City of Culver City, California
City Council Agenda Item Report
RECOMMENDATION:
Staff recommends the City Council receive and file the Regional Housing Needs
Assessment (RHNA) status update report.
BACKGROUND:
The Southern California Association of Governments (SCAG) is responsible for
allocating minimum new housing unit numbers, known as Regional Housing Needs
Assessment (RHNA) to all jurisdictions within its area. RHNA numbers for the entire
SCAG region are determined by the State of California Housing and Community
Development (HCD) Department and reflects the HCD’s assessment as to how
many new units are required in order to provide adequate housing for the expected
increase in the State’s population. The RHNA numbers are further divided by
affordability, that is, very low, low, moderate, and above moderate income levels.
Local jurisdictions are responsible for demonstrating they have the capacity to build
their share of the RHNA numbers. This translates into HCD’s requirement that they
review all Housing Elements in the State. RHNA numbers are usually allocated
every five years, meaning that Housing Elements must be reviewed by the HCD
every five years.
The key issue that HCD reviews when looking at Housing Elements (as well as
supporting documentation such as Land Use elements and Zoning Maps) is whether
or not a local jurisdiction can demonstrate they have adequate General Plan
Housing and Land Use Element policies, goals and objectives and sufficient Zoning
to absorb the number of units expected to be built over the given RHNA cycle.
Meeting Date: 12/18/06 Item Number: A-2
AGENDA ITEM: Regional Housing Needs Assessment (RHNA) Status Update
Report.
Contact Person/Dept.: Susan Yun and
Tevis Barnes
Phone Number: (310) 253-5755 and
(310) 253-5782
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Public Hearing: [] Action Item: [X] Attachments: []
Public Notification: Master Notification List (12/14/06).
Department Approval:
Susan Evans (12/11/06)
City Manager Approval:
Jerry Fulwood (12/14/06)
City Controller Approval:
Marlee Chang (12/14/06)City of Culver City, California
City Council Agenda Item Report
Recently, SCAG issued draft RHNA numbers to all jurisdictions within the SCAG
region. These RHNA numbers are still being fine tuned by SCAG staff with final
draft numbers scheduled for approval in February of 2007 and final RHNA
allocations numbers set around July of 2007.
At this time, staff is presenting to the City Council, a RHNA status update with no
official recommendation other than receiving and filing as background information for
future actions.
Also, staff anticipates coming back to the City Council to request a budget allocation
to pay for a housing consultant that can assist the City in drafting a Housing Element
in response to Culver City’s share of RHNA numbers.
DISCUSSION:
Below is a bullet point synopsis of where the SCAG region is at in the RHNA
process, including milestone dates.
On November 2, 2006, at SCAG’s CEHD Committee Meeting, the draft RHNA
was issued. The total draft RHNA number for Culver City is 499 units over a 6
year RHNA cycle (2008 – 2014).
Draft RHNA numbers for the other Westside Cities are: Beverly Hills – 444,
Santa Monica – 669, West Hollywood – 609, Unincorporated – 1,226.
“Credit” can be taken for housing built between the last cycle and the start of the
new one [3-year gap period (2005-2008)]. The prior RHNA cycle covered the
period 1998-2005. Culver City’s RHNA was 650 units.
Fare share adjustment (110% towards the County distribution in each of the 4
income categories) for Culver City:
Very Low: 25.6% of 499 or 128 units
Low: 15.9% of 499 or 79 units
Moderate: 16.8% of 499 or 84 units
Above: 41.6% of 499 or 208 units
On November 3, 2006, SCAG held a workshop with Westside Cities staff to
gather input on the draft RHNA numbers and is seeking feedback from Cities for
further refinement before adopting the draft RHNA numbers on February 1, 2007. City of Culver City, California
City Council Agenda Item Report
On December 14, 2006, SCAG Regional Council will hold a meeting to discuss
Appeals Policy and/or Trade and Transfer Policy. No action will be taken on the
draft RHNA numbers that day.
On January 11, 2007, SCAG is tentatively scheduling a RHNA methodology
follow up Public Hearing (12 p.m. to 7p.m.) to allow additional input from local
jurisdictions.
On February 1, 2007, SCAG Regional Council will make final decision on draft
RHNA numbers and approve Appeal policies. Comments can be received up to
February 1, 2007, BUT the sooner the better. Appeal process begins February
1, 2007.
On or about June/July of 2007, the Regional Council will have considered all
appeals and adopt Final RHNA numbers.
On June 30, 2008, City approved Draft Housing Element is due to the State
HCD.
Housing Element:
The RHNA has always been the legal basis for jurisdiction’s Quantified Objectives in
the Housing Element, and is also used to determine whether there is sufficient
supply of vacant or underutilized land to accommodate the residential growth
reflected in RHNA.
Recent amendments to State housing law give the RHNA much more importance,
however. The most significant change in law requires that if the analysis of available
sites for housing (the “land inventory”) does not demonstrate adequate capacity to
accommodate the RHNA for all income levels, then jurisdictions must rezone
sufficient land to meet the shortfall and the rezoned sites must allow development
“by right”. State HCD interprets “by right “to mean no discretionary review (e.g.
Conditional Use Permit) and no additional CEQA review. The important
consideration is that the RHNA now has more “teeth” and can directly lead to the
requirement to rezone land for high-density housing. Failure to follow through could
result in judicial intervention in the local land use planning process.
Although the Housing Element update is not due until June 30, 2008, critical steps
that will have major consequences for the Housing Element are now underway. It is
important that Culver City review the preliminary RHNA to determine whether it is
reasonable in relation to City conditions, plans and policies and if not, provide City of Culver City, California
City Council Agenda Item Report
feedback to SCAG as soon as possible. A recent law, AB 2158, set forth a list of
factors that may be used to support a request for modification to RHNA numbers
(the “2158 factors”). Local feedback to SCAG regarding the preliminary RHNA and
residential growth potential should be based on these factors, which includes such
things as physical constraints (slope, floodplains, critical habitats, etc.) and land
ownership (parkland, land owned by other government entities, etc.). SCAG has
broken down the RHNA forecast into traffic analysis zones (TAZ) and has requested
that feedback provide a similar level of detail supported by 2158 factors rather than
general comments.
FISCAL ANALYSIS:
No fiscal analysis at this time. However staff will return to the City Council to request
a budget allocation to pay for a housing consultant that can assist the City in drafting
a Housing Element.
ATTACHMENTS:
No Attachments.
MOTION:
That the City Council receive and file the Regional Housing Needs Assessment
(RHNA) status update report.