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CC SR 20210504 E - AB 1258 Letter of Support CITY COUNCIL MEETING DATE: 05/04/2021 AGENDA REPORT AGENDA HEADING: Consent Calendar AGENDA TITLE: Consideration and possible action to authorize the Mayor to sign a letter of support for AB 1258. RECOMMENDED COUNCIL ACTION: (1) Authorize the Mayor to sign a City letter of support for AB 1258. FISCAL IMPACT: None Amount Budgeted: N/A Additional Appropriation: N/A Account Number(s): N/A ORIGINATED BY: McKenzie Bright, Administrative Analyst REVIEWED BY: Karina Bañales, Deputy City Manager APPROVED BY: Ara Mihranian, AICP, City Manager ATTACHED SUPPORTING DOCUMENTS: A. Draft City letter supporting AB 1258 (page A-1) B. Text of AB 1258 (as amended March 22, 2021) (page B-1) BACKGROUND AND DISCUSSION: Assembly Bill No. 1258, introduced by Assemblymember Janet Nguyen of Fountain Valley, would subject the Department of Housing and Community Development’s (HCD) final determination of a region’s housing needs or a final regional housing needs plan to judicial review. Current law requires local governments to prepare and adopt a general plan for their jurisdiction that contains certain mandatory elements, including the locality’s share of the regional housing need allocation (RHNA). HCD, in consultation with the regional council of governments, determines each region’s existing and projected housing needs. Once that determination is made by HCD, the council of governments may object to the determination, and the department is required to respond to an objecti on by making a final written determination. 1 Previous state law provided a judicial review for challenges to HCD’s final housing needs determination or a regional council of government’s final regional housing needs plan, but was removed with a 2004 law. AB 1258 seeks to reinstate this judicial review. This process would provide for independent review and analysis of the findings and final determinations made by the HCD and regional council of governments. The Southern California Association of Governments (SCAG) is the organization tasked with developing a RHNA allocation plan for the Southern California region. As a result of SCAG’s appeals and redistribution process, the City of Rancho Palos Verdes has been allocated a total of 639 housing units, which m ust be incorporated into the City’s housing element plan. On January 13, 2021, Staff presented the City’s appeal to the RHNA Appeal Committee, outlining the local factors that limit development in the City, including being in a Very High Fire Hazard Severity Zone (VHFHSZ), geologic constraints including the landslide, and that large areas are restricted open space. The appeal was denied. Given the significant impact that a housing element has on local governments’ planning and development, it seems reasonable that there should be the opportunity for judicial review of these decisions. Therefore, Staff recommends the City Council authorize the Mayor to sign a letter to Assemblymember Nguyen as drafted, or with revisions, supporting AB 1258. ALTERNATIVES: In addition to the Staff recommendation, the following alternative actions are available for the City Council’s consideration: 1. Identify revised language to add to the letter. 2. Do not authorize the Mayor to sign the letter. 3. Take other action, as deemed appropriate. 2 May 4, 2021 Via Email The Honorable Janet Nguyen California State Assembly State Capitol, Room 4153 Sacramento, CA 95814 SUBJECT: Notice of Support for AB 1258 Dear Assemblymember Nguyen: The City of Rancho Palos Verdes supports AB 1258, which would subject the Department of Housing and Community Development’s (HCD) final determination of a region’s housing needs, or a final regional housing needs plan, to judicial review. Current law requires local governments to prepare and adopt general plans for their jurisdiction that contains certain mandatory elements, including the locality’s share of the regional housing need allocation (RHNA). HCD, in consultation with the regional council of governments, determines each region’s existing and projected housing needs. Once that determination is made by HCD, the council of governments may object to the determination, and the department is required to respond to an objection by making a final written determination. Previous state law provided judicial review for challenges to HCD’s final housing needs determination or a regional council of government’s final regional housing needs plan , but was removed with a 2004 law. AB 1258 seeks to reinstate this judicial review. This process would provide for independent review and analysis of the findings and final determinations made by the HCD and regional council of governments, which Rancho Palos Verdes supports. Given the significant impact that a housing element has on local governments’ planning and development, it seems reasonable that there should be the opportunity for judicial review of these decisions. Therefore, the City of Rancho Palos Verdes supports AB 1258. A-1 Assemblymember Nguyen May 4, 2021 Page 2 Sincerely, Eric Alegria Mayor cc: David Chiu, Chair, Assembly Housing and Community Development Committee Ben Allen, Senator, 26th State Senate District Al Muratsuchi, Assembly Member, 66th Assembly District Jeff Kiernan, League of California Cities Meg Desmond, League of California Cities Marcel Rodarte, California Contract Cities Association Jacki Bacharach, South Bay Cities Council of Governments Rancho Palos Verdes City Council Ara Mihranian, City Manager Karina Bañales, Deputy City Manager A-2 AMENDED IN ASSEMBLY MARCH 22, 2021 california legislature—2021–22 regular session ASSEMBLY BILL No. 1258 Introduced by Assembly Member Nguyen February 19, 2021 An act to amend Section 65584 of the Government Code, relating to housing. An act to amend Sections 65584 and 65584.01 of the Government Code, relating to housing. legislative counsel’s digest AB 1258, as amended, Nguyen. Housing element: regional housing need plan: judicial review. Existing law requires each city, county, or city and county to prepare and adopt a general plan for its jurisdiction that contains certain mandatory elements, including a housing element. Under existing law, a part of the housing element is an assessment of housing needs, which includes the locality’s share of the regional housing need. Under existing law the Department of Housing and Community Development, in consultation with each council of governments, determines each region’s existing and projected housing needs. Under existing law, upon making that determination, the council of governments may object to the determination, and the department is required to respond to an objection by making a final written determination. Existing law requires that, based on the determination of the department, a council of governments, or for cities and counties without a council of governments, the department, adopts a final regional housing need plan that allocates a share of the regional housing need to each locality in the region. This bill would subject the department’s final written determination of a region’s housing needs to judicial review in an action brought by 98 B-1 the council of governments. The bill would also subject the final regional housing need plan adopted by the council of governments or the department, as the case may be, to judicial review. Existing law requires each city, county, or city and county to prepare and adopt a general plan for its jurisdiction that contains certain mandatory elements, including a housing element. Under existing law, a part of the housing element is an assessment of housing needs, which includes the locality’s share of the regional housing need. Under existing law the appropriate council of governments, or for cities and counties without a council of governments, the Department of Housing and Community Development, adopts a final regional housing need plan that allocates a share of the regional housing need to each locality in the region. This bill would subject the final regional housing need plan to judicial review. Vote: majority. Appropriation: no. Fiscal committee: no yes.​ State-mandated local program: no.​ The people of the State of California do enact as follows: line 1 SECTION 1. Section 65584 of the Government Code is line 2 amended to read: line 3 65584. (a)  (1)  For the fourth and subsequent revisions of the line 4 housing element pursuant to Section 65588, the department shall line 5 determine the existing and projected need for housing for each line 6 region pursuant to this article. For purposes of subdivision (a) of line 7 Section 65583, the share of a city or county of the regional housing line 8 need shall include that share of the housing need of persons at all line 9 income levels within the area significantly affected by the general line 10 plan of the city or county. line 11 (2)  It is the intent of the Legislature that cities, counties, and line 12 cities and counties should undertake all necessary actions to line 13 encourage, promote, and facilitate the development of housing to line 14 accommodate the entire regional housing need, and reasonable line 15 actions should be taken by local and regional governments to line 16 ensure that future housing production meets, at a minimum, the line 17 regional housing need established for planning purposes. These line 18 actions shall include applicable reforms and incentives in Section line 19 65582.1. 98 — 2 — AB 1258 B-2 line 1 (3)  The Legislature finds and declares that insufficient housing line 2 in job centers hinders the state’s environmental quality and runs line 3 counter to the state’s environmental goals. In particular, when line 4 Californians seeking affordable housing are forced to drive longer line 5 distances to work, an increased amount of greenhouse gases and line 6 other pollutants is released and puts in jeopardy the achievement line 7 of the state’s climate goals, as established pursuant to Section line 8 38566 of the Health and Safety Code, and clean air goals. line 9 (b)  (1)   The department, in consultation with each council of line 10 governments, shall determine each region’s existing and projected line 11 housing need pursuant to Section 65584.01 at least two years prior line 12 to the scheduled revision required pursuant to Section 65588. The line 13 appropriate council of governments, or for cities and counties line 14 without a council of governments, the department, shall adopt a line 15 final regional housing need plan that allocates a share of the line 16 regional housing need to each city, county, or city and county at line 17 least one year prior to the scheduled revision for the region required line 18 by Section 65588. The allocation plan prepared by a council of line 19 governments shall be prepared pursuant to Sections 65584.04 and line 20 65584.05. line 21 (2)  The final regional housing need plan adopted under line 22 paragraph (1) by the council of governments or the department, line 23 as the case may be, shall be subject to judicial review pursuant to line 24 Section 1085 of the Code of Civil Procedure. line 25 (c)  Notwithstanding any other provision of law, the due dates line 26 for the determinations of the department or for the council of line 27 governments, respectively, regarding the regional housing need line 28 may be extended by the department by not more than 60 days if line 29 the extension will enable access to more recent critical population line 30 or housing data from a pending or recent release of the United line 31 States Census Bureau or the Department of Finance. If the due line 32 date for the determination of the department or the council of line 33 governments is extended for this reason, the department shall line 34 extend the corresponding housing element revision deadline line 35 pursuant to Section 65588 by not more than 60 days. line 36 (d)  The regional housing needs allocation plan shall further all line 37 of the following objectives: line 38 (1)  Increasing the housing supply and the mix of housing types, line 39 tenure, and affordability in all cities and counties within the region line 40 in an equitable manner, which shall result in each jurisdiction 98 AB 1258 — 3 — B-3 line 1 receiving an allocation of units for low- and very low income line 2 households. line 3 (2)  Promoting infill development and socioeconomic equity, line 4 the protection of environmental and agricultural resources, the line 5 encouragement of efficient development patterns, and the line 6 achievement of the region’s greenhouse gas reductions targets line 7 provided by the State Air Resources Board pursuant to Section line 8 65080. line 9 (3)  Promoting an improved intraregional relationship between line 10 jobs and housing, including an improved balance between the line 11 number of low-wage jobs and the number of housing units line 12 affordable to low-wage workers in each jurisdiction. line 13 (4)  Allocating a lower proportion of housing need to an income line 14 category when a jurisdiction already has a disproportionately high line 15 share of households in that income category, as compared to the line 16 countywide distribution of households in that category from the line 17 most recent American Community Survey. line 18 (5)  Affirmatively furthering fair housing. line 19 (e)  For purposes of this section, “affirmatively furthering fair line 20 housing” means taking meaningful actions, in addition to line 21 combating discrimination, that overcome patterns of segregation line 22 and foster inclusive communities free from barriers that restrict line 23 access to opportunity based on protected characteristics. line 24 Specifically, affirmatively furthering fair housing means taking line 25 meaningful actions that, taken together, address significant line 26 disparities in housing needs and in access to opportunity, replacing line 27 segregated living patterns with truly integrated and balanced living line 28 patterns, transforming racially and ethnically concentrated areas line 29 of poverty into areas of opportunity, and fostering and maintaining line 30 compliance with civil rights and fair housing laws. line 31 (f)  For purposes of this section, “household income levels” are line 32 as determined by the department as of the most recent American line 33 Community Survey pursuant to the following code sections: line 34 (1)  Very low incomes as defined by Section 50105 of the Health line 35 and Safety Code. line 36 (2)  Lower incomes, as defined by Section 50079.5 of the Health line 37 and Safety Code. line 38 (3)  Moderate incomes, as defined by Section 50093 of the Health line 39 and Safety Code. 98 — 4 — AB 1258 B-4 line 1 (4)  Above moderate incomes are those exceeding the line 2 moderate-income level of Section 50093 of the Health and Safety line 3 Code. line 4 (g)  Notwithstanding any other provision of law, determinations line 5 made by the department, a council of governments, or a city or line 6 county pursuant to this section or Section 65584.01, 65584.02, line 7 65584.03, 65584.04, 65584.05, 65584.06, 65584.07, or 65584.08 line 8 are exempt from the California Environmental Quality Act line 9 (Division 13 (commencing with Section 21000) of the Public line 10 Resources Code). line 11 SEC. 2. Section 65584.01 of the Government Code is amended line 12 to read: line 13 65584.01. For the fourth and subsequent revision of the housing line 14 element pursuant to Section 65588, the department, in consultation line 15 with each council of governments, where applicable, shall line 16 determine the existing and projected need for housing for each line 17 region in the following manner: line 18 (a)  The department’s determination shall be based upon line 19 population projections produced by the Department of Finance line 20 and regional population forecasts used in preparing regional line 21 transportation plans, in consultation with each council of line 22 governments. If the total regional population forecast for the line 23 projection year, developed by the council of governments and used line 24 for the preparation of the regional transportation plan, is within a line 25 range of 1.5 percent of the total regional population forecast for line 26 the projection year by the Department of Finance, then the line 27 population forecast developed by the council of governments shall line 28 be the basis from which the department determines the existing line 29 and projected need for housing in the region. If the difference line 30 between the total population projected by the council of line 31 governments and the total population projected for the region by line 32 the Department of Finance is greater than 1.5 percent, then the line 33 department and the council of governments shall meet to discuss line 34 variances in methodology used for population projections and seek line 35 agreement on a population projection for the region to be used as line 36 a basis for determining the existing and projected housing need line 37 for the region. If agreement is not reached, then the population line 38 projection for the region shall be the population projection for the line 39 region prepared by the Department of Finance as may be modified 98 AB 1258 — 5 — B-5 line 1 by the department as a result of discussions with the council of line 2 governments. line 3 (b)  (1)  At least 26 months prior to the scheduled revision line 4 pursuant to Section 65588 and prior to developing the existing and line 5 projected housing need for a region, the department shall meet and line 6 consult with the council of governments regarding the assumptions line 7 and methodology to be used by the department to determine the line 8 region’s housing needs. The council of governments shall provide line 9 data assumptions from the council’s projections, including, if line 10 available, the following data for the region: line 11 (A)  Anticipated household growth associated with projected line 12 population increases. line 13 (B)  Household size data and trends in household size. line 14 (C)  The percentage of households that are overcrowded and the line 15 overcrowding rate for a comparable housing market. For purposes line 16 of this subparagraph: line 17 (i)  The term “overcrowded” means more than one resident per line 18 room in each room in a dwelling. line 19 (ii)  The term “overcrowded rate for a comparable housing line 20 market” means that the overcrowding rate is no more than the line 21 average overcrowding rate in comparable regions throughout the line 22 nation, as determined by the council of governments. line 23 (D)  The rate of household formation, or headship rates, based line 24 on age, gender, ethnicity, or other established demographic line 25 measures. line 26 (E)  The vacancy rates in existing housing stock, and the vacancy line 27 rates for healthy housing market functioning and regional mobility, line 28 as well as housing replacement needs. For purposes of this line 29 subparagraph, the vacancy rate for a healthy rental housing market line 30 shall be considered no less than 5 percent. line 31 (F)  Other characteristics of the composition of the projected line 32 population. line 33 (G)  The relationship between jobs and housing, including any line 34 imbalance between jobs and housing. line 35 (H)  The percentage of households that are cost burdened and line 36 the rate of housing cost burden for a healthy housing market. For line 37 the purposes of this subparagraph: line 38 (i)  The term “cost burdened” means the share of very low, low-, line 39 moderate-, and above moderate-income households that are paying line 40 more than 30 percent of household income on housing costs. 98 — 6 — AB 1258 B-6 line 1 (ii)  The term “rate of housing cost burden for a healthy housing line 2 market” means that the rate of households that are cost burdened line 3 is no more than the average rate of households that are cost line 4 burdened in comparable regions throughout the nation, as line 5 determined by the council of governments. line 6 (I)  The loss of units during a state of emergency that was line 7 declared by the Governor pursuant to the California Emergency line 8 Services Act (Chapter 7 (commencing with Section 8550) of line 9 Division 1 of Title 2), during the planning period immediately line 10 preceding the relevant revision pursuant to Section 65588 that line 11 have yet to be rebuilt or replaced at the time of the data request. line 12 (2)  The department may accept or reject the information line 13 provided by the council of governments or modify its own line 14 assumptions or methodology based on this information. After line 15 consultation with the council of governments, the department shall line 16 make determinations in writing on the assumptions for each of the line 17 factors listed in subparagraphs (A) to (I), inclusive, of paragraph line 18 (1) and the methodology it shall use and shall provide these line 19 determinations to the council of governments. The methodology line 20 submitted by the department may make adjustments based on the line 21 region’s total projected households, which includes existing line 22 households as well as projected households. line 23 (c)  (1)  After consultation with the council of governments, the line 24 department shall make a determination of the region’s existing line 25 and projected housing need based upon the assumptions and line 26 methodology determined pursuant to subdivision (b). The region’s line 27 existing and projected housing need shall reflect the achievement line 28 of a feasible balance between jobs and housing within the region line 29 using the regional employment projections in the applicable line 30 regional transportation plan. Within 30 days following notice of line 31 the determination from the department, the council of governments line 32 may file an objection to the department’s determination of the line 33 region’s existing and projected housing need with the department. line 34 (2)  The objection shall be based on and substantiate either of line 35 the following: line 36 (A)  The department failed to base its determination on the line 37 population projection for the region established pursuant to line 38 subdivision (a), and shall identify the population projection which line 39 the council of governments believes should instead be used for the line 40 determination and explain the basis for its rationale. 98 AB 1258 — 7 — B-7 line 1 (B)  The regional housing need determined by the department line 2 is not a reasonable application of the methodology and assumptions line 3 determined pursuant to subdivision (b). The objection shall include line 4 a proposed alternative determination of its regional housing need line 5 based upon the determinations made in subdivision (b), including line 6 analysis of why the proposed alternative would be a more line 7 reasonable application of the methodology and assumptions line 8 determined pursuant to subdivision (b). line 9 (3)  If a council of governments files an objection pursuant to line 10 this subdivision and includes with the objection a proposed line 11 alternative determination of its regional housing need, it shall also line 12 include documentation of its basis for the alternative determination. line 13 Within 45 days of receiving an objection filed pursuant to this line 14 section, the department shall consider the objection and make a line 15 final written determination of the region’s existing and projected line 16 housing need that includes an explanation of the information upon line 17 which the determination was made. line 18 (4)  The final written determination of the region’s existing and line 19 projected housing need, pursuant to paragraph (3), shall be subject line 20 to judicial review pursuant to Section 1085 of the Code of Civil line 21 Procedure. Such action shall be brought by the council of line 22 governments. line 23 (d)  Statutory changes enacted after the date the department line 24 issued a final determination pursuant to this section shall not be a line 25 basis for a revision of the final determination. line 26 SECTION 1. Section 65584 of the Government Code is line 27 amended to read: line 28 65584. (a)  (1)  For the fourth and subsequent revisions of the line 29 housing element pursuant to Section 65588, the department shall line 30 determine the existing and projected need for housing for each line 31 region pursuant to this article. For purposes of subdivision (a) of line 32 Section 65583, the share of a city or county of the regional housing line 33 need shall include that share of the housing need of persons at all line 34 income levels within the area significantly affected by the general line 35 plan of the city or county. line 36 (2)  It is the intent of the Legislature that cities, counties, and line 37 cities and counties should undertake all necessary actions to line 38 encourage, promote, and facilitate the development of housing to line 39 accommodate the entire regional housing need, and reasonable line 40 actions should be taken by local and regional governments to 98 — 8 — AB 1258 B-8 line 1 ensure that future housing production meets, at a minimum, the line 2 regional housing need established for planning purposes. These line 3 actions shall include applicable reforms and incentives in Section line 4 65582.1. line 5 (3)  The Legislature finds and declares that insufficient housing line 6 in job centers hinders the state’s environmental quality and runs line 7 counter to the state’s environmental goals. In particular, when line 8 Californians seeking affordable housing are forced to drive longer line 9 distances to work, an increased amount of greenhouse gases and line 10 other pollutants is released and puts in jeopardy the achievement line 11 of the state’s climate goals, as established pursuant to Section line 12 38566 of the Health and Safety Code, and clean air goals. line 13 (b)  (1)  The department, in consultation with each council of line 14 governments, shall determine each region’s existing and projected line 15 housing need pursuant to Section 65584.01 at least two years prior line 16 to the scheduled revision required pursuant to Section 65588. The line 17 appropriate council of governments, or for cities and counties line 18 without a council of governments, the department, shall adopt a line 19 final regional housing need plan that allocates a share of the line 20 regional housing need to each city, county, or city and county at line 21 least one year prior to the scheduled revision for the region required line 22 by Section 65588. The allocation plan prepared by a council of line 23 governments shall be prepared pursuant to Sections 65584.04 and line 24 65584.05. line 25 (2)  The final regional housing need plan adopted under line 26 paragraph (1) by the council of governments or the department, line 27 as the case may be, shall be subject to judicial review pursuant to line 28 Section 1094.5 of the Code of Civil Procedure. line 29 (c)  Notwithstanding any other provision of law, the due dates line 30 for the determinations of the department or for the council of line 31 governments, respectively, regarding the regional housing need line 32 may be extended by the department by not more than 60 days if line 33 the extension will enable access to more recent critical population line 34 or housing data from a pending or recent release of the United line 35 States Census Bureau or the Department of Finance. If the due line 36 date for the determination of the department or the council of line 37 governments is extended for this reason, the department shall line 38 extend the corresponding housing element revision deadline line 39 pursuant to Section 65588 by not more than 60 days. 98 AB 1258 — 9 — B-9 line 1 (d)  The regional housing needs allocation plan shall further all line 2 of the following objectives: line 3 (1)  Increasing the housing supply and the mix of housing types, line 4 tenure, and affordability in all cities and counties within the region line 5 in an equitable manner, which shall result in each jurisdiction line 6 receiving an allocation of units for low- and very low income line 7 households. line 8 (2)  Promoting infill development and socioeconomic equity, line 9 the protection of environmental and agricultural resources, the line 10 encouragement of efficient development patterns, and the line 11 achievement of the region’s greenhouse gas reductions targets line 12 provided by the State Air Resources Board pursuant to Section line 13 65080. line 14 (3)  Promoting an improved intraregional relationship between line 15 jobs and housing, including an improved balance between the line 16 number of low-wage jobs and the number of housing units line 17 affordable to low-wage workers in each jurisdiction. line 18 (4)  Allocating a lower proportion of housing need to an income line 19 category when a jurisdiction already has a disproportionately high line 20 share of households in that income category, as compared to the line 21 countywide distribution of households in that category from the line 22 most recent American Community Survey. line 23 (5)  Affirmatively furthering fair housing. line 24 (e)  For purposes of this section, “affirmatively furthering fair line 25 housing” means taking meaningful actions, in addition to line 26 combating discrimination, that overcome patterns of segregation line 27 and foster inclusive communities free from barriers that restrict line 28 access to opportunity based on protected characteristics. line 29 Specifically, affirmatively furthering fair housing means taking line 30 meaningful actions that, taken together, address significant line 31 disparities in housing needs and in access to opportunity, replacing line 32 segregated living patterns with truly integrated and balanced living line 33 patterns, transforming racially and ethnically concentrated areas line 34 of poverty into areas of opportunity, and fostering and maintaining line 35 compliance with civil rights and fair housing laws. line 36 (f)  For purposes of this section, “household income levels” are line 37 as determined by the department as of the most recent American line 38 Community Survey pursuant to the following code sections: line 39 (1)  Very low incomes as defined by Section 50105 of the Health line 40 and Safety Code. 98 — 10 — AB 1258 B-10 line 1 (2)  Lower incomes, as defined by Section 50079.5 of the Health line 2 and Safety Code. line 3 (3)  Moderate incomes, as defined by Section 50093 of the Health line 4 and Safety Code. line 5 (4)  Above moderate incomes are those exceeding the line 6 moderate-income level of Section 50093 of the Health and Safety line 7 Code. line 8 (g)  Notwithstanding any other provision of law, determinations line 9 made by the department, a council of governments, or a city or line 10 county pursuant to this section or Section 65584.01, 65584.02, line 11 65584.03, 65584.04, 65584.05, 65584.06, 65584.07, or 65584.08 line 12 are exempt from the California Environmental Quality Act line 13 (Division 13 (commencing with Section 21000) of the Public line 14 Resources Code). O 98 AB 1258 — 11 — B-11