HomeMy WebLinkAbout2005-02-15; City Council; 17987; Regional Housing Needs Assessment Alternatives13
AB# 17,987 TITLE:
MTG. 2/15/05 REGIONAL HOUSING NEEDS ASSESSMENT (RHNA)
DEPT. PLN ALTERNATIVES
CITY OF CARLSBAD -AGENDA BILL
DEPT. HD.
CITY ATTY-
my MGSS
RECOMMENDED ACTION:
ADVISE the City’s SANDAG representative on the Council’s choice of RHNA alternatives to support
at the February 25 SANDAG Board meeting.
ITEM EXPLANATION:
Backaround. During every State-mandated Housing Element cycle, each region’s Council of
Governments (SANDAG for the San Diego region) is required to develop a Regional Housing Needs
Assessment (RHNA). SANDAG develops, with input from the State and local jurisdictions, formulas
that are used to distribute to the local jurisdictions the estimated need for housing for the up-coming
five-year period. Part of this distribution is to allocate housing for four income groups: very low-
income, low-income, moderate-income, and upper-income. As required by State housing element
law, each jurisdiction is then required to demonstrate in its Housing Element that its general plan and
zoning provide adequate numbers of sites, in a variety of density ranges, to accommodate the units allocated to it. For lower-income housing new State law requires that these densities support multi-
family housing in the range of 20 - 30 dwelling units per acre. The number of lower-income housing
units that are allocated to a jurisdiction determines how many acres of developable, high-density land
the jurisdiction needs to show in its land inventory.
On September 24, 2004, the SANDAG Board distributed a draft Regional Housing Needs
Assessment for the 2005-2010 housing element cycle for a 90-day public review period. The draft
RHNA allocates a share of the region’s needed 107,301 housing units (broken out by the four income
groups) to each jurisdiction. At its December 2, 2004 meeting, the CitylCounty Management
Association requested that the review period be extended by 30 days, which extension ended
January 31, 2005. The reason for the request was that a number of jurisdictions, including Carlsbad,
had raised issues about the formulas that had been used to produce the draft numbers, particularly
the allocations of low- and very low-income housing units. Carlsbad, Encinitas, Poway and the
County all requested that discussions be re-opened to consider alternatives to the formulas that had
been used to produce the draft numbers.
Carlsbad staff provided information to SANDAG that pointed out that the methodology accepted by
the SANDAG Board for the lower-income housing allocations was at odds with both the philosophy
and methodologies used previously by three other Councils of Governments and that these
alternative methodologies had been accepted by the State of California as being consistent with
housing element law. Carlsbad staff pointed out that these alternative approaches had not been
considered in the development of the formulas used in the draft RHNA (See Attachment 3 for a copy
of the Carlsbad letter). In response to these requests, on January 13th SANDAG staff returned the
matter to its Regional Planning Technical Working Group (TWG - Planning Directors), followed the
next day by a policy meeting (non-voting) of the SANDAG Board. Both groups considered a range of
alternative methodologies, including the original three alternatives that SANDAG staff had
considered, two methods that have been used by other COGS (Southern California Association of
Governments [SCAG] and the Association of Bay Area Governments [ABAG]), and a “compromise”
idea put forth by the City of Poway (being called “Alternativel-A). Following extended discussion
and several split straw votes, neither group was able to form a consensus on any of the alternatives
before them. The matter was returned a second time to the Technical Working Group on January
26, 2005, to try to reach a consensus on either the Poway Alternative I-A or the formula used in the
draft RHNA document. While eleven agency representatives (including Carlsbad’s) indicated they
PAGE 2 OF AGENDA BILL NO. 17,987
could support Alternative I-A, seven other agencies could not compromise so as to reach a
consensus. As a result, no recommendation came from this group.
Upcomina Action. SANDAG will send the matter to SANDAG Board’s Regional Planning Committee
on February 4, 2005, with the objective of forming a recommendation to the full SANDAG Board. The
Board is scheduled to adopt the final RHNA document and housing numbers on February 25,2005.
However, in order to adopt the document, the Board will have to adopt a methodology to generate the
lower-income allocations.
The matter before the City Council is to consider what advice to give its representative to the
SANDAG Board for voting on the lower-income methodologies and the final RHNA package on
February 25,2005.
How the alternative allocations affect Carlsbad. The key matter is that whatever allocations are
adopted by the SANDAG Board, each local jurisdiction will have to show in its land inventory that it
has enough land zoned and designated with the densities needed to support the numbers of lower-
income housing in its allocation. The controversy being experienced in the region stems from the
fact that many San Diego jurisdictions, and including Carlsbad, will have an extraordinarily difficult
time providing this land inventory under the allocations proposed in the draft RHNA.
Attachment 1 is a table that shows for all nineteen SANDAG jurisdictions the total housing share (Le.:
for all income groups) that the draft RHNA allocates to them (column 8). In addition the table shows
the number of lower-income housing units each jurisdiction would be assigned under the ABAG,
SCAG and three SANDAG alternatives (columns 8-13). Please note that the draft RHNA document
is based upon SANDAG Alternative 3, the methodology that produces the largest lower-income
numbers for Carlsbad and all the jurisdictions shown in blue on the table. In addition, the Poway
compromise - based upon a modification of SANDAG Alternative 1 (so-called Alt. I-A) - is shown in
column 15. For Carlsbad, the numbers range from a low of 2,798 lower-income units (ABAG
methodology) to a high of 4,322 units under SANDAG Alternative 3, corresponding to 33 percent and
52 percent, respectively, of our total RHNA allocation of 8,376 units.
Attachment 2 is a table that shows the status of staffs analysis of our land use inventory with regard
to the ability to provide land for lower-income housing with the required density. With our current land
inventory, we are allowed to count: a) vacant land at high density (including, we plan to argue, up to
1,000 units in the Village), b) the underutilized capacity of developed high density land that is
underdeveloped relative to the allowed density, c) second dwelling units (limited to our actual
production last cycle), d) redevelopment of existing land uses (for example the Plaza Camino Real
Mall), and e) (unique to Carlsbad) lands to which we can assign density bonuses from our Excess
Dwelling Unit Bank. Based upon staffs preliminary analysis, we may be able to demonstrate up to
3,050 units though these means. It must be noted that even under the most optimistic of these land
use scenarios, Carlsbad will be challenged to meet the numbers produced by even the relatively
favorable Alternative 1 -A (Poway compromise), with SANDAG Alternative 3 (the draft methodology)
likely proving to be extremely difficult to meet.
It must also be noted that the State of California has yet to review our preliminary land use analysis
and State reviewers may challenge some of the things we plan to offer.
Other options to address the issue.
1. In addition, the City can also (may have to) designate residential lands that we would up-zone
and land that might be converted from non-residential to residential use at high densities.
The City is already engaged in identifying potential projects where such actions might be
undertaken. Under new State housing law, such re-zonings/up-zonings would only “count” for
lower-income if they were at a minimum density of 20 d.u./acre. There are a number of
Growth Management and Excess Dwelling Unit Bank issues that need to be sorted out to
PAGE 3 OF AGENDA BILL NO. 17,987
effect these options.
2. State law allows two jurisdictions under the same COG to execute agreements to swap
portions of RHNA allocations providing the total lower-income numbers for the region remain
constant. The County and City of San Diego have entered into such an agreement, under
which the County takes on some of the City’s upper-income needs and the City takes on
some of the County’s lower-income needs. The City of Poway is actively exploring a similar
agreement with National City, in which some financial considerations appear to be part of the
negotiations. However, an agreement has not been concluded as of this writing.
Staff recommendation: Based upon the politics that have been demonstrated at previous SANDAG
meetings, staff believes it is not possible for a SANDAG Board consensus to be achieved with regard
to our recommendation to consider the methodologies used by other COGS, or for SANDAG
Alternative I. Therefore, the City’s best option would be to work for a consensus to use Poway’s
suggested Alternative I-A.
ENVIRONMENTAL:
Providing direction to the Council’s SANDAG representative on how to vote on the RHNA options
does not constitute a project under CEQA and no environmental document is required.
FISCAL IMPACT:
There are no fiscal impacts associated with the proposed action.
GROWTH MANAGEMENT STATUS:
There are no growth management impacts associated with the proposed action.
However, land use changes that may be required to accommodate the final RHNA numbers could
have effects on Growth Management. If the City determines it needs to up-zone or re-designate
land, there likely would be requirements for evaluating the adequacy of the Local Facility
Management Plans where those changes would be considered. In addition, the balances of the
Excess Dwelling Unit Bank may have to be augmented with additional units to meet our
requirements.
EXHIBITS:
Attachment 1 : Table Comparing Lower-Income Allocation Alternatives - All County Jurisdictions
Attachment 2: Table Showing Carlsbad Land Use Inventory Vs Lower-Income Needs
Attachment 3: Letter to SANDAG, dated January 5, 2005, proposing revisions to the RHNA formulas
for lower-income impaction factors
DEPARTMENT CONTACT: Dennis Turner, (760) 602-4609, dturn@ci.carlsbad.ca.us
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ATTACHMENT 3
January 5,2005
San Diego Association of Governments Bob Leiter, Director of Transportation and Land Use
401 B Street San Diego, CA 92101-4321
SUBJECT: REVISING THE DRAFT RHNA LOWER-INCOME IMPACTION FACTOR
On behalf of the City of Carlsbad, I hereby request that SANDAG reconsider the formulas that resulted in the draft RHNA numbers, which numbers are now out for formal review. Specifically, Carlsbad requests that the region adopt a lower-income impaction adjustment that differs from the one used to produce the draft numbers and substitute a methodology that has been used by either ABAG or SCAG.
We have recently learned that the impaction adjustment that SANDAG has used is radically different in philosophy and effect from the approaches used throughout the
state by other California Councils of Government over several housing element cycles.
We feel that SANDAG should use a methodology that is in keeping with accepted practice in California.
The SANDAG method results in lower-income needs numbers that, for many jurisdictions, are excessive and probably impossible to implement in the jurisdiction's land inventory, even where the jurisdiction is considering significant land use changes. It requires jurisdictions to make up in a single housing cycle deficiencies that have often developed over.decades. In 'doing so, it ignores historical and current market demand, one of the principal factors that housing law requires be considered in developing RHNA numbers. The result is that a number of SANDAG jurisdictions have draft RHNA
numbers that call for more than 50% of their remaining residential land capacity to be set
aside for high density development. For suburban jurisdictions that have historically developed with suburban densities this is %a call for extraordinary change. In Carlsbad, where we are rapidly running out of land and over 50% of our remaining vacant land is
entitled by master plans, master tentative maps, and specific plans for suburban density development, we are severely limited in what we can up-zone or convert from non- residential to higher density residential land. Even with the several major land use changes we think we can bring about, we cannot, in one giant step, create a land inventory in keeping with what the draft RHNA numbers would require.
In contrast, the methodologies used by the Association of Bay Area Governments (ABAG), the Southern California Association of Governments (SCAG), and the Sacramento Area Council of Governments (SACOG) all use a different philosophy and result in impaction adjustments that are much more moderated, and, therefore reasonable and achievable. While the methodologies used by these COGS differ somewhat in their specific calculations, all recognize historical market demands and
assume that jurisdictions that vary from the regional lower-income averages should 6
Draft Lower-Income Impaction Adjustments
January 5,2005 .
Paqe 2
make moderate adjustments over a much longer period of time (30 years in the case of
SACOG) to move towards that regional average. Consequently, the numerical
adjustments are reasonable and achievable.
Importantly, we wish you to know that the California Department of Housing and Community Development (HCD) has accepted all of these other methodologies over a number of housing element cycles and certified housing elements that have used RHNA
numbers derived from these methodologies.
The SACOG methodology is mathematically robust and sophisticated and depends upon
collecting a significant amount of localized data. 'In contrast, the methodologies used by
ABAG and SCAG are mathematically simple, easy to understand, and very similar.
Carlsbad requests that SANDAG replace its current methodology and adopt either of
these two latter methodologies. Revised RHNA numbers could be produced very quickly using either methodology, resulting in no delay to the review process.
I have provided additional information as attachments to this letter. First, a two-page memo from our housing consultant, CottonlBddgeslAssociates, summarizes the methodologies of the three other COGS. Second, I have prepared a table that compares
the results of using the SANDAG, ABAG, and SCAG methodologies to generate lower- income RHNA numbers for each SANDAG jurisdiction. The effects of our request can
be immediately seen.
We would respectfully request that this matter be placed before the Regional Planning Working Group at its next meeting for that group's consideration.
If you have any questions please contact me at (760) 602-4609 or at
dfu rn@ci.carls bad .ca. us.
Sincerely,
DENNIS A. TURNER
Principal Planner
Attachments:
Memo from CottonlBridgeslAssoc. Tabie Comparing Lower-Income impaction Correction Factors, by COG
c: Sandy Holder Jane Mobaldi
Don Neu
Mike Grim Debbie Fountain Susan Baldwin - SANDAG
? ,
impaction
Low
’
Average
High
December 17,2004
Definition Adjustment
Share of lower income households is
10 percentage points less than the regional average regional average !
Share of lower income households is within 10 percentage points of the regional average regional average
Share of lower income households is
10 percentage points above the regional average regional average
New construction targets move
V” of the way towc$d the
New construction targets move
% of the way toward the
New construction targets move
3h of the way toward the
To: Dennis Turner and Scott Donnell City of Carlsbad
From: Veronica Tam
Co~on/Bridges/Associates
Subject: Methodologies for RHNA Impaction Correction
Pursuant to State law, each Council of Governments (COG) is responsible for distributing its share of state housing growth to jurisdictions within its region. State law further calls for
each COG to allocate future housing needs for each jurisdiction in a manner as to reduce the concentration of low income households. This memo summarizes the impaction correction methodologies used by the Southern California Association of Governments (SCAG), Association of Bay Area Governments (ABAG), and Sacramento
Area Council of Governments (SACOG).
SCAC - 1998-2005 Regional Housing Needs Plan
SCAG has developed a faire share adjustment that takes into account a community‘s current share of lower income households. Communities are grouped into three categories and a different adjustment is applied depending on how their share of lower income households compares with the region.
ABAG - 1999-2006 Regional Housing Needs Plan ABAG‘s methodology accomplishes this by shifting each jurisdiction’s income distribution as determined by the 1990 Census 50 percent towards the regional average. The distance of each jurisdiction’s existing income percentage from the regional average will determine the amount of adjustment applied.
SACOC - 2000-2007 Regional Housing Needs Plan
The RHNP establishes a minimum floor for each of the four household income categories
of not less than 4 percent of each jurisdiction’s total 2000 - 2007 projected housing unit development. In addition, the RHNP establishes a maximum ceiling of not more than 30 percent of each jurisdiction‘s total 2000 - 2007 projected housing unit development in the very-low and low income categories.
The allocation methodology derives future goals for each community based on SACOG’s objective of achieving the housing market area average by income category in each jurisdiction between 1990 and 2020, The extent of the adjustment depends on
how much the jurisdiction's base-year (1 990) income distribution differs fiom the market area average.
Very Low Income.
Low Income
Total
Jurisdictions having a high percentage of low income housing in 1990 are allocated a declining percentage of low income households through 2020 while jurisdictions having a low percentage of low income housing in 1990 are allocated a rising percentage
through 2020, at which time all jurisdictions, theoretically, would have the same
percentages in all income categories.
Proportion of Lower Income (based on 2003 CHAS) SCAG ABAG Less than 10 Less than percentage regional points below average - '15 Son Diego region - % way way toward Carlsbad County toward region region
'- 12.7% 21.9% 17.3% 17.3%
12.4% 17.5% 15.0% 15.0%
25.1 % 39.4% 32.3% 32.3%
Carlsbad RHNA Based on the draft RHNA. Carlsbad is allocated a future growth need of 8,353 units at the
following income distribution:
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Very Low Income - 30 percent Low Income - 22 percent Moderate Income - 21 percent Above Moderate - 27 percent
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Regional Housing Needs Assessment (RHNA)Housing Element Cycle 7/05 –6/10
The Issue•The final Regional Housing Needs Assessment (RHNA) is to be adopted by SANDAG Board on 2/25•Council should discuss related issues and advise its rep to SANDAG Board
New Housing Elements•Housing cycle 7/05 –6/10•Housing Element to include:–An assessment of needs•Housing Needs Assessment (incl. RHNA)•Inventory of “sites” to meet need•Inventory of resources and constraints–Statement of goals/numerical objectives•May be less than assessed need, if good faith effort–5-year program of actions (including responses to shortage of “sites”)
New Housing Elements•Housing cycle 7/05 –6/10•Housing Element to include:–An assessment of needs•Housing Needs Assessment (incl. RHNA)•Inventory of “sites” to meet need•Inventory of resources and constraints–Statement of goals/numerical objectives–5-year program of actions (including responses to shortage of “sites”)
RHNA (Need) Process:•State gives region 7.5 year est. of total housing need–107,000 d.u. from state HCD–SANDAG Forecast = 89,000 d.u.; extra 18,000 (20%)•Distribute to single share for each jurisdiction (SANDAG formulas)–Uses 2030 Forecasts; extra 18K proportional by pop.–Carlsbad gets 8,353d.u. (of 107,000)•Break-out four income groups (v. low, low, mod, “other”) (SANDAG formulas)
San Diego Income Fractions22.5Very Low17.1Low18.9Moderate41.5UpperPercentage of totalIncome GroupCombined low and very low = 39.6 % (40%)
Controversy: Lower-Income Formula•If divided equally, each jurisdiction gets 40% “lower” income (“fair share”).•However, law calls for seeking to reduce concentrations of lower-income in cities with “disproportionately high proportions”
•SANDAG committees considered 3 alts before draft released. No consensus on methodology.•SANDAG Board released draft RHNA using “Alt 3”–Uses “rewards and penalties” concept
San Diego Lower-Income Fractions70759949257%48%40%21%Poway4,3223,8193,31752%46%40%27%Carlsbad64559654747%43%40%31%Santee6,3226,5716,82137%38%40%42%Chula Vista84590596535%37%40%44%Escondido579212618%29%40%61%National CityAlt 3Alt 2Alt 1 Alt 3Alt 2Alt 1ActualLowerCity
During Draft Review•Carlsbad learns about methods used by other Councils of Government –Accepted by State–ABAG, SACOG, SCAG–All methods more gradual in adjustments than any SANDAG alts. No “penalties and rewards”•Calls for renewed discussion over methodology–Multiple SANDAG forums for discussion•No consensus reached on methods used by other COGs. Debate focused on Alt 1 and Alt 3.•Poway offers compromise methodology: Alt “1-A”
Compromise: Alt “1-A” (Poway)4923,3175476,821965126Alt 1 5023,3825586,82196557Alt 1-A7074,3226456,32284557Alt 3+20521%Poway+94027%Carlsbad+8731%Santee-49942%Chula Vista-12044%Escondido061%National CityDiff. Alt 1-A and Alt 3ActualLowerCityAlt 1-AThe four cities above 45% actual lower income are deemed to be “disproportionately impacted”. They stay at Alt 3. The unit differences between their Alt 1 and Alt 3 are re-allocated to the “blue” cities. Other “red” cities stay at Alt 1.
Where RHNA stands:•No consensus reached on Alt 1-A, although majority of cities could support–All SANDAG committees failed to give recommendations to Board.•SANDAG Board votes on final RHNA on Feb. 25•Board must vote to select methodology before final RHNA adoption. Choice between Alt 1-A and Alt 3
What Does It Mean For Carlsbad?
Make 7.5-To 5-year Adjustment•7.5-year numbers must be reduced to 5-year numbers by subtracting actual progress over 2 1/2 years (1/03 –6/05)•Carlsbad is estimated to produce 575 lower-income units in this period.3,7474,322Alt 32,8073,382Alt 1-A5-years7.5 yearsAlternative
Sites/Land InventoryDo we have enough land with the needed densities to meet the RHNA “need”?
New Sites Law: AB 2348•AB 2348 (Effective 1/1/05)–Limits land inventory Do either:•A. Analyze how existing densities meet need, OR•B. Show land at 30 d.u./ac (We have none)–If “shortfall”, create enough newsites at min. of 20 d.u./ac. for 100% of shortfall (I.e.: all “lower’ must be min of 20 d.u./ac.)–“By Right”. All shortfall must allow development of MF apts./condos “by right”
AB 2348 (cont.)–Law assumes •GP/zoning changes willoccur; •States “growth limiting” ords. have no effect.–GP/Zoning changes may include:•Up-zone vacantresidential land•Up-zone developedres. land and count resulting “under-utilization”•Convert non-res to residential •All at 20+ d.u./ac
How Does Carlsbad Measure Up?•Sites counted with certainty•Sites we can potentiallycount•Sites we will put forward, but HCD acceptance may be questionable•Growth Management Plan and Excess Dwelling Unit Bank
Sites: Certainty1,802Total100Underdeveloped320Ponto (2ndRedevt. Area)1,000Village 125Second Dwelling Units257RH (17-23 d.u./ac.)UnitsType
Sites: Potential 500Plaza Camino Real Mall600Total100Industrial LandPotential UnitsType
Sites: Questionable851Total ?“Quarry Creek II” (Zone 25)851RMH (8-15 d.u./ac.)UnitsType
Adding It UpAlt 3 = 3,7473,153?8511005001003201,000125257UnitsXXXXXExcess D.u. BankTotalsAlt 1-A = 2,807RMH (8-15 d.u./ac.)“Quarry Creek II” (Zone 25)Plaza Camino Real MallIndustrial LandTypeRH (17-23 d.u./ac.)Second Dwelling UnitsVillage Ponto (2ndRedevt. Area)Underdeveloped
Conclusion on Sites•Under Alternative 1-A the City will be challenged to show it has all needed sites. –Depends upon the “potential” and “questionable” sites•Under Alternative 3, the city is short some 700 units of high density land, even with “potential” and “questionable” sites
What Could Happen If Alt 3 is Adopted by SANDAG Bd?•Find still more sites–Up-zone existing res. sites to 20+ d.u./ac•> 50% of vacant land is entitled•Community character issues•Up-zone for addedredevelopment potential (Village, etc.) –Convert non-res. to residential at 20 d.u./ac.–Growth Management Plan issues•Pursue legal challenges to RHNA process/ numbers–Uncertain basis for challenge
What Could Happen? (cont.)•Self-certification (S.D. area demonstration program ends this cycle)–Upside•Required findings probably can be made•State does not review/certify Housing Element–Down side:•No presumption of adequate element, if challenged•Some housing funds not available•Some infrastructure funds maynot be available (ex: transportation)
Questions and Discussion