farm svwtma
^ Housing Needs Oeneroed by the Presence of a Udvenity Campw rvithia nay ]uiadietioe
^ ChangtdCbcnnutatteea
Brkt 1)aaipdoa d Appeal Regoed sad Desires Oatsono:
The basis for this appeal is that SCAG failed to determine the City of Tustin'ts share of the ~
regional housing need in aocordartce with Use established allocation methodology. t
The men-odology requires that the RHNA be based on SCAG's Inkgrated GrowUl Forecast, not
on a subregional forecast. However, SLAG utilized the Orange County Projections (OCP) 2008
as the Integrated Growth Forecast for the Orange County subregion and therefore did not fogovv
the methodobgy estal>fished and approved by SCAO for the RHNA.
Dtrttg the devebpment of the pregmktsry RHNA, t< appears tlrat SCAL3 adhered to b
trret-roddogy when k assigned a preliminary RHNA rrtttrcber b Tustin in September of 2006.
SCAG followed Ns methodology, rectified the issue of replaeemertt need for ndifary housing units,
and then departed hom this methodobgy when it applied OCP 2008 to the RHNA
Litt of Snpportlog Doeamentatlon, M Tltk sad Namber o< Pags:
t. Letters dated between June 15. 200tia and January 11, 2007
3.
a.
FOR S>',.
ONLY:
~ so6rana a.sosr.
r'"y ~ aatocwiosNCOreaarrMra~1C Hearing Date
i
t --
Planner
SLAG Document Reference N
Doer A 133967 r 1
257
TO: Regional Housing Needs Assessment Appeals Boazd
FROM: ~
Lynn Hams, Manager, Community Development, 213.236.1875, hams@scag.ca~ov
PREPARED BY: Rongsheng Luo, Senior Regional Planner Specialist, 213.236.1994, luo@scag.ca.gov
SUBJECT: Appeal from the City of Tustin
PLANNING & POLICY DIRECTOR'S APPROVAL: }tf--~
.. _v .~
RECOMMENDED ACTION (Please Select Oue):
^ APPROVE ^ PARTIALLY APPROVE
® DENY
SUMMARY OF REQUEST:
The City of Tustin states that SCAG's determination of the City's share of the regional housing need is based
on the Orange County Projections (OCP) 2006 and, as a result, is not consistent with the established allocation
methodology. The City also states that it does not agree with all aspects of the RHNA methodology as adopted
by the Regional Council The City submitted this appeal and asks for reconsideration by the SCAG Appeals
Board.
RATIQNALE FOR RECOMMENDED ACTION:
Staff recommends denial of the City of Tustin's appeal because SCAG did not fail to determine the City's share
of the regional housing need in accordance with the RHNA allocation methodology adopted by the Regional
Council.
2006 ~ cortsist~t with the esttablished RHNA allocation methodology because ii is consistent with the
,' vtrvrrall methodology of SCAG's Integrated Growth Forecasting methodology.
OCP 2006 was unanimously approved by the OCCOG Board including the Boatel Member representing the
City of Tustin on November 30, 2006. OCP 2006 and thus the Integrated Growth Forecast for Orange County
~ t~ollecttve '~ ~~~ by ~'~~ jutisdictiona and have incorporated local concerns
ejcpressed by its local jurisdictions including the City of Tustin.
BACKGROUND:
The City of Tustin has actively participated in the RHNA process and provided comments through multiple
letters to SCAG, meetings with SCAG, and the Orange County Subregional Workshop. SCAG has worked
closely with the City of Tustin directly or through OCCOG to address the City's concerns and issues. Most
notably,.~CpQ, ~ ~ nanove aY 985 replacement units associated with demolition ofmilitary-housing
Otte tD base closure From the final RHNA allocation for the City per the request of the City and OCCOG2. The
following is a brief summary of communications between the City of Tustin and SCAG.
' See attachment 1
_ See attachment 4
sourNCRS uuro~Nu
~lfOC1~T10M N ~mn~Ily~Mn 253
M 134225 v4 - Sta1T RHNA Appgl Re~rt . Ciry of Tustin
DATE: Apri126, 2007
The City of Tustin provided its first comments regarding the then proposed RHNA Pilot Program to SCAG in a
letter dated June 15, 2006. In that letter, the City expressed opposition to the following five aspects of the
Proposed RHNA pilot program: (1) The program reduces local land use control; (2) The program ties t:
RHNA with the Regional Transportation Plan (RTP) and, hence, the Orange County Projections (OCP); (3) The
program requires jurisdictions to plan fora 20-yeaz housing supply and zone fora 10-yeaz housing supply; (4)
The program may increase RHNA allocations to cities with large 2% strategy areas; and (5) The program is
uncleaz about the details pertaining to trades and transfers among jurisdictions.
In reaction to SCAG's written responses to its June 15 letter, the City of Tustin wrote a letter dated July 6, 2006
stating that the SCAG's responses were "somewhat vague, and in cases, misleading." In that letter, the City
restated its opposition to the same five aspects of the proposed RHNA Pilot Program as specified in its June 15
letter.
In response to the public release of SCAG Proposed RHNA Pilot Project Language on July 12, 2006, the City
of Tustin wrote a letter dated July 17, 2006. In that letter, the City reiterated its concerns as stated in its
previous two letters. The City particularly opposed to" the proposed use of SCAG's 2% Strategy as a basic for
the allocation of RHNA numbers" and "the proposed limit of one appeal per jurisdiction." Suggested changes
to the proposed language were recommended in the letter.
Upon the public release of SCAG Proposed RHNA Pilot Projxt Language on August 3, 2006, the City of
Tustin wrote a letter dated August 15, 2006. In that letter, the City stated that the August 3 revisions of the
Proposed RHNA Pilot Project Language had not addressed their previous concerns. The City emphasized its
opposition to tying the RHNA with the RTP and the one appeal limit. In addition, the City expressed its
concerns about the severe time constraints associated with participating in the RHNA process and preparing its
housing element by June 30, 2008 deadline.
The City of Tustin participated in the Orange County Subregional Workshop on November 7, 2006 and
provided RHNA related comments. Subsequently, the City of Tustin wrote a letter dated November 27, 2006
disputing the draft replacement need of 1,067 housing units in the draft RHNA methodology and number
released by SCAG on November 2, 2006. The City presented a brief history of the replacement housing units in
dispute and urged SCAG to delete these units from its RHNA allocation.
SCAG met and discussed with the City of Tustin regarding RFlT1A methodology at the Orange County Council
of Governments Board of Directors meeting on November 16, 2006.
As a follow-up to the November 16 meeting, the City of Tustin wrote a letter dated December 11, 2006. In that
letter, the City restated its reasons for the removal of the 985 demolished military housing units and requested
SCAG to adjust the draft replacement need accordingly.
,fin re~rp~se, SCAG issued a letter ~stted Jaauary 11, 2007 stating that SCAG agreed to ranove the replacement
'' -~tlits associated with demolition of mfiitary hotiautg from the final RHNA construction need calculation for the
City of Tustin.
In the letter dated January 11, 2007 to SCAG, the City of Tustin expressed concern about its understanding that
the draft RHNA allocations had been increased substantially for nine Orange County cities where the numbers
of housing units that are projected to be constructed exceed the September 2006 preliminary RHNA allocations
for those cities. The City urged SCAG to consider an alternative methodology to eliminate "disproportion
affordable housing need" that would be assigned to these cities including the City of Tustin.
fOUTMttM GLIfW1Ml~
AtfOt1A71011 N{DYttwYttTf
p134225 v4 - SFaR RHNA Appeal Report - Ciry of Tustin
i
t
2~
On February 1, 2007, SCAG staff met with the City of Tustin and other eight Orange County cities discussing
the extra assigned housing units from CDR and how to apply income categories to the extra units. in the
meeting, SCAG staff informed the City of Tustin that according to state law, fits extra units had to apply to all
income categories, twt just to above moderate housing.
In response to Tustin's letters of November 27 and December 11, SCAG mailed a letter dated February 9, 2007
to the City. In the letter, SCAG stated that the City's comments in the November 27 and December 11 letters
had been considered in the prepazation of the draft RHNA allocation and Integrated Growth Forecast. SCAG
further stated that SCAG ?tad analyze:i the OCP 2006 and had found it to be consistent with the Integrated
'` Growth Forecast. Thus, the RHNA allocation to the City of Tustin has incorporated the local concerns
expressed by the City of Tustin. -.:SCAG staff will continue to work with Tustin to reanlve RHNA allocation by
;income issue and ensure an appropriate solution.
On February 26, 2007, SCAG staff met with the City of Tustin staff again. The City was concerned with the
income breakdown for its draft allocation and indicated that the RHNA number was pretty high compared to
other cities. The city stated that it could meet its RHNA number of 91 I but since a development agreement was
already in place, it couki not meet the income category requirement. In response, SCAG staff stated that they
did not have a good solution for the city. The city also gave SCAG staff a letter from Tustin indicated concern
with SB 12 that was widely distributed.
Finally, the City of Tustin submitted its appeal request in a letter dated March 15, 2007 to SCAG. In the appeal
letter, the City summarized reasons for its appeal and asked for reconsideration by the SCAG Appeals Board.
ANALYSIS:
Pursuant to the RHNA Appeals Procedure, local jurisdictions can appeal under the criteria of "Methodology" if
SCAG failed to determine the jurisdiction's draft allocation in accordance with the final allocation methodology
approved by the Regional Council. In this case, staff finds that it did determine the City of Tustin's draft
allocation in accordance with the final methodology. However, in the interest of fairness, staff has analyzed the
City's azguments relating to methodology
SCAG growth forecasting staff reviewed the Orange County Projections (OCP) 2006 adopted by the Orange
County Council of Governments (OCCOG) Board on November 30, 2006. Based on the review, SCAG staff
determined that OCP 2006 is consistent with the overall methodology of SCAG's Integrated Growth
Forecasting methodology. As a result, t~CP 2{IUb'was ~ ~ {~ ~ ~ l:orbcast for thartge
County including the City of Tustin. As a matter of fact, it has been a standard process for SCAG to utilize
adopted OCP ~ the grotivt)t projetaiott fin. Orange County Therefore, the housing needs allocation for the City
of Tustin was determined in accordance with the RHNA allocation methodology adopted by the Regional
Council.
The essence of SCAG's Integrated Growth Forecasting Process is that the regional planning for growth,
transportation, and housing in this region will be an integrated process. Therefore, the Integrated Growth
Forecast for Orange County, Warningly the OCP 2006, is appropriate for the RHNA allocation purposes as well
as for the RTP growth forecasting purposes.
The preliminary RHNA assigned to the City of Tustin in September 2006 was based on the previous cycle of
growth forecast, the adopted 2004 RTP Growth Forecast, with an understanding that the growth forecast will be
updated later. Further, the previous cycle of OCP, OCP 2004, constituted the adopted 2004 RTP Growth
Forecast for Orange County. OCP 2006 represents the current update to OCP 2004. More importantly, OCP '
sour"e"" w.,.oaru~ 2006 was unanimously approved by the OCCOG Board including the Board
essocunoraroviurun
# 134225 v4 . Staff RHNA Appeal Report - City of Tustin
255
Member representing the City of Tustin. OCP 2006 and thus the Integrated Growth Forecast for Orange County
reflected the collective input provided by individual jurisdictions and have incorporated local concern.
expressed by its local jurisdictions including the City of Tustin.
The City of Tustin did not specify the number of housing units it is appealing. However, following the City's
arguments for appeal, the implied number of housing units the City is appealing ranges from 985 to 1,871
housing units which represents 29 to 56 percent of its RHNA allocation of 3,344.
ATTACHMENTS:
1. RHNA Appeal Request dated March 15, 2007 from the City of Tustin
2. Letter dated March 15, 2007 from the City of Tustin
3. Letter dated February 9, 2007 from SCAG
4. Letter dated January 11, 2007 from SCAG
5. Letter dated January 11, 2007 from the City of Tustin
6. Letter dated December 11, 2006 from the City of Tustin
7. Letter dated November 27, 2006 from the City of Tustin
8. Letter dated August 15, 2006 from the City of Tustin
9. Letter dated July 17, 2006 from the City of Tustin
10. Letter dated July 6, 2006 from the City of Tustin
11. Letter dated June 15, 2006 from the City of Tustin
12. November 30, 2006 OCCOG Board meeting minute
A!!O[N MNfMOK~/^[Krf
256 M t 34225 v4 - Sm[f RHNA Appel Report - Ciry of Tustin