CC SR 20191217 F - RHNAMEETING DATE: 12/17/2019 CITY COUNCIL
AGENDA REPORT AGENDA HEADING: Consent Calendar
AGENDA DESCRIPTION:
Consideration and possible action to adopt a resolution expressing opposition to the
Southern California Association of Governments’ approved Draft Regional Housing
Needs Assessment Allocation Methodology
RECOMMENDED COUNCIL ACTION:
(1) Adopt Resolution No. 2019-__: A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF RANCHO PALOS VERDES EXPRESSING OPPOSITION TO
THE SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS’
APPROVED DRAFT REGIONAL HOUSING NEEDS ASSESSMENT
ALLOCATION METHODOLOGY.
FISCAL IMPACT: There is no fiscal impact associated with this action.
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Octavio Silva, Senior Planner
REVIEWED BY: Terry Rodrigue, Interim Director of Community Development
APPROVED BY: Ara Mihranian, AICP, Interim City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. Resolution No. 2019-__ (page A-1)
B. City Council Staff Report, dated October 15, 2019 (page B-1)
C. HCD final regional housing need determination letter, dated October 15,
2019 (page C-1)
D. City of Rancho Palos Verdes RHNA methodology comment letters, dated
August 20, September 9, and October 29, 2019 (page D-1)
BACKGROUND AND DISCUSSION:
Regional Housing Needs Assessment (RHNA)
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RHNA is a representation of future housing needs for all income levels in a jurisdiction
(city or unincorporated county) and is a requirement of California housing law. Every
jurisdiction must plan for its RHNA allocation in the Housing Element of its General
Plan. The objectives of RHNA include:
Increasing housing supply and mix of housing types, tenure and affordability
Promoting infill development and socioeconomic equity, protection of resources
and encouraging efficient development patterns
Improving an intraregional relationship between jobs and housing
Allocating a lower proportion of housing need in income categories in areas that
have a disproportionately high share in comparison to the county distribution
Affirmatively further fair housing
The Southern California Association of Governments (SCAG) is tasked with developing
a RHNA allocation plan for the Southern California region. SCAG is the nation’s largest
metropolitan planning organization, which represents 6 counties and 191 cities,
including the City of Rancho Palos Verdes.
The City of Rancho Palos Verdes is currently in the fifth RHNA cycle, which covers the
planning period of 2013-2021. As part of the current cycle, the City’s RHNA allocation is
a total of 31 housing units at various income levels. The City is required to provide
annual RHNA progress reports to the California Department of Housing and Community
Development (HCD). In 2019, the City reported the completion of 18 housing units, with
13 remaining that need to be provided by the year 2021. Staff will continue to implement
the programs specified in the City’s Housing Element to ensure that these units are
provided by 2021.
On October 15, 2019, Staff presented the City Council with a status update on SCAG’s
preparation of a sixth RHNA cycle allocation plan to cover the next planning period of
2021-2029 (Attachment B).
Draft RHNA Methodology
An initial step in developing the allocation plan for the sixth RHNA cycle required SCAG
to first develop a RHNA methodology by which to distribute existing and projected
housing need to each jurisdiction. HCD is required to provide SCAG with an existing
and projected housing need, referred to as the regional housing need determination. On
October 15, 2019, HCD provided SCAG with a final regional housing need
determination (Attachment C) of 1,341,827 housing units among four income level
categories, including very-low, low, moderate and above-moderate.
In August 2019, SCAG began to prepare a methodology for the distribution of the
regional housing need determination to local jurisdictions based on a preliminary
assumption of HCD’s regional housing need determination as described above. As part
of this process, SCAG considered four different methodology options and released them
for a 60-day public comment period. The City of Rancho Palos Verdes submitted three
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comment letters (Attachment D) expressing concerns with the draft RHNA
methodologies and requesting more local input in the process.
The methodology options consist of two components, which include an existing housing
need and a projected housing need. The factors used to derive both components vary
among the four methodology options, but generally, the methodology options i nclude
factors such as, but not limited to, a jurisdiction’s share of population and share of
population within high-quality transit areas, as well as local input and social equity
adjustments. The table below provides a listing of the number of housing units that the
City would have been required to provide during the 2021-2029 (6th) RHNA planning
period based on the different draft RHNA methodologies, including the SCAG Staff -
recommended Option No. 4, based on SCAG methodologies that were contemplated
prior to November 7, 2019.
Draft RHNA
Methodology
Number of Required
Housing Units
Option No. 1 1,852
Option No. 2 2,390
Option No. 3 75
Option No. 4
(SCAG Staff-
Recommended Option)
93
On November 7, 2019, SCAG’s Regional Council took action to approve the release of
the SCAG Staff-recommended draft RHNA methodology to submit to HCD for review,
but at the request of representatives from the Inland Empire communities , SCAG Staff’s
presentation also included a revised draft RHNA methodology. This option shifted the
burden for the construction of new housing from the Inland Empire communities to
coastal cities, employment centers and high-quality transit areas. SCAG’s Regional
Council approved the revised RHNA methodology and submitted it to HCD for review on
November 14, 2019.
Under the approved draft RHNA methodology, the City will be required to provide a total
of 619 housing units during the 2021-2029 (6th) RHNA planning period. The City’s
RHNA allocation would be distributed across the following income categories:
244 very-low income units
134 low-income units
121 moderate-income units
119 above-moderate income units
The increase in the City’s RHNA allocation and that of many coastal cities is a result of
modifications to the factors that comprised the SCAG Staff -recommend RHNA
methodology. The City’s RHNA allocation under the approved methodology is a
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significant increase from the previous SCAG Staff-recommended RHNA methodology,
which would have required the City to accommodate 93 housing units during the next
planning period. Staff is concerned that the approved methodology does not consider
the unique challenges and physical constraints facing the City, such as being
designated a Very High Fire Hazard Severity Zone, geologic hazards and wildlife/habitat
preservation. Furthermore, Staff is concerned that “top down” housing mandates
combined with a lack of available housing sites and the State legislature’s willingness to
punish cities that do not achieve their RHNA allocations, are setting up the City for an
unachievable sixth cycle RHNA allocation.
HCD has 60 days to review the draft RHNA methodology and to provide SCAG with
comments. Staff has prepared a resolution (Attachment A) expressing opposition to the
SCAG Regional Council-approved RHNA methodology for the above-mentioned
reasons. If adopted, Staff will provide HCD with a copy of the resolution and a letter
objecting to the methodology. Staff also intends to file an appeal with SCAG as soon as
possible.
ALTERNATIVES:
In addition to the Staff recommendation, the following alternative is available for the City
Council’s consideration:
1. Do not adopt Resolution No. 2019__, and provide Staff with additional
direction.
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RESOLUTION NO. 2019-__
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
RANCHO PALOS VERDES EXPRESSING OPPOSITION TO THE
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS’
APPROVED DRAFT REGIONAL HOUSING NEEDS
ASSESSMENT ALLOCATION METHODOLOGY.
WHEREAS, the Regional Housing Needs Assessment (RHNA) serves as a
representation of future housing needs for all income levels in a jurisdiction during a
specified planning period, and is a requirement of California housing law; and,
WHEREAS, the Southern California Association of Governments (SCAG) is the
regional planning organization tasked with developing a RHNA allocation plan for the
Southern California region, representing six counties and 191 cities, including the City of
Rancho Palos Verdes; and,
WHEREAS, SCAG is in the process of preparing a sixth cycle RHNA allocation
plan to cover the planning period of 2012-2029, which requires the development and
approval of a RHNA methodology to distribute existing and projected housing needs to
each jurisdiction in the SCAG region; and,
WHEREAS, on August 20, September 9, and October 29, 2019, the City of Rancho
Palos Verdes submitted comment letters to SCAG expressing concerns with draft RHNA
methodologies being considered at the time and requesting more local input in the RHNA
methodology preparation process; and,
WHEREAS, on November 7, 2019, the SCAG Regional Council approved a draft
RHNA methodology under which the City of Rancho Palos Verdes would be required to
provide for a total of 619 housing units during the next planning period; and,
WHEREAS, on November 14, 2019, SCAG submitted the approved RHNA
methodology to the State of California Department of Housing and Community
Development (HCD) for a 60-day review and comment period.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF RANCHO PALOS
VERDES DOES HEREBY FIND, DETERMINE, AND RESOLVE AS FOLLOWS:
Section 1: The facts set forth in the recitals of this Resolution are true and
correct and are incorporated herein by references as though set forth in full.
Section 2: The City of Rancho Palos Verdes opposes the SCAG-approved draft
RHNA methodology as it fails to consider the City’s unique challenges and physical
constraints, which include geologic hazards, wildlife/habitat preservation , and having over
90% of its territory designated as a Very High Fire Hazard Severity Zone.
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Resolution No. 2019-__
Page 2 of 2
Section 3: The City of Rancho Palos Verdes also opposes the SCAG-approved
draft RHNA methodology as a “top down” housing mandate that, combined with a lack of
available housing sites and the State legislature’s willingness to punish cities that do not
achieve their RHNA allocations, is setting up the City of Rancho Palos Verdes for an
unachievable sixth cycle RHNA allocation.
Section 4: The City of Rancho Palos Verdes urges SCAG and HCD to work
collaboratively with all jurisdictions to ensure that a sixth cycle RHNA allocation
methodology is developed that incorporates closer local input and continues to meet the
objectives of RHNA.
Section 5: The City Clerk shall certify to the passage, approval, and adoption of
this Resolution, and shall cause this Resolution and her certification to be entered in the
Book of Resolutions of the City Council.
PASSED, APPROVED, AND ADOPTED this 17th day of December 2019.
_________________________________
John Cruikshank, Mayor
ATTEST:
____________________________
Emily Colborn, City Clerk
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss
CITY OF RANCHO PALOS VERDES )
I, EMILY COLBORN, City Clerk of the City of Rancho Palos Verdes, do hereby certify
that the above Resolution No. 2019-__, was duly and regularly passed and adopted by
the said City Council at a regular meeting thereof held on December 17, 2019.
__________________________________
City Clerk
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RANCHO PALOS VERDES CITY COUNCIL MEETING DATE: 10/15/2019
AGENDA REPORT AGENDA HEADING: Regular Business
AGENDA DESCRIPTION:
Consideration and possible action to receive and file a report on the status of the
preparation of the Regional Housing Needs Assessment 6th Cycle Allocation Plan
RECOMMENDED COUNCIL ACTION:
(1) Receive and file a report on the preparation of the Regional Housing Needs
Assessment 6th Cycle Allocation Plan.
FISCAL IMPACT: There is no fiscal impact associated with this action.
Amount Budgeted: N/A
Additional Appropriation: N/A
Account Number(s): N/A
ORIGINATED BY: Octavio Silva, Senior Planner
REVIEWED BY: Ara Mihranian, AICP, Director of Community Development
APPROVED BY: Doug Willmore, City Manager
ATTACHED SUPPORTING DOCUMENTS:
A. HCD’s Regional Housing Need Determination Letter, dated August 22,
2019 (page A-1)
B. SCAG’s Objection Letter to Regional Housing Need Determination , dated
September 18, 2019 (page B-1)
C. RHNA Methodology Estimate Tool (Option Nos.1-3) (page C-1)
D. City of Rancho Palos Verdes RHNA Methodology comment letters, dated
August 20, 2019, and September 9, 2019 (page D-1)
E. RHNA Methodology Estimate Tool (Option No. 4) (page E-1)
BACKGROUND AND DISCUSSION:
Regional Housing Needs Assessment (RHNA)
RHNA is a representation of future housing needs for all income levels in a jurisdiction
(city or unincorporated county) and is a requirement of California State Housing Law.
Every jurisdiction must plan for its RHNA allocation in the Housing Element of its
General Plan. The objectives of RHNA include:
Increasing housing supply and mix of housing types, tenure and affordability
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Promoting infill development and socioeconomic equity, protection of resources
and encouraging efficient development patterns
Improving an intraregional relationship between jobs and housing
Allocating a lower proportion of housing need in income categories in areas that
have a disproportionately high share in comparison to the county distribution
Affirmatively further fair housing
The Southern California Association of Governments (SCAG) is the organization tasked
with developing a RHNA allocation plan for the Southern California region. SCAG is the
nation’s largest metropolitan planning organization, which represents six counties and
191 cities, including the City of Rancho Palos Verdes.
The City of Rancho Palos Verdes is currently in the 5th RHNA cycle, which covers the
planning period between the years of 2013 -2021. As part of the current cycle, the City’s
RHNA allocation is a total of 31 housing units in various income levels. The City is
required to provide annual RHNA progress reports to the State’s Housing and
Community Development (HCD) Department. In 2019, the City reported the completion
of 18 housing units with 13 remaining that need to be provided by the year 2021. Staff
will continue to implement the programs as specified in the City’s Housing Element to
ensure that the remaining units are provided by 2021.
SCAG is in the process of preparing a 6th RHNA cycle allocation plan to cover the
planning periods of 2021-2029.
Regional Housing Need Determination
An initial step in developing the allocation plan for the 6th RHNA cycle requires SCAG to
first develop a RHNA methodology by which to distribute existing and projected housing
need to each jurisdiction. HCD is required to provide SCAG with an existing and
projected housing need, referred to as the regional housing need determination. HCD
recently provided SCAG with a regional housing need determination (Attachment A) of
1,344,740 housing units among four income cat egories, which include very-low, low,
moderate and above-moderate income levels. On September 18, 2019, SCAG
submitted an objection letter (Attachment B) to HCD regarding the regional housing
need determination expressing concerns that HCD did not base its determination on
SCAG’s Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)
Growth Forecast, which is contrary to Government Code requirements. As of the
preparation of this report, HCD has not responded to SCAG’s objection letter.
RHNA Methodology Options
On August 2, 2019, SCAG released three RHNA methodology options for the
distribution of the regional housing need determination to local jurisdictions based on a
preliminary assumption of HCD’s regional housing need determination as described
above. A detailed description and analysis of the three methodology options can be
viewed here. In summary, the methodology options consist of two components, which
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include an existing housing need and a projected housing need. The factors used to
derive both components vary among the three methodology options, but generally, the
methodology options include factors such as a jurisdiction’s share of population and
share of population within high quality transit areas, as well as local input and social
equity adjustment. To better assist local jurisdictions in assessing their RHNA allocation
under the different methodology options, SCAG developed a RHNA Methodology
Estimate Tool. Based on the estimate tool (Attachment C), until recently, the City of
Rancho Palos Verdes would have been required to provide the following housing units
across varying income levels depending on the methodology selected by SCAG:
Option No. 1: 1,852 units
Option No. 2: 2,390 units
Option No. 3: 75 units
As part of the consideration of the three RHNA methodology options, SCAG conducted
a public hearing process in order to receive feedback and input from the public and local
jurisdictions. At the end of the 60-day public comment period, SCAG received 250
public comment letters, two of which were from the City of Rancho Palos Verdes
(Attachment D) and which expressed concerns with the three RHNA methodology
options and requested for more local input.
On September 23, 2019, SCAG staff conducted a RHNA Allocation Methodology
Workshop, which previewed the SCAG staff-recommended draft RHNA methodology
option. This option is a hybrid of the three RHNA methodology options and considers
input provided by the public and local jurisdictions during the public comment period. A
detailed description and analysis of the SCAG staff-recommended draft methodology
option can be viewed here. In summary, the draft RHNA methodology is also composed
of both an existing and a projected housing need, similar to the other three methodology
options. The factors used to derive the existing housing need include: A) projected
household growth, B) future vacancy need, and C) replacement need. The factors used
to derive the projected housing need include: A) household growth, B) transit
accessibility, and C) job accessibility. Below is an illustration of the SCAG staff-
recommended draft RHNA methodology option:
Using the RHNA Methodology Estimate Tool (Attachment E), the City would be required
to provide 94 housing units under this draft RHNA methodology. A reason for the City
having an allocated 6th RHNA Cycle need of 94 units compared to a 5th RHNA Cycle
B-3
allocated need of 31 units is that HCD’s 2021-2029 regional determination is 3 times
larger than for the 2013-2021 period (1,344,740 units vs. 412,000 units). The SCAG
staff-recommended draft methodology presents a significant decrease from
methodology option Nos. 1 and 2 being considered by SCAG, but remains higher than
methodology option No. 3. Moreover, this new number remains difficult for the City to
achieve. Staff will continue to pursue efforts to significantly reduce this allocation
number based on the City’s constraints such as the Very High Fire Hazard Severity
Zone, geology, and federal and state-protected biological resources. After the Draft
RHNA Allocation Plan is released (February 2020), the City will have an opportunity to
appeal the need allocated if necessary.
On October 7, 2019, SCAG staff presented their draft RHNA methodology option to
their RHNA Subcommittee for review and consideration. The RHNA Subcommittee
accepted staff’s recommendation to forward the draft RHNA methodology to the
Community, Economic and Human Development (CEHD) Committee for consideration
and recommendation to the Regional Council to submit the draft RHNA methodology to
HCD for a 60-day review.
Next Steps
The next steps in the RHNA 6th Cycle Allocation Plan include, but are not limited to:
October 21, 2019: Presentation of Methodology Option(s) to the SCAG’s CEHD
Committee
November 7, 2019: Presentation of the Methodology Option (s) to the SCAG
Regional Council
November 2019 - January 2020: HCD 60-day review of adopted methodology
January/February 2020: Final RHNA Allocation Methodology approved by HCD
February 2020: Draft RHNA Allocation Plan issued
March-July: Appeal Process
August 2020: Proposed Final RHNA Allocation Plan issued
October 2020: Final RHNA Allocation Plan approved by HCD
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
August 22, 2019
Kome Ajise, Executive Director
Southern California Association of Governments
900 Wilshire Blvd., Ste. 1700
Los Angeles, CA 90017
Dear Executive Director Ajise:
RE: Regional Housing Need Determination
This letter provides the Southern California Association of Governments (SCAG) its
determination of the Regional Housing Need Determination. Pursuant to Government
Code (Gov. Code) section 65584.01, the Department of Housing and Community
Development (HCD) is required to provide the determination of SCAG’s existing and
projected housing need.
In assessing SCAG’s regional housing need, HCD and SCAG staff completed an
extensive consultation process starting in March 2017 through August 2019 covering
the methodology, data sources, and timeline. HCD also consulted with Walter Schwarm
of the California Department of Finance (DOF) Demographic Research Unit.
Attachment 1 displays the minimum regional housing need determination of 1,344,740
total units among four income categories for SCAG to distribute among its local
governments. Attachment 2 explains the methodology applied pursuant to Gov. Code
section 65584.01.
As you know, SCAG is responsible for adopting a RHNA allocation methodology for the
projection period beginning June 30, 2021 and ending October 15, 2029. Pursuant to
Gov. Code section 65584(d), SCAG’s RHNA allocation methodology must further the
following objectives:
(1) Increasing the housing supply and the mix of housing types, tenure, and affordability in all
cities and counties within the region in an equitable manner, which shall result in each jurisdiction
receiving an allocation of units for low- and very low income households.
(2) Promoting infill development and socioeconomic equity, the protection of environmental and
agricultural resources, the encouragement of efficient development patterns, and the
achievement of the region’s greenhouse gas reductions targets provided by the State Air
Resources Board pursuant to Section 65080.
(3) Promoting an improved intraregional relationship between jobs and housing, including an
improved balance between the number of low-wage jobs and the number of housing units
affordable to low-wage workers in each jurisdiction.
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(4) Allocating a lower proportion of housing need to an income category when a jurisdiction
already has a disproportionately high share of households in that income category, as compared
to the countywide distribution of households in that category from the most recent American
Community Survey.
(5) Affirmatively furthering fair housing.
Pursuant to Gov. Code section 65584.04(e), to the extent data is available, SCAG shall
include the factors listed in Gov. Code section 65584.04(e)(1-12) to develop its RHNA
allocation methodology, and pursuant to Gov. Code section 65584.04(f), SCAG must
explain in writing how each of these factors was incorporated into the RHNA allocation
methodology and how the methodology furthers the statutory objectives described
above. Pursuant to Government Code section 65584.04(h), SCAG must consult with
HCD and submit its draft allocation methodology to HCD for review.
HCD appreciates the active role of SCAG staff in providing data and input throughout
the consultation period. Pursuant to Government Code section 65584.01(c)(1), HCD
may accept or reject the information provided by the council of governments or modify
its own assumptions based on this information.
The Department especially thanks Ping Chang, Ma’Ayn Johnson, Kevin Kane, and
Sarah Jepson. The Department looks forward to its continued partnership with SCAG
and its member jurisdictions and assisting SCAG in its planning efforts to accommodate
the region’s share of housing need.
If HCD can provide any additional assistance, or if you, or your staff, have any
questions, please contact Megan Kirkeby, Assistant Deputy Director for Fair Housing, at
megan.kirkeby@hcd.ca.gov.
Sincerely,
Megan Kirkeby
Assistant Deputy Director for Fair Housing
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ATTACHMENT 1
HCD REGIONAL HOUSING NEED DETERMINATION
SCAG: June 30, 2021 – October 15, 2029 (8.3 years)
Income Category Percent Housing Unit Need
Very-Low* 26.1% 350,998
Low 15.3% 206,338
Moderate 16.7% 225,152
Above-Moderate 41.8% 562,252
Total 100.0% 1,344,740
* Extremely-Low 14.5% Included in Very-Low Category
Notes:
Income Distribution:
Income categories are prescribed by California Health and Safety Code
(Section 50093, et.seq.). Percents are derived based on ACS reported
household income brackets and regional median income, then adjusted
based on the percent of cost-burdened households in the region
compared with the percent of cost burdened households nationally.
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ATTACHMENT 2
HCD REGIONAL HOUSING NEED DETERMINATION
SCAG: June 30, 2021 – October 15, 2029 (8.3 years)
Methodology
SCAG: June 30, 2021-October 15, 2029 (8.3 Years)
HCD Determined Population, Households, & Housing Need
1. Population: DOF 6/30/2029 projection adjusted +3.5 months to 10/15/2029 20,455,355
2. - Group Quarters Population: DOF 6/30/2029 projection adjusted +3.5 months to 10/15/2029 -363,635
3. Household (HH) Population: October 15, 2029 20,079,930
Household Formation Groups
HCD Adjusted
DOF Projected
HH Population
DOF HH
Formation
Rates
HCD Adjusted
DOF Projected
Households
20,079,930 6,801,760
under 15 years 3,292,955 n/a n/a
15 – 24 years 2,735,490 6.45% 176,500
25 – 34 years 2,526,620 32.54% 822,045
35 – 44 years 2,460,805 44.23% 1,088,305
45 – 54 years 2,502,190 47.16% 1,180,075
55 – 64 years 2,399,180 50.82% 1,219,180
65 – 74 years 2,238,605 52.54% 1,176,130
75 – 84 years 1,379,335 57.96% 799,455
85+ 544,750 62.43% 340,070
4. Projected Households (Occupied Unit Stock) 6,801,760
5. + Vacancy Adjustment (2.63%) 178,896
6. + Overcrowding Adjustment (6.76%) 459,917
7. + Replacement Adjustment (.50%) 34,010
8. - Occupied Units (HHs) estimated (June 30, 2021) -6,250,261
9. + Cost Burden Adjustment (Lower Income: 10.63%, Moderate and Above Moderate Income: 9.28%) 120,418
6th Cycle Regional Housing Need Assessment (RHNA) 1,344,740
Explanation and Data Sources
1-4. Population, Group Quarters, Household Population, & Projected Households: Pursuant to
Government Code Section 65584.01, projections were extrapolated from Department of
Finance (DOF) projections. Population reflects total persons. Group Quarter Population
reflects persons in a dormitory, group home, institution, military, etc. that do not require
residential housing. Household Population reflects persons requiring residential housing.
Projected Households reflect the propensity of persons, by age-groups, to form households
at different rates based on Census trends.
5. Vacancy Adjustment: HCD applies a vacancy adjustment based on the difference between a
standard 5% vacancy rate and the region’s current "for rent and sale" vacancy percentage to
provide healthy market vacancies to facilitate housing availability and resident mobility. The
adjustment is the difference between standard 5% and region’s current vacancy rate (2.37%)
based on the 2013-2017 5-year American Community Survey (ACS) data. For SCAG that
difference is 2.63%.
6. Overcrowding Adjustment: In region’s where overcrowding is greater than the U.S
overcrowding rate of 3.35%, HCD applies an adjustment based on the amount the region’s
overcrowding rate (10.11%) exceeds the U.S. overcrowding rate (3.35%) based on the 2013-
2017 5-year ACS data. For SCAG that difference is 6.76%.
Continued on next page
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7. Replacement Adjustment: HCD applies a replacement adjustment between .5% & 5% to total
housing stock based on the current 10-year average of demolitions in the region’s local
government annual reports to Department of Finance (DOF). For SCAG, the 10-year average
is .14%, and SCAG’s consultation package provided additional data on this input indicating it
may be closer to .41%; in either data source the estimate is below the minimum replacement
adjustment so the minimum adjustment factor of .5% is applied.
8. Occupied Units: Reflects DOF's estimate of occupied units at the start of the projection period
(June 30, 2021).
9. Cost Burden Adjustment: HCD applies an adjustment to the projected need by comparing the
difference in cost-burden by income group for the region to the cost-burden by income group
for the nation. The very-low and low income RHNA is increased by the percent difference
(70.83%-60.20%=10.63%) between the region and the national average cost burden rate for
households earning 80% of area median income and below, then this difference is applied to
very low- and low-income RHNA proportionate to the share of the population these groups
currently represent. The moderate and above-moderate income RHNA is increased by the
percent difference (20.48%-11.20%=9.28%) between the region and the national average
cost burden rate for households earning above 80% Area Median Income, then this
difference is applied to moderate and above moderate income RHNA proportionate to the
share of the population these groups currently represent. Data is from 2011-2015
Comprehensive Housing Affordability Strategy (CHAS).
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September 18, 2019
Mr. Doug McCauley
Acting Director
Housing & Community Development (HCD)
2020 W. El Camino Ave.
Sacramento, CA 95833
Subject: SCAG’s Objection to HCD’s Regional Housing Need
Determination
Dear Mr. McCauley,
This letter represents the Southern California Association of Governments
(SCAG)’s formal objection to HCD’s Regional Housing Need
Determination as submitted to SCAG on August 22, 2019 and is made in
accordance with Government Code Section 65584.01(c)(2)(A) and (B). At
the outset, please know that SCAG is fully aware that the State of California
is in the midst of a housing crisis and that resolving this crisis requires strong
partnerships with state, regional and local entities in addition to private and
non-profit sectors.
As such, SCAG desires to be an active and constructive partner with the State
and HCD on solving our current housing crisis, and this objection should not
suggest otherwise. We are in fact currently setting up a housing program that
will assist our local jurisdictions on activities and policies that will lead to
actual housing unit construction.
In the context of the 6th cycle Regional Housing Needs Assessment (RHNA)
process, SCAG appreciates the collaboration with HCD as reflected in the
numerous consultation sessions on the regional determination and other staff
engagement on housing issues with the objective of making RHNA a
meaningful step toward addressing our housing crisis.
As you are aware, HCD transmitted its Regional Housing Needs
Determination of 1,344,740 units for the SCAG region last month. This
number reflects the housing units that local jurisdictions in the region must
plan for during the 8-year period from October 2021 to October 2029. At
the September 5, 2019 meeting, SCAG Regional Council authorized staff to
file an objection to HCD on regional housing need determination pursuant
to Government Code Section 65584.01(c).
B-10
I would like to note that SCAG’s objection focuses on the process and adherence to state housing
law requirements and not necessarily to the regional housing need determination number. The
ultimate aim of this objection, as discussed at length by the Regional Council, is to ensure the most
technically and legally credible basis for a regional determination so that the 197 local
jurisdictions in the SCAG region can approach the difficult task of zoning to accommodate
regional needs with the backing of the most robust and realistic target that is possible.
One of our major concerns is that HCD did not base its determination on SCAG’s RTP/SCS
Growth Forecast, which was inconsistent with Government Code 65584.01(c)(2)(A). Another
major concern is that pursuant to Government Code 65584.01(c) (2) (B), HCD’s determination of
housing need in the SCAG region is not a reasonable application of the methodology and
assumptions described in statute. Specifically, HCD compared household overcrowding and cost-
burden rates in the SCAG region to national averages rather than to rates in comparable regions as
statutorily required. These and two additional basis for objections are described in detail in the
section below which also includes a deduction for household growth on tribal land and a concern
that the vacancy rate standards used by HCD are not substantiated by data, analysis, or literature.
In addition, the attached EXCEL worksheet and technical documentation contain SCAG’s
alternative proposed 6th cycle RHNA determination, which would consist of a range of total
housing unit need between 823,808 and 920,772.
BASIS FOR SCAG OBJECTION
Use of SCAG’s Population Forecast
HCD did not base its determination on SCAG’s RTP/SCS Growth Forecast, which was provided
in the original consultation package and via follow-up email to HCD. Government Code
65584.01(a) indicates [emphasis added]:
“(a) The department’s determination shall be based upon population projections produced by the
Department of Finance and regional population forecasts used in preparing regional
transportation plans, in consultation with each council of governments. If the total regional
population forecast for the projection year, developed by the council of governments and used
for the preparation of the regional transportation plan, is within a range of 1.5 percent of the
total regional population forecast for the projection year by the Department of Finance, then
the population forecast developed by the council of governments shall be the basis from which
the department determines the existing and projected need for housing in the region. If the
difference between the total population projected by the council of governments and the total
population projected for the region by the Department of Finance is greater than 1.5 percent, then
the department and the council of governments shall meet to discuss variances in methodology
used for population projections and seek agreement on a population projection for the region to
be used as a basis for determining the existing and projected housing need for the region. If no
agreement is reached, then the population projection for the region shall be the population
projection for the region prepared by the Department of Finance as may be modified by the
department as a result of discussions with the council of governments.”
B-11
SCAG projects total regional population to grow to 20,725,878 by October, 2029. SCAG’s
projection differs from Department of Finance (DOF) projection of 20,689,591, which was issued
by DOF in May, 2018, by 0.18%. The total population provided in HCD’s determination is
20,455,355, reflecting an updated DOF projection, differs from SCAG’s projection by 1.32%. As
SCAG’s total projection is within the statutory tolerance of 1.5%, accordingly HCD is to use
SCAG’s population forecast.
While HCD has emphasized that consistency in approach to the 6th cycle RHNA across regions is
a priority, deference to the Council of Governments’ forecast as specified in statute is an important
aspect of regional planning. Federal requirements for SCAG’s Regional Transportation Plan
necessitate a forecast of population, households, and employment for evaluating future land use
patterns and measuring future travel demand as well as air quality conformity under the federal
Clean Air Act. In addition, under SB 375, the State requires SCAG to develop a Sustainable
Communities Strategy which is a coordination of transportation and land use in the regional
planning process to achieve State’s climate goals. Both federal and State requirements are
predicated on SCAG’s forecast of population, households and employment.
As a result, SCAG has a long-established and well-respected process for producing a balanced
forecast of population, households, and employment for the region, the details of which can be
found in each Regional Transportation Plan (e.g.
http://scagrtpscs.net/Documents/2016/final/f2016RTPSCS_DemographicsGrowthForecast.pdf).
SCAG’s quadrennial growth forecast begins with a consensus on appropriate assumptions of
fertility, migration, immigration, household formation, and job growth by a panel of state and
regional experts including members of DOF’s Demographic Research Unit. In addition, SCAG
co-hosts an annual demographic workshop with the University of Southern California to keep state
and regional experts and stakeholders appraised of demographic and economic trends
(https://www.scag.ca.gov/calendar/Pages/DemographicWorkshop.aspx).
SCAG places a high priority on generating its own forecasts of population, households, and
employment and ensuring the highest possible degree of consistency and integrity of its projections
for transportation, land use, and housing planning purposes.
Use of Comparable Regions
Pursuant to Government Code 65584.01(c)(2)(B), HCD’s determination of housing need in the
SCAG region is not a reasonable application of the methodology and assumptions described in
statute. Specifically, HCD compared household overcrowding and cost-burden rates in the SCAG
region to national averages rather than to rates in comparable regions as statutorily required.
SCAG’s initial consultation package provided an approach using comparable regions to evaluate
household overcrowding SCAG staff met with HCD staff in-person in both Los Angeles and
Sacramento to discuss adjustment criteria and how to define a comparable region to Southern
California, as our region’s size precludes a straightforward comparison. At the direction of HCD,
SCAG staff refined its methodology for identifying comparable regions and provided a state-of-
the-practice analysis supported by recent demographic and economic literature which determined
B-12
that the most appropriate comparison to the SCAG region would be an evaluation against the San
Jose, New York, San Francisco, Miami, Seattle, Chicago, San Diego, Washington D.C., Houston,
and Dallas metropolitan areas. Despite this collaboration on the subject between HCD and SCAG,
HCD elected to reject this approach and instead used national average statistics, which include
small metropolitan areas and rural areas having little in common with Southern California.
HCD’s choice to use national averages:
Is inconsistent with the statutory language of SB 828, which added the comparable region
standard to RHNA law in order to improve the technical robustness of measures of housing
need.
Is inconsistent with empirical data as economic and demographic characteristics differ
dramatically based on regional size and context. For comparison, the median-sized
metropolitan region in the country is Fargo, North Dakota with a population of 207,500. That
is not a meaningful basis of comparison for the nation’s largest MPO.
Is inconsistent with HCD’s own internal practice for the 6th cycle of RHNA. The regional need
determination for the Sacramento Area Council of Governments (SACOG), issued on July 18,
2019, was the first 6th cycle RHNA determination following SB 828’s inclusion of the
comparable region standard. During their consultation process with HCD, SACOG also
produced a robust technical analysis to identify comparable regions for the purposes of using
overcrowding and cost-burden statistics to determine regional housing needs. However,
HCD’s final determination for SACOG used this analysis while the SCAG region was held to
a different and less reasonable standard.
Improved Vacancy Rate Comparison
HCD seemingly uses unrealistic comparison points to evaluate healthy market vacancy, which is
also an unreasonable application of the methodology and assumptions described in statute. While
SB 828 specifies a vacancy rate for a healthy rental housing market as no less than 5 percent,
healthy market vacancy rates for for-sale housing are not specified. HCD’s practice is to compare
actual, ACS vacancy rates for the region versus a 5 percent total vacancy rate (i.e. owner and renter
markets combined).
During the consultation process, SCAG discussed this matter with HCD staff and provided several
points of comparison including historical data, planning standards, and comparisons with other
regions. In addition, SCAG staff illustrated that given tenure shares in the SCAG region, HCD’s
suggestion of a 5 percent total vacancy rate is mathematically equivalent to an 8 percent rental
market vacancy rate plus a 2.25 percent for-sale housing vacancy rate. However, in major
metropolitan regions, vacancy rates this high are rarely experienced outside of severe economic
recessions such as the recent, housing market-driven Great Recession. Given the region’s current
housing shortage, the high volume of vacant units envisioned in HCD’s planning target would be
rapidly absorbed, making it an unrealistic standard.
B-13
SCAG staff’s original suggestion of 5 percent rental vacancy and 1.5 percent for-sale vacancy
(resulting in a 3.17 percent total vacancy rate based on current tenure shares) is in fact higher than
the observed rate in the comparable regions defined above. It is also above Federal Housing
Authority standards for regions experiencing slow or moderate population growth. It is also above
the very liberal standard of 6 percent for for-rent housing and 2 percent for for-sale housing
suggested by the California Office of Planning and Research (equivalent to 3.90 percent total
vacancy based on SCAG tenure shares) which would also be a more reasonable application of the
methodology.1
Additional Considerations
In addition to the three key points above, SCAG’s proposed alternative includes several other
corrections to technical shortcomings in HCD’s analysis of regional housing needs.
1. HCD’s evaluation of replacement need is based on an arbitrary internal standard of 0.5 percent
to 5.0 percent of total housing units. 2010-2019 demolition data provided by DOF suggest that
over an 8.25-year period, it is reasonable to expect that 0.14 percent of the region’s total
housing units will be demolished, but not replaced. This would form the basis of a more
reasonable housing needs determination, as DOF’s survey represents the most comprehensive
and robust data available.
2. Anticipated household growth on tribal land was not excluded from the regional determination
as indicated in the consultation package and follow-up communications. Tribal entities within
the SCAG region have repeatedly requested that this estimate be excluded from the RHNA
process entirely since as sovereign nations, state law does not apply. SCAG’s proposed
approach is to subtract estimates of household growth on tribal land from the regional
determination and ensure that these figures are also excluded from local jurisdictions’ annual
progress reports (APRs) of new unit construction to HCD during the 6th cycle.
3. A refinement to the adjustment for cost burden would yield a more reasonable determination
of regional housing needs. SCAG has repeatedly emphasized the shortcomings of and overlap
across various ACS-based measures of housing need. Furthermore, the relationship between
new unit construction and cost burden is poorly understood (i.e., what will be the impact of
new units on cost, and by extension, cost-burden). Nonetheless, SCAG recognizes that the
region’s cost burden exceeds that of comparable regions and proposes one modification to
HCD’s methodology, which currently considers cost burden separately by lower and higher
income categories.
While housing security is dependent on income, it is also heavily dependent on tenure. While
spending above 30 percent of gross income on housing for renters can reflect true housing
insecurity, spending above this threshold for owners is substantially less problematic. This is
particularly true for higher income homeowners, who generally benefit from housing shortages
as it results in home value appreciation. Thus, a more reasonable application of cost burden
1 See Nelson, AC. (2004), Planner’s Estimating Guide Projecting Land-Use and Facility Needs. Planners Press,
American Planning Association, Chicago. P. 25.
B-14
statistics would exclude cost-burden experienced by moderate and above-moderate owner
households and instead make an adjustment based on three of the four income and tenure
combinations: lower-income renters, higher-income renters, and lower-income owners.
4. From our review, HCD’s data and use of data is not current. In large metropolitan regions,
there is no reasonable basis for using 5-year ACS data, which reflects average conditions from
2013 to 2017. For cost-burden adjustments, HCD relies on 2011-2015 CHAS data. By the
beginning of the 6th cycle of RHNA, some of the social conditions upon which the
determination is based will be eight years old.
During the consultation process, SCAG staff provided HCD with Excel-version data of all
inputs needed to replicate their methodology using ACS 2017 1-year data (the most recent
available); however, this was not used. The Census bureau is scheduled to release ACS 2018
1-year data on September 26, 2019. SCAG staff would support replicating the same analysis,
but substituting 2018 data when it becomes available in order to ensure the most accurate
estimates in planning for the region’s future.
Finally, given that the manner and order in which modifications are made affects the total housing
need, the attachments demonstrate two alternatives with varying interpretations of three of the
above points (see boldface, red text in attachments):
- Vacancy rate comparison – SCAG’s originally proposed values versus an alternative which
emerged from the consultation process
- Replacement need – DOF survey value versus HCD’s current practice
- Cost burden measure – whether or not to include higher-income homeowners in this
adjustment
We appreciate your careful consideration of this objection. RHNA is a complex process and we
recognize the difficult positions that both SCAG and HCD are in but are hopeful that our agencies
can reach a reasonable conclusion with respect to the regional need determination. Please contact
me if you have questions. I look forward to continuing our close partnership to address the housing
crisis in our state.
Sincerely,
Kome Ajise
Executive Director
Attachments
1. SCAG Alternative Determination
2. Excel version: SCAG Alternative Determination and supporting data
3. HCD Letter on Regional Need Determination, August 22, 2019
B-15
Attachment 1
SCAG Alternative Determination
1 OPTION A: SCAG region housing needs, June 30 2021-October 1 2029 (8.25 Years)
2 Population: Oct 1, 2029 (SCAG 2020 RTP/SCS Forecast)20,725,878
3 - Less Group Quarters Population (SCAG 2020 RTP/SCS Forecast)-327,879
4 Household (HH) Population, Oct 1, 2029 20,397,998
Household Formation Groups
20,397,998 6,668,498
under 15 years 3,812,391 n/a
15 - 24 years 2,642,548 147,005
25 - 34 years 2,847,526 864,349
35 - 44 years 2,821,442 1,304,658
45 - 54 years 2,450,776 1,243,288
55 - 64 years 2,182,421 1,116,479
65 -74 years 1,883,181 1,015,576
75 - 84 years 1,167,232 637,415
85+590,480 339,727
5 Projected Households (Occupied Unit Stock)6,668,498
6 + Vacancy Owner Renter
Tenure Share (ACS 2017 1-year)52.43% 47.57%
Households by Tenure 3,496,058 3,172,440
Healthy Market Vacancy Standard 1.50% 5.00%
SCAG Vacancy (ACS 2017 1-year)1.13% 3.30%
Difference 0.37% 1.70%
Vacancy Adjustment 12,953 53,815 66,768
7 + Overcrowding (Comparison Point vs. Region ACS %)5.20% 9.82% 4.62%308,264
8 + Replacement Adj (Actual DOF Demolitions)9,335
- Household Growth on Tribal Land (SCAG Estimate)-2,766
9 - Occupied Units (HHs) estimated June 30, 2021 (from DOF data)-6,250,261
10 + Cost-burden Adjustment (Comparison Point vs. Region)23,969
823,808
SCAG Projected
HH Population Headship rate -
see Table 2
Projected
Households
6th Cycle Regional Housing Need Assessment (RHNA)
0.14%
B-16
1 OPTION B: SCAG region housing needs, June 30 2021-October 1 2029 (8.25 Years)
2 Population: Oct 1, 2029 (SCAG 2020 RTP/SCS Forecast)20,725,878
3 - Less Group Quarters Population (SCAG 2020 RTP/SCS Forecast)-327,879
4 Household (HH) Population, Oct 1, 2029 20,397,998
Household Formation Groups
20,397,998 6,668,498
under 15 years 3,812,391 n/a
15 - 24 years 2,642,548 147,005
25 - 34 years 2,847,526 864,349
35 - 44 years 2,821,442 1,304,658
45 - 54 years 2,450,776 1,243,288
55 - 64 years 2,182,421 1,116,479
65 -74 years 1,883,181 1,015,576
75 - 84 years 1,167,232 637,415
85+590,480 339,727
5 Projected Households (Occupied Unit Stock)6,668,498
6 + Vacancy Owner Renter
Tenure Share (ACS 2017 1-year) 52.43% 47.57%
Households by Tenure 3,496,058 3,172,440
Healthy Market Vacancy Standard 2.00% 6.00%
SCAG Vacancy (ACS 2017 1-year) 1.13% 3.30%
Difference 0.87% 2.70%
Vacancy Adjustment 30,433 85,540 115,973
7 + Overcrowding (Comparison Point vs. Region ACS %)5.20% 9.82% 4.62%308,264
8 + Replacement Adj (HCD minimum standard)33,340
- Household Growth on Tribal Land (SCAG Estimate)-2,766
9 - Occupied Units (HHs) estimated June 30, 2021 (from DOF data)-6,250,261
10 + Cost-burden Adjustment (Comparison Point vs. Region)47,724
920,772 6th Cycle Regional Housing Need Assessment (RHNA)
SCAG Projected
HH Population Headship rate -
see Table 2
Projected
Households
0.50%
B-17
1
2-5
6
7
8
9
10
Cost Burden Adjustment: A cost-burden adjustment is applied to the projected need by comparing the difference in cost-burden by income and
tenure group for the region to the cost-burden by income and tenure group for comparable regions. Data are from 2017 1-year ACS and the ACS
$50,000/year household income threshold is used to distinguish between lower and higher income groups. The lower income RHNA is increased by
the percent difference between the region and the comparison region cost burden rate for households earning approximately 80% of area median
income and below (88.89%-84.39%=4.51% for renters and 27.33%-20.97%=6.36% for owners), then this difference is applied to very low- and low-
income RHNA proportionate to the share of the population these groups currently represent (Very Low=63% of lower, Low=37% of lower). The
higher income RHNA is increased by the percent difference between the region and the comparison region cost burden rate (67.15%-65.53%=1.62%
for renters and 23.78%-17.06%=6.72% for owners) for households earning above 80% Area Median Income, then this difference is applied to
moderate and above moderate income RHNA proportionate to the share of the population these groups currently represent (Moderate=29% of
higher, Above Moderate=71% of higher). SCAG's analysis of the cost-burden measure suggests that it may be less appropriate to apply for
higher-income owners and it may be excluded from the adjustment.
Occupied Units: Reflects DOF's estimate of occupied units at the start of the projection period (June 30, 2021).
Projection period: Gov. Code 65588(f) specifies RHNA projection period start is December 31 or June 30, whichever date most closely precedes end
of previous RHNA projection period end date. RHNA projection period end date is set to align with planning period end date. The planning period
end date is eight years following the Housing Element due date, which is 18 months following the Regional Transportation Plan adoption rounded to
the 15th or end of the month.
Population, Group Quarters, Household Population, & Projected Households: Pursuant to Government Code Section 65584.01, projections were
extrapolated from SCAG's Regional Transportation Plan projections. Population reflects total persons. Group Quarter Population reflects persons in
a dormitory, group home, institution, military, etc. that do not require residential housing. Household Population reflects persons requiring residential
housing. Projected Households reflect the propensity of persons, by age-groups, to form households at different rates based on Census trends.
Vacancy Adjustment: Pursuant to Government Code 65584.01, a 5% minimum is considered to be healthy market vacancy in the for-rent housing
market. Vacancy rates in the for-sale market are unspecified in statute. SCAG's analysis of vacancy rates suggests a healthy market standard
of 5% for fore-rent housing and 1.5% for for-sale housing. After extensive consultation with HCD, a review of historical trends, regional
and national comparison, and various planning standards, a more liberal vacancy standard of 6% for for-rent housing and 2% for for-sale
housing may also be supported by this analysis. These standards are compared against ACS 2017 1-year data based on the renter/owner share in
the SCAG region.
Overcrowding Adjustment: In regions where overcrowding is greater than the Comparable Region Rate, an adjustment is applied based on the
amount the region's overcrowding rate (9.82%) exceeds the Comparable Region Rate (5.20%). Data is from 2017 1-year ACS.
Replacement Adjustment: A replacement adjustment is applied based on the current 10-year average % of demolitions according to local government
annual reports to Department of Finance. While these data suggest an adjustment of 0.14% is most appropriate, SCAG recognizes that
HCD's internal practice is to use an adjustment factor of 0.5%.
B-18
Income Category Percent Housing Unit Need
Very-Low *25.8%212,284
Low 15.1%124,375
Moderate 17.1%140,601
Above-Moderate 42.1%346,547
Total 100.0%823,808
* Extremely-Low 14.6%
Income Category Percent Housing Unit Need
Very-Low *25.8%231,084
Low 15.1%135,390
Moderate 17.1%159,982
Above-Moderate 42.1%394,316
Total 100.0%920,772
* Extremely-Low 14.6%
Option A: Regional Housing Need Allocation (RHNA) Determination
SCAG Region
June 30, 2021 through October 1, 2029
Option B: Regional Housing Need Allocation (RHNA) Determination
SCAG Region
June 30, 2021 through October 1, 2029
included in Very-Low Category
Income Distribution : Income categories are prescribed by California Health
and Safety Code (Section 50093, et.seq.). Percents are derived based on
ACS reported household income brackets and county median income, then
adjusted based on the percent of cost-burdened households in the region
compared with the percent of cost burdened households nationally.
included in Very-Low Category
B-19
Regional Housing Needs Assessment Methodology Estimate Tool (Option No.1-3)
B-20
B-21CITY OF August20, 2019 Honorable Peggy Huang, Chair Regional Housing Needs Assessment Subcommittee Southern California Association of Governments 900 Wilshire Blvd, Suite No. 1700 Los Angeles, CA 90017 RANCHO PALOS VERDES COMMUNITY DEVELOPMENT DEPARTMENT SUBMITTED ELECTRONICALLY SUBJECT: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) PROPOSED METHODOLOGY Dear Chair Huang, The City of Rancho Palos Verdes appreciates the opportunity to provide the following comments on the proposed RHNA methodology for your consideration. Since the 2013 adoption of the Housing Element, the City has actively engaged in implementing the goals and policies of the Housing Element including the creation of housing units to meet designated RHNA allocations. More specifically, the City has provided for housing units in various income levels and anticipates that remaining units will be provided as identified in the City's Housing Element. The City joins other jurisdictions in expressing concerns as to the feasibility of meeting new RHNA allocations under the methodology options proposed by the Southern California Association of Governments (SCAG). While the City supports the development of housing units that improve the availability of affordable and safe housing throughout the region, the City also promotes housing that reflects the City's character and recognizes development constraints and hazards. The City requests that SCAG consider the following challenges that face the City, as it considers proposed methodology options for the upcoming 61h RHNA cycle: 1) Very High Fire Severity Zone Approximately 97% of the City of Rancho Palos Verdes is located within the Very High Fire Severity Zone, as classified through the California Department of Forestry and Fire Protection. Senate Bill 35 recognizes the hazards associated with such classifications by exempting mandatory density provisions for very high fire severity zone communities. The City requests that this designation weigh heavily on the methodology option selected for Rancho Palos Verdes. 2) Geologic Hazards The Portuguese Bend Landslide Complex (PBLC), which is the largest fastest moving landslide in North America, is located along the south central section of the Palos Verdes Peninsula entirely within the City of Rancho Palos Verdes. The terminus of the active landslide complex, and generally the southwest boundary of the PBLC is the Pacific Ocean. The PBLC is divided into two parts with the main landslide having an area of about 190 acres and the other segment having an 30940 I lA VVTHr lf\fiE Rl ll li_EVAf<D I !\ANI ;11r l I 'ALO~ \IEI~DES 1 ~A 90275-5391 I (3101 544-5228 I FAX 13101 544-5293 WWVV f<PVCA GOV 0 PRINl ED ON RECYCLED PAr>m
B-22area of about 70 acres. The PBLC moves at various rates and over the last several decades has resulted in significant infrastructure damage to homes, utilities, and roadways. The City has expended nearly 50 million dollars over the years repairing and maintaining the damage and addressing the overall technical and administrative issues associated with managing such a complex problem. As a result of geologic and geotechnical studies, the City prohibits the construction on vacant lots within the entire PBLC through with the establishment of a landslide moratorium area that has been codified since 1978. 3) Wildlife and Habitat Preservation The City of Rancho Palos Verdes includes area of lands that are protected from development as a result of Federal and State programs. More specifically, the City has adopted a Natural Community Preservation Plan and Habitat Conservation Plan (NCCP/HCP or Plan). The Plan was prepared to maximize the benefits to wildlife and vegetation communities while accommodating appropriate economic development within the City. The City's primary conservation strategy is to dedicate 1,402.4 acres of habitat protection for the NCCP/HCP Preserve assembly. The dedication includes Existing Public Lands that are currently owned by the City (1,123.0 acres) and the Palos Verdes Peninsula Land Conservancy (PVPLC) (20.7 acres). The remainder of the Preserve is comprised of 258.7 acres of City owned land or land that will eventually be owned by the City which has been previously dedicated for conservation as mitigation for certain private projects and will be added to the Preserve. The City also includes the Abalone Cove, which contains a State-designated Ecological Preserve with important natural marine resources at the bottom of the Portuguese Bend landslide area. The City's NCCP/HCP is unique to Los Angeles County, as it is the only such Plan in the County. It benefits the natural environment and protection of species, including listed endangered species, as well as passive recreational opportunities to the general public. The approximate 1 ,400 acres of undeveloped vacant open space that make up the Palos Verdes Nature Preserve is encumbered with conservation easements and deed restrictions that prohibit development in perpetuity which should be factored in the RHNA methodology applied to the City. In addition to the large areas of the City dedicated to wildlife and vegetation communities, the City also is home to three federal facilities. These include the Point Vicente Lighthouse and Coast Guard Station (29 acres}, the United States Air Force and Federal Aviation Administration Radar Station (11 acres) on San Pedro Hill, and a World War II bunker and Coast Guard antenna site (4 acres) at Point Vicente Park/Civic Center. The City would like to thank the Chair and Committee in advance for considering the unique challenges and physical constraints that face Rancho Palos Verdes, and asks that such factors weigh heavily in considering the methodology for the upcoming 61h RHNA cycle. If you should have any questions, or would like further assistance, please feel free to contact me at (31 0) 544-5227 or by email at aram@rpvca.gov. Ara Mihranian, ACIP Director of Community Development c: Jerry Duhovic, Mayor. Rancho Palos Verdes Rancho Palos Verdes City Council Doug Wilmore, City Manager Octavia Silva, Senior Planner
B-23CITY OF September 9, 2019 Honorable Peggy Huang, Chair Regional Housing Needs Assessment Subcommittee Southern California Association of Governments 900 Wilshire Blvd, Suite No. 1700 Los Angeles, CA 90017 RANCHO PALOS VERDES COMMUNITY DEVELOPMENT DEPARTMENT SUBMITTED ELECTRONICALLY SUBJECT: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) PROPOSED METHODOLOGY Dear Chair Huang, On August 20, 2019, the City of Rancho Palos Verdes submitted a comment letter regarding the proposed 61h cycle RHNA methodology options currently being considered by the Southern California Association of Governments (SCAG). The City's comment letter highlighted the unique challenges and physical constraints that face the City, such as being designated a Very High Fire Hazard Severity Zone, the presence of geologic hazards, and the preservation of sensitive wildlife and habitat. The comment letter urged the RHNA Subcommittee to consider such factors in selecting a RHNA methodology. Since the issuance of the City's comment letter, the State's Housing and Community Development Department (HCD) issued a regional determination need of 1,344,740 total housing units for the SCAG region. Based on this figure and using SCAG's RHNA Methodologies Estimate Tool, the City of Rancho Palos Verdes would have a RHNA allocation of 1,852 housing units under Option 1, 2,390 housing units under Option 2, and 75 housing units under Option 3. Methodology Options 1 and 2 present a significantly higher RHNA allocation than what the City was assigned for the 51h RHNA cycle. These methodology options would pose an undue burden upon the City to accommodate for housing in the next Housing Element cycle without considering the unique physical challenges faced by the City. The City would also like to bring attention to the need for housing with access to high-quality transit in order to meet the State's objectives to reduce greenhouse gas emissions and vehicle miles traveled. The City of Rancho Palos Verdes, along with its neighboring Palos Verdes Peninsula cities, are located in a region with very limited access to high-quality transit. In fact, the City recently learned that, due to the recent reduction in ridership, the LA Metro is considering eliminating Route 344, which serves Hawthorne Blvd., a major arterial for the Peninsula. With limited access to high-quality transit, combined with the consideration to eliminate Route 344, any new high-density housing required to be built in the City by the State will inevitably require residents to rely primarily upon private vehicles for transportation. Based on Options 1 and 2--and perhaps Option 3--the State-mandated housing units will result in a significant increase in vehicle miles traveled and greenhouse gas emissions, which is fundamentally counterproductive with the State's and Governor's objectives. The City recommends that SCAG appeal HCD's regional determination need figure before deciding on a RHNA methodology option. The City also strongly urges SCAG to select RNHA Methodology Option 3, as 30~40 11<'\WTIIr >f<I~E 131 >I ILE\IAf\1 >I f\ANI ~Ht >I 'AU J:--; VE:I\flb I A 8021!1-5391 I 13101 544-!1228 I FAX 1310\ 544-5293 WV'.'VI' f<I'VCA GOV 0 PI<INTED ON RECYCLED PAPEJ<
B-24this option most appropriately utilizes local input amongst the three options, and provides the City with a RHNA allocation that the City can plan for in the upcoming Housing Element planning cycle. If you should have any questions, or would like further assistance, please feel free to contact me at (31 0) 544-5227 or by email at aram@rpvca.gov. '\ ra in , ACIP Director of Community Development c: Jerry Duhovic, Mayor, Rancho Palos Verdes Rancho Palos Verdes City Council Hon. Dan Medina, RC District# 28, GCCOG Hon. James Gazeley, RC District# 39, SBCCOG Hon. Judy Mitchell, RC District #40, SBCCOG Jacki Bacharach, Executive Director of the SBCCOG Doug Wilmore, City Manager Kit Fox, Interim Deputy Director of Community Development Octavia Silva, Senior Planner
Regional Housing Needs Assessment Methodology Estimate Tool (Option No. 4)
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C-1SI8ILQLCALIEQJlli.IA-BUSINESS CONSlJMER..sE~I.C.ES..AND HOUSING AGENCY DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento. CA 95833 (916) 263-2911/ FAX (916) 263-7453 www.hcd.ca.qov October 15, 2019 Kome Ajise Executive Director Southern California Association of Governments 900 Wilshire Boulevard, Suite 1700 Los Angeles, CA 90017 Dear Executive Director Ajise, RE: Final Regional Housing Need Assessment AGENDA ITEM 3 GAVIN NEWS.OM Governor The California Department of Housing and Community Development (HCD) has received and reviewed your objection to the Southern California Association of Governments (SCAG)'s Regional Housing Needs Assessment (RHNA) provided on August 22, 2019. Pursuant to Government Code (Gov. Code) section 65584.01(c)(3), HCD is reporting the results of its review and consideration, along with a final written determination of SCAG's RHNA and explanation of methodology and inputs. As a reminder, there are several reasons for the increase in SCAG's 61h cycle Regional Housing Needs Assessment (RHNA) as compared to the 51h cycle. First, as allowed under Gov. Code 65584.01 (b)(2), the 61h cycle RHNA applied housing need adjustment factors to the region's total projected households, thus capturing existing and projected need. Second, overcrowding and cost burden adjustments were added by statute between 51h and 61h cycle; increasing RHNA in regions where incidents of these housing need indicators were especially high. SCAG's overcrowding rate is 10.11%, 6.76% higher than the national average. SCAG's cost burden rate is 69.88% for lower income households, and 18.65% for higher income households, 10.88% and 8.70% higher than the national average respectively. Third, the 51h cycle RHNA for the SCAG region was impacted by the recession and was significantly lower than SCAG's 41h cycle RHNA. This RHNA methodology establishes the minimum number of homes needed to house the region's anticipated growth and brings these housing need indicators more in line with other communities, but does not solve for these housing needs. Further, RHNA is ultimately a requirement that the region zone sufficiently in order for these homes to have the potential to be built, but it is not a requirement or guarantee that these homes will be built. In this sense, the RHNA assigned by HCD is already a product of moderation and compromise; a minimum, not a maximum amount of planning needed for the SCAG region. For these reasons HCD has not altered its RHNA approach based on SCAG's objection. However, the cost burden data input has been updated following SCAG's objection due to the availability of more recent data. Attachment 1 displays the minimum RHNA of 1,341,827 total homes among four income categories for SCAG to distribute among its local governments. Attachment 2 explains the methodology applied pursuant to Gov. Code section 65584.01. Special Meeting of the CEHD Committee, 10-21-19 Page 70 of 87
C-2Page 2 of 7 The following briefly responds to each of the points raised in SCAG's objection: Use of SCAG's Population Forecast SCAG's overall population estimates for the end of the projection period exceed Department of Finance's (DOF) population projections by 1.32%, however the SCAG household projection derived from this population forecast is 1.96% lower than DOF's household projection. This is a result of SCAG's population forecast containing 3,812,391 under 15-year old persons, compared to DOF's population projection containing 3,292,955 under 15-year old persons; 519,436 more persons within the SCAG forecast that are anticipated to form no households. In this one age category, DOF's projections differ from SCAG's forecast by 15.8%. Due to a greater than 1.5% difference in the population forecast assessment of under 15-year aids (15.8%), and the resulting difference in projected households (1.96%), HCD maintains the use of the DOF projection in the final RHNA. Use of Comparable Regions While the statute allows for the council of government to determine and provide the comparable regions to be used for benchmarking against overcrowding and cost burden, Gov. Code 65584.01 (b)(2) also allows HCD to "accept or reject information provided by the council of governments or modify its own assumptions or methodology based on this information." Ultimately, HCD did not find the proposed comparable regions an effective benchmark to compare SCAG's overcrowding and cost burden metrics to. HCD used the national average as the comparison benchmark, which had been used previously throughout 6th cycle prior to the addition of comparable region language into the statute starting in January 2019. As the housing crisis is experienced nationally, even the national average does not express an ideal overcrowding or cost burden rate; we can do more to reduce and eliminate these worst-case housing needs. Vacancy Rate No changes have been made to the vacancy rate standard used by HCD for the 6th cycle RHNA methodology. Replacement Need No changes have been made to the replacement need minimum of adjustment .5%. This accounts for replacement homes needed to account for homes potentially lost during the projection period. Household Growth Anticipated on Tribal Lands No changes have been made to reduce the number of households planned in the SCAG region by the amount of household growth expected on tribal lands. The region should plan for these homes outside of tribal lands. Overlap between Overcrowding and Cost Burden No changes have been made to overcrowding and cost burden methodology. Both factors are allowed statutorily, and both are applied conservatively in the current methodology. Special Meeting of the CEHD Committee, 10-21-19 Page 71 of 87
C-3Page 3 of 7 Data Sources No changes have been made to the data sources used in the methodology. 5-year American Community Survey data allows for lower margin of error rates and is the preferred data source used throughout this cycle. With regard to cost burden rates, HCD continues to use the Comprehensive Housing Affordability Strategy, known as CHAS data. These are custom tabulations of American Community Survey requested by the U.S. Department of Housing and Urban Development. These customs tabulations display cost burden by income categories, such as lower income, households at or below 80% area median income; rather than a specific income, such as $50,000. The definition of lower income shifts by region and CHAS data accommodates for that shift. The 2013-2016 CHAS data became available August 9, 2019, shortly prior to the issuance of SCAG's RHNA determination so that data is now used in this RHNA. Next Steps As you know, SCAG is responsible for adopting a RHNA allocation methodology for the projection period beginning June 30, 2021 and ending October 15, 2029. Pursuant to Gov. Code section 65584(d), SCAG's RHNA allocation methodology must further the following objectives: (1) Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and counties within the region in an equitable manner, which shall result in each jurisdiction receiving an allocation of units for low-and very-low income households. (2) Promoting infill development and socioeconomic equity, the protection of environmental and agricultural resources, the encouragement of efficient development patterns, and the achievement of the region's greenhouse gas reductions targets provided by the State Air Resources Board pursuant to Section 65080. (3) Promoting an improved intraregional relationship between jobs and housing, including an improved balance between the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction. (4) Allocating a lower proportion of housing need to an income category when a jurisdiction already has a disproportionately high share of households in that income category, as compared to the countywide distribution of households in that category from the most recent American Community Survey. (5) Affirmatively furthering fair housing. Pursuant to Gov. Code section 65584.04(e), to the extent data is available, SCAG shall include the factors listed in Gov. Code section 65584.04(e)(1-12) to develop its RHNA allocation methodology. Pursuant to Gov. Code section 65584.04(f), SCAG must explain in writing how each of these factors was incorporated into the RHNA allocation methodology and how the methodology furthers the statutory objectives described above. Pursuant to Gov. Code section 65584.04(h), SCAG must consult with HCD and submit its draft allocation methodology to HCD for review. Special Meeting of the CEHD Committee, 10-21-19 Page 72 of 87
C-4Page 4 of 7 HCD appreciates the active role of SCAG staff in providing data and input throughout the consultation period. HCD especially thanks Ping Chang, Ma'Ayn Johnson, Kevin Kane, and Sarah Jepson. HCD looks forward to its continued partnership with SCAG to assist SCAG's member jurisdictions meet and exceed the planning and production of the region's housing need. Just a few of the support opportunities available for the SCAG region this cycle include: • SB 2 Planning Grants and Technical Assistance (application deadline November 30, 2019) • Regional and Local Early Action Planning Grants • Permanent Local Housing Allocation If HCD can provide any additional assistance, or if you, or your staff, have any questions, please contact Megan Kirkeby, Assistant Deputy Director for Fair Housing, at meg an. klrl<eby@hcd. ca. gov. Sincerely, ~~e. (I<...~ Douglas R. McCauley Acting Director Enclosures Special Meeting of the CEHD Committee, 10-21-19 Page 73 of 87
C-5Page 5 of 7 ATTACHMENT 1 HCD REGIONAL HOUSING NEED DETERMINATION SCAG: June 30, 2021 -October 15, 2029 (8.3 years) Income Category Percent Housing Unit Need Very-Low* 26.2% 351,796 Low 15.4% 206,807 Moderate 16.7% 223,957 Above-Moderate 41.7% 559,267 Total 100.0% 1,341,827 * Extremely-Low 14.5% Included in Very-Low Category Notes: Income Distribution: Income categories are prescribed by California Health and Safety Code (Section 50093, et.seq.). Percents are derived based on ACS reported household income brackets and regional median income, then adjusted based on the percent of cost-burdened households in the region compared with the percent of cost burdened households nationally. Special Meeting of the CEHD Committee, 10-21-19 Page 74 of 87
C-6Page 6 of 7 ATTACHMENT 2 HCD REGIONAL HOUSING NEED DETERMINATION SCAG: June 30, 2021 -October 15, 2029 (8.3 years) Methodology SCAG: June 30, 2021-0ctober 15, 2029 (8.3 Years) HCD Determined Population, Households & Housing Need 1. Population: DOF 6/30/2029 projection adjusted +3.5 months to 10/15/2029 2. -Group Quarters Population: DOF 613012029 projection adjusted +3.5 months to 1011512029 3. Household (HH) Population: October 15, 2029 HCD Adjusted DOFHH HCD Adjusted Household Formation Groups DOF Projected Formation DOF Projected HH Population Rates Households 20,079,930 6,801,760 under 15 years 3,292,955 n/a n/a 15-24 years 2.735,490 6.45% 176,500 25-34 years 2,526,620 32.54% 822,045 35-44 years 2,460,805 44.23% 1,088,305 45-54 years 2,502,190 47.16% 1,180,075 55-64 years 2.399,180 50.82% 1,219,180 65-74 years 2,238,605 52.54% 1,176,130 75-84 years 1,379,335 57.96% 799,455 85+ 544,750 62.43% 340,070 4. Projected Households_(Occupied Unit Stock) 5. + Vacancy Adjustment (2.63%) 6. +Overcrowding Adjustment (6.76%) 7. + Replacement Adjustment (.50%) 8. -Occupied Units (HHsl estimated (June 30, 2021) 9. +Cost Burden Adjustment (Lower Income: 10.63%. Moderate and Above Moderate Income: 9.28%) 6th Cycle Regional Housing Need Assessment (RHNA) Explanation and Data Sources 20,455,355 -363,635 20,079,930 6,801,760 178,896 459.917 34,010 -6,250,261 117,505 1,341,827 1-4. Population, Group Quarters, Household Population, & Projected Households: Pursuant to Government Code Section 65584.01, projections were extrapolated from Department of Finance (DOF) projections. Population reflects total persons. Group Quarter Population reflects persons in a dormitory, group home, institution, military, etc. that do not require residential housing. Household Population reflects persons requiring residential housing. Projected Households reflect the propensity of persons, by age-groups, to form households at different rates based on Census trends. 5. Vacancy Adjustment: HCD applies a vacancy adjustment based on the difference between a standard 5% vacancy rate and the region's current "for rent and sale" vacancy percentage to provide healthy market vacancies to facilitate housing availability and resident mobility. The adjustment is the difference between standard 5% and region's current vacancy rate (2.37%) based on the 2013-2017 5-year American Community Survey (ACS) data. For SCAG that difference is 2.63%. 6. Overcrowding Adjustment: In region's where overcrowding is greater than the U.S overcrowding rate of 3.35%, HCD applies an adjustment based on the amount the region's overcrowding rate (1 0.11 %) exceeds the U.S. overcrowding rate (3.35%) based on the 2013-2017 5-year ACS data. For SCAG that difference is 6.76%. Continued on next page 7. Replacement Adjustment: HCD applies a replacement adjustment between .5% & 5% to total housing stock based on the current 1 0-year average of demolitions in the region's local Special Meeting of the CEHD Committee, 10-21-19 Page 75 of 87
C-7Page 7 of 7 government annual reports to Department of Finance (DOF). For SCAG, the 1 0-year average is .14%, and SCAG's consultation package provided additional data on this input indicating it may be closer to .41 %; in either data source the estimate is below the minimum replacement adjustment so the minimum adjustment factor of .5% is applied. 8. Occupied Units: Reflects DOF's estimate of occupied units at the start of the projection period (June 30, 2021). 9. Cost Burden Adjustment: HCD applies an adjustment to the projected need by comparing the difference in cost-burden by income group for the region to the cost-burden by income group for the nation. The very-low and low income RHNA is increased by the percent difference (69.88%-59.01 %=1 0.88%) between the region and the national average cost burden rate for households earning 80% of area median income and below, then this difference is applied to very low-and low-income RHNA proportionate to the share of the population these groups currently represent. The moderate and above-moderate income RHNA is increased by the percent difference (18.65%-9.94%=8.70%) between the region and the national average cost burden rate for households earning above 80% Area Median Income, then this difference is applied to moderate and above moderate income RHNA proportionate to the share of the population these groups currently represent. Data is from 2013-2016 Comprehensive Housing Affordability Strategy (CHAS). Special Meeting of the CEHD Committee, 10-21-19 Page 76 of 87
D-1CITY OF September 9, 2019 Honorable Peggy Huang, Chair Regional Housing Needs Assessment Subcommittee Southern California Association of Governments 900 Wilshire Blvd, Suite No. 1700 Los Angeles, CA 90017 RANCHO PALOS VERDES COMMUNITY DEVELOPMENT DEPARTMENT SUBMITTED ELECTRONICALLY SUBJECT: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) PROPOSED METHODOLOGY Dear Chair Huang, On August 20, 2019, the City of Rancho Palos Verdes submitted a comment letter regarding the proposed 61h cycle RHNA methodology options currently being considered by the Southern California Association of Governments (SCAG). The City's comment letter highlighted the unique challenges and physical constraints that face the City, such as being designated a Very High Fire Hazard Severity Zone, the presence of geologic hazards, and the preservation of sensitive wildlife and habitat. The comment letter urged the RHNA Subcommittee to consider such factors in selecting a RHNA methodology. Since the issuance of the City's comment letter, the State's Housing and Community Development Department (HCD) issued a regional determination need of 1,344,740 total housing units for the SCAG region. Based on this figure and using SCAG's RHNA Methodologies Estimate Tool, the City of Rancho Palos Verdes would have a RHNA allocation of 1,852 housing units under Option 1, 2,390 housing units under Option 2, and 75 housing units under Option 3. Methodology Options 1 and 2 present a significantly higher RHNA allocation than what the City was assigned for the 51h RHNA cycle. These methodology options would pose an undue burden upon the City to accommodate for housing in the next Housing Element cycle without considering the unique physical challenges faced by the City. The City would also like to bring attention to the need for housing with access to high-quality transit in order to meet the State's objectives to reduce greenhouse gas emissions and vehicle miles traveled. The City of Rancho Palos Verdes, along with its neighboring Palos Verdes Peninsula cities, are located in a region with very limited access to high-quality transit. In fact, the City recently learned that, due to the recent reduction in ridership, the LA Metro is considering eliminating Route 344, which serves Hawthorne Blvd., a major arterial for the Peninsula. With limited access to high-quality transit, combined with the consideration to eliminate Route 344, any new high-density housing required to be built in the City by the State will inevitably require residents to rely primarily upon private vehicles for transportation. Based on Options 1 and 2--and perhaps Option 3--the State-mandated housing units will result in a significant increase in vehicle miles traveled and greenhouse gas emissions, which is fundamentally counterproductive with the State's and Governor's objectives. The City recommends that SCAG appeal HCD's regional determination need figure before deciding on a RHNA methodology option. The City also strongly urges SCAG to select RNHA Methodology Option 3, as 30940 111\WTIII li<I~E 131 l\ILEVAr\1) I I< ANI ~Hl J I 'AU l:-> VE:I\Ilb I .A 90215-5391 I 13101 544-5228 I FAX 1310l 544-5293 WWI'I' I<I'VCA GGV 0 PI<INTED ON RECYCLED PAPEI<
D-2this option most appropriately utilizes local input amongst the three options, and provides the City with a RHNA allocation that the City can plan for in the upcoming Housing Element planning cycle. If you should have any questions, or would like further assistance, please feel free to contact me at (31 0) 544-5227 or by email at aram@rpvca.gov. ' ra in , ACIP Director of Community Development c: Jerry Duhovic, Mayor, Rancho Palos Verdes Rancho Palos Verdes City Council Hon. Dan Medina, RC District# 28, GCCOG Hon. James Gazeley, RC District# 39, SBCCOG Hon. Judy Mitchell, RC District #40, SBCCOG Jacki Bacharach, Executive Director of the SBCCOG Doug Wilmore, City Manager Kit Fox, Interim Deputy Director of Community Development Octavia Silva, Senior Planner
D-3CITY OF August20, 2019 Honorable Peggy Huang, Chair Regional Housing Needs Assessment Subcommittee Southern California Association of Governments 900 Wilshire Blvd, Suite No. 1700 Los Angeles, CA 90017 RANCHO PALOS VERDES COMMUNITY DEVELOPMENT DEPARTMENT SUBMITTED ELECTRONICALLY SUBJECT: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) PROPOSED METHODOLOGY Dear Chair Huang, The City of Rancho Palos Verdes appreciates the opportunity to provide the following comments on the proposed RHNA methodology for your consideration. Since the 2013 adoption of the Housing Element, the City has actively engaged in implementing the goals and policies of the Housing Element including the creation of housing units to meet designated RHNA allocations. More specifically, the City has provided for housing units in various income levels and anticipates that remaining units will be provided as identified in the City's Housing Element. The City joins other jurisdictions in expressing concerns as to the feasibility of meeting new RHNA allocations under the methodology options proposed by the Southern California Association of Governments (SCAG). While the City supports the development of housing units that improve the availability of affordable and safe housing throughout the region, the City also promotes housing that reflects the City's character and recognizes development constraints and hazards. The City requests that SCAG consider the following challenges that face the City, as it considers proposed methodology options for the upcoming 61h RHNA cycle: 1) Very High Fire Severity Zone Approximately 97% of the City of Rancho Palos Verdes is located within the Very High Fire Severity Zone, as classified through the California Department of Forestry and Fire Protection. Senate Bill 35 recognizes the hazards associated with such classifications by exempting mandatory density provisions for very high fire severity zone communities. The City requests that this designation weigh heavily on the methodology option selected for Rancho Palos Verdes. 2) Geologic Hazards The Portuguese Bend Landslide Complex (PBLC), which is the largest fastest moving landslide in North America, is located along the south central section of the Palos Verdes Peninsula entirely within the City of Rancho Palos Verdes. The terminus of the active landslide complex, and generally the southwest boundary of the PBLC is the Pacific Ocean. The PBLC is divided into two parts with the main landslide having an area of about 190 acres and the other segment having an 30940 IIAWTHI ll\liE fil ll II_EVAf~D I !\ANI ;11r l I 'Al_O~ VEI~DE~ I~A 90275-5391 I 13101 544-5228/ FAX 13101 544-5293 WW\11/ I~PVCA GOV 0 PRINl ED ON RECYCLED PAI"EI~
D-4area of about 70 acres. The PBLC moves at various rates and over the last several decades has resulted in significant infrastructure damage to homes, utilities, and roadways. The City has expended nearly 50 million dollars over the years repairing and maintaining the damage and addressing the overall technical and administrative issues associated with managing such a complex problem. As a result of geologic and geotechnical studies, the City prohibits the construction on vacant lots within the entire PBLC through with the establishment of a landslide moratorium area that has been codified since 1978. 3) Wildlife and Habitat Preservation The City of Rancho Palos Verdes includes area of lands that are protected from development as a result of Federal and State programs. More specifically, the City has adopted a Natural Community Preservation Plan and Habitat Conservation Plan (NCCP/HCP or Plan). The Plan was prepared to maximize the benefits to wildlife and vegetation communities while accommodating appropriate economic development within the City. The City's primary conservation strategy is to dedicate 1,402.4 acres of habitat protection for the NCCP/HCP Preserve assembly. The dedication includes Existing Public Lands that are currently owned by the City (1,123.0 acres) and the Palos Verdes Peninsula Land Conservancy (PVPLC) (20.7 acres). The remainder of the Preserve is comprised of 258.7 acres of City owned land or land that will eventually be owned by the City which has been previously dedicated for conservation as mitigation for certain private projects and will be added to the Preserve. The City also includes the Abalone Cove, which contains a State-designated Ecological Preserve with important natural marine resources at the bottom of the Portuguese Bend landslide area. The City's NCCP/HCP is unique to Los Angeles County, as it is the only such Plan in the County. It benefits the natural environment and protection of species, including listed endangered species, as well as passive recreational opportunities to the general public. The approximate 1 ,400 acres of undeveloped vacant open space that make up the Palos Verdes Nature Preserve is encumbered with conservation easements and deed restrictions that prohibit development in perpetuity which should be factored in the RHNA methodology applied to the City. In addition to the large areas of the City dedicated to wildlife and vegetation communities, the City also is home to three federal facilities. These include the Point Vicente Lighthouse and Coast Guard Station (29 acres}, the United States Air Force and Federal Aviation Administration Radar Station (11 acres) on San Pedro Hill, and a World War II bunker and Coast Guard antenna site (4 acres) at Point Vicente Park/Civic Center. The City would like to thank the Chair and Committee in advance for considering the unique challenges and physical constraints that face Rancho Palos Verdes, and asks that such factors weigh heavily in considering the methodology for the upcoming 61h RHNA cycle. If you should have any questions, or would like further assistance, please feel free to contact me at (31 0) 544-5227 or by email at aram@rpvca.gov. Ara Mihranian, ACIP Director of Community Development c: Jerry Duhovic, Mayor. Rancho Palos Verdes Rancho Palos Verdes City Council Doug Wilmore. City Manager Octavia Silva. Senior Planner
D-5CITY OF October 29, 2019 Honorable Peggy Huang, Chair Regional Housing Needs Assessment Subcommittee Southern California Association of Governments 900 Wilshire Blvd, Suite No. 1700 Los Angeles, CA 90017 RANCHO PALOS VERDES COMMUNITY DEVELOPMENT DEPARTMENT SUBMITTED ELECTRONICALLY SUBJECT: DRAFT REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) PROPOSED METHODOLOGY Dear Chair Huang, On August 20, 2019, and September 9, 2019, the City of Rancho Palos Verdes submitted comment letters regarding the proposed 61h cycle RHNA methodology options being considered by the Southern California Association of Governments (SCAG). The City's comment letters urged SCAG to develop a methodology that considers unique challenges and physical constraints that may face a city, such as being designated a Very High Fire Hazard Severity Zone, geologic hazards and wildlife/habitat preservation, as are present in the City of Rancho Palos Verdes. The City also urged SCAG to develop a RHNA methodology that promoted housing with access to high-quality transit in order to meet the State's objectives to reduce greenhouse gas emissions and vehicle miles traveled. On September 23, 2019, SCAG staff previewed a staff-recommended draft methodology, which has since been presented to SCAG's RHNA Sub-Committee and Community, Economic and Human Development (CEHD) Committee for consideration. Using the RHNA Methodologies Estimate Tool under the recommended draft RHNA methodology, the City of Rancho Palos Verdes would be required to provide 94 housing units at various income levels during the next planning period of 2021-2029. As SCAG proceeds toward a final RHNA methodology, the City of Rancho Palos Verdes continues to urge SCAG to finalize a RHNA methodology that considers the City's unique challenges and physical constraints, as such factors severely limit the availability of land throughout the City to accommodate new housing. City Staff is concerned that "top down" housing mandates combined with the lack of available housing sites, combined with the State legislature's willingness to punish cities that do not achieve their RHNA allocations, are setting up the City for an unachievable 61h Cycle RHNA allocation. While the City continues to express concerns regarding the proposed RHNA methodologies, the City appreciates the efforts of SCAG throughout the RHNA process and in further considering the comments provided in this letter. If you should have any questions, or would like further assistance, please feel free to contact me at (31 0) 544-5227 or by email at aram@rpvca.gov or Senior Planner, Octavia Silva at (31 0) 544-5234 or by email at octavios@rpvca.gov. 30940 I lAVVTHOI\NE 8( ll JLEVAf~l) I 1\ANlllC l f1AU J::; VEkDES t ;A 90275-5391 I 1310l 544-5228 I FAX 13101 544-5293 '1/1/V•iW RPVCA GOV 0 PI<INTED ON RECYCLED PAPER
D-6c: Jerry Duhovic, Mayor, Rancho Palos Verdes Rancho Palos Verdes City Council Hon. Dan Medina, RC District# 28, GCCOG Hon. James Gazeley, RC District# 39, SBCCOG Hon. Judy Mitchell, RC District #40, SBCCOG Jacki Bacharach, Executive Director of the SBCCOG Doug Wilmore, City Manager Kit Fox, Interim Deputy Director of Community Development Octavia Silva, Senior Planner