What is RHNA? How does RHNA affect my jurisdiction’s general plan?
The Regional Housing Needs Assessment (RHNA) is a requirement of State housing law and is a process that determines projected and existing housing need for all jurisdictions (city or unincorporated county) in California. The process to determine a RHNA allocation is conducted by a council of governments, such as SCAG, every eight (8) years. Every jurisdiction must plan for its RHNA allocation in its housing element of its General Plan by ensuring there is enough sites and zoning to accommodate their RHNA allocation. Many jurisdictions use the housing element as an opportunity to complement their economic development, open space, and sustainability goals with its housing goals. Once updated, housing elements are reviewed by the California Department of Housing and Community Development (HCD) and must be adopted by the jurisdiction.
The 5th Cycle RHNA allocation for the SCAG region was adopted in October 2012 and covers the housing element planning period October 2013 to October 2021. The 6th cycle allocation, which will cover the planning period October 2021 through October 2029, was adopted in March 2021.
How will it affect California’s housing crisis?
The goal of RHNA is to ensure that local plans accommodate existing and projected housing need for all income levels throughout their communities. The State of California has a serious shortage of housing, which impacts the number of homes available and affordability levels, and the current crisis is a result of a cumulative deficit in housing supply. The crisis has far reaching effects ranging from company relocations and employment losses to fewer dollars spent on basic needs to increased traffic due to longer commutes. Ensuring that there are enough places to accommodate housing need is the first step in helping to increase housing supply.
How do you decide a jurisdiction’s RHNA allocation?
The RHNA process has several milestones before the adoption of the final allocation plan. First, HCD provides a regional housing need determination to SCAG. For the 6th cycle, this number is 1,341,827 units for the region. SCAG then develops a methodology to distribute the regional determination so that every jurisdiction will receive a share of the regional number.
What is the approval process for the RHNA methodology?
State housing law requires that every council of governments, including SCAG, to adopt a RHNA methodology to distribute existing and projected housing need to every jurisdiction within the region. The process to develop a draft RHNA methodology involved an extensive public input process, which included four public hearings and a public information session in August 2019. Around 250 public written comments were received during the public comment period. Based on comments received, SCAG staff developed a recommended draft RHNA methodology. In November 2019, the Regional Council approved the draft RHNA methodology to submit to HCD for their 60-day review and comment period, which is required by State law.
HCD found that SCAG’s draft RHNA methodology furthered the five objectives of State housing law and in March 2020, the SCAG Regional Council adopted the Final RHNA methodology. Based on the adopted methodology, SCAG distributed the draft RHNA allocation in September 2020.
What are the factors that influence the RHNA methodology?
The RHNA methodology applies several factors to further the objectives of State law and meet the goals of the Connect SoCal plan. The main determining factors in the methodology are household growth (based on Connect SoCal Growth Forecast), job accessibility, and transit accessibility. A certain number of jurisdictions have a higher calculated need based on this formula that is larger than their Connect SoCal Growth Forecast for household growth between 2020 and 2045. In those cases that occur in designated disadvantaged communities, there is a “residual.”
The residual for those jurisdictions is taken off their calculation, and then the residuals are summed for the region. The regional residual is then distributed back to jurisdictions that meet three conditions: 1) They are in the top 50th percentile for transit accessibility; 2) top 50th percentile for job accessibility; and 3) less than 50% of their population is considered extremely disadvantaged.
After a RHNA total is calculated, a social equity adjustment is applied to determine the four income categories. The social equity adjustment is based on household income and access to resources. The resource indicator used is based on factors such as educational attainment, low-income job access, reading proficiency, and pollution levels. These same resource indicators are used to determine whether a jurisdiction is designated as disadvantaged under the RHNA methodology.
What were the factors used in prior RHNA cycle methodologies?
The 6th RHNA cycle methodology is very different in comparison to the 4th and 5th cycle methodologies. Both the 4th and 5th cycle only used projected household growth as the basis for a RHNA allocation and only household income was used to determine social equity to calculate the four income categories.
What is the role of local input in RHNA? What is the methodology’s relationship to the Connect SoCal Plan?
Local input, or more accurately SCAG’s Growth Forecast, plays an important role in regional planning. The Growth Forecast is developed using reputable data sources and then reviewed by panels of experts, partner agencies, and local jurisdictions in determining future growth patterns in the region. The Growth Forecast is used as a basis for Connect SoCal transportation planning and for the methodology, is a major component of determining need.
State housing law requires that the RHNA be consistent with the development pattern of the SCS (Connect SoCal) but does not specify any other requirements between the two plans. To meet this requirement, the use of “local input” helps to strengthen the consistency between SCS and the projected RHNA need. Additionally, the inclusion of transit and job access as major factors in the RHNA methodology align with the strategies in Connect SoCal, strengthening the consistency between the two regional plans.
What were other factors considered during the development of the RHNA methodology?
The proposed methodology included three options for distribution regional need. Option 1 included household growth (Connect SoCal Growth Forecast), existing population share, transit accessibility, and building activity as main factors. Option 2 considered existing population share and transit accessibility, but did not include household growth. Option 3 considered household/population growth, but did not include any other major factors. There were also some differences regarding social equity adjustment.
What does vacancy adjustment mean?
To ensure that there is enough housing stock to support household growth, a future vacancy need is applied. The vacancy adjustment, or vacancy need, is a fixed percentage of household growth. If the vacancy need was 0%, that would mean that there are 0 units for a family to move into and would not support household growth. In the recommended draft methodology, a 1.5% adjustment is applied to owner-occupied units and 4.5% is applied to renter units and are based on the proportion of owners and renters in a jurisdiction. This vacancy need is independent of current vacancy rates of a jurisdiction.
What is a “social equity adjustment”?
One of the five objectives of State housing law is to ensure that there is not an overconcentration of households by income group in comparison to the county. To ensure that the RHNA methodology does not overburden low-income jurisdictions with more low-income households, a social equity adjustment is applied during the income category process. In the methodology existing household income distribution is the main factor. The higher the percentage, the more shifting of income categories is seen in the jurisdiction. The result is that higher income jurisdictions are required to plan for fewer market rate units and more affordable units, while lower income jurisdictions plan for more market rate units and fewer affordable units.
What qualifies a jurisdiction as “extremely disadvantaged”?
The recommended draft methodology uses indicators developed by the U.S. Department of Housing and Urban Development (HUD), the California Tax Credit Allocation Committee (TCAC), and HCD to determine a community’s level of resources, which is considered a reflection on its access to fair housing and opportunity, and include indicators such as educational attainment, reading proficiency, access to low-income jobs, and pollution levels. Extremely disadvantaged communities are considered those communities with more than half of their population that are in poverty and/or segregation and are low resource areas.
Was there an opportunity to appeal my jurisdiction’s RHNA allocation?
There was a formal appeals process conducted after the draft RHNA allocation was distributed in September 2020. All jurisdictions and HCD had the opportunity to appeal their draft RHNA allocation along with the draft allocation of other jurisdictions. All filed appeals were reviewed and determined by the RHNA Appeals Board in January 2020. Per the adopted RHNA Appeals Procedures, the determinations made on appeals by the RHNA Appeals Board are considered final and not subject to further review.
How many appeals were granted and where do the units go if an appeal is granted?
Per State housing law and the adopted RHNA Appeals Procedures, successfully appealed units were redistributed proportionally to all jurisdictions in the SCAG region and were not confined to any one particular jurisdiction or geography. Of the fifty-two appeals filed, two were partially granted. A total of 3,132 units from these successful appeals were reallocated back to the region in order to ensure that the 1,341,827 regional determination was met for the Final RHNA Allocation.
How can I become involved in the RHNA process and housing programs at SCAG?
While the 6th RHNA cycle process has concluded, SCAG will continue to engage stakeholders in housing element assistance and accelerating housing production in the region. Announcements of public workshops, meetings, and milestones are announced through the housing email list. To submit a written comment or question, or to be added to the housing mailing list, send an email to firstname.lastname@example.org. Additional resources on RHNA and housing can be found at www.scag.ca/housing.
Will my jurisdiction be penalized if we do not build enough housing?
Jurisdictions are required to plan for their RHNA allocation and there are penalties for not doing so, but there are no direct penalties for not building enough housing. However, residential projects that meet certain conditions and are located in jurisdictions that did not permit enough housing consistent with RHNA goals, may elect to a ministerial process to get project approval in those jurisdictions.
Updated: March 24, 2021