Regional Housing Needs Allocation

SACOG Releases Draft Allocations for Regional Housing Needs; Requests for Revisions due by June 18

At its April 19 meeting, the SACOG Board of Directions publicly released the draft allocations for the 2013-21 Regional Housing Needs Allocation (RHNA). The draft allocations are based on the adopted RHNA methodology, Methodology B, that the SACOG Board approved at its December 15, 2011 meeting. Cities and counties may submit a formal Request for Revision to the draft allocations for the Board's consideration. The request must be based on the factors identified in California statutes Government Code 65584.04.

Please submit written Requests for Revisions to Greg Chew, SACOG, 1415 L Street, Suite 300, Sacramento, CA 95814, or to gchew@sacog.org BY NO LATER THAN MONDAY, JUNE 18, 2012.

You may download the board packet that contains the draft allocation tables, the description of the methodology, the above referenced Government code 65584.04, and a letter from the California Housing and Community Development Department clarifying the housing element adoption process. In addition, the FAQ document provides a background on RHNA.

• RHNA FAQ
• RHNA draft allocations

Summary

The Regional Housing Needs Plan (RHNP) allocates to SACOG cities and counties their "projected share" of the region's projected housing needs. The SACOG Board of Directors must adopt an update of the plan every eight years. Each city and county in the RHNP will receive a Regional Housing Needs Allocation (RHNA) of total number of housing units that it must plan for within the eight year time period through their General Plan Housing Elements. Allocations are also distributed within four economic income categories; these four categories must add up to the total overall number a jurisdiction is allocated.

The current RHNP period covers from January 1, 2006 through June 30, 2013. That plan including the allocations may be downloaded in the box below.

The next RHNP that SACOG has begun working on, will cover the period from January 1, 2013 through October 31, 2021.

Web Page

This webpage provides SACOG member jurisdictions and other stakeholders information regarding the upcoming 2013-21 Regional Housing Needs Allocation (RHNA) and the Regional Housing Needs Plan (RHNP), which is the document that encapsulates the RHNA. This page provides two key features:

1. A series of Frequently Asked Questions (FAQ) is shown below, addressing issues from the basic background about RHNA and an explanation of the key components of the RHNP;
2. The adopted 2006-2013 RHNP (approved February 21, 2008), which may be downloaded below. Also, the most important features of the RHNP are the adopted allocation tables, which may also be downloaded.

This website will be periodically update, particularly in the Frequently Asked Questions section below. The FAQ will add new questions and provide further elaboration and clarifications to others as the 2013-21 RHNA is developed.

Key Documents from 2006-13 RHNA:

Frequently Asked Questions

(updated April 20, 2012)

These Frequently Asked Questions (FAQ) address the 2013-2021 Regional Housing Needs Allocation (RHNA) for the SACOG region.

Background Information

What are the Regional Housing Needs Allocation (RHNA) and Regional Housing Needs Plan (RHNP)?

The State of California, through the Housing and Community Development Department (HCD), will issue a Regional Housing Needs Determination to SACOG's six-county region for the January 1, 2013 to October 31, 2021 planning period. HCD calculates the regional determination using information provided by the California Department of Finance. The regional determination includes an overall housing need number, as well as a breakdown of the number of units required in four income distribution categories, as further defined below.

Based on the regional determination provided by HCD, SACOG must develop a Regional Housing Needs Allocation (RHNA) and a Regional Housing Needs Plan (RHNP). These state-mandated documents allocate a "projected share" of the regional determination to each of the cities and counties in SACOG's six-county region. The RHNA establishes the total number of housing units that each city and county must plan for within the eight-year planning period. Based on the adopted RHNA, each city and county must update its Housing Element to demonstrate how the jurisdiction will meet the expected growth in housing need over the eight-year planning period.

What is SACOG's role in the RHNA Process?

California's Housing Element Law (Government Code, §§ 65580 et seq.) mandates that SACOG develop and approve a RHNA and RHNP for its six-county region, including the counties of El Dorado, Placer, Sacramento, Sutter, Yolo, and Yuba, and their 22 cities. The RHNA and RHNP must also include the Tahoe Basin portions of El Dorado and Placer counties, and the city of South Lake Tahoe, which are not normally within SACOG's planning area.

It is SACOG's responsibility to coordinate with HCD prior to its determination of the regional housing need. Once SACOG receives the regional determination, including the overall need number and the income category distribution, it must adopt a methodology for distributing the regional growth number throughout the region. The methodology is the basis for the final RHNA and RHNP that SACOG ultimately adopts.

What are the two types of allocations in the RHNA?

The Regional Housing Needs Allocation has two parts as required by state law:

1. Overall Allocation: SACOG receives a total housing unit number for growth during the planning period in the six-county SACOG region, including the Tahoe Regional Planning Area, from HCD. SACOG is required to distribute this regional housing growth number to the jurisdictions within the region for the period from January 1, 2013 to October 31, 2021.
2. Income Category Distributions: HCD also provides a household income distribution of the total regional housing unit number. As defined by state law, four income categories make up this distribution: very low income (less than 50 percent median family income [MFI]); low income (50 to 80 percent MFI); moderate income (80 to 120 percent MFI); and above moderate income (above 120 percent MFI). The total housing unit growth SACOG allocates to each jurisdiction must be further allocated into the four household income categories.

What are the four income categories and what do they mean for cities and counties?

The four economic categories, as listed above, must be addressed in a jurisdiction's housing element. Specifically, accommodations must be made to ensure that the jurisdiction provides sufficient zoning capacity to accommodate the projected housing need in each income category.

It is important to note that each jurisdiction is responsible for providing sufficient zoning capacity for the units allocated to all four economic income categories, but is NOT responsible for the construction of these units. The intent of the Housing Element law is to ensure that jurisdictions do not impede the construction of housing in any income category. Other factors, such are market forces, are well beyond a jurisdiction's control and have considerable influence over whether or not housing units in each income category are actually constructed.

Procedural Questions

What's the RHNA timeline?

The timelines for the RHNA process changed after the State of California passed Senate Bill 375 in 2008. One key goal of SB 375 is to better coordinate transportation planning with land use and housing planning. For this reason, the RHNA process is now tied to the adoption of the regional Metropolitan Transportation Plan (MTP). Essentially, as a result of SB 375, RHNPs must be adopted every eight years, following the adoption of the update of the MTP. Because of the transition period created by SB 375, this RHNA period will be more than exactly eight years - it will cover the period from January 1, 2013 through October 31, 2021.

The SACOG MTP was adopted by the SACOG Board on April 19,  2012.  Under SB 375, this date determines the related RHNA timeline.  Based on state statutory timelines, below are the key milestones:

• September, 15, 2011 – SACOG Board released draft methodologies for 60-day public comment;
• December 15, 2011 – SACOG Board approved Methodology B as selected methodology;
• April 19, 2012 – SACOG released draft allocations
• June 18, 2012 – last day for cities and counties to submit a Request for Revision to the draft allocations
• June 21 or August 16, 2012 – SACOG Board action to accept, modify or reject request for revisions (date depends on when request is received by SACOG)
• Within 60 days of revised allocation, if one is made, jurisdictions may appeal revised allocation, and the SACOG Board has 60 days to take action
• September to December Board meeting – SACOG releases final proposed RHNP (date depends on prior actions)
• October to January Board meeting – Adoption of final RHNP (date depends on prior actions)
• October 31, 2013 – Housing element due date for cities and counties within SACOG region.

*The dates for proposing and adopting allocations are subject to change as the RHNA process advances.

Generally, what factors are used to determine the RHNA?

State law requires SACOG to consider the following factors, to the extent sufficient data is available, when developing its RHNA methodology:

• Existing and projected jobs and housing relationship;
• Opportunities and constraints to development of additional housing, including:
  • Lack of capacity for sewer and water due to federal or state laws, regulations or regulatory actions, or supply and distribution decisions made by a sewer or water service provider that preclude the jurisdiction from providing necessary infrastructure for additional development during the planning period;
  • Availability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for infill development and increased residential densities (SACOG may not limit its consideration based on the jurisdiction's existing zoning ordinances and land use restrictions);
  • Lands preserved or protected from urban development under existing federal or state programs, or both, designed to protect open space, farmland, environmental habitats, and natural resources on a long-term basis;
  • County policies to preserve prime agriculture lands within an unincorporated area;
  • Distribution of household growth assumed for a comparable period in the regional transportation plan and opportunities to maximize the use of public transportation and existing transportation infrastructure;
• Market demand for housing;
• Agreements between a county and cities in the county to direct growth toward incorporated areas of the county;
• Loss of units contained in assisted housing developments;
• High housing cost burdens;
• Housing needs of farmworkers;
• Housing needs generated by the presence of a private university or a campus of the California State University or the University of California; and
• Any other relevant factors, as determined by SACOG.

Where is the RHNA process now and what's next?

During the summer and fall of 2011, SACOG worked with HCD on the RHNA determination, which is the number of units the overall regional allocation. SACOG received the RHNA determination on September 28, 2011. Simultaneously, SACOG worked with its member jurisdictions and interested parties in developing different RHNA methodologies for consideration. Five methodologies were submitted to the Board for review and selection. On December 15, the SACOG Board approved Methodology B. .

On April 19, 2012, the SACOG Board released the draft allocations associated with the approved methodology.  Jurisdictions have until June 18, 2012 to submit a formal request for revision.  The request for revision must be made on the basis of the factors identified in state law, Government Code Section 65584.04(d) (1) through (9).  From there, the Board will receive and hear requests for revisions and appeals.  The revision and appeals process may alter the timeline, but the target date for the Board to approve the Regional Housing Needs Plan is October 18, 2012..

The 2006-13 RHNP

What's in the current RHNP?

The current RHNP covers the planning period beginning January 1, 2006, through June 30, 2013. The six-county region received an overall allocation from HCD of 118,652 housing units for the 7.5 year period. Of that amount, the percentage of units allocated to each income category distribution was as follows: 22.8 percent very low income; 17.2 percent low income; 20.1 percent moderate income; and 41.3 percent above moderate income.