Council to Discuss RHNA, Consider Action

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Posted By: Bill Coburn June 27, 2011

At Tuesday’s Council meeting, the Council will discuss the 2012 Regional Housing Needs Assessment process at the request of Council Member MaryAnn MacGillivray.  Council Member MacGillivray will be providing an update regarding the Regional Housing Needs Assessment Update (RHNA) and Council action may be requested, for example, if the Council would like to submit a letter to the Southern California Association of Governments (SCAG) regarding the RHNA process.

From the analysis by Staff that is in the Council packet: “SCAG has begun development of the 2012 RHNA process. SCAG, as a regional planning agency, is responsible for coordinating the development of the 2012 RHNA with the 2012 Regional Transportation Plan (RTP) and Sustainable Communities Strategy (CSC).

RHNA is a process that State law requires SCAG to perform as part of the Housing Element and General Plan updates adopted by local governments. RHNA quantifies the need for housing by income group within each jurisdiction during specific planning periods, based on a regional housing target set by the California Department of Housing and Community Development (HCD).

Very simply stated, SCAG will determine existing needs by examining census data to measure how the housing market is meeting the needs of current residents, including low-income households; and SCAG will assess future housing needs as determined by SCAG’s growth forecast and local input process.

SCAG has formed a RHNA Subcommittee to conduct in-depth review of the policy considerations necessary to develop the RHNA, and to make decisions related to methodology, draft and final RHNA allocations and revision requests and appeals by local jurisdictions.

SCAG has identified upcoming milestones to completing RHNA, and the RTP/SCS. The milestones are:

  • August 2011- State HCD determines regional housing target
  • December 2011 – SCAG adopts RHNA methodology
  • April 2012 – Draft RHNA issued & 2012 RTP/SCS adopted
  • Fall 2012 – Public Hearings
  • October 2012 – SCAG adopts RHNA
  • October 2012 – Updated Housing Elements due to HCD”

The entire staff report on this item is 86 pages long, 2 pages of staff analysis and 84 pages of documents (with some commentary) provided by Council Member MacGillivray.  Here’s a link to the document posted on Patch.  But here are the first couple pages, which appear to have been prepared by Council Member MacGillivray.

Page 1 of attachments

Introduction and Background

SB375 requires that SCAG’s 2012 Regional Transportation Plan (RTP) Sustainable Communities Strategy (SCS) and Regional Housing Assessment (RHNA) be developed under an integrated process so that these policy initiatives will be consistent and fulfill state applicable laws and planning regulations.

The subcommittee was appointed by the CEHD committee and will make recommendation to that group which will, in turn, make recommendation to the SCAG Regional Council for implementation. The CEHD Committee asked for applications from within their group, yet not every appointee submitted an application. Consequently, at a subsequent CEHD meeting, a member who had submitted an application asked for an explanation of the selection process and was not satisfied with the answer.

The committee consists of 12 appointees with only 6 having voting power. One individual and one alternate were appointed from each county in the MPO, those counties being San Bernadino County, Los Angeles County, Orange County, Riverside County, Ventura County and Imperial County. This means one vote one county.

Documents included (in the staff packet) for review

  1. What’s New RHNA: Changes to Housing Element
  2. AB2158 factors list.
  3. Technical Appendix to Draft RHNA Methodology Framework Report for RHNA Subcommittee Meeting on April 19, 2011.
  4. SCAG RHNA Subregional Delegation Guidelines and Timeline
  5. California Govt. Code Sections 65584-65584.05 (“RHNA” Statutes)
  6. Draft RHNA Consultation Packet T State Housing and Community Development Department (HCD)/ Department of Finance (DOF).
  7. Report from the Center for Continuing Study of the California Economy regarding prior HCD efforts to develop consistent regional projections including the 2006 Regional Forecasting Task force Report.
  8. RHNA Social Equity Adjustment Report
  9. RHNA Subcommittee Schedule
  10. Letter from Hermosa Beach to SCAG addressing shortcomings in the RHNA process

Page 2 of Attachments

Areas of Concern:

  1. “One vote one County” means that one individual representing all of Los Angeles County has the authority to vote on the guidelines for this 5th RHNA cycle – Sierra Madre is a very small part of this county geography and can easily suffer collateral damage as a result.
  2. The underpinning of this entire process is the 2012 SCAG RTP/SCS, so the housing assessment must be compatible with SCAG’s Integrated Growth Forecast for that plan. As a result there is a good deal of mathematical equivocation and statistical maneuvering without regard to a reality match.
  3. In order to support SCAG’s forecasted level of regional population growth and labor force, they have projected, optimistically, a job growth of just under 14% between 201~ and 2020 and 22% between 2010 and 2035. They have also projected unemployment to decrease to 7% by 2020 and stabilize at 5% by 2035. Sounds good but indicators are not moving in that direction yet.
  4. SCAG is projecting an increase in regional population of 1.6 million by September 2021 and, therefore, a need for an additional 628,211 dwelling units. Allowing for vacancy rates and replacements, the total housing need for the SCAG region for the 5th RHNA Cycle is 554,871 units. Everyone, including Sierra Madre, must assume their “fair share” of that.
  5. The social equity adjustment is a method to make each community close the gap between their current income household distribution and the county median distribution derived from the 2000 census. That is a ten year old data point and the resulting “fair share adjustment” can significantly impact communities like Sierra Madre. Social engineering?
  6. Meetings are very poorly attended and these detailed reports are not getting to the policy makers in all communities affected.
  7. There appears to be no evaluation of the 4th (or any previous) RHNA Cycle to determine its effectiveness or whether the multiple iterations of projections represent what is occurring in communities. And so SCAG goes forward with the 5th cycle.

There are another 82 pages in this report, and as I said, when Patch gets them posted, I’ll put a link here. 

But having started to review them, I will say this (and from  here on is editorializing, folks, and should be recognized as my opinion, not news coverage): There’s a lot of very complicated factors involved, and language that is very hard to follow.  It’s a prime example of what people are talking about when they complain about the ridiculousness of big government.  Chances are when all is said and done, Sierra Madre is going to be assigned ridiculously high numbers for the housing we are required to make available for construction (no they don’t have to be built, there just has to be zoning that would allow it).  We are a small town in a big region, and we just aren’t going to be able to stop the steamroller.  Which is why it’s important that we keep an eye on this whole process and do our best to keep the damage as low as possible.  And that’s why, when there has been discussion about pulling out of SCAG, I’ve argued against it.  I think it’s important that we stay in SCAG, so that even if we can’t stop the steamroller, we can be a squeaky enough wheel to maybe get some consideration for our concerns.  You can’t be one of the voices in the discussion if you aren’t sitting at the table.

I hope the Council will decide to send a letter letting SCAG know that Sierra Madre has concerns, if only as the first of many “squeaks” to let them know we aren’t going to be rolled over without them having to hear what we have to say.  The more Cities that speak up, the more likely it is that someone, somewhere, in the regional bureaucracy will figure out that there are problems in the system that need to be addressed.   I don’t necessarily agree with everything Council Member MacGillivray is saying on this issue, but I commend her effort to keep it in the forefront of the issues the council is considering.