RHNA: Statutory Factors and Proposed Allocation Methodology

Statutorily Required Factors

1. Existing and projected jobs and housing relationship.
2. Opportunities and constraints to development in member jurisdictions, including:
   1. Capacity for sewer or water service
   2. 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.
   3. Lands preserved or protected from urban development to protect open space, farmland, environmental habitats, and natural resources.
   4. County policies to preserve prime agricultural land
3. Opportunities to maximize the use of public transportation and existing transportation infrastructure.
4. The market demand for housing.
5. Agreements between a county and cities in a county to direct growth toward incorporated areas of the county.
6. The loss of affordable housing units contained in assisted housing developments.
7. High-housing cost burdens.
8. The housing needs of farm workers.
9. The housing needs generated by the presence of a university
10. Any other factors adopted by the council of governments.
11. It is the intent of the Legislature that housing planning be coordinated and integrated with the regional transportation plan. The allocation plan shall allocate housing units within the region consistent with the development pattern included in the sustainable communities strategy.
12. The final allocation plan shall ensure that the total regional housing need, by income category is maintained, and that each jurisdiction in the region receive an allocation of units for low- and very low income households.

Proposed 2014-2022 Allocation Methodology

• Ensures growth is focused on land suitable for urban development and infill residential development that increases density in core areas (Factor 2b).
• Protects open spaces, both state/federally protected and agricultural, by focusing growth in areas nominated by local jurisdictions as appropriate for increased growth (Factor 2c & d).
• Because PDAs are nominated by local jurisdictions as locations with infrastructural capacity (including water and sewer) for increased growth, focusing the majority of growth into these areas allows the RHNA allocation to take sewer and water capacity into consideration (Factor 2a).
• Priority Development Areas were nominated as suitable locations in which local and regional agencies may encourage 'complete communities' which support both housing and employment (Factor 1).
• PDA's were nominated based on transit accessibility. This sustainability component thus ensures the majority of growth is focused in transit-rich areas to maximize use of public transit and existing infrastructure (Factor 3).
• The Statute includes intentions that planning for housing be coordinated and integrated with the regional transportation plan by allocating housing units consistent with the development pattern included in the Sustainable Communities Strategy. This piece of the RHNA methodology will be directly based on the growth pattern in the SCS Preferred Scenario (Factor 11).

• Past RHNA Performance (total low- and very-low income units permitted)
  • The number of units permitted will likely be related to the market demand for housing - for example, in cities with inclusionary housing ordinances or developer impact fees to fund affordable housing, a hot housing market will produce larger numbers of permits for affordable housing development (Factor 4).
  • Jurisdictions with insufficient past RHNA performance likely also suffer from high housing costs (Factor 7).
• Non-PDA employment (number of jobs)
  • Allocating housing in accordance with employment opportunities encourages a balanced relationship between jobs and housing (Factor 1).
• Transit (frequency and coverage)
  • Considering both the coverage and frequency of available transit throughout a jurisdiction in the RHNA methodology will maximize use of existing public transit infrastructure (Factor 3).
• Upper Housing Threshold (if growth in PDAs meets or exceeds 110% of the jurisdiction's household formation growth based on the Sustainability Component, it would not be assigned additional growth based on the Fair Share Components)
  • Ensures that cities which exhibit desirable amenities to support growth (such as PDAs and areas with transit and employment opportunities) are not overburdened by being allocated growth beyond their infrastructural capacity (Factor 2a).
• Minimum housing floor (40% of household formation however, a jurisdiction's allocation would be capped at twice what it received during the 2007-2014 RHNA period if its growth was increased to the 40 percent minimum in the SCS Preferred Scenario and its allocation based on the proposed methodology would be more than twice its 2007-2014 allocation.)
  • Encourages all jurisdictions to produce a portion of total housing need. This ensures that, even after the number of urban-oriented mechanisms for promoting infill development in transit-rich areas (including the Sustainability Component and the Transit Factor), less-intensely developed areas with a need for worker and farm worker housing are still required to produce new residential units (Factor 8).
  • Household growth is influenced by local land use plans and policies, including planned and protected agricultural lands (Factor 2d), open space and parks (Factor 2c), city-centered growth policies, urban growth boundaries (Factor 5), and any physical or geological constraints.
  • Ensures housing allocation is not based solely on existing amenities but also planned or projected growth.

• Promotes an equitable regional income distribution. In jurisdictions which have lost a significant number of affordable housing units in assisted housing developments (or which have a low share of low-income housing for other reasons) this factor will increase their responsibility for the provision of affordable housing towards the regional average (Factor 6).
• Government Code Sections 65584 (d.1) and 65584 (d.4) state that the goals for the Regional Housing Need Allocation process include increasing the housing supply and the mix of housing types and levels of affordability in all cities and counties in an equitable manner, as well as allocating a lower proportion of housing need to an income category when a jurisdiction already has a disproportionately high share of households in that category. This 175% shift method ensures that jurisdictions receive lower allocations for housing of a given affordability level if they already supply a disproportionate amount of that housing category, in accordance with state objectives. This also promotes the state objective for increasing the mix of housing types among cities and counties equitably.

• Sphere of Influence allocation rules are different among the Bay Area's counties, reflecting the fact that each county in the Bay Area is different in terms of whether a city or county has jurisdiction over land use and development within unincorporated SOIs, and thus respecting various County and City agreements regarding how to direct growth within the County (Factor 5).