Shawn Raymundo and Lillian Boyd, Dana Point Times
Counties and cities across Southern California will collectively need to plan to construct more than 1.34 million new homes over the next 10 years, the state’s housing department recently determined.
Late last month, the California Department of Housing and Community Development released its Regional Housing Needs Assessment (RHNA), finding that between 2021 and 2029, the six counties in Southern California will need to prepare for the development of 1.34 million additional housing units across four income categories.
However, the Southern California Association of Governments, a public agency representing the region’s six counties including Orange, believes that the assessment is much higher than what’s actually needed and is now questioning the HCD’s methodology.
“We acknowledge that there’s a housing crisis and are committed to doing everything within our authority to help solve it, but the RHNA allocation process has to have integrity,” Kome Ajise, SCAG’s executive director, said in an email. “We will continue to work with the state to ensure that the determination is on the firmest possible technical ground, and that ultimately the needs of our communities are met.”
The housing department submitted the RHNA on Aug. 22. Under state law, SCAG has 30 days from receipt of the assessment to analyze and review it, determining to either accept its findings or file an objection.
In a 48-2 vote on Sept. 5, SCAG’s regional council authorized Ajise to file an objection to the state housing department over its methodology. The council comprises elected officials from Southern California including Orange County Board Supervisor Donald Wagner. No official from the tri-city area, including Dana Point, is on the regional council.
“Overall, HCD did not use the appropriate population forecasts for their determination of the SCAG region’s housing needs and did not conduct a reasonable application of the methodology and assumptions pursuant to statute,” the agency states in its council report.
The RHNA breaks the 1.34 million housing needs figure into four income categories: very-low, low, moderate and above-moderate.
About 26%, or nearly 351,000 housing units are to be designated for very-low income and 15.3% will encompass housing for low income persons and families. Moderate income housing units will make up 16.7% while the bulk of the housing units—nearly 42%, or 562,252—will be allocated for above-moderate income housing.
According to the RHNA, the housing department’s methodology takes into account population growth, the population of households and projected households, as well as the state’s overcrowding and vacancy percentages.
Using the projection from the Department of Finance, the RHNA estimates Southern California’s population to exceed 20.45 million by October 2029. The region, according to the RHNA, has an overcrowding rate of 10.11%, exceeding the national rate of 3.35%, while its current “for rent and sale” vacancy rate is 2.37%, lower than the standard 5%.
SCAG, however, estimates the population to grow to more than 20.72 million and instead of the 1.34 million homes needed, the agency’s alternative RHNA proposes the region needing between 821,000 to 924,000 new homes.
“SCAG’S alternative proposed determination provides a more reasonable, current, balanced, and technically robust application of HCD’s stated approach toward determining housing needs,” the agency’s report states.
If the agency later accepts the RHNA, whether that be an updated one from the housing department or not, it will work on an allocation plan to divvy up the housing needs to local jurisdictions.
Currently, the agency is working on its methodology for how to allocate the housing needs to the cities and counties for the 2021-2029 planning period and has been accepting public input. The period for public comments on that methodology closes Friday, Sept. 13.
For the current planning period of 2014-2021, Orange County was allocated 5,272 units of the total 412,137 units for Southern California, according to Board Supervisor Wagner.
This past June, Wagner, on behalf of the county, submitted a letter to the chair of SCAG’s committee with oversight of the RHNA, requesting that the agency propose a total allocation of 430,000 housing units for the region from the housing department.
Each jurisdiction’s General Plan must contain a Housing Element that allows adequate provision for the existing and projected housing needs of all economic segments of the community. Currently in 5th Cycle RHNA, the 2014-2021 General Plan Housing Element includes the City of Dana Point’s housing strategy to plan for existing and projected housing demand, identify adequate sites to accommodate the City’s allocated share of regional housing needs, and analyze local policies, regulations, and requirements that have the potential to constrain development of housing for all income levels.
For the 5th Cycle planning period of Jan. 1, 2014 to Oct. 31, 2021, the RHNA allocation for City of Dana Point is 76 very-low income households (0-50% median); 53 low-income households (51-80% median); 61 moderate-income households (81-120% median); and 137 above moderate-income households (121%+ median).
The City of Dana Point’s total RHNA allocation for the 5th cycle (2014-2021) is 327.
In December 2018, Southern California Association of Governments (SCAG) initiated the development of the 6th Cycle RHNA. The 6th Cycle RHNA is the next Housing Element cycle from June 30, 2021 to October 15, 2029.
According to a memo from City Manager Mark Denny, city staff has been monitoring and providing input on the development of the RHNA determination and methodology through participation in the RHNA subcommittee monthly meetings via webinar, the Orange County Council of Governments Technical Advisory Committee and the Proposed RHNA Methodology Public Hearing on Aug. 22.
On August 2, 2019, SCAG staff released three allocation methodologies for public comment, which were developed based on feedback from the RHNA Subcommittee and stakeholders. Each option applies different components and factors.
Option 1 is based on share of population, share of population within high-quality transit areas, share of regional undersupply of building permits issued, local input/future vacancy need/replacement need, and social equity adjustment. Estimated total RHNA for City of Dana Point: 1,471.
Option 2 is based on share of population, share of population within high-quality transit areas, and social equity adjustment. Estimated total RHNA for City of Dana Point: 1,921.
Option 3 is based on local input/future vacancy need/replacement need, and social equity adjustment. Estimated total RHNA for City of Dana Point: 689.
WHAT’S NEXT: According to the city memo, city staff will submit a public-comment letter regarding the proposed RHNA Methodology to SCAG by the Sept. 13 deadline. Staff will highlight its preference for the methodology utilized in Option 3, which includes local input and population forecasting. Staff will also participate in the Preview of Staff Recommended RHNA Allocation Methodology Workshop scheduled on Sept. 23. The next RHNA Subcommittee Meeting is scheduled on Oct. 7.
The regional council is expected to consider SCAG’s Final Proposed RHNA Allocation Methodology in early November.