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Home My WebLink About2019-08-12; Draft 6th Cycle Regional Housing Needs Assessment Methodology; |Fountain, Debbie| Barberio, Gary|To the members of the: p1YCOUNCIL Date'BI 1~! 1~ CA _:!_ cc .:L, CM ..:::__ coo ..:£_ DCM {3) L August 12, 2019 Council Memorandum To: Honorable Mayor Hall and Members of the City Council {cityof Carlsbad Memo ID# 2019092 From: Via: Re: Debbie Fountain, Community and Economic Development Director Gary Barberio, Deputy City Manager Co t?.nity Services Elaine Lu key, Chief Operations Officer Draft 6th Cycle Regional Housing Needs ssessment Methodology The purpose of this memorandum is to provide City Council with an update on San Diego Association of Government's (SANDAG) draft 6th Cycle Regional Housing Needs Assessment (RHNA) Methodology, providing information on the SANDAG staff and Board subcommittee recommendations and the public input process and next steps for processing and approval. Background As required by state law, cities and counties must plan for housing needs through periodic updates to their housing elements. For the next 2021-2029 housing element planning period (6th cycle), the Housing and Community Development Department (HCD) has determined that the San Diego region needs to accommodate 171,685 total new housing units. Planning for the next Housing Element update is underway by the SANDAG, regional planning agency. The new Regional Housing Needs Assessment (RHNA) must be completed and allocations must be made to each of the San Diego County region's 19 jurisdictions by Fall 2019 to allow local jurisdictions to prepare their 6th cycle Housing Elements and submit to HCD for approval by April 2021. On July 26, 2019, the SANDAG Board of Directors released the draft RHNA Methodology and justification for meeting RHNA objectives and factors as outlined in state law for public comment. Written comments are due to SAN DAG by Aug. 21, 2019, in order to include them in the handouts provided to the SAN DAG Board of Directors for the public hearing scheduled for Aug. 23, 2019, where a final decision on the draft methodology will be requested from the Board. Attached as Exhibit 1 is the SANDAG Draft 6th Cycle Regional Housing Needs Assessment . Methodology which provides for additional overview and explanation of the process and criteria for a RHNA allocation of housing units to each jurisdiction for Housing Element planning purposes. Also attached for City Council review as Exhibit 2 is the July 26, 2019, SAN DAG Board Staff Report which provides additional information on the process and related considerations for the draft methodology. Community Services Branch Community & Economic Development Department 1635 Faraday Avenue I Carlsbad, CA 92008 I Honorable Mayor Hall and Members of the City Council Aug. 12,2019 Page 2 Discussion The RHNA is mandated by state law and accomplishes two goals; 1) it quantifies the need for housing and 2) it informs land use planning in addressing identified existing and future housing needs resulting from population, employment, and household growth. As the council of governments, SAN DAG is responsible for overseeing the RHNA process for the San Diego region and its 19 jurisdictions. In December 2018, the SAN DAG Board of Directors created the RHNA Subcommittee to provide input and guidance to the SANDAG Board of Directors regarding the RHNA plan for San Diego County and its 19 jurisdictions. The RHNA methodology was developed with input from this RHNA Board Subcommittee who was also charged with making a recommendation to the full board on the draft RHNA methodology and allocation to each jurisdiction. Development of the RHNA methodology was also informed by input from the Regional Planning Technical Working Group (TWG), Regional Planning Committee (RPC), the Board of Directors, and ultimately the public. The State Department of Housing and Community Development (HCD) determined in July 2018 that the San Diego region would need to plan for 171,685 housing units. Since February 2019 SANDAG staff have been working with the RHNA Subcommittee to develop an allocation methodology to distribute housing needs in the region. State law requires the SAN DAG housing unit methodology to focus on five objectives; however, state law does not dictate how those objectives should be prioritized. The five objectives are: 1. Increasing the 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. 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 further fair housing. After considerable discussion and consideration of the state's objectives, the RHNA Subcommittee decided to focus on a framework that emphasized housing access to transit and Honorable Mayor Hall and Members of the City Council Aug. 12,2019 Page 3 proximity to jobs centers, with adjustments for equity and jobs/housing ratio. Other factors that the subcommittee considered were population share and whether to include total or civilian- only employment in the jobs factor. In the methodology, the RHNA Subcommittee provided direction on a 65%-35% weighting of transit and total jobs, and to consider equity and jobs/housing ratio adjustments based on a jurisdiction's variance from regional averages. Jurisdictions with higher relative household incomes and/or higher jobs/housing ratios would receive an upward adjustment to the overall and/or lower income housing share, while those jurisdictions with lower relative incomes and/or jobs-to-housing ratios would receive downward adjustments. At their May 24, 2019, meeting, the RHNA Subcommittee directed staff to also conduct additional analysis to account for military- provided housing and corresponding jobs to consider an exclusion of these housing units and ultimately reduce the allocation for cities and the county who host military bases. After continuing discussion on the methodology; the subcommittee recommended the methodology summarized below but with a military exclusion for housing units located on a military base. At the SANDAG Board Meeting on July 26, 2019, the Board approved the original staff recommendation that included no military housing exclusion for release for a public comment period. Attached as Exhibit 1 is a copy of the draft 6th Cycle RHNA Methodology; this draft methodology is submitted for review by the City Council and has been noticed by SANDAG for public comment. A summary of the draft methodology is noted below: • 65% of the RHNA is to be distributed according to each jurisdiction's relative share of transit stations, rapid bus stations, and major transit stops. Carlsbad has two of the region's 154 rail and rapid bus stations, and none of the 140 major transit stops. • 35% of the RHNA is to be distributed according to each jurisdiction's relative share of the region's total jobs. Carlsbad has the region's third highest share of jobs (76,779 jobs or 4.76% of the region). • An equity adjustment is applied to each jurisdiction's allocation such that more housing units are allocated to an income category that is less than the regional average. Carlsbad's household incomes skew higher than the region overall, therefore more of its allocation would skew towards the lower income categories. • No adjustment is made for jobs/housing balance. Carlsbad's job-to-housing ratio is 1.66 compared to the region's 1.39. Please note that the above draft methodology does not include an exclusion for military base housing. The SANDAG Board decided to approve the original methodology recommended by staff, without the exclusion for military housing. The Board, however, reserved its right to reconsider its approval of the draft methodology after review of the public input. Honorable Mayor Hall and Members of the City Council Aug. 12,2019 Page 4 For each of the 19 jurisdictions, housing need will be apportioned among four income categories: Very Low, Low, Moderate, and Above Moderate. If the draft RHNA Methodology is ultimately approved by SAN DAG and HCD, the housing allocation for Carlsbad will be as set forth below. For comparison purposes, the current 5th cycle Carlsbad RHNA is also shown. Carlsbad Allocation {proposed methodology): Very Low Low Moderate Above Total Region (s;S0%AMl 1) (51-80%) (81-120%) Moderate Total (>120%) Proposed 6th 1,310 784 750 1,029 3,873 171,685 Housing Element Cycle {2021-2029} Current 5th 912 693 1,062 2,332 4,999 161,990 Housing Element Cycle (2013-2021) Difference +398 +91 -312 -1,303 -1126 9,695 The table shows that, while the proposed (6th Cycle) allocation overall is less than the current (5th Cycle) one, more units are allocated to the very low and low income categories. This is due to the proposed equity adjustment, which differs from the previous RHNA cycle. The implication here is that Carlsbad would need to demonstrate it has enough higher density (at least 30+ dwelling units per acre), multi-family land capacity to accommodate more than half of its RHNA share. Implications for Carlsbad {draft methodology) Preliminary analysis of the proposed RHNA allocations in relation to available Housing Element sites in Carlsbad reveals a likely need to identify (and rezone) more sites to accommodate higher density multi-family use for the next cycle. For purposes of this analysis, available sites are those sites in the current Housing Element inventory less the sites that have since been developed, are in construction (building permits issued), or have received a planning approval during the current period. Comparing the estimated yield from available Housing Element sites to the recommended RHNA allocation (under the proposed RHNA methodology) reveals a potential deficit of 1,062 units in the very low and low income categories, and a lesser shortfall of 238 units in the moderate and above moderate income categories. Several recent changes to state law will complicate the city's efforts to develop a suitable sites inventory for the next Housing Element update. Recent changes to "No Net Loss" provisions in state law (Government Code Section 65863} now require cities to continually monitor the adequacy of Housing Element sites not only by density but also by the income categories at which housing projects are approved, and to identify additional sites to make up for any shortfall that 11Area Median Income. The 2019 AMI for San Diego-Carlsbad MSA for a family of four is $86,300. Honorable Mayor Hall and Members of the City Council Aug. 12,2019 Page 5 may occur. A problem could arise, for example, when above moderate, market rate residential projects are approved on high density multi-family sites. To avoid repeated re-zoning efforts, a recommended best practice is to build extra capacity into the Housing Element sites inventory to account for approval of residential projects in an income category different than planned in the sites inventory.2 Additionally, changes to Housing Element law will make it more of a challenge than in the past to count certain sites (e.g. small infill or nonvacant redevelopment) as suitable for development. For example, sites smaller than one-half acre and those larger than 10 acres are presumed to be inappropriate for lower income housing unless the city can substantiate otherwise to the satisfaction of HCD. Another potentially complicating factor for the next Housing Element update is the city's local Growth Management Plan. The city's ability to create additional housing capacity through density increases (rezoning) is limited by Proposition E housing caps. As of June 1, 2019, there is the potential to accommodate up to an additional 2,345 dwelling units beyond existing and planned capacity citywide. However, that potential capacity is unevenly distributed among the city's quadrants, being more limited in the Northwest (127 outside the Village) and Northeast (102) than in the Southwest (1,232) and Southeast (318). Therefore, the quadrant caps will have a larger influence in developing the next Housing Element sites inventory than in the past. Next Steps The draft RHNA methodology was released by SAN DAG for a public review and comment period on July 26, 2019. Written comments to be included in the public hearing report for the SAN DAG Board public hearing on Aug.23, 2019, must be received by SAN DAG staff by Aug. 21, 2019. On Aug. 23, 2019, the SANDAG Board will consider all public comments and then determine if any changes need to be made to the methodology. After any revisions are made based on SANDAG Board direction, SAN DAG must forward the draft methodology to HCD for review and tentative approval. Within 60 days, HCD will review the draft methodology and provide any findings to SANDAG. Staff will prepare a staff report for City Council consideration at the Aug. 20, 2019, City Council meeting to share the RHNA methodology proposed by SAN DAG and discuss sending a comment letter to SANDAG or to allow for any other direction on this matter. The SAN DAG Board will be asked to adopt a final methodology in late 2019. At t~at time, a draft allocation showing the number and types of housing units allocated to each jurisdiction based on the final adopted methodology will be posted on SANDAG's website. The draft allocation will be distributed to the local jurisdictions and HCD for an additional 45-day review by those entities. After the RHNA Plan 2By law, cities may not deny a housing project on the basis that it is inconsistent with the income category planned for the site in the Housing Element (GC 65863(c)(2)). Honorable Mayor Hall and Members ofthe City Council Aug. 12,2019 Page 6 is adopted, including both methodology and the allocation, it will be incorporated into the Regional Transportation Plan (RTP) for the region {2021 Regional Plan) and in the housing elements in each local jurisdiction's general plan. The 6th Cycle Housing Elements must be adopted by April 2021. In the coming weeks, city staff will release a Request for Proposals to solicit consultant services to assist with preparing the city's 6th cycle Housing Element update. The SANDAG process to allocate housing units is anticipated to be complete by the end of 2019; this allocation will guide Carlsbad's efforts and land use policies to update its Housing Element. Exhibits 1. Draft 6th Cycle Regional Housing Needs Assessment Methodology, prepared by SANDAG 2. SAN DAG Board of Directors Staff Report, Regional Housing Needs Assessment Draft Methodology, dated July 26, 2019 cc: Scott Chadwick, City Manager Celia Brewer, City Attorney I Ron Kemp, Assistant City Attorney Don Neu, City Planner David de Cordova, Principal Planner Scott Donnell, Senior Planner DRAFT 6th Cycle Regional Housing Needs Assessment Methodology E)<.H U31'T .1 July 26, 2019 Table of Contents Overview ....................................................................................................................................................... 2 Draft Regional Housing Needs Assessment Methodology ........................................................................... 2 Underlying Data and Assumptions ............................................................................................................... 3 Proximity to Transit ................................................................................................................................... 3 Proximity to Jobs ....................................................................................................................................... 5 Equity Adjustment .................................................................................................................................... 6 Local Government Conditions ....................................................................................................................... 8 Board of Directors ..................................................................................................................................... 9 Regional Housing Needs Assessment Subcommittee ............................................................................... 9 Regional Planning Technical Working Group ............................................................................................ 9 Regional Planning Committee ................................................................................................................. 10 Regional Housing Needs Assessment Objectives and Factors .................................................................... 10 Objectives ............................................................................................................................................... 10 Factors ..................................................................................................................................................... 13 Overview On July 5, 2018, the State Department of Housing and Community Development (HCD) determined the San Diego region would need to plan for 171,685 housing units (Regional Housing Needs Assessment [RHNA] Determination) during the 6th Housing Element Cycle (2021-2029). As the council of governments for the San Diego region, the San Diego Association of Governments (SANDAG) is responsible for developing a methodology for allocating the regional housing need among the region's 19 jurisdictions. The methodology must distribute each jurisdiction's housing unit allocation among the four income categories - low, very-low, moderate, and above moderate -and further the objectives set forth in state law. State housing element law requires SANDAG to provide a discussion of the draft methodology that includes the data and assumptions relied upon, and an explanation of how information about local government conditions and how each of the factors required by law was used to develop the draft methodology. (See Government Code Section 65584.04.) SANDAG must also describe how the draft methodology would further the five objectives in Government Code Section 65584. This document is meant to provide the information required by statute to assist the public in understanding the basis for the draft methodology. State law also prohibits consideration of certain criteria. The following justifications have not been used in development of the draft methodology and cannot be the basis for a determination of a jurisdiction's share of the regional housing need: 1. Any ordinance, policy, voter-approved measure, or standard of a city or county that directly or indirectly limits the number of residential building permits issued by a city or county. 2. Prior underproduction of housing in a city or county from the previous regional housing need allocation. 3. Stable population numbers in a city or county from the previous regional housing needs cycle. In addition to state housing element law, state law associated with development of Regional Transportation Plans (RTPs) requires that there be consistency between transportation planning, development of housing, and reduction of greenhouse gas (GHG) emissions. (Government Code Sections 65080 and 65584.) Increased use of public transportation leads to reduced GHG emissions compared to driving alone. This is why the draft methodology was developed with an eye toward maximizing access between public transportation and all housing types. Following the public comment period, and the public hearing planned for August 23, 2019, the SANDAG Board of Directors will determine whether to make changes to the draft methodology. After any revisions are made to the draft methodology as a result of comments received, SANDAG must forward the draft methodology to HCD. Within 60 days, HCD will review the draft methodology and provide any findings to SANDAG. The Board will be asked to adopt a final methodology in late 2019. At that time, a draft allocation showing the number and types of housing units allocated to each jurisdiction based on the final adopted methodology will be posted on SANDAG's website. The draft allocation will be distributed to the local jurisdictions and HCD for an additional 45-day review by those entities. After the RHNA Plan, including both the methodology and the allocation, is adopted it w ill be incorporated in the RTP for the region (202 1 Regional Plan) and in the housing elements in each local jurisdiction's general plan. Draft Regional Housing Needs Assessment Methodology 1. Sixty-five percent of the total housing units will be allocated to jurisdictions with access to transit, including rail stations, Rapid bus stations, and major transit stops. Significant investments in transit have been made throughout the region, and the draft methodology prioritizes housing growth in those areas with access to transit. Encouraging housing growth near transit can promote infill development and preserve open space, as most transit is located in urbanized areas. Improved access to transit also can lower the vehicle miles traveled in a car and reduce GHG gas emissions. DRAFT 6th Cycle Reg ional Hous ing Needs Assessmen t Methodology j 2 2. Within the housing units allocated for jurisdictions with access to transit, 75 percent of the units will be allocated to jurisdictions with rail stations and Rapid bus stations and 25 percent will be allocated to jurisdictions with major transit stops. To ensure future growth is located near transit, the draft methodology prioritizes 75 percent of the housing units in areas with rail and Rapid bus stations. Rail stations and Rapid bus stations usually are located along fixed routes that require significant capital investment to construct. Unlike bus stops or routes, rail and Rapid stations and routes are not amended or eliminated on a regular basis. The remaining 25 percent of the housing units will be allocated in jurisdictions with major transit stops. Major transit stops, as defined in state law, have two intersecting bus routes that arrive at 15-minute intervals during peak commute hours. 3. Thirty-five percent of the total housing units will be allocated to jurisdictions based on the total number of jobs in their jurisdiction. This portion of the methodology was included to address the objectives of promoting infill and improving the intraregional relationship between jobs and housing, jurisdictions should plan for housing to provide opportunities for more residents to live near their place of employment. 4. The allocation applies an equity adjustment. The HCD's RHNA Determination divided the number of housing units needed in the region into four income categories based on the region's current percentages of households in each income category. To promote equity and fair housing, the draft methodology allocates more housing units of an income category to jurisdictions with a percentage of households in that category that is lower than the regional percentage. Underlying Data and Assumptions There are three components of the draft methodology: proximity to transit, proximity to jobs, and the equity adjustment. The underlying data and assumptions used in each component are discussed below. Proximity to Transit Sixty-five percent of the RHNA Determination, or 111 ,595 housing units, will be allocated based on proximity to transit. Because most transit infrastructure is located in the urbanized areas of the San Diego region, heavily weighting proximity to transit will promote infill development, preserve open space, lower-vehicle miles traveled, and reduce GHG emissions. Proximity to transit is further defined by each jurisdiction's share of Rail & Rapid Stations and Major Transit Stops, which are described below. • Rail & Rapid (R&R) Stations: Stations served by rail (North County Transit District [NCTD] COASTER; NCTD SPRINTER; and Metropolitan Transit System [MTS] Trolley, including planned Mid-Coast stations) and Rapid bus routes (NCTD BREEZE Route 350; MTS Rapid Routes 215, 225, and 235; and MTS Rapid Express Routes 280 and 290). ■ Major Transit Stops: The intersection of two or more major local bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. Seventy-five percent of the proximity to transit housing units, or 83,696 housing units, will be allocated based on each jurisdiction's share of R&R Stations, while 25 percent, or 27,899 housing units, will be allocated based on each jurisdiction's share of Major Transit Stops. This reflects the significant investment the region has made to build and improve rail lines and Rapid routes as well as the permanency of rail lines relative to local bus service. Additionally, rail and Rapid routes have higher capacities and are among the more popular DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 3 transportation services in the region. Therefore, the draft methodology assumes these services can have a larger impact on changing commute behavior and achieving mode shift goals. Data Source The data source for proximity to transit is the SANDAG Activity Based Model (ABM). For R&R stations, SANDAG ABM Forecast Year 2025 No Build was used in order to capture the Mid-Coast Trolley stations currently under construction and anticipated to be open for service to the public by 2021. For major transit stops, SANDAG ABM Forecast Year 2020 was used as the specific data source to align with the start of the 6th Housing Element Cycle planning period . For Rapid Stations and major transit stops that have stops on either side of the road, which correspond to northbound/southbound or eastbound/westbound travel, stop pairs were counted as one station or stop. Stations that serve more than one rail and/or Rapid route were counted once in the R&R data. For example, the Oceanside Transit Center, which is served by two rail lines (NCTD COASTER and NCTD SPRINTER), accounts for only one of the seven R&R stations in Oceanside. Some R&R stations are also considered major transit stops because they are also served by two or more bus lines with 15-minute frequencies during peak commute. The Old Town Transit Center in the City of San Diego, for example, is both a R&R station (served by the NCTD COASTER and MTS Trolley) and major transit stop (served by MTS Bus routes 10, 30, 35, and 44, which have 1 5-minute peak period frequencies). The data underlying the proximity to transit component is included in Table 1. Table 1: Proximity to Trans it Data Rail & Rapid Stations Major Transit Stops Jurisdiction Count Regional Share(%) Count Regional Share(%) Carlsbad Chula Vista Coronado Del Mar El Cajon Encinitas Escondido Imperial Beach La Mesa Lemon Grove National City Oceanside Poway San Diego San Marcos Santee Solana Beach Unincorporated County Vista 2 9 0 0 3 1 14 0 5 2 2 7 0 100 3 1 1 2 2 1.3% 5.8% 0.0% 0.0% 1.9% 0.6% 9.1% 0.0% 3.2% 1.3% 1.3% 4.5% 0.0% 64.9% 1.9% 0.6% 0.6% 1.3% 1.3% 0 18 0 0 0 0 0 6 0 0 15 0 0 101 0 0 0 0 0.0% 12.9% 0.0% 0.0% 0.0% 0.0% 0.0% 4.3% 0.0% 0.0% 10.7% 0.0% 0.0% 72.1% 0.0% 0.0% 0.0% 0.0% 0 0.0% Region 154 100.0% 140 100.0% Sources: R&R Stations -SANDAG ABM, Forecast Year 2025 No Build7; Major Transit Stops -SANDAG ABM, Forecast Year 20202 1 SANDAG ABM, Forecast Year 2025 No Build, Release v14.0.1, Reference Scenario #242, January 2019. 2 SANDAG ABM, Forecast Year 2020, Release v14.0.1, Reference Scenario #243, January 2019. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology 14 Proximity to Jobs Thirty-five percent of the RHNA Determination, or 60,090 units, will be allocated based on proximity to jobs. Proximity to jobs considers the number of jobs in each jurisdiction . Data Source The data source for proximity to jobs is the SANDAG Employment Estimates, w hich are also being used to develop the latest Regional Growth Forecast. SANDAG Employment Estimates are derived from Quarterly Census of Employment and Wages (QCEW) data from the Economic Development Department (EDD) and the Longitudinal Employer-Household Dyna mics Origin-Destination Employment Statistics (LODES) data from the Center for Economic Studies at the U.S. Census Bureau . The LODES data combines federal, state, and Census Bureau survey data on employers and employees and SANDAG uses the QCEW dataset for its detailed geographic information on businesses to geolocate "job spaces" throughout the region. Then LODES data (average of the last five years), which are available at the census block level, are used to fi ll the job spaces to determine total jobs within various geographies. SAN DAG Employment Estimates are also supplemented by other data sources including the San Diego Military Advisory Council (SDMAC) and Defense Manpower Data Center (DMDC). Of note, SDMAC and DMDC assign jobs associated with a Navy ship to the installation that is the ship's homeport. Finally, the jobs data are validated against published job totals for the County from the EDD Labor Market Information's yea rly data . The proximity to jobs data consists of all job types and includes jobs that are classified as a primary source of income, w hich can be part-time or full-time, year-round or seasonal. The data underlying the proximity to jobs component is included in Table 2. Table 2: Proximity to Jobs Data Jurisdiction Total Jobs Regional Share (%) Carlsbad 76,779 4.6% Chula Vista 72,403 4.4% Coronado 27,594 1.7% Del Mar 4,484 0.3% El Cajon 45,468 2.7% Encinitas 27,871 1.7% Escondido 55,059 3.3% Imperial Beach 4,936 0.3% La Mesa 29,773 1.8% Lemon Grove _ 7,492 0.5% National City 37,497 2.3% Oceanside 45,178 2.7% Poway 36,349 2.2% San Diego 921,054 55.6% San Marcos 40,964 2.5% Santee 18,634 1.1% Solana Beach 9,151 0.6% Unincorporated County 154,686 9.3% Vista 40,629 2.5% Region 1,656,001 100.0% Source: SANDAG Employment Estimates and/or SANDAG 2019 Regional Growth Forecast; U.S. Department of Defense DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 5 Equity Adjustment In addition to distributing the RHNA Determination among jurisdictions, SANDAG must distribute units for each jurisdiction among the four income categories defined by HCD. Each income category is defined as a range of household incomes that represents a percentage of the area median income (AMI). The AMI for the San Diego region is $66,529, as provided by HCD. Table 3 provides the definition for each income category and the income ranges for San Diego region households per category. Table 3: Income Categories Income Category Definition Very Low Less than 50% of AMI Low 50-80% of AMI Moderate 80-120% of AMI Above Moderate Over 120% of AMI Income Range* $33,259 or less $33,260 -$53,219 $53,220 -$79,829 $79,830 or more Percent of Regional Households (RHNA Determination) 24.7% 15.5% 17.3% 42.5% Source: HCD Determination Letter; 2012-2016 American Community Survey 5-Year, DP03 Household income data was used to determine the number of households per category in each jurisdiction and subsequently each jurisdiction's percentage breakdown of households per category, which is included in Table 4. The jurisdictional percentages were then compared to the regional percentages for each income category to determine a multiplier, which is an "adjustment" toward the regional percentages. A jurisdiction's multiplier for a given income category is applied to the total RHNA units allocated to the jurisdiction to determine how many of its total RHNA units are allocated to that income category. Jurisdictions that have a higher percentage of existing households in a given income category than the region receive a downward adjustment toward the regional percentage, which results in a smaller share of the allocated housing units within that income category than if no adjustment were applied. Jurisdictions that have a lower percentage of households in a given income category than the region receive an upward adjustment toward the regional percentage, which results in a greater share of the allocated housing units within that income category than if no adjustment were applied. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 6 Table 4: Households per Income Category Total Existing Households by Income Category Jurisdiction Households Above Very Low % Low % Moderate % Moderate % Carlsbad 42,926 6,981 16.3% 4,644 10.8% 5,940 13.8% 25,360 59.1% Chula Vista 77,804 19,459 25.0% 11,987 15.4% 13,643 17.5% 32,715 42.0% Coronado 8,986 1,506 16.8% 1,109 12.3% 1,442 16.1% 4,929 54.9% Del Mar 2,258 430 19.0% 102 4.5% 248 11.0% 1,478 65.5% El Cajon 32,937 12,434 37.8% 5,754 17.5% 5,615 17.0% 9,135 27.7% Encinitas 23,695 4,287 18.1% 2,168 9.2% 3,182 13.4% 14,058 59.3% Escondido 45,217 13,880 30.7% 8,239 18.2% 8,245 18.2% 14,853 32.8% Imperial Beach 9,044 2,888 31.9% 2,105 23.3% 1,726 19.1% 2,325 25.7% La Mesa 23,767 6,368 26.8% 4,468 18.8% 4,609 19.4% 8,322 35.0% Lemon Grove 8,465 2,316 27.4% 1,643 19.4% 1,730 20.4% 2,776 32.8% National City 15,870 6,436 40.6% 3,271 20.6% 2,848 17.9% 3,315 20.9% Oceanside 61 ,480 16,148 26.3% 11 ,348 18.5% 11,297 18.4% 22,687 36.9% Poway 15,797 2,418 15.3% 1,675 10.6% 2,281 14.4% 9,422 59.6% San Diego 490,219 119,014 24.3% 75,283 15.4% 82,616 16.9% 213,305 43.5% San Marcos 29,125 7,707 26.5% 4,212 14.5% 5,043 17.3% 12,163 41.8% Santee 19,517 3,493 17.9% 2,812 14.4% 3,683 18.9% 9,528 48.8% Solana Beach 5,750 883 15.4% 698 12 .1% 854 14.9% 3,315 57.7% Unincorporated County 159,642 35,996 22.5% 26,493 16.6% 27,598 17.3% 69,555 43.6% Vista 30,629 9,016 29.4% 5,746 18.8% 6,112 20.0% 9,754 31 .8% Region 1,103,128 271,661 24.6% 173,760 15.8% 188,713 17.1% 468,995 42.5% Source: 2012-2016 American Community Survey (ACS) 5-Year, B 19001 "Household Income In The Past 12 Months (In 2016 Inflation-Adjusted Dollars)" DRAFT 6th Cycle Regional Housing Needs Assessment Methodology 17 Table 5 below shows this inverse relationship by using plus(+) and minus(-) signs in the Adjustment (Adjust.) column. The regional percentages of household per income category are included in the first row and shaded in blue. The jurisdictions' percentages of household per income category are included in the "Percent of Households" (% of HH) and shaded in grey. Table 5: Determining an Equity Adjustment Region Very Low 24.7% Low 15.5% Jurisdiction % ofHH Adjust. % ofHH Adjust. Carlsbad 16.3% + 10.8% + Chula Vista 25 .0% -15.4% + Coronado 16.8% + 12.3% + Del Mar 19.0% + 4.5% + El Cajon 37.8% -17.5% - Encinitas 18.1 % + 9.2% + Escondido 30.7% -18.2% - Imperial Beach 31.9% -23.3% - La Mesa 26 .8% -18.8% - Lemon Grove 27.4% -19.4% - National City 40.6% -20.6% - Oceanside 26 .3% -18.5% - Poway 15.3% + 10.6% + San Dieqo 24.3% + 15.4% + San Marcos 26.5% -14.5% + Santee 17 .9% + 14.4% + Solana Beach 15.4% + 12.1 % + Unincorporated 22.5% + 16.6% - Vista 29.4% -18.8% - Source: 2012-2016 American Community Survey (ACS) 5-Year, 819001 Data Source Moderate 17.3% Above Mod. %ofHH Adjust. % ofHH 13.8% + 59.1% 17.5% -42.0% 16.1% + 54.9% 11.0% + 65.5% 17.0% + 27.7% 13.4% + 59.3% 18.2% -32.8% 19.1 % -25.7% 19.4% -35.0% 20.4% -32.8% 17.9% -20.9% 18.4% -36.9% 14.4% + 59.6% 16.9% + 43.5% 17.3% + 41 .8% 18.9% -48.8% 14.9% + 57.7% 17.3% + 43.6% 20.0% -31 .8% SANDAG used data from the 2012-2016 ACS 5-Year, Table 819001 "Household Income In The Past 42.5% Adjust. - + - - + - + + + + + + - - + - - - + 12 Months (In 2016 Inflation-Adjusted Dollars)" to determine the jurisdictions' household breakdown among income categories. This dataset was also used by HCD to calcu late the unit distribution across income category for the San Diego region's RHNA Determination. Local Government Conditions The draft methodology was developed with input and recommendation from the Board of Directors, RHNA Subcommittee (a subcommittee of the SAN DAG Board), the TWG (including planning directors from each jurisdiction and housing stakeholders), the SANDAG Regional Planning Committee (a policy advisory committee of the Board), and public stakeholders. Several meetings were held with each stakeholder group and meetings were open to the public. Attendees at each meeting provided information regarding the types of data SANDAG should use, assumptions that should be made, as well as information regarding conditions in their individual jurisdictions that should be taken into consideration. Jurisdictions and stakeholders also provided written comments during the process. There was general consensus at the meetings that the approach chosen should keep the draft methodology simple and easy to explain to the public. Nuanced adjustments that may have modified the methodology in marginal ways in relation to the overall objectives and factors were discussed and considered. Factors and DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 8 adjustments that would have created a complicated formula, however, ultimately were not pursued since the draft methodology was developed with the intent to keep it transparent and understandable. A discussion of each stakeholder group and their major contributions to the development of the draft methodology is included below. Board of Directors At its September 14, 2018, meeting, the Board was surveyed to determine each member jurisdiction's priorities for the upcoming RHNA cycle, including which RHNA objectives and factors would be most important when determining the distribution of housing units in the region. The member jurisdictions requested that their initial set of priorities be further discussed by the TWG, which consists of the planning or community development director from each jurisdiction, among other members. The Board also directed the formation of a RHNA Subcommittee to review and provide input and guidance on potential policy and technical options for developing the RHNA methodology for allocation of housing units to each jurisdiction in the RHNA Plan. The Board received an update on the preliminary methodology in May 2019 and approved the release of this draft methodology for public comment at its July 26, 2019, meeting. Regional Housing Needs Assessment Subcommittee In December 2018, the Board formed the RHNA Subcommittee, which was comprised of Board members from each SANDAG subregion to reflect the diversity of geography, jurisdiction size, and other attributes of member jurisdictions. To develop its recommendation, the RHNA Subcommittee explored options for how to build consensus around a RHNA methodology that complies with state law while best achieving the goals of the Board. The RHNA Subcommittee held six meetings prior to the Board release of the draft methodology. All meetings were open to the public. Critical direction provided by the RHNA Subcommittee included the following: • Create a narrative around housing that promotes regional unity in addressing the housing need; • Establish a framework that incorporates "proximity to transit" and "proximity to jobs" to further the objective of increasing transit use, reducing vehicle miles traveled and GHG emissions, and relieving traffic congestion • Include an equity adjustment to ensure the allocation furthered fair housing and increased affordability in all cities and the County of San Diego • Evaluate opportunities for the military installations within the region to provide housing for military and their families Regional Planning Technical Working Group The TWG is a SAN DAG working group that consists of the planning or community development director from each jurisdiction and representatives from other single-purpose regional agencies, such as the transit operators. The TWG advises the Regional Planning Committee and Board on the development and implementation of San Diego Forward: The 202 1 Regional Plan, which includes, and must be consistent with, the RHNA plan. The TWG discussed and provided input on the development of the draft methodology at 11 meetings, including two workshops specifically focused on RHNA. Information on local government conditions provided by TWG members included: • Preserved open space, agricultural lands, and airports and associated safety zones ■ Universities and community colleges DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 9 • Military installations • Low-wage jobs • Voter requirements Feedback provided by TWG members for which there was general consensus that was incorporated into the draft methodology included: • Prioritizing proximity to transit, with greater weight given to major transit investments (R&R stations) over local bus service ■ Improving the job-housing relationship • Encouraging the development of a mix of housing types across the reg ion and addressing historical patterns of inequity in housing development Reg ional Planning Committee The Regional Planning Committee (RPC) is one of the SANDAG policy advisory committees, which provides oversight for the preparation and implementation of San Diego Forward: The Regional Plan. The RPC discussed the RHNA process at two of their meetings. Information on local government conditions provided by RPC members included: • Airport safety zones • Housing development opportunities at major employment centers • Sea level rise Feedback received from the RPC that informed the development of the draft methodology included: • Aligning priorities for the RHNA methodology with priorities adopted by jurisdictions through other planning efforts such as climate action plans Regional Housing Needs Assessment Objectives and Factors Objectives The draft methodology and allocation furthers the five objectives listed in Government Code Section 65584. 7. 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 a/location of units for low-and very low-income households. Per state law, the draft methodology allocates units in all four income categories to each of the region's 19 jurisdictions. The draft methodology does so equitably, ensuring each jurisdiction receives an allocation for low-and very low-income units, and further, allocating a higher share of low-and very-low units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. State law requires jurisdictions to zone at higher densities to accommodate its low-and very low-income housing allocation. As jurisdictions plan for and build housing, the mix of housing types will increase. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 10 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 GHG gas reductions targets provided by the State Air Resources Board pursuant to Section 65080. The draft methodology prioritizes "proximity to transit" and "proximity to jobs" to encourage efficient development patterns and reduce GHG emissions. By allocating housing units based on these two factors, SANDAG sets a guiding principle for local jurisdictions to zone and build housing near transit and jobs. Transit and job centers are located in the urbanized areas of the region. Therefore, an allocation based on the proximity of transit and jobs will lead to more infill development while protecting natural resources and open space. Because infill development does not rely on available space and can occur in areas that already have a dense population, the draft methodology supports provision of housing even in areas that are currently considered built-out. SANDAG's GHG reduction target, as set by the California Air Resources Board, is to reduce the region's per capita emissions of GHG from cars and light trucks by 15 percent by 2020, compared with a 2005 baseline. By 2035, the target is to reduce GHG emissions by 19 percent per capita. The draft methodology encourages the development of housing near jobs and transit, which will provide the region's residents with opportunities to live where they work and/or readily access transit, which can facilitate shorter commutes, reduce vehicle miles traveled, and increase trip-taking by transit or alternative modes. 3. Promoting an improved intraregional relationship between jobs and housing, including an improved balance between the number of /ow-wage jobs and the number of housing units affordable to /ow-wage workers in each jurisdiction. SANDAG conducted an analysis of the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction. The analysis shows that the number of low-wage jobs far exceeds the number of existing housing units affordable to low-wage workers in each jurisdiction. The draft methodology allocates 35 percent of the 171,685-unit regional housing need based on each jurisdiction's share of existing regional total jobs to encourage development of housing near job centers so that jurisdictions can improve the jobs-housing relationship. The draft methodology's Equity Adjustment (see Objective 4) also improves the balance between the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction by allocating a higher share of low-and very low-income housing units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. 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 ACS. This objective guided the development of the Equity Adjustment used to ensure the draft methodology will result in allocation of housing units to each of the income categories. This adjustment results in a jurisdiction receiving a lower proportion of its total housing units within an income category when it has a higher share of households within that income category compared to the region. This method shifts units across income categories, rather than adding units to a jurisdiction's total housing unit allocation, allowing for a mix of housing types and affordability near transit and jobs. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 11 5. Affirmatively furthering fair housing. For purposes of this section, "affirmatively furthering fair housing" means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. During development of the draft methodology, SANDAG reviewed the California Tax Credit Allocation Committee (TCAC) 2019 Opportunity Map for the San Diego region. The TCAC map demonstrates how public and private resources are spatially distributed within the region . The map is part of a larger study that shows how communities with better air quality, higher educational attainment, and better economic indicators are communities that have higher "opportunity", or pathways that offer low-income children and adults the best chance at economic advancement. The study finds that historically communities with higher opportunity -through plans, policies, and practices -may have systematically denied equal opportunity to low socioeconomic and minority populations. Areas of "low resource" and "high segregation & poverty" on the TCAC maps are also many of the same areas with a high concentration of low-income households in the San Diego region. The Equity Adjustment within the draft methodology addresses the disparities in access to resource-ri.ch areas by providing housing opportunities for people in all income levels to reside in any given community. This is meant to foster and maintain compliance with civil rights and fair housing laws. The Equity Adjustment in the draft methodology assists in overcoming patterns of discrimination and transforming racially and ethnically concentrated areas of poverty into areas of opportunity by allocating a higher proportion of low-income housing units to jurisdictions with a lower share of low-income households, which tend to be jurisdictions with a high concentration of resource-rich areas. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology j 12 California Tax Credit Allocation Committee Opportunity Map TCAC/HCD Opp<>mmity M~p (2019 Draft) Legend -H~ RMOlll(~ -HL9ihM\ Res-ouf<e O+t•S&J•(~ c...,tom,.. '" C:tedit .an«11:t,(!l'l((;'Tl,,..tltt KICA.Cl i'.",1 1 "l o ' ., ~= ,, N knf,l!,,.llllf,_-:S Factors In addition to furthering the objectives outlined above, state law requires that SANDAG consider several factors in the development of the draft methodology, to the extent sufficient data is available pertaining to each factor. See Government Code Section 65584.04(e). The RHNA factors and how each were considered in the development of the draft methodology are described below. 1. Each jurisdiction's existing and projected jobs and housing relationship. This shall include an estimate based on readily available data on the number of low-wage jobs within the jurisdiction and how many housing units within the jurisdiction are affordable to low-wage workers as well as an estimate based on readily available data, of projected job growth and projected household growth by income level within each member jurisdiction during the planning period. The draft methodology prioritizes "proximity to jobs" as a factor in allocating the regional housing need. The jobs factor seeks to encourage development of housing near job centers so that jurisdictions can achieve greater jobs-housing balance. The jobs factor uses current data on existing jobs instead of a projection. Given the housing shortage within the region, it is critical that housing is built where existing jobs are located to begin to address the current jobs-housing imbalance. Although data for projected job and household growth by income level for the next Regional Plan update is not yet available, SAN DAG used the most recent readily available data for projected job growth and projected household growth by income level within each member jurisdiction to conduct its analysis. DRAFT 6th Cycle Regional Hous ing Needs Assessment Methodology I 13 SANDAG analyzed the number of low-wage jobs and the number of housing units affordable to low- wage workers in each jurisdiction. The analysis showed that the number of low-wage jobs far exceeds the number of existing housing units affordable to low-wage workers in each jurisdiction. The draft methodology is expected to increase the supply of affordable housing by allocating each jurisdiction low- and very low-income housing units. The draft methodology's Equity Adjustment (see Objective 4) should also improve the balance between the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction by allocating a higher share of low-and very low- income housing units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. 2. The opportunities and constraints to development of additional housing in each member jurisdiction, including all of the following: a. Lack of capacity for sewer or water service due to federal or state laws, regulations or regulatory actions, or supply and distribution decisions made by a sewer or water service provider other than the local jurisdiction that preclude the jurisdiction from providing necessary infrastructure for additional development during the planning period. SANDAG notes that general plans for some jurisdictions may account for constraints to housing development arising from lack of capacity for sewer or water service. For example, rural areas may rely more heavily on well water and septic systems, which constrains housing development due to lack of sufficient infrastructure. For the draft methodology, however, "proximity to transit" factor allocates housing units based on each jurisdiction's share of regional ra il and Rapid bus stations as well as major transit stops. Rail and Rapid bus stations are located in the region's more developed areas where land uses generate enough ridership to support the investment to the transit infrastructure. Major transit stops also are located in the region's urbanized areas and surrounded by land uses that support higher service frequencies. By prioritizing transit connectivity, the draft methodology encourages infill development in urban areas that are likely to have existing capacity for sewer or water service. b. The availability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for infill development and increased residential densities. The council of governments may not limit its consideration of suitable housing sites or land suitable for urban development to existing zoning ordinances and land use restrictions of a locality but shall consider the potential for increased residential development under alternative zoning ordinances and land use restrictions. The determination of available land suitable for urban development may exclude lands where the Federal Emergency Management Agency or the Department of Water Resources has determined that the flood management infrastructure designed to protect that land is not adequate to avoid the risk of flooding. The draft methodology is not constrained by existing zoning ordinances and land use restrictions. Instead the draft methodology prioritizes "proximity to transit" and "proximity to jobs", which aligns with several beneficial land use planning principles, such as promoting infill and increasing residential densities. The ava ilability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for infill development and increased residential densities are accounted for due to the draft methodology's use of the proximity to jobs and transit factors. When development of housing is promoted near transit and jobs in areas that are already more densely populated and developed than other areas of each jurisdiction, it allows the jurisdictions to focus on infill development that can occur without reliance on the availability of additional land, but instead on underutilized land that can be converted to uses that allow for increased residential density. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 14 The "proximity to transit" factor allocates housing units based on each jurisdiction's share of regional rail and Rapid bus stations as well as major transit stops. Rail and Rapid bus stations are located in the region's urbanized areas where land uses generate enough ridership to support the investment to the transit infrastructure. Major transit stops are also located in the region's urbanized areas and surrounded by land uses that support higher service frequencies. By prioritizing transit, the draft methodology encourages infill development in areas that are suitable for urban development. A transit-focused methodology also promotes increased densities as jurisdictions must plan for housing in urban areas already served by high quality transit. The draft methodology aligns with the region's priorities for growth. As shown in Figure 3.1, general plans in the San Diego region have focused growth and development in existing urban areas, preserved more land for habitat and open space, and looked to accommodate more housing near transit and key destinations. Figure 3.1: Priorities for Growth Then and Now Prior Regional Growth Forecasi (Series 9, 1999) Open Space Planned for Preservation 1999 New Housing Multi· Family Single Family \ Available for Development •• Current Regional Growth Forecast Total Housing Open Space Multi- >•,~'• 2015 New Housing •· ~ -, Total Housing Multi- Fam~% S. .. ~. ,.~ -~-.... i . 5anO~go J.~~•~--f'QRWARD' ':·· c. Lands preserved or protected from urban development under existing federal or state programs, or both, designed to protect open space, farmland, environmental habitats, and natural resources on a long-term basis, including land zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or restricts conversion to non-agricultural uses. General plans for individual jurisdictions may account for constraints to housing development arising from lands preserved or protected from urban development under existing federal or state programs. As shown in the figures below though, preserved land, farmland, and habitats are primarily in the eastern portion of San Diego County. The draft methodology focuses housing units in areas with access to transit and jobs, which are located in existing urbanized areas. Therefore, the draft methodology will not encourage encroachment upon open space areas. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology j 15 1-Muluole !-lab1ut Com-ervalon Progrim (MHC.~ 2. f:m: (ounry Multlp!e Species (Ciili:'.-f\'ilUOn Prog;:;;m {MSCP} 3. South County Mult1~1e Spooes CoN..CViltlOn Program {M:i(P) ~-North Coum; Multiple Sped a. Ccruerviltlon Prcgram {~lSCPJ Figure C.6 San Diego Regional Habitat Preserved Lands October 2015 Conserved Habitat Lands Proposed Conserved Habitat Lands M-'H 0 0 • iC'lCMETUlS ~DAG Figure C.5 A N San Diego Region Important Agricultural Lands October 2015 C':I] ~l?i~U:sU:: :~s(~:7~and USDA Farmland Category -Farmland of local Importance -Prime F.armland -Farmland of Std.tewide Importance M:U~ 0 Unique Fannland C,SIINDAG A N Tecate:e:e. DRAFT 6th Cycle Regional Housing Needs Assessment Methodology I 16 d. County policies to preserve prime agricultural land, as defined pursuant to Section 56064, within an unincorporated and land within an unincorporated area zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or restricts its conversion to non-agricultural uses. The County of San Diego General Plan accounts for some constraints to housing development arising from policies to preserve prime agricultural land and incorporates local ballot measure provisions prohibiting or restricting the conversion of agricultural to non-agricultural uses. The draft methodology allocates housing units based on access to jobs and transit, which are located in existing urbanized areas. Therefore, this constraint is not expected to impact the draft methodology's capacity to allow for development of additional housing . 3. The distribution of household growth assumed for purposes of a comparable period of regional transportation plans and opportunities to maximize the f1Se of public transportation and existing transportation infrastructure. As shown in Figure 3.1, plans for growth are focused on the urbanized areas of the region. The draft methodology prioritizes "proximity to transit" as a factor -specifically high-quality transit, which is located in the urbanized area. The emphasis on proximity to transit allows local jurisdictions that have invested in transit the opportunity to maximize the use of existing transportation infrastructure. 4. Agreements between a county and cities in a county to direct growth toward incorporated areas of the county, and land within an unincorporated area zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of the jurisdiction that prohibits or restricts conversion to non-agricultural uses. Regional planning undertaken by SANDAG and its member agencies during the past 15 to 20 years, has focused the region's growth in the western third of the region, primarily in its incorporated cities and near transit service (Figure 3.1 ). SAND AG has funded "smart growth" grants to encourage growth in incorporated areas of the county with sufficient density to support transit-oriented development. Consistent with this, the draft methodology prioritizes "proximity to transit" and "proximity to jobs". High-quality transit service and a high concentration of the region's jobs are located in the urbanized, incorporated areas of the region. Thus, the draft methodology is consistent with agreements between SANDAG, the County of San Diego, and the cities to develop public transportation infrastructure and supporting land uses away from areas that are zoned or designated for agricultural protection or preservation. lnterjurisdictional agreements may account for some development constraints; however, those agreements are not expected to be in conflict with the draft methodology due to the prioritization of proximity to transit and jobs. 5. The loss of units contained in assisted housing developments, as defined in paragraph (9) of subdivision (a) of Section 65583, that changed to non-low-income use through mortgage prepayment, subsidy contract expirations, or termination of use restrictions. The data for these units is not readily available and varies by jurisdiction. The loss of assisted housing developments for lower income households is an issue that should be addressed by the jurisdictions when preparing their housing elements. DRAFT 6th Cycle Reg ional Housing Needs Assessment Methodology I 17 6. The percentage of existing households at each of the income levels listed in subdivision (e) of Section 65584 that are paying more than 30 percent and more than 50 percent of their income in rent. This factor was not included in state law at the time the HCD was making its determination on the regional housing need of the San Diego region, and sufficient data for this factor is not readily available. The San Diego region received its largest RHNA Determination this cycle, however, and it is expected that an influx of housing units in each income category will help alleviate the rent burden in the region. 7. The rate of overcrowding. HCD used the 2012-2016 ACS to determine the rate of overcrowding in the San Diego region when making its RHNA Determination. HCD then compared the San Diego region's overcrowding rate (6.43% of all households) to the national rate (3 .34% of all households). To address the needs of overcrowding in the region, HCD's RHNA Determination included an overcrowding adjustment of 3.09 percent, which added 38,700 housing units to the regional housing need to alleviate overcrowding in the region. Thus, this factor has already been accounted for in the draft methodology. 8. The housing needs of farmworkers. The draft methodology prioritizes "proximity to jobs" as a factor in allocating the regional housing need. Farmworkers are included in the data on existing jobs. Therefore, their housing needs along with the housing needs of all the region's workers are considered. The draft methodology increases the supply of affordable housing by allocating each jurisdiction low- and very low-income housing units. The draft methodology's Equity Adjustment (see Objective 4) also improves the balance between the number of low-wage jobs, including farming jobs, and the number of housing units affordable to low-wage workers in each jurisdiction by allocating a higher share of low- and very low-income housing units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. Although the low-income housing needs of farmworkers are unique given their low wages and job locations, the allocation expected from the draft methodology is expected to provide more low-income housing in every jurisdiction and accordingly should provide farmworkers the ability to live in more areas of the region and commute shorter distances to their seasonal jobs. 9. The housing needs generated by the presence of a private university or a campus of the California State University or the University of California within any member jurisdiction. The major universities and community colleges in the San Diego region are located in urban areas served by the existing transportation network. The City of San Diego is home to San Diego State University; University of California San Diego; University of San Diego; Point Loma Nazarene University; various smaller, private universities; and three community colleges: San Diego City College, San Diego Mesa College, and San Diego Miramar College. It also has the greatest share of the region's transportation system in p<;1rt because of transportation investments near universities and colleges located within its jurisdiction. Similarly, the cities of Chula Vista (Southwestern Community College), El Cajon (Cuyamaca College), Oceanside (Mira Costa College), and San Marcos (California State University San Marcos and Palomar College) have made transportation investments to improve access to transit near colleges and universities. By prioritizing transit proximity, the draft methodology encourages housing development near existing transit and the key destinations that transit links, including the region's universities and colleges. The draft methodology will result in additional housing units being allocated based on proximity to transit. This will help these jurisdictions address the housing needs of students, faculty, and staff beyond what these colleges or universities may provide. DRAFT 6th Cycle Regiona l Housing Needs Assessment Methodology j 18 10. The loss of units during a state of emergency that was declared by the Governor pursuant to the California Emergency Services Act (Chapter 7 (commencing with Section 8550) of Division 1 of Title 2), during the planning period immediately preceding the relevant revision pursuant to Section 65588 that have yet to be rebuilt or replaced at the time of the analysis. Jurisdictions report demolished units to the Department of Finance on an annual basis. Demolished units include those lost during a state of emergency. Between 2011 and 2018, states of emergency in the San Diego region declared by the Governor pursuant to the California Emergency Services Act, and in which homes were lost, include the following wildfires: the 2014 wildfires (Cocos Fire and Poinsettia Fire), 2017 Lilac Fire, and 2018 West Fire. HCD analyzed the most recent ten-year average rate of demolition within the San Diego region based on jurisdictions' annual reports to the Department of Finance. The ten-year average rate of demolition in the San Diego region is 0.32 percent of the total housing stock. The RHNA Determination included HCD's minimum replacement adjustment of 0.5 percent, which exceeds the region's demolition rate. This adjustment added 6,255 housing units to the RHNA Determination. SANDAG does not have readily available data broken down by jurisdiction to use for this factor and has therefore relied on HCD's data and adjustment to address this factor at a regional level. 11 . The region's GHG emissions targets provided by the State Air Resources Board pursuant to Section 65080. SANDAG's GHG reduction target, as set by the California Air Resources Board, is to reduce the region's per capita emissions of GHG from cars and light trucks by 15 percent by 2020, compared with a 2005 baseline. By 2035, the target is to reduce GHG emissions by 19 percent per capita. The draft methodology encourages the development of housing near jobs and transit, which will provide the region's residents with opportunities to live where they work and/or readily access transit, which can facilitate shorter commutes, reduce GHG emissions, and increase trip-taking by transit or alternative modes. 12. Any other factors adopted by the council of governments, that further the objectives listed in subdivision (d) of Section 65584, provided that the council of governments specifies which of the objectives each additional factor is necessary to further. The council of governments may include additional factors unrelated to furthering the objectives listed in subdivision (d) of Section 65584 so long as the additional factors do not undermine the objectives listed in subdivision (d) of Section 65584 and are applied equally across all household income levels as described in subdivision (f) of Section 65584 and the council of governments makes a finding that the factor is necessary to address significant health and safety conditions. No other factors were included in the draft methodology. To the extent additional proposed factors are provided to the Board of Directors during the public comment period or public hearing that would lead to adjustments to the draft methodology, such proposals must not interfere with the achievement of any of the objectives or factors required in the RHNA statutes cited in this document. In addition, it must be shown that such factors are necessary to address significant health and safety concerns. Persons proposing that adjustments be made to the draft methodology based on new factors should include information establishing that the requirements in Section 65584.04(e)(12) will be met. DRAFT 6th Cycle Regiona l Housing Needs Assessment Methodology I 19 t~\-U'3lT 2 ltem:23 Board of Directors July 26, 2019 Regional Housing Needs Assessment Draft Methodology Overview On July 5, 2018, the State Department of Housing and Community Development (HCD) determined the San Diego region would need to plan for 171,685 housing units during the 6th Housing Element Cycle (2021-2029). On December 21, 2018, the Board of Directors formed the Regional Housing Needs Assessment (RHNA) Subcommittee to review and provide input and guidance on potential policy and technical options for developing the RHNA methodology, which is then used for the allocation of housing units to each jurisdiction. Based upon objectives in state law, the RHNA Subcommittee identified priorities to be used in drafting the RHNA methodology and allocation. This information was shared with the Regional Planning Technical Working Group (TWG), consisting of the planning and community development directors from each jurisdiction in the region and interested housing stakeholders. Action: Approve The Regional Housing Needs Assessment (RHNA) Subcommittee recommends tliat the Board of Directors release the draft RHNA methodology for public review. Fiscal Impact: Development of the RHNA Plan is funded through Overall Work Program No. 3102000 in the FY 2019 Program Budget. Schedule/Scope Impact: The RHNA methodology and draft allocation is scheduled to be adopted by the Board of Directors in late 2019. Local governments will have until April 2021 to update their housing elements to accommodate the housing unit allocations. At the June 14, 2019, meeting, the RHNA Subcommittee voted to recommend a methodology to the Board of Directors (Attachment 1). At its June 27, 2019, meeting, the TWG recommended the same methodology as the RHNA Subcommittee. Staff has determined that the recommended methodology furthers the five objectives listed in Government Code Section 65584. Key Considerations State law requires the SANDAG housing unit methodology further five objectives; however, state law does not dictate how those objectives should be prioritized. The RHNA Subcommittee determined the priorities for the methodology include increasing transit use, improving the jobs and housing relationship, providing an equitable distribution, and reducing greenhouse gas emissions. Attachment 3 summarizes the RHNA Subcommittee's discussions during each of its meetings. Attachment 4 summarizes TWG and stakeholder meetings held to solicit input on the methodology. Each objective can be prioritized and adjusted to consider other factors or data sets. The RHNA Subcommittee and TWG discussed several adjustments that could be made to the methodology based on local conditions and priorities, including adjusting the manner in which jobs were counted for each jurisdiction and determining what should qualify as a major transit stop. As described in the June 14, 2019, report to the RHNA Subcommittee, SANDAG staff recommended using the total number of jobs in the methodology. The RHNA Subcommittee included an adjustment to the total number of jobs to account for military jobs housed on base, since those jobs did not require off-base housing in the jurisdiction. The RHNA Subcommittee members directed staff to focus on a methodology that was transparent and not overly complicated so that it could be easily understood by the public. Due to the Regional Plan's inclusion of smart growth principles, which call for housing near transit and in urban areas, existing density, available space w ithin each jurisdiction, the cost of land, airport land use regulations, and other limiting factors within each jurisdiction were not identified as priorities warranting an adjustment to the methodology. Ultimately, the RHNA Subcommittee and TWG recommended that the following methodology be released for public review. 1. 65 percent of the total housing units should be allocated to jurisdictions with access to transit, including rail stations, Rapid bus stations, and major transit stops. Significant investments in transit have been made throughout the region, and the RHNA methodology prioritizes housing growth in those areas with access to transit. Encouraging housing growth near transit can help the allocation promote infill development and preserve open space, as most transit is located in urbanized areas. Improved access to transit also can lower the vehicle miles traveled in a ca r and reduce greenhouse gas emissions. 2. Within the housing units allocated for jurisdictions with access to transit, 75 percent of the units should be allocated to jurisdictions with rail stations and Rapid bus stations and 25 percent should be allocated to jurisdictions with major transit stops. To ensure future growth is located near transit, the methodology prioritizes 75 percent of the housing units in areas with rail and Rapid bus stations. Rail stations and Rapid bus stations usually are located along fixed routes that require significant capital investment to construct. Unlike bus stops or routes, rail and Rapid stations and routes are not amended or eliminated on regular basis. The remaining 25 percent of the housing units would be allocated in jurisdictions with major transit stops. Major transit stops, as defined in state law, have two intersecting bus routes that arrive at 15-minute intervals during peak commute hours. 3. 35 percent of the total housing units should be allocated to jurisdictions based on the total number of jobs in their jurisdiction adjusted to account for military housing on bases. Jurisdictions should plan for housing to provide opportunities for more residents to live near their place of employment. The RHNA Subcommittee and TWG recommended the number of jobs in each jurisdiction with a military base be reduced to account for military jobs housed directly on a base. 4. The allocation should apply an equity adjustment. The HCD's RHNA Determination divided the number of housing units needed in the region into four income categories based on the region's current percentages of households in each income category. To promote equity and fair housing, the RHNA methodology would allocate more housing units of an income category to jurisdictions with a percentage of households in that category that is lower than the regional percentage. Following a public hearing and public comment period, the draft RHNA methodology must be sent to HCD for a 60-day review period. If no changes to the methodology are required by HCD, the Board of Directors can adopt the final methodology and release a draft version of the al location resulting from the methodology for a 45-day appeal period. Attachment 2 shows how the recommended methodology would be used to allocate housing units to each jurisdiction if no changes are made to the methodology between July and final adoption. Next Steps The Board of Directors is asked to release a draft of the RHNA methodology for public review. A public hearing will be conducted and the draft RHNA methodology will be sent to the HCD for its review following the Board's acceptance of the draft at the end of the public review period. The Board of Directors will be asked to approve a final RHNA Methodology and draft allocation based upon any comments from the public and HCD. Local governments will have until April 2021 to update their housing elements to accommodate the housing unit allocations. Hasan lkhrata, Executive Director Key Staff Contact: Seth Litchney, (619)699-1943, seth.litchney@sandag.org Attachments: 1. Development Background for the Draft RHNA Methodology 2. Draft RHNA Methodology Recommended by RHNA Subcommittee and TWG 3. Summary of RHNA Subcommittee meetings 4. Summary of Additional Public Meetings Held to Solicit Input on the Draft Methodology 2 Attachment 1 DEVELOPMENT BACKGROUND FOR THE DRAFT RHNA METHODOLOGY Introduction State housing element law requires SANDAG to provide a discussion of the Regional Housing Needs Assessment (RHNA) allocation methodology that includes the data and assumptions relied upon, and an explanation of how information about local government conditions and how each of the factors required by law was used to develop the proposed methodology. (See Government Code Section 65584.04.) In addition, SANDAG is required to describe how the draft methodology would further the five objectives in Government Code Section 65584. This document and the other attachments to the SANDAG Board Report concerning RHNA dated July 26, 2019, is intended to provide the information needed for the public to comment on the proposed draft methodology. Data, Assu mptions, and Information on Local Government Conditions Prior to and during the development of the methodology, the RHNA Subcommittee, which was established by the Board of Directors, the Regional Planning Technical Working Group (including planning directors from each jurisdiction and housing stakeholders), the SANDAG Regional Planning Committee, and the Board of Directors held public meetings to obtain input on the data, assumptions and local condition information that SANDAG should use to develop the draft methodology. At these meetings, stakeholders, staff from the cities and the County of San Diego, and elected officials were asked to help determine the priorities for the methodology, and discuss the data needed to prepare the methodology. The Regional Planning Technical Working Group (TWG) held a workshop to discuss the RHNA objectives and factors in state law. The TWG members provided feedback on relevant data to consider approaches to the methodology. Attendees at each meeting provided information regarding the types of data SANDAG should use, assumptions that should be made, as well as information regarding conditions in their individual jurisdictions that should be taken into consideration. For example, the RHNA Subcommittee members were surveyed to determine which objectives and factors were highest priority for the region, and the draft RHNA methodology was developed based on that data and input. The TWG members provided written comments on the development of the methodology throughout the process. There was general consensus at the meetings that the approach chosen should keep the allocation methodology simple and easy to explain to the public. Nuanced adjustments that may have modified the methodology in marginal ways in relation to the overall objectives and factors were discussed and considered. Factors and adjustments that would have created a complicated formula, however, ultimately were not pursued since the draft methodology was developed with the intent to keep it transparent and understandable. RHNA Objectives The RHNA methodology and allocation furthers the five objectives listed in Government Code Section 65584. 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 a/location of units for low-and very low-income households. Per state law, the RHNA methodology allocates units in all four income categories to each of the region's 19 jurisdictions. The methodology does so equitably, ensuring each jurisdiction receives an allocation for low-and very low-income units, and further, allocating a higher share of low-and very low units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. State law requires jurisdictions to zone at higher densities to accommodate its low-and very low- income housing allocation. As jurisdictions plan for and build housing, the mix of housing types will increase. 3 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. The RHNA methodology prioritizes "proximity to transit" and "proximity to jobs" to encourage efficient development patterns and reduce greenhouse gas (GHG) emissions. By allocating housing units based on these two factors, SANDAG sets a guiding principle for local jurisdictions to zone and build housing near transit and jobs. Transit and job centers are located in the urbanized areas of the region. Therefore, an allocation based on the proximity of transit and jobs will lead to more infill development while protecting natural resources and open space. Because infill development does not rely on available space and can occur in areas that already have a dense population, the methodology supports provision of housing even in areas that are currently considered built-out. SANDAG's GHG reduction target, as set by the California Air Resources Board, is to reduce the region's per capita emissions of GHG from cars and light trucks by 15 percent by 2020, compared with a 2005 baseline. By 2035, the target is to reduce GHG emissions by 19 percent per capita. The RHNA methodology encourages the development of housing near jobs and transit, which will provide the region's residents with opportunities to live where they work and/or readily access transit, which can facilitate shorter commutes, reduce vehicle miles traveled, and increase trip-taking by transit or alternative modes. 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. SANDAG conducted an analysis of the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction. The analysis shows that the number of low-wage jobs far exceeds the number of existing housing units affordable to low-wage workers in each jurisdiction. The RHNA methodology allocates 35 percent of the 171,685-unit regional housing need based on each jurisdiction's share of existing regional total jobs to encourage development of housing near job centers so that jurisdictions can improve the jobs-housing relationship. The draft RHNA methodology's Equity Adjustment (see Objective 4) also improves the balance between the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction by allocating a higher share of low-and very low-income housing units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. 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. This objective guided the development of the Equity Adjustment used to ensure the methodology will result in allocation of housing units to each of the income categories. This adjustment results in a jurisdiction receiving a lower proportion of its total housing units within an income category when it has a higher share of households within that income category compared to the region. This method shifts units across income categories, rather than adding units to a jurisdiction's total housing unit allocation, allowing for a mix of housing types and affordability near transit and jobs. 5. Affirmatively furthering fair housing. For purposes of this section, "affirmatively furthering fair housing" means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming 4 racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. During development of the RHNA methodology, SANDAG reviewed the California Tax Credit Allocation Committee (TCAC) 2019 Opportunity Map for the San Diego region. The TCAC map demonstrates how public and private resources are spatially distributed within the region. The map is part of a larger study that shows how communities with better air quality, higher educational attainment, and better economic indicators are communities that have higher "opportunity", or pathways that offer low-income children and adults the best chance at economic advancement. The study finds that historically communities with higher opportunity -through plans, policies, and practices -may have systematically denied equal opportunity to low socioeconomic and minority populations. Areas of "low resource" and "high segregation & poverty" on the TCAC maps are also many of the same areas with a high concentration of low-income households in the San Diego region. The Equity Adjustment within the RHNA methodology addresses the disparities in access to resource-rich areas by providing housing opportunities for people in all income levels to reside in any given community. This is meant to foster and maintain compliance with civil rights and fair housing laws. The Equity Adjustment in the RHNA methodology assists in overcoming patterns of discrimination and transforming racially and ethnically concentrated areas of poverty into areas of opportunity by allocating a higher proportion of low-income housing units to jurisdictions with a lower share of low-income households, which tend to be jurisdictions with a high concentration of resource-rich areas. TCACIHCO Opportunity Map (2019 o,.tt} .l,Qwfl~OWf.lP Modetoilt.!AC\OUl(le --,H19J RflQl.lltt --Hi,ght,t AKOUrtt C..S.~l~( ~• ... {f'f"1<t,.,10(.tl~(~Uio:., 4'11;"-0 California Tax Credit Allocation Committee (TCAC) Opportunity Map 5 RHNA Factors In addition to furthering the objectives outlined above, state law requires that SANDAG consider several factors in the development of the RHNA methodology, to the extent sufficient data is available pertaining to each factor. See Government Code Section 65584.04(e). The RHNA factors and how each were considered in the development of the draft RHNA methodology are described below. 1. Each jurisdiction's existing and projected jobs and housing relationship. This shall include an estimate based on readily available data on the number of low-wage jobs within the jurisdiction and how many housing units within the jurisdiction are affordable to low-wage workers as well as an estimate based on readily available data, of projected job growth and projected household growth by income level within each member jurisdiction during the planning period. The RHNA methodology prioritizes "proximity to jobs" as a factor in allocating the regional housing need. The jobs factor seeks to encourage development of housing near job centers so that jurisdictions can achieve greater jobs-housing balance. The jobs factor uses current data on existing jobs instead of a projection. Given the housing shortage within the region, it is critical that housing is built where existing jobs are located to begin to address the current jobs-housing imbalance. Although data for projected job and household growth by income level for the next Regional Plan update is not yet available, SAN DAG used the most recent readily available data for projected job growth and projected household growth by income level within each member jurisdiction to conduct its analysis. SANDAG analyzed the number of low-wage jobs and the number of housing units affordable to low- wage workers in each jurisdiction. The analysis showed that the number of low-wage jobs far exceeds the number of existing housing units affordable to low-wage workers in each jurisdiction. The draft RHNA methodology is expected to increase the supply of affordable housing by allocating each jurisdiction low-and very low-income housing units. The draft RHNA methodology's Equity Adjustment (see Objective 4) should also improve the balance between the number of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction by allocating a higher share of low-and very low-income housing units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. 2. The opportunities and constraints to development of additional housing in each member jurisdiction, including all of the following: a. Lack of capacity for sewer or water service due to federal or state laws, regulations or regulatory actions, or supply and distribution decisions made by a sewer or water service provider other than the local jurisdiction that preclude the jurisdiction from providing necessary infrastructure for additional development during the planning period. SAN DAG notes that general plans for some jurisdictions may account for constraints to housing development arising from lack of capacity for sewer or water service. For example, rural areas may rely more heavily on well water and septic systems, which constrains housing development due to lack of sufficient infrastructure. For the draft methodology, however, the "proximity to transit" factor allocates housing units based on each jurisdiction's share of regional rail and Rapid bus stations as well as major transit stops. Rail and Rapid bus stations are located in the region's more developed areas where land uses generate enough ridership to support the investment to the transit infrastructure. Major transit stops also are located in the region's urbanized areas and surrounded by land uses that support higher service frequencies. By prioritizing transit connectivity, the methodology encourages infill development in urban areas that are likely to have existing capacity for sewer or water service. 6 c. The availability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for infill development and increased residential densities. The council of governments may not limit its consideration of suitable housing sites or land suitable for urban development to existing zoning ordinances and land use restrictions of a locality, but shall consider the potential for increased residential development under alternative zoning ordinances and land use restrictions. The determination of available land suitable for urban development may exclude lands where the Federal Emergency Management Agency (FEMA) or the Department of Water Resources has determined that the flood management infrastructure designed to protect that land is not adequate to avoid the risk of flooding. The draft RHNA methodology is not constrained by existing zoning ordinances and land use restrictions. Instead the methodology prioritizes "proximity to transit" and "proximity to jobs", which aligns with several beneficial land use planning principles, such as promoting infill and increasing residential densities. The availability of land suitable for urban development or for conversion to residential use, the availability of underutilized land, and opportunities for infill development and increased residential densities are accounted for due to the methodology's use of the proximity to jobs and transit factors. When development of housing is promoted near transit and jobs in areas that are already more densely populated and developed than other areas of each jurisdiction, it allows the jurisdictions to focus on infill development that can occur without reliance on the availability of additional land, but instead on underutilized land that can be converted to uses that allow for increased residential density. The "proximity to transit" factor allocates housing units based on each jurisdiction's share of regional rail and Rapid bus stations as well as major transit stops. Rail and Rapid bus stations are located in the region's urbanized areas where land uses generate enough ridership to support the investment to the transit infrastructure. Major transit stops are also located in the region's urbanized areas and surrounded by land uses that support higher service frequencies. By prioritizing transit, the methodology encourages infill development in areas that are suitable for urban development. A transit-focused methodology also promotes increased densities as jurisdictions must plan for housing in urban areas already served by high quality transit. The RHNA methodology aligns with the region's priorities for growth. As shown in Figure 3.1, general plans in the San Diego region have focused growth and development in existing urban areas, preserved more land for habitat and open space, and looked to accommodate more housing near transit and key destinations. 7 Figure 3.1: Priorities for Growth Then and Now Prior Regional Grnwth Forecast Open Space Planned for Preservation 1999 New Housing Multi· Family Single Family \ Available for Development Current Regional Growth Forecast (Serie_, 13, 201 4) Total Housing Open Space Multi- Family Single Family ~ 2015 New Housing . ' • . •· • Total Housing Multi- Family Single Family --'. ,•i _ .. -;.:.~-. ~c~. o e::go J.1#?.'-!•"'-~ .. f'OR~RD'\'.• d. Lands preserved or protected from urban development under existing federal or state programs, or both, designed to protect open space, farmland, environmental habitats, and natural resources on a long-term basis, including land zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or restricts conversion to non-agricultural uses. General plans for individual jurisdictions may account for constraints to housing development arising from lands preserved or protected from urban development under existing federal or state programs. As shown in the figures below though, preserved land, farmland, and habitats are primarily in the eastern portion of San Diego County. The draft RHNA methodology focuses housing units in areas with access to transit and jobs, which are located in the existing urbanized areas. Therefore, the draft methodology will not encourage encroachment upon open space areas. 8 ~- Habitat Conservation Pl annlng Areas I ' 1 -Mult1pl2 H;ibltil'; Com"JV•U:Hl Progr.:rr,(MI-ICl'1 2-~;°,,~~!t~~~ft~~~Pl 3-Soutti County Mui~.! {:~)s Cons..v,;tlonProgr.i 4-lforth Count'/ Multlple~~r Coid«v~lon Progr;,m :> Figure C.6 Enon1t.is San Diego Regional Habitat Preserved Lands October 2015 Conserved Habitat lands Proposed Conserved Habitat Lands MW ' ' . 1(!1..Cll.£TlRS SAND4G 0,~(011.my • N Agriculture Preserve Land Cs] Williamson Act (2007) USDA Fannland Category -Farmland of Local Importance -Prime Farmland -Farmland of State-v11 "de Importance Unique-Farmland ' . t(!l..OMETEIIS CSANPAG " i I " N 9 L:oI COfU"'.~i- . ::;-::-<'c:n ~---~,.-n. E----------""~--. • e. County policies to preserve prime agricultural land, as defined pursuant to Section 56064, within an unincorporated and land within an unincorporated area zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or restricts its conversion to non-agricultural uses. The County of San Diego General Plan accounts for some constraints to housing development arising from policies to preserve prime agricultural land and incorporates local ballot measure provisions prohibiting or restricting the conversion of agricultural to non-agricultural uses. The draft RHNA methodology allocates housing units based on access to jobs and transit, which are located in existing urbanized areas. Therefore, this constraint is not expected to impact the methodology's capacity to allow for development of additional housing. 3. The distribution of household growth assumed for purposes of a comparable period of regional transportation plans and opportunities to maximize the use of public transportation and existing transportation infrastructure. As shown in Figure 3.1, plans for growth are focused on the urbanized areas of the region. The RHNA methodology prioritizes "proximity to transit" as a factor-specifically high-quality transit, which is located in the urbanized area. The emphasis on proximity to transit allows local jurisdictions that have invested in transit the opportunity to maximize the use of existing transportation infrastructure. 4. Agreements between a county and cities in a county to direct growth toward incorporated areas of the county, and land within an unincorporated area zoned or designated for agricultural protection or preservation that is subject to a local ballot measure that was approved by the voters of the jurisdiction that prohibits or restricts conversion to non-agricultural uses. Regional planning undertaken by SANDAG and its member agencies during the past 15 to 20 years, has focused the region's growth in the western third of the region, primarily in its incorporated cities and near transit service (Figure 3.1 ). SAND AG has funded "smart growth" grants to encourage growth in incorporated areas of the county with sufficient density to support transit-oriented development. Consistent with this, the draft RHNA methodology prioritizes "proximity to transit" and "proximity to jobs". High-quality transit service and a high concentration of the region's jobs are located in the urbanized, incorporated areas of the region. Thus, the methodology is consistent with agreements between SAN DAG, the County of San Diego, and the cities to develop public transportation infrastructure and supporting land uses away from areas that are zoned or designated for agricultural protection or preservation. lnterjurisdictional agreements may account for some development constraints; however, those agreements are not expected to be in conflict with the draft methodology due to the prioritization of proximity to transit and jobs. 5. The loss of units contained in assisted housing developments, as defined in paragraph (9) of subdivision (a) of Section 65583, that changed to non-low-income use through mortgage prepayment, subsidy contract expirations, or termination of use restrictions. The data for these units is not readily available and varies by jurisdiction. The loss of assisted housing developments for lower income households is an issue that should be addressed by the jurisdictions when preparing their housing elements. 6. The percentage of existing households at each of the income levels listed in subdivision (e) of Section 65584 that are paying more than 30 percent and more than 50 percent of their income in rent. This factor was not included in state law at the time the Department of Housing and Community Development (HCD) was making its determination on the regional housing need of the San Diego region, and sufficient data for this factor is not readily available. The San Diego region received its largest RHNA Determination this cycle, however, and it is expected that an influx of housing units in each income category will help alleviate the rent burden in the region. 10 7. The rate of overcrowding. HCD used the 2012-2016 American Community Survey to determine the rate of overcrowding in the San Diego region when making its RHNA Determination. HCD then compared the San Diego region's overcrowding rate (6.43% of all households) to the national rate (3.34% of all households). To address the needs of overcrowding in the region, HCD's RHNA Determination included an overcrowding adjustment of 3.09 percent, which added 38,700 housing units to the regional housing need to alleviate overcrowding in the region. Thus, this factor has already been accounted for in the draft methodology. 8. The housing needs of farmworkers. The draft RHNA methodology prioritizes "proximity to jobs" as a factor in allocating the regional housing need. Farmworkers are included in the data on existing jobs. Therefore, their housing needs along with the housing needs of all the region's workers are considered. The draft methodology increases the supply of affordable housing by allocating each jurisdiction low- and very low-income housing units. The RHNA methodology's Equity Adjustment (see Objective 4) also improves the balance between the number of low-wage jobs, including farming jobs, and the number of housing units affordable to low-wage workers in each jurisdiction by allocating a higher share of low- and very low-income housing units to jurisdictions that currently have a smaller share of low-and very low-income households than the regional share. Although the low-income housing needs of farmworkers are unique given their low wages and job locations, the allocation expected from the draft methodology is expected to provide more low-income housing in every jurisdiction and accordingly should provide farmworkers the ability to live in more areas of the region and commute shorter distances to their seasonal jobs. 9. The housing needs generated by the presence of a private university or a campus of the California State University or the University of California within any member jurisdiction. The major universities and community colleges in the San Diego region are located in urban areas served by the existing transportation network. The City of San Diego is home to San Diego State University; University of California San Diego; University of San Diego; Point Loma Nazarene University; various smaller, private universities; and three community colleges: San Diego City College, San Diego Mesa College, and San Diego Miramar College. It also has the greatest share of the region's transportation system in part because of transportation investments near universities and colleges located within its jurisdiction. Similarly, the cities of Chula Vista (Southwestern Community College), El Cajon (Cuyamaca College), Oceanside (MiraCosta College), and San Marcos (California State University San Marcos and Palomar College) have made transportation investments to improve access to transit near colleges and universities. By prioritizing transit proximity, the draft RHNA methodology encourages housing development near existing transit and the key destinations that transit links, including the region's universities and colleges. The draft methodology will result in additional housing units being allocated based on proximity to transit. This will help these jurisdictions address the housing needs of students, faculty, and staff beyond what these colleges or universities may provide. 10. The loss of units during a state of emergency that was declared by the Governor pursuant to the California Emergency Services Act (Chapter 7 (commencing with Section 8550) of Division 1 of Title 2), during the planning period immediately preceding the relevant revision pursuant to Section 65588 that have yet to be rebuilt or replaced at the time of the analysis. Jurisdictions report demolished units to the Department of Finance on an annual basis. Demolished units include those lost during a state of emergency. Between 2011 and 2018, states of emergency in the San Diego region declared by the Governor pursuant to the California Emergency Services Act, and in which homes were lost, include the following wildfires: the 2014 wildfires (Cocos Fire and Poinsettia Fire), 2017 Lilac Fire, and 2018 West Fire. 11 HCD analyzed the most recent ten-year average rate of demolition within the San Diego region based on jurisdictions' annual reports to the Department of Finance. The ten-year average rate of demolition in the San Diego region is 0.32 percent of the total housing stock. The RHNA Determination included HCD's minimum replacement adjustment of 0.5 percent, which exceeds the region's demolition rate. This adjustment added 6,255 housing units to the RHNA Determination. SANDAG does not have readily available data broken down by jurisdiction to use for this factor and has therefore relied on HCD's data and adjustment to address this factor at a regional level. 11 . The region's greenhouse gas emissions targets provided by the State Air Resources Board pursuant to Section 65080. SANDAG's GHG reduction target, as set by the California Air Resources Board, is to reduce the region's per capita emissions of GHG from cars and light trucks by 15 percent by 2020, compared with a 2005 baseline. By 2035, the target is to reduce GHG emissions by 19 percent per capita. The RHNA methodology encourages the development of housing near jobs and transit, which will provide the region's residents with opportunities to live where they work and/or readily access transit, which can facilitate shorter commutes, reduce GHG emissions, and increase trip-taking by transit or alternative modes. 12. Any other factors adopted by the council of governments, that further the objectives listed in subdivision (d) of Section 65584, provided that the council of governments specifies which of the objectives each additional factor is necessary to further. The council of governments may include additional factors unrelated to furthering the objectives listed in subdivision (d) of Section 65584 so long as the additional factors do not undermine the objectives listed in subdivision (d) of Section 65584 and are applied equally across all household income levels as described in subdivision (f) of Section 65584 and the council of governments makes a finding that the factor is necessary to address significant health and safety conditions. The presence of a significant number of military jobs in certain jurisdictions was taken in consideration in the development of the draft methodology. Information was sought from representatives of the military branches in the region and the number of on-base housing units provided by the military were taken into account during the development of the methodology. The number of jobs in each jurisdiction with a military base was reduced to account for military jobs housed directly on a base. 12 RHNA Calculator Tool with RHNA Subcommittee Recommendations This calculator Tool is intended to allow stakeholders to try out various methodologies to distribute the total regional housing allocation of: I Step 1: Assign weighting to each variable category ! Units to be allocated based on the two priority categories (transit and jobs) is determined by multiplying the RHNA Determination Units {171,685) by the percentages entered into each of the yellow boxes in this step. Note, there is an opportunity to assign weighting to "Transit" subfactors in Step 2 and choose a specific "Job" variable in Step 3. ! Step 2: Assign weighting to each Transit subfactor Sub/actor 1: Rail & Rapid Sub/actor 2: Select from: Weighting Units A. Rail&Ropid A. Transit 65% 111,595 i. High-Frequency Transit Stop (served by at least one local bus with 15 min. peak-period frequency) Major transit stops ii. Major Transit Stop (served by at least two local buses with 15 min. peak-period frequency) Number of Jobs B. ._ ____ ~yj Number of Jobs with a Jobs-Housing adjustment 3b. If applicable, assign weighting to Jobs subfactors: {If greyed out, skip this step I] Attachment 2 171,685 8. Total Jobs _35% 100% 60,090 171,685 Weighting Units 75% 83,696 25% 27,8991 100% 111,595 Select from drop-down: Number of Jobs If Variable (b.) "Number of Jobs with a Jobs-Housing adjustment" was selected above, select weighting for "Jobs-Housing Adjustment". The Jobs-Housing Adjustment adjusts a jurisdiction's jobs-based unit allocation (based on share of regional jobs) up or down based on the relative difference between a jurisdiction's job-housing ratio and the regional ratio. For example, if a jurisdiction has a higher jobs-housing ratio than the region, it would receive a upward adjustment (higher housing unit allocation). 3c. Select Jobs Dataset: Select between: Jurisdiction Carlsbad Chula Vista Coronado Del Mar El Caion Encinitas Escondido Imperial Beach la Mesa lemon Grove National atv Oceanside Powav San Dlee:o San Marcos Santee Solana Beach Unincorporated Vista Region Notes: 1. Total Jobs 2. Civilian Jobs (excludes active duty military; includes civilian defense jobs) 3. Total Excluding Housed Military (excludes active duty military for which on-base military housing is provided; 1 housing unit= 1 job reduction) Calculator Tool A. B. _.,_ Transit .··:::i..,-. ' ?••\' : .. .,,.. ..... w/ Totallobs 1,087 2,860 8,478 2,697 808 167 1,630 1,694 543 1,038 7,609 2 051 1,196 184 2,717 1,109 1,087 279 4,076 1,327 3,804 1,683 1,354 74,478 33,962 1,630 1,526 543 694 543 341 1,087 4,802 1,087 1,514 111,595 60,090 Jobs-Housing Ratio Weighting! Select from drop-down: 8. Total Excluding Housed Military Jobs with J-H Adjustment Total Allocation1 w/Total Excluding w/ Civilian Jobs Housed Mllitarv 3,947 11,175 808 167 3,324 1,581 9,660 1,380 3,826 1,366 5,403 5,487 1,354 108,440 3,156 1,237 884 5,889 2,601 171,685 1. The total number of units per jurisdiction assigned within each of the priority categories (transit and jobs) is determined by multiplying the number of units to be allocated for the specific priority category {See Step 1) by each jurisdiction's share (as a percentage) of the total regional count for each variable and subfactor. I Step 4: Equity Adjustment ! To avoid an overconcentration of low income households and comply with Government Code 65584 (d), this draft RHNA Allocation Methodology assigns more housing units of an income category to jurisdictions with a percentage of households in that category that is lower than the regional percentage . .. ____________ _.I Income Cateug0o_itSrv HCD Determination . Very low Low Moderate Above Mod. Total 42,332 26,627 29,734 72,992 171,685 Income Category Allocations Considering Equity Total Allocation Very low Low Moderate Above Mod. Carlsbad 1,336 798 764 1,049 3,947 Chula Vista 2,770 1,788 1,922 4,695 11,175 Coronado 277 150 141 240 808 Del Mar 38 64 33 32 167 El Caion 487 419 526 1,892 3,324 Encinitas 477 376 313 415 1,581 Escondido 1,875 1,256 1,536 4,993 9,660 Imperial Beach 234 128 190 828 1,380 La Mesa 865 491 582 1,888 3,826 Lemon Grove 298 166 194 708 1,366 National Citv 642 503 706 3,552 5,403 Oceanside 1,279 724 890 2,594 5,487 Poway 480 275 247 352 1,3S4 San Diego 27,667 17,390 19,391 43,992 108,440 San Marcos 738 537 549 1,332 3,1S6 Santee 412 203 191 431 1,237 Solana Beach 320 161 160 243 884 Unincorporated 1,614 872 1,024 2,379 5,889 Vista 523 326 375 1,377 2,601 Re2ion 42,332 26,627 29,734 72,992 171,685 Revised July 19, 2019 13 RHNA Subcommittee Meeting Summaries Meeting Date February 8, 2019 February 22, 2019 March 22, 2019 April 26, 2019 May 24, 2019 June14,2019 Materials Presented • RHNA Subcommittee Charter • RHNA Plan Timeline • RHNA Statutory Objectives and Factors • SANDAG 2017 Regional Housing Progress Report • 5th Cycle RHNA Progress • Housing Legislative Update • SANDAG 2016 Commuting Patterns in the San Diego Region • Housing Definitions • SANDAG Smart Growth Concept Map • RHNA Subcommittee Survey Results • Potential RHNA Methodology Framework • RHNA Allocation Calculator Tool • Regional Planning Technical Working Group (TWG) Comments on RHNA Calculator Tool • Revised RHNA Allocation Calculator Tool • Additional TWG Comments on RHNA Calculator Tool • Staff Recommended RHNA Methodology • On-Base Military Housing Data • Calculation of Methodology Adjusted for On -Base Military Housing 14 Attachment 3 Comments/Direction • Requested 5th Cycle RHNA Progress • Inquired about the impact of recent state legislation on the RHNA process • Requested definitions of housing terms and information on commuting patterns. • Requested a list of RHNA Objectives and Factors to prioritize • In addition to transit-oriented development, the allocation should assign housing to job-rich areas • Discussed the definitions used for the transit calculation including the rail, Rapid bus, and high frequency transit. • Requested to pursue an allocation methodology based on the potential framework • How should accessory dwelling units be considered in the allocation? • Should a jurisdiction size or other constraints be considered in the allocation? • Population should not be a factor in the methodology. • Transit should receive a higher prioritization to reduce VMT. • Allocation should provide 65% of the units to areas with transit and 35% of the units based on jobs in the jurisdiction. • Consider military housing as part of the jobs count for each jurisdiction. • Keep the allocation methodology simple and easy to explain • Consider the type of job in each jurisdiction. • Discussed whether to adjust the jobs total to account for on - base military housing . • Discussed transit calculation • Recommended a methodology to the Board of Directors Summary of Additional Public Meetings Held to Solicit Input on the Draft Methodology Attachment 4 Meeting Date Discussion Board of Directors September 14, 2018 Board of Directors Asked to Provide Ideas on RHNA Priorities Regional Planning Committee October 5, 2018 RHNA Update on Board of Directors RHNA Priorities TWG and Housing Stakeholders October 11, 2018 Board Direction on the RHNA and the Role of the Regional Planning Technical Working Group TWG and Housing Stakeholders December 13, 2018 RHNA Workshop TWG and Housing Stakeholders January 10, 2019 Update on RHNA Subcommittee, RHNA Work Plan, and Recap of the RHNA Workshop Regional Planning Committee February 1, 2019 RHNA Update TWG and Housing Stakeholders February 14, 2019 RHNA Update TWG and Housing Stakeholders March 14, 2019 RHNA Methodology Discussion TWG and Housing Stakeholders April 3, 2019 RHNA Methodology Workshop TWG and Housing Stakeholders May 9, 2019 RHNA Methodology Calculation Tool Amendments Discussion Board of Directors May 10, 2019 Update on the RHNA Subcommittee TWG and Housing Stakeholders June 6, 2019 Update on RHNA Subcommittee and Discussion on Methodology TWG and Housing Stakeholders June 13, 2019 RHNA Update and Discussion on Methodology TWG and Housing Stakeholders June 27, 2019 RHNA Methodology Recommendation 15