Regional Housing Needs Assessment

The Regional Housing Needs Assessment (RHNA) is the California state-mandated process within the housing element of its General Plan, to determine how much housing must be planned for each jurisdiction (city or unincorporated county) according to Housing Element Law to meet 'projected and existing' housing needs at a variety of affordability levels. Based on demographic data, the state calculates housing need in coordination with each region’s planning body, known as a Council of Governments (COG). Once the state and the COG agree, the COG is responsible for the allocation among all jurisdictions within that region through a RNHA Plan. Housing elements are then reviewed by the California Department of Housing and Community Development (HCD) and must be adopted by the jurisdiction which is then responsible for ensuring there are enough sites and proper zoning to accommodate its RHNA allocation. The cycle repeats every eight years.^[1][2][3] Jurisdictions which fail to adequately accommodate projected growth as determined by HCD are subject to fines from $10,000 per month to $600,000 per month.^[4][5]

Sixth Cycle Objections[edit]

UCLA Study[edit]

Gavin Newsom had declared in his 2017 gubernatorial campaign, “As governor, I will lead the effort to develop the 3.5 million new housing units we need by 2025, because our solutions must be as bold as the problem is big.”^[6] In 2022, the sixth cycle RHNA figure for the eight year period 2023-2031 came in at 2.5 million, a million below the Governor's promise and yet more than double what the fifth cycle goal had been of 1.2 million.^[7] The Embarcadero Institute emphasized the 2.5 million figure was based on New York as a benchmark while Texas would result in an assessment of 1.5 million.^[8] UCLA noted that actual construction does not tend to meet assessments; for example, over the Housing Element planning period covering 2003-2014, permitted construction only met 47 percent of assessed needs. The study by UCLA found that not enough land exists in the state of California to have met Governor Newsom's ambitious target, and most of the land that is available for building lies in areas where there is no demand.^[9]

California State Audit[edit]

In early 2022, the California State Auditor reviewed the sixth cycle RHNA and determined that "HCD does not ensure that its needs assessments are accurate and adequately supported." Multiple areas were identified in which the auditor reported "HCD must improve its process." HCD’s needs assessments also relied on some projections provided by the Department of Finance which failed to support assumptions made. The auditor reported the Finance Department "cannot ensure that it is providing the most appropriate information to HCD" without reevaluation; and regarding HCD projections stated that "insufficient oversight and lack of support for its considerations risks eroding public confidence."^[10]

Embarcadero Institute Audit[edit]

The President of the Embarcadero Institute, Gab Layton PhD, reported double counting in the sixth cycle RHNA assessments. His report claims the use of an incorrect vacancy rate and double counting, inspired by SB-828, caused the HCD to exaggerate housing needs in Southern California, the Bay Area and the Sacramento area by more than 940,000 units. Four regional planning agencies cover the 21 most urban counties and account for 80% of California’s housing, and all four of these regions saw a significant jump in the state’s assessment of their housing need for the sixth cycle. These regions include the San Diego region, six southern California counties, the Greater Bay Area, and the Sacramento area. The Embarcadero Institute audit found Senate Bill 828 had been drafted absent a detailed understanding of the Department of Finance’s methodology for developing household forecasts, and absent an understanding of the difference between rental and home-owner vacancies, leading to a series of double counts. Layton stressed that inaccuracies on this scale mask the fact that cities and counties are surpassing the state’s market-rate housing targets but falling far short in meeting affordable housing targets; the inaccuracies obscure the real problem and the associated solution to the housing crisis — the funding of affordable housing.^[11]

Department of Finance - Population Revisions[edit]

The California Department of Finance revised the state population projection to 2060 down to a flat 39.6 million, compared to the current population which is just over 39 million.^[12] The new projection is 4.7 million lower than the original projection made two years earlier, which is more people than live in 26 states. In 2007, the population had been projected to grow to a staggering 59.5 million residents by 2050.^[13]

References[edit]

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