CC - Item 6A - Regional Housing Needs Assessment Discussion s E M
° ROSEMEAD CITY COUNCIL
CIVIC PRIDE STAFF REPORT
,NCORPORATED X959
TO: THE HONORABLE MAYOR AND CITY COUNCIIL
FROM: GLORIA MOLLEDA, CITY MANAGER
DATE: FEBRUARY 25, 2020
SUBJECT: REGIONAL HOUSING NEEDS ASSESSMENT (RHNA)DISCUSSION
SUMMARY
This item is presented to the City Council at the request of Mayor Margaret Clark. On Monday,
February 24, 2020, the RHNA subcommittee discussed and recommended the approval of the
Final RHNA Methodology and the 6th Cycle RHNA appeals procedures.
STAFF RECOMMENDATION
Staff is seeking further direction from the City Council.
PUBLIC NOTICE PROCESS
This item has been noticed through the regular agenda notification process.
Attachment A: Regional Housing Needs Assessment Subcommittee
Attachment B: SCAG RHNA Methodology: staff Recommendation and 10/7 Substitute motion
AGENDA ITEM 6.A
S E M F
lic
O
M/
CIv IC PRIDE
COA 90
Attachment A
Regional Housing Needs Assessment
(RHNA) Subcommittee
IIS
SPECIAL MEETING
411.111016TM
INNOVATING FOR A BETTER TOMORROW --- ��
SOUTHERN CALIFORNIA REGIONAL HOUSING
ASSOCIATION OF GOVERNMENTS
90o Wilshire Blvd.,Ste.17oo
Lo(Angeles,CA 9o017
T:(213)236 t800 NEEDS ASSESSMENT
www.scag.ca.gov
( RHNA) SUBCOMMITTEE
REGIONAL COUNCIL OFFICERS
President
Bill Jahn,Big Bear Lake
First Vice President Monday, February 24, 2020
Rex Richardson,Long Beach 10:00 a.m. - 12.00 p.rn.
Second Vice President
Clint Lorimore,Eastvale
Immediate Past President SCAG Main Office
Alan D.Wapner,San Bernardino
County Transportation Authority 900 Wilshire Blvd., Ste. 1700
COMMITTEE CHAIRS RC Board Room
Executive/Administration Los Angeles, CA 90017
Bill Jahn,Big Bear Lake
Community,Economic& (213) 236-1800
Human Development
Peggy Huang,Transportation
Corridor Agencies
Energy&Environment See Next Page for Other Meeting Locations and
Linda Parks,Ventura County
Transportation Webcasting information
Cheryl Viegas-Walker,El Centro
If members of the public wish to review the attachments or have any questions or
comments on any of the agenda items related to RHNA, please send an email to
housing@scag.ca.gov. Agendas and Meeting Minutes are also available at:
www.scag.ca.gov/committees
SCAG, in accordance with the Americans with Disabilities Act (ADA), will
accommodate persons who require a modification of accommodation in order to
participate in this meeting. SCAG is also committed to helping people with limited
proficiency in the English language access the agency's essential public information
and services.You can request such assistance by calling(213)236-1908.We request
at least 72 hours(three days)notice to provide reasonable accommodations and will
make every effort to arrange for assistance as soon as possible.
Videoconference Sites&Addresses
SCAG Los Angeles Office (Main Office)
900 Wilshire Blvd., Ste. 1700, Los Angeles, CA 90017
SCAG Imperial County Regional Office
1503 N. Imperial Ave., Ste. 104, El Centro, CA 92243
SCAG Orange County Regional Office
600 S. Main St., Orange, CA 92868
*Due to limited capacity, please RSVP prior to the meeting to ensure availability,
housing@scag.ca.gov
SCAG Riverside County Regional Office
3403 10th St., Ste. 805, Riverside, CA 92501
SCAG San Bernardino County Regional Office
1170 W. 3rd St., Ste. 140, San Bernardino, CA 92410
SCAG Ventura County Regional Office
4001 Mission Oaks Blvd., Ste. L, Camarillo, CA 93012
City of Palmdale Office
38250 Sierra Hwy., Palmdale, CA 93550
South Bay Cities Council of Governments Office
South Bay Environmental Services Center, 20285 S. Western Avenue, Suite 100 Torrance, CA 90501
Teleconference Sites&Addresses
Simi Valley City Hall
2929 Tapo Canyon Road
Simi Valley, CA 93063
Webcasting Available-Webcast participation is view-only.
To join the meeting, click on this link: https://scag.zoom.us/j/807124298
To join by phone, please dial 1-669-900-6833 and Enter Meeting ID: 807 124 298
RHNA SUBCOMMITTEE MEMBERS—RHNA 6TH CYCLE
VOTING MEMBERS
Representing Imperial County
Primary: Hon.Jim Predmore, Holtville
Alternate: Hon. Bill Hodge, Calexico
Representing Los Angeles County
Primary: Hon. Margaret Finlay, Duarte
Alternate: Hon. Rex Richardson, Long Beach
Representing Orange County
Primary: Hon. Wendy Bucknum, Mission Viejo
Alternate: CHAIR Peggy Huang, Yorba Linda,TCA
Representing Riverside County
Primary: Hon. Rusty Bailey, Riverside
Alternate: Hon. Russell Betts, Desert Hot Springs
Representing San Bernardino County
Primary: Hon. Bill Jahn, Big Bear Lake
Alternate: Hon. Jim Mulvihill, San Bernardino
Representing Ventura County
Primary: Hon. Carmen Ramirez, Oxnard
Alternate: Hon. Mike Judge, Simi Valley, VCTC
NON-VOTING/EX-OFFICIO MEMBERS
Representing Academia
Ex-Officio: Paavo Monkkonen, Vice Chair, Dept. of Urban Planning, UCLA
Representing Non-Profit/Advocate
Ex-Officio: Cesar Covarrubias, Executive Director, Kennedy Commission
Representing Building Industry
Ex-Officio: Jeff Montejano, Chief Executive Officer, BIA of Southern California
This Page Intentionally Left Blank
RHNA SUBCOMMITTEE
SPECIAL MEETING AGENDA
Southern California Association of Governments
900 Wilshire Boulevard, Suite 1700
Los Angeles, California 90017
Monday, February 24, 2020
10:00 AM
CALL TO ORDER AND PLEDGE OF ALLEGIANCE
(The Honorable Peggy Huang, Chair)
ROLL CALL
PUBLIC COMMENT PERIOD
Members of the public desiring to speak on items on the Special Meeting Agenda must fill out and
present a Public Comment Card to the Assistant prior to speaking. Comments will be limited to three
(3) minutes per speaker.The Chair has the discretion to reduce the time limit based upon the number
of speakers and may limit the total time for all public comments to twenty (20) minutes.
REVIEW AND PRIORITIZE AGENDA ITEMS
ACTION / DISCUSSION ITEMS
1. Recommended Final RHNA Methodology Page 1
(Kome Ajise, Executive Director, SCAG)
Recommended Action: Approve a recommendation that the Community,
Economic and Human Development Committee (CEHD) recommend Regional
Council (RC) approval of Resolution No. 20-619-2 Adopting the Final Regional
Housing Needs Assessment (RHNA) Methodology for the Sixth Housing
Element Cycle (2021- 2029).
2. 6th Cycle RHNA Appeals Procedures Page 65
(Kome Ajise, Executive Director,SCAG)
Recommended Action: Recommend that the Community, Economic and
Human Development (CEHD) Committee recommend Regional Council
approval of the 6th Cycle RHNA Appeals Procedures.
CONSENT CALENDAR
3. Minutes of the Meeting—October 7, 2019 Page 115
'11 .
KAGSPECIAL MEETING AGENDA
Receive and File
4. State HCD Review Findings of SCAG's Draft RHNA Methodology Page 124
5. Written Comments Received Page 126
6. 6th Cycle RHNA Development Timeline Page 139
CHAIR'S REPORT
(The Honorable Peggy Huang, Chair)
STAFF REPORT
ANNOUNCEMENT/S
ADJOURNMENT
....
.u.I.
'.` AGENDA ITEM 1
_,
....,AG REPORT
Southern California Association of Governments
900 Wilshire Boulevard, Suite 1700, Los Angeles, California 90017
February 24, 2020
To: Regional Housing Needs Assessment Subcommittee (RHNA) EXECUTIVE DIRECTOR'S
APPROVAL
From: Kome Ajise, Executive Director, Executive Management, -- Ice..
213-236-1835, Aiise@scag.ca.gov
Subject: Recommended Final RHNA Methodology
RECOMMENDED ACTION FOR RHNA SUBCOMMITTEE:
Approve a recommendation that the Community, Economic and Human Development Committee
(CEHD) recommend Regional Council (RC) approval of Resolution No. 20-619-2 Adopting the Final
Regional Housing Needs Assessment (RHNA) Methodology for the Sixth Housing Element Cycle
(2021- 2029).
STRATEGIC PLAN:
This item supports the following Strategic Plan Goal 1: Produce innovative solutions that improve
the quality of life for Southern Californians.
EXECUTIVE SUMMARY:
As part of the RHNA process, SCAG must develop a final RHNA methodology, which will determine
each jurisdiction's draft RHNA allocation as a share of the regional determination of 1,341,827
housing unit need as determined by the California Department of Housing and Community
Development(HCD). Following the Regional Council approval of a draft RHNA methodology I and
review finding by HCD that the methodology furthers the applicable statutory objectives, staff
requests for the RHNA Subcommittee to approve a recommendation that CEHD recommend
Regional Council approval of Resolution No. 20-619-2, which reflects adoption of the draft RHNA
methodology as the final RHNA methodology.
BACKGROUND:
As part of the RHNA process, SCAG must develop a final RHNA methodology, which will determine
each jurisdiction's draft RHNA allocation as a share of the regional determination of 1,341,827
housing unit need as determined by HCD.
Between August 1 and September 13, 2019, SCAG solicited public comments on three options for
allocating the regional determination to the region's 197 local jurisdictions. Based on feedback
received, and after careful consideration of the statutory objectives of RHNA which guide the
methodology process, the Regional Council voted on November 7, 2019 to approve a draft RHNA
OUR MISSION OUR VISION
To foster innovative regional solutions that improve Southern California's Catalyst for a Brighter Future
the lives of Southern Californians through inclusive
collaboration,visionary planning,regional advocacy, OUR CORE VALUES
information sharing,and promoting best practices. Be Open I Lead by Example I Make an Impact I Be Courageous
RHNA Subcommittee Meeting-Feb.24,2020
Page 1 of 139
vimit
REPORT
methodology. A detailed timeline of meetings, submissions, staff reports, and correspondences is
attached.
Per Government Code 65584.04 et seq., HCD has 60 days to review the draft methodology and
determine whether it furthers the statutory objectives of RHNA. If HCD finds that the draft
methodology is not consistent with the five statutory objectives of RHNA, SCAG may make revisions
to further the statutory objectives per HCD review comments. On January 13, 2020, HCD
completed their statutory review and found that SCAG's Draft RHNA Methodology furthers the five
statutory objectives of RHNA, which allows SCAG to finalize the RHNA methodology and issue draft
RHNA allocations to each individual jurisdiction. HCD's comment letter(attached) notes:
"HCD has completed its review of the methodology and finds that the draft SCAG
RHNA methodology furthers the five statutory objectives of RHNA. HCD
acknowledges the complex task of developing a methodology to allocate RHNA to
197 diverse jurisdictions while furthering the five statutory objectives of RHNA. This
methodology generally distributes more RHNA, particularly lower income RHNA,
near jobs, transit, and resources linked to long term improvements of life outcomes.
In particular, HCD applauds the use of objective factors specifically linked the
statutory objectives in the existing need methodology."
HCD's analysis individually reviews the five statutory objectives of RHNA. Particular emphases are
placed on data-based indicators of the extent to which SCAG's draft RHNA methodology (1) assigns
more lower-income units to high-income/high-resourced jurisdictions, and (2) assigns lower-income
units to jurisdictions with more low-wage jobs. HCD concludes its letter with an indication that
"any changes made in response to appeals should be in the interest of seeking ways to more deeply
further the objectives without compromising other objectives." HCD's findings confirm and
complement SCAG's assessment of the methodology and illustrate how the distribution of units
across the region advances statutory objectives (see attached PowerPoint).
Following HCD's findings of compliance, staff recommends that the Regional Council adopt the draft
RHNA methodology as the final RHNA methodology by resolution. A detailed description of the
staff-recommended final RHNA methodology is attached. Thereafter, individual jurisdictions' draft
RHNA allocation numbers will be issued in the Draft RHNA Allocation Plan, an appeals process will
be conducted, and final RHNA allocations are scheduled to be issued by October 2020.
The staff-recommended final RHNA methodology will utilize final Connect SoCal data for the
purpose of calculating each jurisdiction's allocation. These data have recently become available
following the January 24, 2020 close of the Connect SoCal public comment period and reflect the
data and model updates made since the draft Connect SoCal Plan release on November 7, 2019.
While the draft methodology and staff-recommended final methodology are identical, jurisdictions
RHNA Subcommittee Meeting-Feb.24,2020
Page 2 of 139
REPORT
vommeamammingr
may see slight changes in their estimated RHNA allocation totals owing to changes in the data,
which are used in the measurement of transit access and job access in the RHNA methodology.
Region-wide, these data changes are equivalent to no more than 1.69% of the regional total. No
further changes to these data are anticipated.
Justifications for Adopting RC-Approved Draft Methodology without Change in March 2020
SCAG is required to distribute a draft RHNA allocation to each city and county in the region prior to
adoption of the Connect SoCal Plan scheduled for April 2, 2020 (Government Code 65584.05(a)).
Since the draft RHNA allocation shall be based on the adopted final RHNA methodology, adoption
of the final RHNA methodology by the Regional Council at its March 5th, 2020 meeting would
ensure that SCAG is fully compliant with statutory requirements.
In addition, staff recommends against submitting any alternative draft methodology to HCD at this
stage for another 60-day review as it would jeopardize HCD's consistency findings described above,
is not provided for in statute, will jeopardize the October 2020 completion of the 6th cycle final
RHNA allocations, and will jeopardize the ability of local jurisdictions to timely complete their
housing element updates by October 2021.
FISCAL IMPACT:
Current work on the Regional Housing Needs Assessment is included in the current FY 19-20
General Fund Budget (800.0160.03: RHNA). There is no immediate fiscal impact for the tasks
proposed under these funds.
ATTACHMENT(S):
1. Staff Recommended Final RHNA Methodology Presentation
2. HCD Review of Draft RHNA Methodology
3. Resolution No. 20-619-2 to adopt Final RHNA Methodology and Attachment A
4. Estimated RHNA Allocations
5. RHNA Timeline of Key Activities and Milestones
RHNA Subcommittee Meeting-Feb.24,2020
Page 3 of 139
This Page Intentionally Left Blank
• - taff-Recommended Final A
Methodolo
gy ._-
Kevin Kane, PhD
SCAG Staff
February 24, 2020
www.scag.ca.gov INNOVATING
Outline of Presentation
• RHNA timeline
• HCD and RC - approved draft RHNA methodology a
inputs
• Methodology's performance vs. statutory objective
The RHNA Methodology Process
• Proposed RHNA Methodology
• Released for public comment August 1
• Four public hearings and one public information session
Aug-Sept` • Multiple options and components for review and comment
2019
• Draft RHNA Metho • ology
• One methodology based on state housing law and regional goals while
considering public comments
• October 7: RHNA Subcommittee
Sept-Nov • October 21: CEHD Committee
2019 • November : Re:ional Council a. •roval
1110 • HCD Comment Period
• 60 day review of draft RHNA methodology
• January 13: HCD concluded that SCAG draft methodology furthers RHNA
Nov 2019- ' objectives—statute does not provide for further changes to methodolog'
Jan 2020
• Final RHNA Methodology
• Following HCD finding, staff recommends RC-approved Draft Methodolc
as Final Methodology
10, • February 24: RHNA Subcommittee
Feb-Apr • March 5: CEHD Committee
2020 • March 5: Regional Council adopts final methodology by resolution
• April 2: Regic#tb Ctt n9►lgerpir e.edrift°REINA allocations to each jurisdiction
RHNA Timeline Continued
Al
• Draft RHNA Allocations issued
• See detailed appeal timeline.
Apr
2020
• Final RHNA Allocation
NAI*. Oct
2020
111 • Local Housing Element Updates Due
Oct
2021
High Quality Transit Ar:as (HQTAs; 2045; Final Connect SoCal Plan Data)
d
Ventura
County
i ® + \\1
H Q T A ...,. .
Los Angeles
+
•
Final -
County
t.
I`Boundaries . - A,
-
a Oaks
to
. .
using � � 4
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:411: 401M la ri
Connect SoCal n '''
1 i v iroiiiviN
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Data San Bernardino a- _ T
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Riverside < 4r...---- aos , , `
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Imperial Orange
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Please note this map depicts the"High Quality Transit Areas(HQTAs)"within the SCAG Region and is based on the planned year transit network fo\Konnect SoCz
Transportation Commissions.SCAG updates its inventory of planned majoftransiftstbps and high quality transit corridors with the adoption of a new RTP/SCS,o
may be completed by transit agencies on a more frequent basis than the RTP/SC9is ul3dated by SCAG.Local jurisdictions should consult with the appropriate tra
planned transit routes,stop locations,and service intervals.This map is intended-fbr.planning purposes only,and SCAG shall incur no responsibility or liability as
information.SCAG assumes no responsibility arising from use of this information by individuals,businesses,or other public entities.The information Is provided
including but not limited to the implied warranties of merchantability and fitness for a particular purpose.
City Boundaries t "i t3r gYAIRRgifhri (MTAs) Freeway
Page 8 of 139
Source:SCAG,2020 P:\Jung\RHNA\6th_RHNA\mxds\Transit Ac
Job Accessibility
(Share of Regional Jobs Accessible by TAZ by Auto in 30 minutes; 2045; Final Connec
Job ,..
1
Accessibility
using .„.,, c,_
-3
Final
,,.t.
Connect SoCalr.
Data , , ,
Ili
ww, lii 4PacificOcean
. ,.,
41Los Angeles �, 11
.M411 County
1 I I FA IT'illIti' .
;e1ce Layer LredIr:Esri.tN
Job Accessibility(Share of Regional Jobs Accessible by TAZ by Auto in 30 minutes; 2045; Final Connect SoC
H�q gg F `, More Accesible
2.5% 5% R7.596Subc��no,
1 �• 24 &}, ' 20%
Source:SCAG, 2020 5 P:\Jung\RHNA\6th_RHNA\mxds\Job Ac
The RHNA Methodology: A plan to allocate 1,341,827 units t
197 jurisdictions
Staff Recommended Final RHNA Methodology - Regional
Breakdown
• Connect SoCal Hous
Growth, 2021-2029
Future vacancy nee,
34.8%
Future replacement
Transit access
Y. . 1.1%
• Job access
1.8%
Note: The draft RHNA methodology uses jurisdiction-level Connect ScCal 2O2 Z 3C household g? owth multiplied by 8.25 to match the dur
planning period. At the jurisdictional level, Connect SoCal household growth is ides.tical to local input, and over this time period is perfectly
regional RHNA share depicted above.
Comparison vs. Previous Version
Original Recommendation, NOT approved RC-Approved Draft Methodolog
by RC
r.
15.6%s
31.2%
011111111111.
37.6%
68.8°lo
31.2%
■ Need due to household growth • Job access Transit access ■ Need due to household growth • Job access Tr,
Note: RC-approved draft methodology included changes to proportional shares of allocation factors, caps, and, the redist
residual need (i.e. within counties) as compared to the original staff recommendation. These changes results in the diff:
above. See methodology document for details.
Note: In both charts, need due to household growth includes 38,012 units due to future vacancy and replacement need (
Review of methodology's performance versus statutory obje
• Comparisons previously presented by SCAG staff
• Comparisons relied upon by HCD in their review
"HCD has completed its review of the methodology and finds
draft SCAG RHNA methodology furthers the five statutory obje
RHNA. HCD acknowledges the complex task of developing a met
to allocate RHNA to 197 diverse jurisdictions while furthering t
statutory objectives of RHNA. This methodology generally dist
more RHNA, particularly lower income RHNA, near jobs, transi
resources linked to long term improvements of life outcomes
particular, HCD applauds the use of objective factors specifical
the statutory objectives in the existing need methodolog
Review: Statutory objectives of RHNA
0 ) To increase the housing supply and mix of housing "4
types, tenure and affordability within each region in an
equitable manner
II 67 71701
2) Promoting infill development and socioeconomic ; k4h�yf. a
equity the protection of environmental and '� ''�' ,y '4 (�
LN it ]I �1J, K • ..
agricultural resources, and the encouragement of )r, � `*�r� :�� w _
gg e4 'x`
efficient development patterns
3) Promoting an improved intraregional relationship
between jobs and housing
Allocatinga lower proportion of housingneed in 1 e
4) p , 1
income categories in jurisdictions that have a
disproportionatelyhigh share in comparison to the
�
... ,..
county distribution , _
5) Affirmatively furthering fair housing (AFF )
Re: RHNA objective 1, Equitable Geographic Distribution
Share of Total RHNA and Population by County & LA City (% of To
5.c 33.6%34.0%
32.4%
O.0
26.6%
23.7%
21.1%
0.0
17.55,;
16.8%
5.0%o 13.7% 13.5%
12.5% 12.7%
11
10.3%
8.0%
f
S
1.6% o f 0
1.2/0 1.0%
r
rri 1 l
Imperial Los Angeles City Los Angeles County Orange Riverside San Bernardi
(excluding LA city)
RHNA Subcommittee Meeting-Feb.24,2020
Original Recommendation, NOT approved by RC ■TC'At3loved Draft Methodology ® 2019 Popu
Re: RHNA objective 1, Equitable Geographic Distributi 1
Share of Total RHNA and Population by Subregion (% of Total)
33.634.0
30.0
25.0
21.1
.- 7�
2(1.0
'45 16.1
u 7
0 1`3.0
d / 12.9/ 12.6 12.8
1116105
/I
// 9.6 9.8
10.0 8.9 �/% i
7.1 8.1 � '
6.7
5.5 1 5.4
5.0 4.1 4.0 1 4.0
3.2 2.9 r
10
1.3 1.7 1.6 2.4 2.1 1.3 2.0 121
/4 I I R I i
•
.- m i • ..„, 0.1 0.1 "
0.0
po° PCS aJ i�a\ �J `�J �J 67
OV OO OV .e5 'a
�e`aJ (J Oa`e� �cc�e �a\ z��` co
OC` ���� `�C�O a Oi e6P`e
oJ° ewe V- .i.(‘�.c P OLAP ;0 of
V.' ',tea ,,°h °t �o °cQ
\.• Jc`cc
RHNA Subcommittee Meeting-Feb.24,2020
• Original Recommendation, NOT approved by RC PaRCiApp oved Draft Methodology 12 2019 Population (CA DOF)
e: ' ' ` A • I pec we - n 1 an I e mien ' eve opmen
Comparison of total RHNA with transit access measure used in draft methodoloE
45.0%
I N
39.69:
40.0% ___
33.6'1:34.6°b
..t 29.5%
30.0%
26.5%
. 2
25.0% 3.7% ''�0.0 `
%
17.59.
/ 13.6%14.1%
15.0% _ 13.5%
12.3%
10.1%
3.09.:rr,,
10.0% 0 //F1 ,, f/f/ 8.3%
� 3.09.: r
5.0% \
1.6% 1.2% 1.0% 4F
0.0% M ITZ2 / 4 ee.,./ e
Imperial Los Angeles City Los Angeles County Orange Riverside San Bernardino
(excluding LA city)
RHNASubcommit etin -Feb .4 2
Original Recommendation, NOT approved by � �. { ved r<art Methodology Q Population in 2045 HQT
e: a ' ` i • . jec we - n 1 an I e icien . eve opmen an . •
Objective 3 - Improved intraregional jobs-housing relationshi
Comparison of total RHNA with job access measure used in draft methodology
3
33.6% 4.6% 33.6%
30.6%
I 26.5°
23.7%
(17.5n:
13.6%°IF:\
12.3% 13.5%
10.1%
10 If 8.0% 7.49c
5.4%
116O.196
. % 1.2% jr
/ 4"
, .elf '/f:::
Imperial Los Angeles City Los Angeles County Orange Riverside San Bernardino
(excluding LA city)
RHNA Subcommittee Meeting-Feb.24,2020
Original Recommendation, NOT approved by RC ■ RC-Approwd haatitAvlethodology Mob Accessibility (Population-We
e: • ' ` A • Ijec we - mprove . in raregiona re a ions ips
between low-wage jobs and affordable housing
Low-wage jobs and lower-income RHNA allocation
40.0%
l 35.5(
35.0% 33.0%33.0°x0
30.0% 28.0qc
24.9=
15.U`.%o
20.2°. , c
:: : ' / .0� 170%13.50.;: 13.5%
12.2°x0
0 10.0,o
o� 10.3%10.39
10.0% 8.0':`;:
/ / I 7/
E.>.0%
1.7% o iI I
1.3/0 1.296 000/4
0.0% 4 ./...7" /-.../ 4 , ..4
Imperial Los Angeles City Los Angeles County Orange Riverside San Bernardino
(excluding LA city)
RHNA Subcommittee Meeting-Feb.24,2020
Original Recommendation, NOT approved by RC is RC-Appaget,KcbDRaft Methodology Q Low-wage jobs, Census LEHC
Conclusions / Next Steps
• Performance indicators show the RC - approved version impro
performance with respect to statutory objectives
• Methodology found to further statutory objectives by HCD:
"HCD has completed its review of the methodology and finds that t
SCAG RHNA methodology furthers the five statutory objectives of R
particular, HCD applauds the use of objective factors specifically
the statutory objectives in the existing need methodology. '
• Therefore, staff recommends adoption of the draft RHNA
methodology as the Final RHNA Methodology by resolution
Thank you .
Kevin Kane, PhD
kane(cvscag.ca.gov
www.scag.ca.gov INNOVATING
This Page Intentionally Left Blank
STATE OF CALIFORNIA-BUSINESS,CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM.. Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT cM1 Yf,r
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W.El Camino Ave < ° _PI'
Sacramento,CA 95833-1829 I "
916)263-2911 FAX:(916)263-7453 yy:,
www.hcd.ca.gov 41./ ox^Ar
January 13, 2020
Kome Ajise
Executive Director
Southern California Association of Governments
900 Wilshire Boulevard, Suite 1700
Los Angeles, CA 90017
Dear Executive Director Ajise:
RE: Review of Draft Regional Housing Need Allocation (RHNA) Methodology
Thank you for submitting the draft Southern California Association of Governments
(SCAG) Sixth Cycle Regional Housing Need Allocation (RHNA) Methodology. Pursuant to
Government Code Section 65584.04(i), the California Department of Housing and
Community Development (HCD) is required to review draft RHNA methodology to
determine whether the methodology furthers the statutory objectives described in
Government Code Section 65584(d).
In brief, the draft SCAG RHNA methodology begins with the total regional determination
provided by the California Department of Housing and Community Development (HCD)
and separates it into two methodologies to allocate the full determination: projected need
(504,970) and existing need (836,857).
For projected need, the household growth projected in SCAG's Connect SoCal growth
forecast for the years 2020-2030 is used as the basis for calculating projected housing
need for the region. A future vacancy and replacement need are also calculated and
added to the projected need.
The existing need is calculated by assigning 50 percent of regional existing need based
on a jurisdiction's share of the region's population within the high-quality transit areas
(HQTAs) based on future 2045 HQTAs. The other 50 percent of the regional existing
need is based on a jurisdiction's share of the region's estimated jobs in 2045 that can be
accessed within a 30-minute driving commute. For high segregation and poverty areas as
defined by HCD/TCAC Opportunity Maps,1 referred to by SCAG as extremely
disadvantaged communities (DACs), existing need in excess of the 2020-2045 household
growth forecast is reallocated to non-DAC jurisdictions within the same county.
--continued on next page--
1 Created by the California Fair Housing Task Force and commissioned by HCD and the California Tax Credit
Allocation Committee (TCAC)to assist public entities in affirmatively furthering fair housing. The version used in
this analysis is the 2019 HCD/TCAC Opportunity Maps available at treasurer.ca.gov/ctcac/opportunity.asp.
RHNA Subcommittee Meeting-Feb.24,2020
..i.10n
--continued from previous page--
Within both the projected and existing need methodologies the four RHNA income
categories (very low, low, moderate, and above moderate) are assigned to each
jurisdiction by the use of a 150 percent social equity adjustment, which inversely adjusts
based on the current incomes within the jurisdiction. An additional percentage of social
equity adjustment is made for jurisdictions that have a high concentration of DACs or
Highest Resource areas as defined by the HCD/TCAC Opportunity maps. Overall, the
social equity adjustments result in greater shares of lower income RHNA to higher income
and higher-resource areas.
HCD has completed its review of the methodology and finds that the draft SCAG
RHNA Methodology furthers the five statutory objectives of RHNA.2 HCD
acknowledges the complex task of developing a methodology to allocate RHNA to 197
diverse jurisdictions while furthering the five statutory objectives of RHNA. This
methodology generally distributes more RHNA, particularly lower income RHNA, near
jobs, transit, and resources linked to long term improvements of life outcomes. In
particular, HCD applauds the use of objective factors specifically linked the statutory
objectives in the existing need methodology.
Below is a brief summary of findings related to each statutory objective described within
Government Code Section 65584(d):
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 allocation of units for low- and very low-income households.
The methodology generally allocates increased shares of lower income RHNA to
jurisdictions that have higher housing costs. In support of a mix of affordability, the
highest housing cost cities generally receive higher shares of lower income RHNA. Under
this methodology the 15 cities with the highest median housing costs all receive greater
than 50 percent of the RHNA as lower income RHNA. Beverly Hills with the 18th highest
median housing costs receives the 25th highest share of lower income RHNA; Westlake
Village with the 14th highest median housing costs receives the 12th highest share of
lower income RHNA; Aliso Viejo with the 23rd highest median housing costs receives the
38th highest share of lower income RHNA; and Villa Park with the 10th highest median
housing costs receives the 31st highest share of lower income RHNA.
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 draft SCAG RHNA methodology furthers the environmental principles of this
objective as demonstrated by the transportation and job alignment with the RHNA
allocations.
--continued on next page--
2 While HCD finds that this particular methodology furthers the objectives of RHNA, HCD's determination is subject
to change depending on the region or cycle, as housing conditions in those circumstances may differ.
RHNA Subcommittee Meeting-Feb.24,2020
Page 22 of 139
--continued from previous page-
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.
Half of the existing need portion of the draft SCAG RHNA methodology is set based on
the jurisdiction's share of the region's estimated jobs in 2045. While future looking job
projections are important for housing planning, and housing built in the next decade will
likely exist for 50-100 years or more, it is also critical to plan for the needs that exist
today. This objective specifically considers the balance of low-wage jobs to housing
available to low-wage workers. As part of HCD's analysis as to whether this jobs-housing
fit objective was furthered by SCAG's draft methodology, HCD analyzed how the
percentage share of the region's lower income RHNA compared to the percentage share
of low-wage jobs.
For example, under the draft SCAG RHNA methodology Irvine would receive 1.84
percent of the region's lower income RHNA, and currently has 2.07 percent of the
region's low-wage jobs, .23 percent less lower income RHNA than low-wage jobs for the
region. Pomona would receive .71 percent of the region's lower income RHNA, and
currently has .57 percent of the region's low-wage jobs, .13 percent more lower income
RHNA than low-wage jobs for the region. Across all jurisdictions there is generally good
alignment between low-wage jobs and lower income RHNA, with all but 15 jurisdictions
within a half percent plus or minus difference between their share of lower income RHNA
for the region and their percentage low-wage jobs for the region.
HCD is aware there has been some opposition to this current methodology from
jurisdictions that received lower allocations under prior iterations; however it is worth
noting that even if it is by a small amount, many of the jurisdictions that received
increases are still receiving lower shares of the region's lower income RHNA compared to
their share of the region's low-wage jobs. HCD recommends any changes made in
response to appeals should be in the interest of seeking ways to more deeply further
objectives without compromising other objectives.
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 is furthered directly by the social equity adjustment factor included in the
draft SCAG RHNA methodology. Jurisdictions in the SCAG region range from as little as
10.9 percent lower income households to 82.7 percent lower income households. The 20
jurisdictions with the greatest share of lower income households, 67.2-82.7 percent lower
income households, would receive an average of 31.6 percent lower income share of
their RHNA; compared to the 20 jurisdictions with the lowest share of lower income
households, 10.9-25.1 percent lower income households, would receive an average of
59.1 percent lower income share of their RHNA. While the social equity adjustment
explicitly responds to objective four, it also assists in the methodology furthering each of
the other objectives.
--continued on next page—
RHNA Subcommittee Meeting-Feb.24,2020
Page 23 of 139
--continued from previous page-
5. Affirmatively furthering fair housing, which 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.
HCD applauds the inclusion of the affirmatively furthering fair housing adjustment factor in
the methodology. This factor directs more lower income RHNA to higher opportunity
areas and reduces allocations in segregated concentrated areas of poverty, as defined in
the HCD/TCAC Opportunity Maps, which evaluate access to opportunity, racial
segregation, and concentrated poverty on 11 dimensions, which are all evidence-based
indicators related to long term life outcomes. 14 of the top 15 highest shares of lower
income RHNA are in regions over 99.95 percent High and Highest Resource areas.
These include: Imperial, La Habra Heights, Rolling Hills Estates, Hermosa Beach, La
Canada Flintridge, Palos Verdes Estates, Manhattan Beach, Rolling Hills, Agoura Hills,
Rancho Palos Verdes, Westlake Village, San Marino, Eastvale, and Hidden Hills. With the
exceptions of the cities of Vernon and Industry, the 31 jurisdictions with the highest share
of lower income RHNA are all over 95 percent High and Highest Resource areas.
HCD appreciates the active role of SCAG staff in providing data and input
throughout the draft SCAG RHNA methodology development and review
period. HCD especially thanks Ping Chang, Kevin Kane, Sarah Jepson, and
Ma'Ayn Johnson for their significant efforts and assistance.
HCD looks forward to continuing our partnership with SCAG to assist its
member jurisdictions to meet and exceed the planning and production of the
region's housing need.
Support opportunities available for the SCAG region this cycle include, but are
not limited to:
• SB 2 Planning Technical Assistance (Technical assistance available
now through June 2021)
• Regional and Local Early Action Planning grants (25 percent of
Regional funds available now, all other funds available early 2020)
• SB 2 Permanent Local Housing Allocation (Available April – July 2020)
If HCD can provide any additional assistance, or if you, or your staff, have any
questions, please contact Megan Kirkeby, Assistant Deputy Director for Fair
Housing, megan.kirkeby(a�hcd.ca.gov.
Megan Kirkeby
Assistant Deputy Director for Fair Housing
RHNA Subcommittee Meeting-Feb.24,2020
Page 24 of 139
•gm .
RESOLUTION NO. 20-619-2
11111116G.'
A RESOLUTION OF THE SOUTHERN CALIFORNIA
tynoeauNc FOR A BET ASSOCIATION OF GOVERNMENTS (SCAG) ADOPTING THE FINAL
SOUTHERN CALIFORNIA REGIONAL HOUSING NEEDS ASSESSMENT (RHNA) METHODOLOGY
ASSOCIATION OF GOVERNMENTS FOR THE SIXTH HOUSING ELEMENT CYCLE (2021—2029)
goo Wilshire Blvd.,Ste.i7oo
Los Angeles,CA 90017
T:(213)236-1800 WHEREAS, the Southern California Association of Governments (SCAG) is the
www.scag.ca.gov Metropolitan Planning Organization, for the six county region consisting of Los Angeles,
Orange, San Bernardino, Riverside, Ventura, and Imperial Counties;
REGIONAL COUNCIL OFFICERS
WHEREAS, California state housing element law requires that the Southern
President
Bill Jahn,Big Bear Lake California Association of Governments (SCAG) adopt a methodology for distributing the
First Vice President existing and projected regional housing need to each of the local jurisdictions within the
Rex Richardson,Long Beach SCAG region;
Second Vice President
Clint Lorimore,Eastvale
WHEREAS, the California Department of Housing and Community Development
Immediate Past President
Alan D.Wapner,San Bernardino (HCD) is required to consult with SCAG in determining the existing and projected housing
County Transportation Authority need for the region prior to each housing element cycle;
COMMITTEE CHAIRS WHEREAS,on October 15, 2019, HCD provided SCAG with a regional housing need
Executive/Administration number of 1,341,827 units distributed among four income categories, very-low (26.2%),
Bill Jahn,Big Bear Lake
low (15.4%), moderate (16.7%), and above-moderate (41.7%) for the 6th Housing Element
Community,Economic&
Human Development Cycle (2021-2029);
Peggy Huang,Transportation
Corridor Agencies
Energy&Environment WHEREAS,SCAG conducted four public hearings in August 2019 to formally receive
Linda Parks,Ventura County verbal and written comments on the proposed Regional Housing Needs Assessment
Transportation (RHNA) methodology options, in addition to one public information session with a total of
Cheryl Viegas-Walker,El Centro approximately 250 participants. Almost 250 written comments were submitted to SCAG
specifically on the proposed methodology and over 35 verbal comments were shared at
the four public hearings;
WHEREAS, after considering the public comments received, at its November 7,
2019 meeting,the SCAG Regional Council approved and submitted to HCD the Draft RHNA
Methodology for the 6th Housing Element Cycle, for a 60-day review;
WHEREAS, on January 13, 2020, HCD determined that the Draft RHNA
methodology furthers the objectives set forth in state law, California Government Code
Section 65584(d);
Page I 1 of 2
RHNA Subcommittee Meeting-Feb.24,2020
Page 25 of 139
• Allocation methodology, per Government Code 65584.04(a)
• How the allocation methodology furthers the objectives State housing law, per GC
65584.04(f)
• How local planning factors are incorporated into the RHNA methodology, per GC
65584.04(f)
• Furthering the objectives of affirmatively furthering fair housing (AFFH), per GC
65584.04(d)
• Public engagement, per GC 65584.04(d)
Additionally,SCAG has developed a dynamic estimator tool and data appendix that contains a full set
of various underlying data and assumptions to support the recommended final methodology. Due to
the size of the appendix, a limited number of printed copies are available. SCAG has posted the
dynamic estimator tool and full methodology appendix, on its RHNA webpage:
www.scag.ca.gov/rhna.
Per State housing law,the RHNA methodology must distribute existing and projected housing need
to all jurisdictions. The following section provides the staff-recommended final methodology for
distributing projected and existing need to jurisdictions from the RHNA regional determination
provided by the California Department of Housing and Community Development (HCD) pursuant to
Government Code Section 65584.01.
Guiding Principles for RHNA Methodology
In addition to furthering the five objectives pursuant to Government Code 65585(d),there are
several guiding principles that SCAG staff has developed to use as the basis for developing the
distribution mechanism for the RHNA methodology. These principles are based on the input and
guidance provided by the RHNA Subcommittee during their discussions on RHNA methodology
between February 2019 and June 2019.
1. The housing crisis is a result of housing building not keeping up with growth over the last
several decades.The RHNA allocation for all jurisdictions is expected to be higher than the
5th RHNA cycle.
2. Each jurisdiction must receive a fair share of their regional housing need.This includes a fair
share of planning for enough housing for all income levels, and consideration of factors that
indicate areas that have high and low concentration of access to opportunity.
3. It is important to emphasize the linkage to other regional planning principles to develop
more efficient land use patterns, reduce greenhouse gas emissions, and improve overall
quality of life.
The jurisdictional boundaries used in the recommended RHNA methodology will be based on those
as of August 31, 2016. Spheres of influence in unincorporated county areas are considered within
unincorporated county boundaries for purposes of RHNA.
Proposed RHNA Allocation Methodology
The proposed RHNA methodology, which was released for public review on August 1, contained
three (3) options to distribute HCD's regional determination for existing and projected need for the
2
RHNA Subcommittee Meeting-Feb.24,2020
Page 28 of 139
SCAG region. HCD provided SCAG a final regional determination of 1,341,827 units for the 6th cycle
RHNA on October 15, 2019.1
The three options were developed based on RHNA Subcommittee feedback on various factors at
their meetings between February and June 2019 and feedback from stakeholders. SCAG solicited
formal public comment on the three options and any other factors, modifications, or alternative
options during the public comment period, which commenced on August 1 and concluded on
September 13, 2019.
Four public hearings were conducted to formally receive verbal and written comments on the
proposed RHNA methodology, in addition to one public information session with a total
participation of approximately 250 people. Almost 250 written comments were submitted to SCAG
specifically on the proposed methodology and over 35 verbal comments were shared at four(4)
public hearings held in August 2019.
Draft and Final RHNA Allocation Methodology
Based on comments received during the public comment period, staff recommended a combination
of the three options in the proposed methodology further enhanced by factors specifically
suggested by stakeholders.
On November 7, 2019, SCAG's Regional Council voted to approve the Draft RHNA Methodology.
The approved draft methodology includes modifications to the staff-recommended draft
methodology for calculating existing housing need to more closely align the methodology with job
and transit accessibility factors.
On January 13, 2020, HCD completed their statutory review and found that SCAG's Draft RHNA
Methodology furthers the five statutory objectives of RHNA, which allows SCAG to finalize the
RHNA methodology and issue draft RHNA allocations to each individual jurisdiction. HCD's
comment letter, which can be found at www.scag.ca.gov/rhna, notes:
"HCD has completed its review of the methodology and finds that the draft SCAG RHNA
methodology furthers the five statutory objectives of RHNA. HCD acknowledges the
complex task of developing a methodology to allocate RHNA to 197 diverse jurisdictions
while furthering the five statutory objectives of RHNA. This methodology generally
distributes more RHNA,particularly lower income RHNA, near jobs, transit, and
resources linked to long term improvements of life outcomes. In particular, HCD
applauds the use of objective factors specifically linked the statutory objectives in the
existing need methodology."
1 On September 5,2019,the SCAG Regional Council voted to object to HCD the regional determination of
1,344,740, per Government Code Section 65584.01,that was provided on August 15,2019.After review of SCAG's
objection letter, HCD provided a final regional determination of 1,341,827 units on October 15, 2019.
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Page 29 of 139
Following this finding, staff recommends the draft RHNA methodology as the final RHNA
methodology. Since some of the data inputs to the draft RHNA methodology utilized draft Connect
SoCal data,the staff-recommended final RHNA methodology will utilize final Connect SoCal data.
The finding of compliance from HCD allows SCAG's Regional Council to adopt the final RHNA
methodology and send a draft RHNA allocation to each local jurisdiction. Following a separate
appeals phase described in Government Code 65584.05 et seq., RHNA allocations will be finalized in
approximately October 2020.
The next section describes the staff-recommended final RHNA methodology mechanism to
distribute the 1,341,827 housing units determined by HCD to all SCAG jurisdictions.
Determining Existing Need and Projected Need
The staff-recommended final RHNA methodology starts with the total regional determination
provided by HCD and separates existing need from projected need.
Projected need is considered as household growth for jurisdictions between the RHNA projection
period between July 1, 2021 and October 1, 2029, in addition to a calculated future vacancy need
and replacement need. For projected household growth, SCAG's Connect SoCal growth forecast for
the years 2020-2030 is used as the basis for calculating projected housing unit need for the region.
The anticipated growth in households over this period is multiplied by 0.825 to approximate growth
during the 8.25-year RHNA projection period of July 1, 2021 to October 1, 2029.
For several jurisdictions, SCAG's growth forecast includes projected household growth on tribal
land. For these jurisdictions, SCAG's estimate of household growth on tribal land from July 1, 2021
to October 1, 2029 is subtracted from the jurisdictional projected household growth (see note in
the accompanying dynamic estimator tool). A vacancy adjustment of 1.5%for owner-occupied
units and 5%for renter-occupied units representing healthy-market vacancy will be applied to
projected household growth to determine future vacancy need. Next a replacement need is added,
which is an estimate of expected replacement need over the RHNA period. Based on these
components,the regional projected need is 504,970 units.
Existing need is considered the remainder of the regional determination after projected need is
subtracted. Based on this consideration,the regional existing need is 836,857 units.
Determining a Jurisdiction's RHNA Allocation (Existing and Projected Need)
In determining the existing need and projected need for the region,the methodology applies a
three-step process to determine a jurisdiction's RHNA allocation by income category:
1. Determine a jurisdiction's projected housing need
a. Assign household growth to jurisdictions based on SCAG's Connect SoCal Regional
Transportation Plan/Sustainable Communities Strategy Growth Forecast between 2020
and 2030
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RHNA Subcommittee Meeting-Feb.24,2020
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b. Calculate a jurisdiction's future vacancy need by applying a healthy market vacancy rate
separately to the jurisdiction's owner and renter households
c. Assign a replacement need to jurisdictions based on each jurisdiction's share of regional
net replacement need based on information collected from the replacement need
survey submitted by local jurisdictions
2. Determine a jurisdiction's existing housing need
a. Assign 50 percent of regional existing need based on a jurisdiction's share of region's
population within the high quality transit areas(HQTAs) based on future 2045 HQTAs
b. Assign 50 percent of regional existing need based on a jurisdiction's share of the
region's jobs that can be accessed within a 30-minute driving commute
c. For extremely disadvantaged communities (hereafter"DACs," see definition below),
identify residual existing need, which is defined herein as total housing need in excess of
household growth between 2020 and 20452. DACs are jurisdictions with more than half
of the population living in high segregation and poverty or low resource areas as defined
by the California Tax Credit Allocation Committee (TCAC)/HCD Opportunity Index Scores
further described in the document.
d. Reallocate residual existing need by county to non-DAC jurisdictions within the same
county based on the formula in (a) and (b) above, i.e. 50%transit accessibility and 50%
job accessibility.
3. Determine a jurisdiction's total housing need
a. Add a jurisdiction's projected housing need from (1) above to its existing housing need
from (2) above to determine its total housing need.
4. Determine four RHNA income categories (very low, low, moderate, and above moderate)
a. Use a minimum 150%social equity adjustment
b. Add an additional percentage of social equity adjustment to jurisdictions that have a
high concentration of very low or very high resource areas using the California Tax
Credit Allocation Committee (TCAC)'s index scoring
i. Add a 10%social equity adjustment to areas that are designated as 70-80%very
high or very low resource area
ii. Add a 20% social equity adjustment to areas that are designated as 81-90%very
high or very low resource area
iii. Add a 30% social equity adjustment to areas that are designated as 91-100%
very high or very low resource area
2 Since HCD's regional determination of 1,341,827 exceeds SCAG's 2020-2045 household growth forecast of
1,297,000 by 3.46 percent,for the purposes of existing need allocation,exceeding"local input"or more accurately,
Connect SoCal Growth Forecast, household growth shall mean exceeding 1.0368 times household growth.
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RHNA Subcommittee Meeting-Feb.24,2020
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- The forecast generates a 2045 regional unemployment rate of 4.7 percent which is
reasonable based on past trends and ensured that the forecast is balanced, i.e.there are not
too many jobs for the number of anticipated workers
- The forecast generates a 2045 population-to-household ratio of 2.9 which is consistent with
the preliminary forecast and reflects expert-anticipated decreases in this ratio, ensuring that
there are not too many people for the anticipated number of households region-wide
- From 2020-2045, the forecast anticipates household growth of 21 percent and population
growth of 15 percent, indicating an alleviation of the region's current housing shortage over
this future period.
SCAG's growth forecast for the years 2020-2030 is used as the basis for calculating projected housing
unit need. Because the 6th cycle RHNA projection period covers July 1, 2021 through October 15,
2029, it is necessary to adjust reported household growth between 2020 and 2030 and adjust it to an
8.25 year projection period. The anticipated growth in households over this period is multiplied by
0.825 to approximate growth during the 8.25-year RHNA projection period (July 1, 2021 to October
15, 2029).
Step 1b: Future Vacancy Need
The purpose of a future vacancy need is to ensure that there are enough vacant units to support a
healthy housing market that can genuinely accommodate projected household growth. An
undersupply of vacant units can prevent new households from forming or moving into a jurisdiction.
Formulaically, future vacancy need is a percentage applied to the jurisdiction's household growth by
tenure type (owner and renter households). While individual jurisdictions may experience different
vacancy rates at different points in time, future vacancy need is independent of existing conditions
and instead is a minimum need to support household growth.
To calculate a jurisdiction's future vacancy need, its proportion of owner-occupied units and renter-
occupied units are determined using American Community Survey (ACS) 2013-2017 data—the most
recent available at the time of the draft methodology's development.The percentages are applied to
the jurisdiction's projected household growth from the previous step, which results in the number of
projected households that are predicted to be owners and those that are predicted to be renters.
Next, two different vacancy rates are applied based on the regional determination provided by HCD.
The recommended methodology uses 1.5 percent for owner-occupied units and a rate of 5 percent
for renter-occupied units.The difference is due to the higher rates of turnover generally reported by
renter units in comparison to owner-occupied units.The vacancy rates are applied to their respective
tenure category to determine how many future vacant units are needed by tenure and then added
together to get the total future vacancy need.
Step 1c: Replacement Need
Residential units are demolished for a variety of reasons including natural disasters, fire, or desire to
construct entirely new residences. Each time a unit is demolished, a household is displaced and
disrupts the jurisdiction's pattern of projected household growth.The household may choose to live
in a vacant unit or leave the jurisdiction, of which both scenarios result in negative household growth
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RHNA Subcommittee Meeting-Feb.24,2020
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through the loss of a vacant unit for a new household or subtracting from the jurisdictions number
of households.
For these reasons, replacement need is a required component of the regional determination provided
by HCD. The methodology's replacement need will be calculated using a jurisdiction's net
replacement need based on data submitted for the replacement need survey, which was conducted
between March and April 2019.
Each jurisdiction's data on historical demolitions between reporting years 2008 and 2018, which was
collected from the California Department of Finance (DOF), was tabulated and provided to
jurisdictions in the replacement need survey. Jurisdictions were asked to provide data on units that
replaced the reported demolished units. A net replacement need was determined based on this
information for each jurisdiction.
After determining each of the projected housing need components,they are combined to determine
a jurisdiction's projected housing need.
Step 2: Determine Existing Housing Need
After determining a jurisdiction's projected need,the next step is to determine a jurisdiction's existing
need. Following the above discussion and based on HCD's determination of total regional housing
need,existing need is defined as the total need minus the projected need—approximately 62 percent
of the entire regional determination. SCAG's Regional Council determined that the regional existing
need be split into two parts:
• Fifty(50) percent on population near transit (HQTA), or 31 percent of total need
• Fifty(50) percent on job accessibility, or 31 percent of total need
Regional Existing Need
Jurisdiction Existing Need
Population
within HQTAs Transit
Accessibility
50%
Step 2a: Share of Regional HQTA Population
The next step involves the consideration of proximity to transit to distribute fifty (50) percent of the
region's existing housing need, in an effort to better align transportation and housing planning.
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RHNA Subcommittee Meeting-Feb.24,2020
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For several years, SCAG has developed a measure called High Quality Transit Areas (HQTAs) which
are areas within a half-mile of transit stations and corridors with at least a fifteen (15) minute
headway during peak hours for bus service. HQTAs are based on state statutory definitions of high-
quality transit corridors (HQTCs) and major transit stops. For the development of Connect SoCal,
freeway-running HQTCs have been excluded from HQTAs to better reflect the level of service they
provide to nearby areas.
Planned HQTCs and major transit stops for future years are improvements that are expected to be
implemented by transit agencies by the Connect SoCal horizon year of 2045. SCAG updates its
inventory with the quadrennial adoption of each RTP/SCS; however, planning and environmental
impact studies may be completed by transit agencies more frequently. Therefore, HQTAs in future
years reflect the best information currently available to SCAG regarding the location of future high-
quality transit service accessibility. More detailed information on HQTA-related definitions is
available in the data appendix.
50 percent of the regional existing housing need will be distributed based on a jurisdiction's share of
regional residential population within an HQTA, based on the HQTA boundaries used in the final
Connect SoCal Plan anticipated to be adopted by SCAG in April 2020. Not all jurisdictions have an
HQTA within their jurisdictional boundaries and thus may not receive existing need based on this
factor.
Step 2b: Job Accessibility
The concept behind job accessibility is to further the statewide housing objective and SCAG's Connect
SoCal objective of improving the relationship between jobs and housing. While none of the three
options presented in the proposed RHNA methodology included a factor directly based on job
accessibility, an overwhelming number of public comments expressed support for the methodology
to include this specific component.
The methodology assigns fifty (50) percent of regional existing need based on job accessibility. Job
accessibility is based on the share of the region's jobs accessible by a thirty (30) minute commute by
car in 2045. Importantly, the RHNA methodology's job access factor is not based on the number of
jobs within a jurisdiction from SCAG's Connect SoCal Plan or any other data source. Rather, it is a
measure based on of how many jobs can be accessed from that jurisdiction within a 30-minute
commute, which includes jobs in other jurisdictions. Since over 80 percent of SCAG region workers
live and work in different jurisdictions, genuinely improving the relationship between jobs and
housing necessitates an approach based on job access rather than the number of jobs in a jurisdiction.
These job accessibility data are derived at the transportation analysis zone (TAZ) level from travel
demand modelling output from SCAG's final Connect SoCal Plan. SCAG realizes that in many
jurisdictions, especially larger ones,job access many not be uniform in all parts of the city or county.
However, since the RHNA process requires allocating housing need at the jurisdictional-level, staff
reviewed several ways to measure the typical commuter's experience in each jurisdiction. Ultimately,
the share of the region's jobs that could be accessed by a jurisdiction's median TAZ was found to be
the best available measure of job accessibility for that jurisdiction. Based on this measure, in central
parts of the region, residents of some jurisdictions can access as much as 23 percent of the region's
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RHNA Subcommittee Meeting-Feb.24,2020
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jobs in a 30 minute car commute, while the average across all the region's jurisdictions was 10.5
percent.
This measure is multiplied by a jurisdiction's share of total population in order to allocate housing
unit need to jurisdictions. This important step ensures that the potential beneficiaries of greater
accessibility (i.e., the population in a jurisdiction with good job access) are captured in the
methodology. Based on this approach, jurisdictions with limited accessibility to jobs will receive a
smaller RHNA allocation based on this component.
Step 2c: "Residual" Adjustment Factor for Existing Need
In many jurisdictions defined as "disadvantaged communities (DACs)", the calculated projected and
existing need is higher than its household growth between 2020 and 2045, as determined by the
SCAG Growth Forecast used in the final Connect SoCal regional plan. Those DAC jurisdictions that
have a need as determined by the RHNA methodology as higher than its 2020 to 2045 household
growth3 will be considered as generating "residual" existing need. Residual need will be subtracted
from jurisdictional need in these cases so that the maximum a DAC jurisdiction will receive for existing
need is equivalent to its 2020 to 2045 household growth. Not all DAC jurisdictions will have a residual
existing need.
Extremely Disadvantaged County"residual" existing need
Communities: F.
City A calculated E City A
projected+existing need
alt.
"Residual"existing need1/7 +
Lit}/F
ViNeW F
T •.
City M-
�41dAli
Housing unit need b., city •
on 2020-2045 Conn
SoCal household growt
Cityr
3 Since HCD's regional determination of 1,341,827 exceeds SCAG's 2020-2045 household growth forecast of
1,297,000 by 3.68 percent,for the purposes of existing need allocation,exceeding"local input"or"Connect SoCal"
household growth shall mean exceeding 1.0368 times household growth.
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A social equity adjustment ensures that jurisdictions accommodate their fair share of each income
category. First, the percentage of each jurisdiction's distribution of four income categories is
determined using the county median income as a benchmark. For example, in Los Angeles County, a
household earning less than $30,552 annually, or 50 percent of the county median income, would
be considered a very low income household. A household in Los Angeles County earning more than
$73,218 annually, or 120 percent of the county median income, would be counted in the above
moderate category. The number of households in each category is summed and then a percentage
of each category is then calculated.
For reference, below is the median household income by county.
• Imperial County: $44,779
• Los Angeles County: $61,015
• Orange County: $81,851
• Riverside County: $60,807
• San Bernardino County: $57,156
• Ventura County: $81,972
• SCAG region: $64,114
Source:American Community Survey(ACS)2013-2017 5-year estimates
Once a jurisdiction's household income distribution by category is determined, the percentage is
compared to the county's percentage of existing household income distribution. For example, if a
jurisdiction has an existing distribution of 30 percent of very low income households while the county
is 25 percent, the jurisdiction is considered as having an overconcentration of very low income
households compared to the county. A social equity adjustment ensures that the jurisdiction will be
assigned a smaller percentage of very low income households for its RHNA allocation than both what
it and the county currently experience.
If the jurisdiction is assigned a social equity adjustment of 150 percent, the formula to calculate its
very low income percentage is:
Household Income Level Formula to Calculate City A Social Equity Adjustment of 150%
Very Low Income 30%-[(30%-25%)x1.5] = 22.5%
In this example, 22.5 percent of the jurisdiction's total RHNA allocation would be assigned to the very
low income category. This adjustment is lower than both its existing household income distribution
(30 percent) and the existing county distribution (25 percent).
The inverse occurs in higher income categories. Assuming 20 percent of a jurisdiction's households
are above moderate income while 25 percent of the county's households are above moderate
income, the jurisdiction will be assigned a distribution of 27.5 percent for above moderate income
need.
Household Income Level Formula to Calculate City A Social Equity Adjustment of 150%
Above moderate income 20%-[(20%-25%)x1.5] = 27.5%
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If the adjustment was 100 percent a jurisdiction's distribution would be exactly the same as the
County's distribution. Conceptually a 150 percent adjustment means that the City meets the County
distribution and goes beyond that threshold by 50 percent, resulting in a higher or lower distribution
than the County depending on what existing conditions are in the City. The higher the adjustment,
the more noticeable the difference between the jurisdiction's existing household income distribution
and its revised distribution.
The RHNA methodology recommends a minimum of 150 percent social equity adjustment with an
additional 10, 20, or 30 percent added depending on whether the jurisdiction is considered a very
low or very high resource area based on its Opportunity Index score.
In 2015 the U.S. Department of Housing and Urban Development (HUD) developed a set of
"Opportunity Indices" to help states and localities identify factors that contribute to fair housing
issues in their region and comply with the federal Fair Housing Act. In late 2017, a Task Force
convened by HCD and the California Tax Credit Allocation Committee (TCAC) released an
"Opportunity mapping"tool based on these HUD indices to identify areas in California that can "offer
low-income children and adults the best chance at economic advancement, high educational
attainment, and good physical and mental health."4
The TCAC and HCD Opportunity mapping tool includes a total of eleven (11)census-tract level indices
to measure exposure to opportunity in local communities. The indices are based on measures of
economic, environmental, and educational opportunities within communities. Regional patterns of
segregation are also identified based on this tool. Below is a summary table of the 11 indices sorted
by type:
Economic Environment Education
Poverty CalEnviroScreen 3.0 indicators Math proficiency
Adult education • Ozone Reading proficiency
Employment • PM2.5 High school graduation rates
Low-wage job proximity • Diesel PM Student poverty rate
Median home value • Drinking water
contaminates
• Pesticides
• Toxic releases from
facilities
• Traffic density
• Cleanup sites
• Groundwater threats
• Hazardous waste
• Impaired water bodies
• Solid waste sites
4 California Fair Housing Taskforce Revised opportunity Mapping Technology, Updated November 27,2018:
https://www.treasurer.ca.gov/ctcac/opportunity/final-opportu n ity-mappi ng-methodology.pdf
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Based on its respective access to opportunity, each census tract is given a score that designates it
under one of the following categories:
• High segregation & poverty
• Low resource
• Moderate resource
• High resource
• Highest resource
Tract-level indices were summed to the jurisdictional-level by SCAG using area-weighted
interpolation. Using 2013-2017 American Community Survey population data, SCAG determined the
share of each jurisdiction's population in each of these five categories. For example:
Lowest Resource Very High
Resource
Opportunity High Low resource Moderate High Highest
Indicator segregation & resource resource resource
Category poverty
City A 10% 10% 30% 30% 20%
Percentage of
population
City B 90% 5% 5% 0% 0%
Percentage of
population
City C 0% 0% 10% 15% 75%
Percentage of
population
The recommended methodology determines high resource concentration using the "very high"
resource area score. The recommended methodology determines "lowest" resource areas by
combining the two lowest measures. In the above table, City B would be considered to have a much
higher concentration of lower resource areas than City A. City C would be considered to have a much
higher concentration of highest resource areas. '
• High segregation & Poverty+ Low Resource = Lowest Resource
• Highest Resource
Jurisdictions that are identified as having between 70 and 100 percent of the population within a
lowest or very high resource area are assigned an additional 10 and 30 percent social equity
adjustment:
S As a cross-reference, if City B has both a high job and transit accessibility it would be exempt from the
redistribution of residual existing need from the RHNA methodology's Step 2d because more than 50 percent of its
population is within a very low resource area.On the other hand City A and City C,if they have a high job and
transit access,would not be exempt from receiving regional residual need because they have only 20 percent and
0 percent of their respective population within a very low resource area.
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Concentration of population within very low or Additional social equity adjustment
very high resource area
70-80% +10%
80-90% +20%
90-100% +30%
In the example table,City B would receive an additional social equity adjustment of 30%because 95%
of its population is within a lowest resource area (sum of high segregation&poverty and low resource
measures). City C would receive an additional social equity adjustment of 10% because 75% of its
population is within a very high resource area. City A would not receive a further adjustment because
it does not have a high enough concentration of population within either the lowest or very high
resource categories.
Assigning a higher social equity adjustment based on Opportunity Indices will result in a higher
percentage of affordable housing units to areas that have higher resources.Concurrently, it will assign
a lower percentage of affordable housing in areas where they is already an overconcentration.
Because Opportunity Indices consider factors such as access to lower wage jobs, poverty rates, and
school proficiency, the social equity adjustment in the RHNA methodology will result in factors
beyond simply household income distribution. This additional adjustment will help to adjust the
disparity in access to fair housing across the region, furthering the AFFH objective required in State
housing law.
Once the social equity adjustment is determined, it is used to assign need to the four income
categories.
Social equity adjustment Jurisdiction Total RHNA Allocation
� y a a3fb
V V A`d
Jurisdiction Total
P k"
‘,�,:'��' r � i Low
RHNA Allocation
Moderate
Additional AFFH%(0-30%) r Above moderate
Final Adjustments
On a regional level the final RHNA allocation plan must be the same as the regional determination,
by income category, provided by HCD. The final RHNA methodology will result in slight differences,
among income categories, since income categories are required to use county distributions as
benchmarks and the HCD determination does not include county-level benchmarks. For this reason,
after the initial income categories are determined for jurisdictions, SCAG will apply a normalization
adjustment to the RHNA allocation to ensure that the regional total by income category is
maintained.
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Additionally, in the event that a jurisdiction receives an allocation of zero (0) units under the RHNA
methodology a minimum RHNA allocation of eight (8) units would be assigned. Government Code
Section 65584.04(m)(2) requires that the final RHNA allocation plan ensure that each jurisdiction
receive an allocation of units for low-and very low income households. Under these circumstances,
SCAG will assign those jurisdictions a minimum of four(4) units in the very low income category and
four(4) units in the low income category for a draft RHNA allocation of eight (8) units.
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Meeting the Objectives of RHNA
Government Code Section 65584.04(a) requires that the RHNA methodology furthers the five
objectives of the Regional Housing Needs Assessment:
(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 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
pursuant to Section 65080.
(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 furthering fair housing.
(e) 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.
On January 13, 2020, HCD completed its review of SCAG's draft RHNA methodology and found that it
furthers the five statutory objectives of RHNA.
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Local Planning Factors
As part of the development of the proposed RHNA methodology, SCAG must conduct a survey of
planning factors that identify local conditions and explain how each of the listed factors are
incorporated into the RHNA methodology. This survey, also known as the "Local Planning Factor"
survey, is a specific requirement for the RHNA methodology process and is separate from the local
review process of the Growth Forecast used as the basis for determining future growth in the Connect
SoCal plan.
The survey was distributed to all SCAG jurisdictions in mid-March 2019 with a posted due date of May
30, 2019. One-hundred and nine (109)jurisdictions, or approximately 55%, submitted a response to
the local planning factor survey. To facilitate the conversation about local planning factors, between
October 2017 and October 2018 SCAG included these factors as part of the local input survey and
surveyed a binary yes/no as to whether these factors impacted jurisdictions. The formal local
planning factor survey was pre-populated with the pre-survey answers to help facilitate survey
response. The full packet of local planning factor surveys can be downloaded at
www.scag.ca.gov/rh na.
SCAG staff reviewed each of the submitted surveys to analyze planning factors opportunities and
constraints across the region. The collected information was used to ensure that the methodology
will equitably distribute housing need and that underlying challenges as a region are collectively
addressed.
(1)Each member jurisdiction's existing and projected jobs and housing relationship. This shall
include an estimate, based on readily available data, of 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 directly considers job accessibility and determines a portion of
housing need for each jurisdiction based on this factor. Using transportation analysis zones
as a basis, the percentage of jobs accessible within a 30 minute drive for a jurisdiction's
population is determined and then weighted based on the jurisdiction's population size to
determine individual shares of regional jobs accessible. Based on a review of other potential
mechanisms to factor in jobs into the RHNA methodology, SCAG staff has determined that
this mechanism most closely aligns with the goals of State housing law.
A supplemental analysis of the impact of the draft RHNA methodology's impact on jobs-
housing relationships and low-wage jobs-housing relationships was provided to the Regional
Council on February 5, 2020.
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(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.
(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(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.
(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.
(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.
Consideration of the above planning factors have been incorporated into the Growth
Forecast process and results by way of analysis of aerial land use data, general plan, parcel
level property data, open space, agricultural land and resource areas, and forecast surveys
distributed to local jurisdictions. The bottom-up Local Input and Envisioning Process, which
is used as the basis for both RHNA and SCAG's Connect SoCal (Regional Transportation
Plan/Sustainable Communities Strategy) started with an extensive outreach effort involving
all local jurisdictions regarding their land use and development constraints. All local
jurisdictions were invited to provide SCAG their respective growth perspective and input.
The RHNA methodology directly incorporates local input on projected household growth,
which should be a direct reflection of local planning factors such as lack of water or sewer
capacity, FEMA-designated flood sites, and open space and agricultural land protection.
Prior RHNA cycles did not promote direct linkage to transit proximity and the methodology
encourages more efficient land use patterns by utilizing existing as well as future planned
transportation infrastructure and preserves areas designated as open space and agricultural
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lands. In particular the inclusion of transit proximity places an increased emphasis on infill
opportunities and areas that are more likely to support higher residential densities.
(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 indicated above, the Growth Forecast used as the basis for the Connect SoCal Plan is also
used as the basis for projected household growth in the RHNA methodology.The weighting
of a jurisdiction's population share within an HQTA directly maximizes the use of public
transportation and 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
nonagricultural uses.
This planning factor has been identified through the local input process and local planning
factor survey collection as affecting growth within Ventura County.The urban growth
boundary, known as Save Our Agricultural Resources (SOAR), is an agreement between the
County of Ventura and its incorporated cities to direct growth toward incorporated areas,
and was recently extended to 2050. Based on the input collected, SCAG staff has concluded
that this factor is already reflected in the RHNA methodology since it was considered and
incorporated into the local input submitted by jurisdictions.
(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 conversion of low income units into non-low income units is not explicitly addressed
through the distribution of existing and projected housing need. Staff has provided statistics
in the RHNA methodology appendix on the potential loss of units in assisted housing
developments.The loss of such units affects the proportion of affordable housing needed
within a community and the region as a whole.
Local planning factor survey responses indicate that the impact of this factor is not
regionally uniform. Many jurisdictions that replied some units are at-risk for losing their
affordability status in the near future have indicated that they are currently reviewing and
developing local resources to address the potential loss. Based on this, SCAG staff has
determined that at-risk units are best addressed through providing data on these units as
part of the RHNA methodology and giving local jurisdictions the discretion to address this
factor and adequately plan for any at-risk unit loss in preparing their housing elements.
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(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.
An evaluation of survey responses reveals that cost-burdened households, or those who pay
at least 30 percent of their household income on housing costs, is a prevalent problem
throughout the region. The RHNA methodology also includes in its appendix data from the
ACS 2013-2017 on cost-burdened statistics for households who pay more than 30 percent of
their income on housing by owner and renter, and for renter households who pay 50
percent or more of their income on housing. The general trend is seen in both high and low
income communities, suggesting that in most of the SCAG region high housing costs are a
problem for all income levels.
Nonetheless a large number of jurisdictions indicated in the survey that overpaying for
housing costs disproportionately impacts lower income households in comparison to higher
income households.This issue is exacerbated in areas where there is not enough affordable
housing available, particularly in higher income areas. For this reason, the RHNA
methodology incorporates not only a 150 percent social equity adjustment, but also uses
the TCAC Opportunity Indices to distribute the RHNA allocation into the four income
categories in areas identified as being the highest resource areas of the region.The
Opportunity Indices include a proximity to jobs indicator, particularly for low-wage jobs,
which identifies areas with a high geographical mismatch between low wage jobs and
affordable housing. Increasing affordable housing supply in these areas can help alleviate
cost-burden experienced by local lower income households because more affordable
options will be available.
The reason for using social equity adjustment and opportunity indices to address cost-
burden households rather than assigning total need is because it is impossible to determine
through the methodology how and why the cost-burden is occurring in a particular
jurisdiction. Cost-burden is a symptom of housing need and not its cause. A jurisdiction
might permit a high number of units but still experiences cost-burden because other
jurisdictions restrict residential permitting. Or, a jurisdiction might have a large number of
owner-occupied housing units that command premium pricing, causing cost-burden for high
income households and especially on lower income households due to high rents from high
land costs. An analysis of existing need indicators by jurisdiction, which is part of the RHNA
methodology data appendix, does not reveal a single strong trend to base a distribution
methodology for cost-burden and thus the RHNA methodology distributes this existing need
indicator regionally using social equity adjustment and Opportunity Indices rather than to
where the indicators exist.
(7)The rate of overcrowding.
An evaluation of survey responses indicates that there is a variety of trends in overcrowding
throughout the region. Overcrowding is defined as more than 1.01 persons per room (not
bedroom) in a housing unit. Some jurisdictions have responded that overcrowding is a
severe issue, particularly for lower income and/or renter households, while others have
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responded that overcrowding is not an issue at all. At the regional determination level HCD
applied an overcrowding component, which is a new requirement for the 6th RHNA cycle.
Because
Similar to cost-burden, overcrowding is caused by an accumulated housing supply deficit
and is considered an indicator of existing housing need. The reason for not assigning need
directly based on this indicator is because it is impossible to determine through the
methodology how and why the overcrowding is occurring in a particular jurisdiction. A
jurisdiction that has an overcrowding rate higher than the regional average might be issuing
more residential permits than the regional average while the surrounding jurisdictions
might not have overcrowding issues but issue fewer permits than the regional average.An
analysis of existing need indicators by jurisdiction, which is part of the RHNA methodology
data appendix, does not reveal a single strong trend to base a distribution methodology for
overcrowding and thus the methodology distributes this existing need indicator regionally
rather than to where the indicators exist.
While not specifically surveyed, several jurisdictions have indicated that density has affected
their jurisdictions and have requested that the methodology should consider this as a factor.
While density is not directly addressed as a factor,the social equity adjustment indirectly
addresses density particularly for lower income jurisdictions. In housing elements,
jurisdictions most demonstrate that a site is affordable for lower income households by
applying a "default density", defined in State housing law as either 20 or 30 dwelling units
per acre depending on geography and population. In other words, a site that is zoned at 30
dwelling units per acre is automatically considered as meeting the zoning need for a low
income household.
However there is not a corresponding default density for above moderate income zoning.
Assigning a lower percentage of lower income households than existing conditions indirectly
reduces future density since the jurisdiction can zone at lower densities if it so chooses.
While this result does not apply to higher income jurisdictions, directing growth toward less
dense areas for the explicit purpose of reducing density is in direct contradiction to the
objectives of state housing law, especially for promoting infill development and
socioeconomic equity,the protection of environmental and agricultural resources,the
encouragement of efficient development pattern.
(8)The housing needs of farmworkers.
The RHNA methodology appendix provides data on agricultural jobs by jurisdiction as well
as workers by place of residence.The survey responses indicate that most jurisdictions do
not have agricultural land or only have small agricultural operations that do not necessarily
require designated farmworker housing. For the geographically concentrated areas that do
have farmworker housing, responses indicate that many jurisdictions already permit or are
working to allow farmworker housing by-right in the same manner as other agricultural uses
are allowed. Jurisdictions that are affected by the housing needs of farmworkers can be
assumed to have considered this local factor when submitting feedback on SCAG's Growth
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Forecast. A number of jurisdictions reiterated their approach in the local planning factor
survey response.
Similar to at-risk units,the RHNA methodology does not include a distribution mechanism to
distribute farmworker housing. However, SCAG has provided data in its RHNA methodology
appendix related to this factor and encourages local jurisdictions to adequately plan for this
need in their housing elements.
(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.
SCAG staff has prepared a map outlining the location of four-year private and public
universities in the SCAG region along with enrollment numbers from the California School
Campus Database (2018). Based on an evaluation of survey responses that indicated a
presence of a university within their boundaries, SCAG staff concludes that most housing
needs related to university enrollment are addressed and met by dormitories provided by
the institution both on-and off-campus. No jurisdiction expressed concern in the surveys
about student housing needs due to the presence of a university within their jurisdiction.
However, some jurisdictions have indicated outside of the survey that off-campus student
housing is an important issue within their jurisdictions and are in dialogue with HCD to
determine how this type of housing can be integrated into their local housing elements.
Because this circumstance applies to only a handful of jurisdictions, it is recommended that
housing needs generated by a public or private university be addressed in the jurisdiction's
housing element if it is applicable.
(1O)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.
Replacement need, defined as units that have been demolished but not yet replaced, are
included as a component of projected housing need in the RHNA methodology.To
determine this number, HCD reviewed historical demolition permit data between 2008 and
2017 (reporting years 2009 and 2018) as reported by the California Department of Finance
(DOE), and assigned SCAG a regional replacement need of 0.5%of projected and existing
need, or 34,010 units.
There have been several states of emergency declared for fires in the SCAG region that have
destroyed residential units, as indicated by several jurisdictions in their local planning factor
survey responses. Survey responses indicate that a total of 1,785 units have been lost
regionally from fires occurring after January 1, 2018. Units lost from fires that occurred prior
to January 1, 2018, have already been counted in the replacement need for the 6th RHNA
cycle.
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In spring 2019, SCAG conducted a replacement need survey with jurisdictions to determine
units that have been replaced on the site of demolished units reported. Region wide 23,545
of the region's demolished units still needed to be replaced based on survey results.The
sum of the number of units needing to be replaced based on the replacement need survey
and the number of units reported as lost due to recent states of emergency, or 25,330, is
lower than HCD's regional determination of replacement need of 34,010. One can
reasonably conclude that units lost based on this planning factor are already included in the
regional total and distributed, and thus an extra mechanism to distribute RHNA based on
this factor is not necessary to meet the loss of units.
(11)The region's greenhouse gas emissions targets provided by the State Air Resources Board
pursuant to Section 65080.
An assessment of survey responses indicate that a number of jurisdictions in the SCAG
region are developing efforts for more efficient land use patterns and zoning that would
result in greenhouse gas emissions.These include a mix of high-density housing types,
neighborhood based mixed-use zoning, climate action plans, and other local efforts to
reduce greenhouse gas emissions at the regional level.
The RHNA methodology includes a distribution of 50 percent of regional existing need based
on a jurisdiction's share of regional population within an HQTA.The linkage between
housing planning and transportation planning will allow for a better alignment between the
RHNA allocation plan and the Connect SoCal RTP/SCS. It will promote more efficient
development land use patterns, encourage transit use, and importantly reduce greenhouse
gas emissions. This will in turn support local efforts already underway to support the
reduction of regional greenhouse gas emissions.
Moreover the RHNA methodology includes the Growth Forecast reviewed with local input
as a distribution component, particularly for projected housing need. Local input is a basis
for SCAG's Connect SoCal Plan, which addresses greenhouse gas emissions at the regional
level since it is used to reach the State Air Resources Board regional targets. An analysis of
the consistency between the RHNA and Connect SoCal Plan is included as an attachment to
this document.
(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 planning factors were adopted by SCAG to review as a specific local planning
factor.
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Affirmatively Furthering Fair Housing(AFFH)
Among a number of changes due to recent RHNA legislation is the inclusion of affirmatively furthering
fair housing (AFFH) as both an addition to the listed State housing objectives of Government Section
65588 and to the requirements of RHNA methodology as listed in Government Code Section
65584.04(b) and (c), which includes surveying jurisdictions on AFFH issues and strategies and
developing a regional analysis of findings from the survey.
AFFH Survey
The AFFH survey accompanied the required local planning factor survey and was sent to all SCAG
jurisdictions in mid-March 2019 with a posted due date of May 30, 2019. Ninety (90) of SCAG's 197
jurisdictions completed the AFFH survey,though some jurisdictions indicated that they would not be
submitting the AFFH survey due to various reasons. The full packet of surveys submitted prior to the
development of the proposed methodology packet can be downloaded at www.scag.ca.gov/rhna.
Jurisdictions were asked various questions regarding fair housing issues,strategies and actions.These
questions included:
• Describe demographic trends and patterns in your jurisdiction over the past ten years. Do
any groups experience disproportionate housing needs?
• To what extent do the following factors impact your jurisdiction by contributing to
segregated housing patterns or racially or ethnically-concentrated areas of poverty?
• To what extent do the following acts as determinants for fair housing and compliance issues
in your jurisdiction?
• What are your public outreach strategies to reach disadvantaged communities?
• What steps has your jurisdiction undertaken to overcome historical patterns of segregation
or remove barriers to equal housing opportunity?
The survey questions were based on the U.S. Department of Housing and Urban Development(HUD)
Analysis of Impediments to Fair Housing Choice survey that each jurisdiction, or their designated local
Housing Authority, must submit to HUD to receive Community Development Block Grant (CDBG)
funds. For the AFFH survey,jurisdictions were encouraged to review their HUD-submitted surveys to
obtain data and information that would be useful for submitting the AFFH survey.
Pursuant to Government Code Section 65584.04(c),the following is an analysis of the survey results.
Themes
Several demographic themes emerged throughout the SCAG region based on submitted AFFH
surveys. A high number of jurisdictions indicated that their senior populations are increasing and
many indicated that the fixed income typically associated with senior populations might have an
effect on housing affordability. Other jurisdictions have experienced an increase in minority
populations, especially among Latino and Asian groups. There is also a trend of the loss of young
adults (typically younger than 30) and a decrease in the number of families with children in more
suburban locations due to the rise in housing costs.
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Barriers
There was a wide variety of barriers reported in the AFFH survey, though a number of jurisdictions
indicated they did not have any reportable barriers to fair access to housing. Throughout the SCAG
region, communities of all types reported that community opposition to all types of housing was an
impediment to housing development.Sometimes the opposition occurred in existing low income and
minority areas. Some jurisdictions indicated that high opportunity resource areas currently do not
have a lot of affordable housing or Section 8 voucher units while at the same time, these areas have
a fundamental misunderstanding of who affordable housing serves and what affordable housing
buildings actually look like. Based on these responses, it appears that community opposition to
housing, especially affordable housing and the associated stigma with affordable housing, is a
prevalent barrier throughout the SCAG region.
Other barriers to access to fair housing are caused by high land and development costs since they
contribute to very few affordable housing projects being proposed in higher opportunity areas. The
high cost of housing also limits access to fair housing and is a significant contributing factor to
disparities in access to opportunity. Increasing property values were reported across the region and
some jurisdictions indicated that they are occurring in existing affordable neighborhoods and can
contribute to gentrification and displacement. Additionally, during the economic downturn a large
number of Black and Latino homeowners were disproportionately impacted by predatory lending
practices and therefore entered foreclosure in higher numbers than other populations.
Other barriers reported in the AFFH survey include the lack of funding available to develop housing
after the dissolution of redevelopment agencies in 2012. Moreover, some jurisdictions indicated
that the lack of regional cooperation contributes to segregation.
Strategies to Overcome Barriers
All submitted AFFH surveys indicated that their respective jurisdictions employed at least a few
strategies to overcome barriers to access fair housing. These strategies ranged from local planning
and zoning tools to funding assistance to innovative outreach strategies.
In regard to planning and zoning tools, a number of jurisdictions indicated they have adopted
inclusionary zoning ordinances or an in-lieu fee to increase the number of affordable units within
their jurisdictions. Others have adopted an accessory dwelling unit (ADU) ordinance with
accommodating standards to allow for higher densities in existing single-family zone neighborhoods.
A few jurisdictions indicated that they have adopted an unpermitted dwelling unit (UDU) ordinance,
which legalizes unpermitted units instead of removing them provided that the units meet health and
safety codes. In addition to ADU and UDU ordinances, some jurisdictions have also adopted density
bonuses, which allow a project to exceed existing density standards if it meets certain affordability
requirements. Some responses in the survey indicate that the establishment of some of these tools
and standards have reduced community opposition to projects. In addition, some jurisdictions
responded that they have reduced review times for residential permit approvals and reduced or
waived fees associated with affordable housing development.
To combat gentrification and displacement, some jurisdictions have established rent-stabilization
ordinances while others have established a rent registry so that the jurisdiction can monitor rents
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and landlord practices. Some jurisdictions have adopted relocation plans and others are actively
seeking to extend affordability covenants for those that are expiring.
In regard to funding, SCAG jurisdictions provide a wide variety of support to increase the supply of
affordable housing and increase access to fair housing. A number of jurisdictions provide citywide
rental assistance programs for low income households and some indicated that their programs
include favorable home purchasing options. Some of these programs also encourage developers to
utilize the local first-time homebuyer assistance program to specifically qualify lower income
applicants.
Other jurisdictions indicate that they manage housing improvement programs to ensure that their
existing affordable housing stock is well maintained.Some AFFH surveys describe local multiple rental
assistance programs, including Section 8 Housing Choice vouchers and financial support of
tenant/landlord arbitration or mediation services.
Some jurisdictions indicated that they have focused on mobile homes as a way to increase access to
fair housing. There are programs described that assist households that live in dilapidated and unsafe
mobile homes in unpermitted mobile home parks by allowing the household to trade in their mobile
home in exchange for a new one in a permitted mobile park.Other programs include rental assistance
specifically for households who live in mobile homes.
In regard to community outreach,a large number of jurisdictions in the SCAG region have established
or are seeking to establish innovative partnerships to increase access to fair housing and reduce
existing barriers. Many jurisdictions work with fair housing advocacy groups such as the Housing
Rights Center, which provide community workshops, counseling, and tenant-landlord mediation
services. Other jurisdictions have established landlord-tenant commissions to resolve housing
disputes and provide services to individuals with limited resources.Some jurisdictions have partnered
with advocacy groups, such as the League of United Latin American Citizens (LULAC), to hold
community-based workshops featuring simultaneous multi-lingual translations. Other innovative
partnerships created by jurisdictions include those with local schools and school districts and public
health institutions to engage disadvantaged groups and provide services to areas with limited
resources.
A large number of jurisdictions have also indicated that they have increased their social media
presence to reach more communities. Others have also increased their multi-lingual outreach efforts
to ensure that limited-English proficiency populations have the opportunity to engage in local fair
housing efforts.
Based on the AFFH surveys submitted by jurisdictions, while there is a wide range of barriers to fair
housing opportunities in the SCAG region there is also a wide range of strategies to help overcome
these barriers at the local level.
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Meeting AFFH Objectives on a Regional Basis
To work towards the objective of AFFH, several benchmarks were reviewed as potential indicators of
increasing access to fair housing and removing barriers that led to historical segregation patterns.
Opportunity Indices
The objectives of affirmatively furthering fair housing are to not only overcome patterns of
segregation, but to also increase access to opportunity for historically marginalized groups,
particularly in racially and ethnically concentrated areas of poverty. In 2015 the U.S. Department of
Housing and Urban Development (HUD) developed a set of indices, known as "Opportunity Indices"
to help states and jurisdictions identify factors that contribute to fair housing issues in their region
and comply with the federal Fair Housing Act.
In 2015 the U.S. Department of Housing and Urban Development (HUD) developed a set of indices,
known as "Opportunity Indices"to help states and jurisdictions identify factors that contribute to fair
housing issues in their region and comply with the federal Fair Housing Act. In late 2017, a Task Force
convened by HCD and the California Tax Credit Allocation Committee (TCAC) released an
"Opportunity mapping"tool based on these HUD indices to identify areas in California that can "offer
low-income children and adults the best chance at economic advancement, high educational
attainment, and good physical and mental health."
The TCAC and HCD Opportunity mapping tool includes a total of eleven (11)census-tract level indices
to measure exposure to opportunity in local communities. Regional patterns of segregation can be
identified based on this tool.The indices are based on indicators such as poverty levels, low wage job
proximity, pollution, math and reading proficiency. Below is a summary table of the 11 indices sorted
by type:
Economic Environment Education
Poverty CalEnviroScreen 3.0 indicators Math proficiency
Adult education • Ozone Reading proficiency
Employment • PM2.5 High school graduation rates
Low-wage job proximity • Diesel PM Student poverty rate
Median home value • Drinking water
contaminates
• Pesticides
• Toxic releases from
facilities
• Traffic density
• Cleanup sites
• Groundwater threats
• Hazardous waste
• Impaired water bodies
• Solid waste sites
To further the objectives of AFFH, SCAG utilizes the Opportunity indices tool at multiple points in the
RHNA methodology. Jurisdictions that have the highest concentration of population in low resource
areas are exempted from receiving regional residual existing need, which will result in fewer units
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assigned to areas identified as having high rates of poverty and racial segregation. Additionally,
jurisdictions with the highest concentration of population within highest resource areas will receive
a higher social equity adjustment, which will result in more access to opportunity for lower income
households.
Public Engagement
The development of a comprehensive RHNA methodology requires comprehensive public
engagement. Government Code Section 65584.04(d) requires at least one public hearing to receive
oral and written comments on the proposed methodology, and also requires SCAG to distribute the
proposed methodology to all jurisdictions and requesting stakeholders, along with publishing the
proposed methodology on the SCAG website. The official public comment period on the proposed
RHNA methodology began on August 1, 2019 after Regional Council action and concluded on
September 13, 2019.
To maximize public engagement opportunities, SCAG staff hosted four public workshops to receive
verbal and written comment on the proposed RHNA methodology and an additional public
information session in August 2019:
• August 15, 6-8 p.m. Public Workshop, Los Angeles (View-only webcasting available)
• August 20, 1-3 p.m. Public Workshop, Los Angeles (Videoconference at SCAG regional offices
and View-only webcasting available)
• August 22, 1-3 p.m., Public Workshop, Irvine
• August 27, 6-8 p.m., Public Workshop, San Bernardino (View-only webcasting available)
• August 29, 1-3pm Public Information Session, Santa Clarita
Approximately 250 people attended the workshops in-person, at videoconference locations, or via
webcast. Over 35 individual verbal comments were shared over the four workshops.
To increase participation from individuals and stakeholders that are unable to participate during
regular working hours, two of the public workshops were be held in the evening hours. One of the
workshops was held in the Inland Empire. SCAG will worked with its Environmental Justice Working
Group (EJWG) and local stakeholder groups to reach out to their respective contacts in order to
maximize outreach to groups representing low income, minority, and other traditionally
disadvantaged populations.
Almost 250 written comments were submitted by the comment deadline and included a wide range
of stakeholders. Approximately 50 percent were from local jurisdictions and subregions, and the
other 50 percent were submitted by advocacy organizations, industry groups, residents and resident
groups,and the general public.All of the comments received, both verbal and written,were reviewed
by SCAG staff, and were used as the basis for developing the RHNA methodology.
The increased involvement by the number of jurisdictions and stakeholders beyond the municipal
level compared to prior RHNA cycles indicate an increased level of interest by the public in the
housing crisis and its solutions, and the efforts of SCAG to meet these interests. As part of its housing
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program initiatives, SCAG will continue to reach out to not only jurisdictions, but to advocacy groups
and traditionally disadvantaged communities that have not historically participated in the RHNA
process and regional housing planning. These efforts will be expanded beyond the RHNA program
and will be encompassed into addressing the housing crisis at the regional level and ensuring that
those at the local and community level can be part of solutions to the housing crisis.
Additional RHNA Methodology Supporting Materials
Please note that additional supporting materials for the RHNA Methodology have been posted on
SCAG's RHNA website at www.scag.ca.gov/rhna including Data Appendix, Local Planning Factor
Survey Responses and Affirmatively Furthering Fair Housing Survey Responses.
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ESTIMATE OF SCAG RHNA ALLOCATION BASED ON STAFF-RECOMMENDED FINAL RHNA METHODOLOGY
13-Feb-20
ALLOCATION BY COUNTY
Moderate Above moderate
Total Very-low income Low income income income
Imperial 15,953 4,652 2,349 2,192 6,760
Los Angeles 813,071 217,492 123,141 131,523 340,916
Orange 183,425 46,264 29,166 32,476 75,519
Riverside 167,191 41,922 26,443 29,146 69,681
San Bernardino 137,796 35,556 21,849 24,089 56,302
Ventura 24,398 5,751 3,799 4,516 10,332
TOTAL 1,341,834 351,637 206,747 223,941 559,509
ALLOCATION BY SUBREGION
Moderate Above moderate
Total Very-low income Low income income income
Arroyo Verdugo 22,143 5,974 3,572 3,650 8,947
CVAG 31,557 6,183 4,652 5,551 15,171
Gateway 74,423 20,805 10,776 11,221 31,621
Imperial 11,661 3,452 1,754 1,613 4,841
Las Virgenes Malibu 932 357 198 182 196
Los Angeles City 455,565 115,676 68,591 74,934 196,364
North LA County 27,428 7,837 4,127 4,278 11,185
OCCOG 173,050 43,136 27,305 30,442 72,167
SBCTA/SBCOG 128,972 33,381 20,491 22,566 52,534
SGVCOG 89,407 25,119 13,360 14,042 36,886
South Bay Cities 34,099 10,183 5,220 5,525 13,170
Unincorporated 155,364 42,801 24,347 25,907 62,309
Ventura 23,139 5,434 3,574 4,267 9,864
Westside Cities 19,225 5,957 3,635 3,538 6,095
WRCOG 94,869 25,342 15,144 16,224 38,159
ALLOCATION BY LOCAL JURISDICTION
Moderate Above moderate
County Subregion Total Very-low income Low income income income
Adelanto city San Bernardino SBCTA/SBCOG 3755 393 565 650 2148
Agoura Hills city Los Angeles Las Virgenes Malibu 318 126 72 55 65
Alhambra city Los Angeles SGVCOG 6810 1769 1033 1077 2931
Aliso Viejo city Orange OCCOG 1193 388 213 205 386
Anaheim city Orange OCCOG 17412 3757 2391 2939 8325
Apple Valley town San Bernardino SBCTA/SBCOG 4281 1082 599 745 1855
Arcadia city Los Angeles SGVCOG 3205 1098 568 604 935
Artesia city Los Angeles Gateway 1067 310 168 128 462
Avalon city Los Angeles Gateway 27 7 5 3 12
Azusa city Los Angeles SGVCOG 2644 757 366 381 1139
Baldwin Park city Los Angeles SGVCOG 1996 574 274 262 886
Banning city Riverside WRCOG 1669 315 192 279 882
Barstow city San Bernardino SBCTA/SBCOG 1516 171 227 299 819
Beaumont city Riverside WRCOG 4201 1225 719 722 1535
Bell city Los Angeles Gateway 228 42 23 29 134
Bell Gardens city Los Angeles Gateway 502 99 29 72 303
Bellflower city Los Angeles Gateway 3725 1011 486 552 1676
Beverly Hills city Los Angeles Westside Cities 3096 1005 678 600 813
Big Bear Lake city San Bernardino SBCTA/SBCOG 212 49 33 37 93
Blythe city Riverside CVAG 493 81 70 96 245
Bradbury city Los Angeles SGVCOG 40 15 8 9 8
Brawley city Imperial Imperial 1423 397 209 202 615
Brea city Orange OCCOG 2360 666 392 402 899
Buena Park city Orange OCCOG 8900 2113 1340 1570 3876
Burbank city Los Angeles Arroyo Verdugo 8752 2546 1415 1406 3386
Calabasas city Los Angeles Las Virgenes Malibu 353 131 70 70 82
Calexico city Imperial Imperial 4854 1274 653 612 2315
Calimesa city Riverside WRCOG 2012 493 274 378 867
Calipatria city Imperial Imperial 151 35 21 16 79
Camarillo city Ventura Ventura 1372 351 243 270 508
Canyon Lake city Riverside WRCOG 129 43 23 24 39
Carson city Los Angeles South Bay Cities 5606 1765 911 873 2057
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ESTIMATE OF SCAG RHNA ALLOCATION BASED ON STAFF-RECOMMENDED FINAL RHNA METHODOLOGY
Moderate Above moderate
County Subregion Total Very-low income Low income income income
Cathedral City city Riverside CVAG 2543 537 352 456 1197
Cerritos city Los Angeles Gateway 1902 676 344 331 551
Chino city San Bernardino SBCTA/SBCOG 6959 2106 1281 1200 2373
Chino Hills city San Bernardino SBCTA/SBCOG 3720 1384 819 787 731
Claremont city Los Angeles SGVCOG 1705 553 308 296 548
Coachella city Riverside CVAG 7875 1030 998 1366 4482
Colton city San Bernardino SBCTA/SBCOG 5418 1313 666 904 2536
Commerce city Los Angeles Gateway 246 54 22 38 132
Compton city Los Angeles Gateway 1001 234 120 130 517
Corona city Riverside WRCOG 6078 1748 1038 1094 2198
Costa Mesa city Orange OCCOG 11727 2910 1789 2083 4946
Covina city Los Angeles SGVCOG 1908 612 267 281 747
Cudahy city Los Angeles Gateway 393 79 36 53 224
Culver City city Los Angeles Westside Cities 3332 1104 602 558 1067
Cypress city Orange OCCOG 3924 1145 655 622 1502
Dana Point city Orange OCCOG 529 146 84 101 199
Desert Hot Springs city Riverside CVAG 3864 567 534 686 2077
Diamond Bar city Los Angeles SGVCOG 2514 841 432 435 805
Downey city Los Angeles Gateway 6504 2072 943 912 2578
Duarte city Los Angeles SGVCOG 873 263 142 135 333
Eastvale City Riverside WRCOG 3021 1141 671 634 576
El Centro city Imperial Imperial 3431 997 488 460 1485
El Monte city Los Angeles SGVCOG 8482 1791 851 1230 4610
El Segundo city Los Angeles South Bay Cities 491 188 88 83 132
Fillmore city Ventura Ventura 413 72 60 72 209
Fontana city San Bernardino SBCTA/SBCOG 17476 5095 2943 3029 6410
Fountain Valley city Orange OCCOG 4832 1304 785 833 1911
Fullerton city Orange OCCOG 13180 3189 1985 2267 5739
Garden Grove city Orange OCCOG 19124 4154 2795 3204 8970
Gardena city Los Angeles South Bay Cities 5719 1479 758 892 2589
Glendale city Los Angeles Arroyo Verdugo 13391 3429 2158 2244 5561
Glendora city Los Angeles SGVCOG 2271 732 385 387 766
Grand Terrace city San Bernardino SBCTA/SBCOG 628 187 91 106 243
Hawaiian Gardens city Los Angeles Gateway 330 60 43 46 181
Hawthorne city Los Angeles South Bay Cities 1731 443 204 249 835
Hemet city Riverside WRCOG 6451 809 730 1171 3741
Hermosa Beach city Los Angeles South Bay Cities 556 231 126 105 94
Hesperia city San Bernardino SBCTA/SBCOG 8135 1915 1228 1406 3587
Hidden Hills city Los Angeles Las Virgenes Malibu 41 16 8 9 7
Highland city San Bernardino SBCTA/SBCOG 2508 617 408 470 1013
Holtville city Imperial Imperial 171 40 33 26 73
Huntington Beach city Orange OCCOG 13337 3651 2179 2303 5204
Huntington Park city Los Angeles Gateway 1601 263 195 242 901
Imperial city Imperial Imperial 1598 702 345 294 258
Indian Wells city Riverside CVAG 381 116 80 91 94
Indio city Riverside CVAG 7793 1787 1167 1312 3527
Industry city Los Angeles SGVCOG 17 5 4 2 6
Inglewood city Los Angeles South Bay Cities 7422 1808 952 1110 3552
Irvine city Orange OCCOG 23555 6379 4225 4299 8652
Irwindale city Los Angeles SGVCOG 119 35 11 16 56
Jurupa Valley City Riverside WRCOG 4484 1203 747 729 1806
La Canada Flintridge city Los Angeles SGVCOG 611 251 135 139 87
La Habra city Orange OCCOG 803 191 116 130 367
La Habra Heights city Los Angeles Gateway 171 77 34 31 29
La Mirada city Los Angeles Gateway 1958 632 341 319 665
La Palma city Orange OCCOG 800 222 140 137 301
La Puente city Los Angeles SGVCOG 1928 543 275 275 836
La Quinta city Riverside CVAG 1526 419 268 296 544
La Verne city Los Angeles SGVCOG 1343 412 238 223 470
Laguna Beach city Orange OCCOG 393 117 80 79 118
Laguna Hills city Orange OCCOG 1979 565 352 353 709
Laguna Niguel city Orange OCCOG 1205 347 201 223 435
Laguna Woods city Orange OCCOG 992 125 135 191 541
Lake Elsinore city Riverside WRCOG 6666 1873 1097 1131 2566
Lake Forest city Orange OCCOG 3229 953 541 558 1177
Lakewood city Los Angeles Gateway 3915 1293 636 652 1335
Lancaster city Los Angeles North LA County 9004 2218 1192 1326 4269
Lawndale city Los Angeles South Bay Cities 2491 729 310 370 1082
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ESTIMATE OF SCAG RHNA ALLOCATION BASED ON STAFF-RECOMMENDED FINAL RHNA METHODOLOGY
Moderate Above moderate
County Subregion Total Very-low income Low income income income
Loma Linda city San Bernardino SBCTA/SBCOG 2052 522 311 353 866
Lomita city Los Angeles South Bay Cities 828 238 123 127 339
Long Beach city Los Angeles Gateway 26440 7122 4038 4149 11131
Los Alamitos city Orange OCCOG 767 192 118 145 312
Los Angeles city Los Angeles Los Angeles City 455565 115676 68591 74934 196364
Lynwood city Los Angeles Gateway 1555 375 138 235 807
Malibu city Los Angeles Las Virgenes Malibu 78 27 18 17 17
Manhattan Beach city Los Angeles South Bay Cities 773 321 164 155 133
Maywood city Los Angeles Gateway 364 54 47 55 209
Menifee city Riverside WRCOG 6593 1755 1049 1103 2686
Mission Viejo city Orange OCCOG 2211 671 400 396 744
Monrovia city Los Angeles SGVCOG 1670 518 262 254 636
Montclair city San Bernardino SBCTA/SBCOG 2589 696 382 399 1112
Montebello city Los Angeles SGVCOG 5171 1309 705 774 2383
Monterey Park city Los Angeles SGVCOG 5246 1320 820 846 2260
Moorpark city Ventura Ventura 1287 376 233 245 434
Moreno Valley city Riverside WRCOG 13595 3768 2046 2161 5620
Murrieta city Riverside WRCOG 3035 1005 581 543 905
Needles city San Bernardino SBCTA/SBCOG 86 9 10 16 51
Newport Beach city Orange OCCOG 4832 1451 927 1048 1406
Norco city Riverside WRCOG 453 144 84 81 143
Norwalk city Los Angeles Gateway 5024 1542 757 657 2068
Ojai city Ventura Ventura 52 12 8 10 22
Ontario city San Bernardino SBCTA/SBCOG 20803 5624 3279 3322 8579
Orange city Orange OCCOG 3927 1064 603 676 1585
Oxnard city Ventura Ventura 8529 1834 1068 1535 4092
Palm Desert city Riverside CVAG 2785 673 459 460 1193
Palm Springs city Riverside CVAG 2554 543 407 461 1142
Palmdale city Los Angeles North LA County 6625 1772 933 1001 2919
Palos Verdes Estates city Los Angeles South Bay Cities 198 81 44 47 26
Paramount city Los Angeles Gateway 363 90 43 48 182
Pasadena city Los Angeles SGVCOG 9409 2739 1659 1562 3449
Perris city Riverside WRCOG 7786 2024 1124 1271 3367
Pico Rivera city Los Angeles Gateway 3939 1148 562 572 1657
Placentia city Orange OCCOG 4363 1226 678 768 1690
Pomona city Los Angeles SGVCOG 10532 2791 1336 1506 4899
Port Hueneme city Ventura Ventura 125 25 15 18 66
Rancho Cucamonga city San Bernardino SBCTA/SBCOG 10500 3236 1916 2033 3315
Rancho Mirage city Riverside CVAG 1743 429 317 328 670
Rancho Palos Verdes city Los Angeles South Bay Cities 637 251 138 125 122
Rancho Santa Margarita city Orange OCCOG 679 208 120 125 227
Redlands city San Bernardino SBCTA/SBCOG 3507 963 614 650 1280
Redondo Beach city Los Angeles South Bay Cities 2483 932 507 489 555
Rialto city San Bernardino SBCTA/SBCOG 8252 2211 1203 1368 3470
Riverside city Riverside WRCOG 18419 4849 3057 3133 7379
Rolling Hills city Los Angeles South Bay Cities 44 19 9 11 6
Rolling Hills Estates city Los Angeles South Bay Cities 191 81 42 38 30
Rosemead city Los Angeles SGVCOG 4604 1151 636 685 2131
San Bernardino city San Bernardino SBCTA/SBCOG 8104 1411 1094 1445 4154
San Buenaventura(Ventura)city Ventura Ventura 5302 1184 863 948 2307
San Clemente city Orange OCCOG 975 279 162 186 347
San Dimas city Los Angeles SGVCOG 1245 382 219 206 438
San Fernando city Los Angeles North LA County 1790 459 272 283 776
San Gabriel city Los Angeles SGVCOG 3017 843 414 465 1295
San Jacinto city Riverside WRCOG 3385 797 464 559 1565
San Juan Capistrano city Orange OCCOG 1052 268 172 183 428
San Marina city Los Angeles SGVCOG 398 149 91 91 68
Santa Ana city Orange OCCOG 3087 583 360 522 1621
Santa Clarita city Los Angeles North LA County 10009 3388 1730 1668 3222
Santa Fe Springs city Los Angeles Gateway 950 252 158 152 388
Santa Monica city Los Angeles Westside Cities 8874 2786 1668 1698 2721
Santa Paula city Ventura Ventura 655 101 98 121 335
Seal Beach city Orange OCCOG 1240 256 200 238 545
Sierra Madre city Los Angeles SGVCOG 204 78 38 34 53
Signal Hill city Los Angeles Gateway 516 159 78 90 189
Simi Valley city Ventura Ventura 2788 746 492 517 1032
South El Monte city Los Angeles SGVCOG 576 130 63 70 313
South Gate city Los Angeles Gateway 8263 2130 991 1171 3971
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ESTIMATE OF SCAG RHNA ALLOCATION BASED ON STAFF-RECOMMENDED FINAL RHNA METHODOLOGY
Moderate Above moderate
County Subregion Total Very-low income Low income income income
South Pasadena city Los Angeles SGVCOG 2061 754 397 333 578
Stanton city Orange OCCOG 1228 164 144 231 690
Temecula city Riverside WRCOG 4183 1355 799 777 1253
Temple City city Los Angeles SGVCOG 2183 628 349 369 837
Thousand Oaks city Ventura Ventura 2616 733 493 531 860
Torrance city Los Angeles South Bay Cities 4929 1617 844 851. 1617
Tustin city Orange OCCOG 6777 1722 1045 1131 2879
Twentynine Palms city San Bernardino SBCTA/SBCOG 1044 229 126 184 504
Unincorporated Imperial Co. Imperial Unincorporated 4292 1200 595 579 1919
Unincorporated Los Angeles Co. Los Angeles Unincorporated 89849 25583 13662 14152 36452
Unincorporated Orange Co. Orange Unincorporated 10375 3128 1861 2034 3352
Unincorporated Riverside Co. Riverside Unincorporated 40765 10398 6647 7370 16350
Unincorporated San Bernardino Co. San Bernardino Unincorporated 8824 2176 1358 1522 3768
Unincorporated Ventura Co. Ventura Unincorporated 1259 317 225 249 468
Upland city San Bernardino SBCTA/SBCOG 5673 1579 956 1011 2127
Vernon city Los Angeles Gateway 8 4 4 0 0
Victorville city San Bernardino SBCTA/SBCOG 8146 1730 1133 1500 3782
Villa Park city Orange OCCOG 295 92 59 61 83
Walnut city Los Angeles SGVCOG 1292 426 224 231 411
West Covina city Los Angeles SGVCOG 5333 1648 847 863 1974
West Hollywood city Los Angeles Westside Cities 3923 1062 687 681 1493
Westlake Village city Los Angeles Las Virgenes Malibu 142 57 29 32 24
Westminster city Orange OCCOG 9733 1874 1469 1780 4610
Westmorland city Imperial Imperial 33 7 5 4 17
Whittier city Los Angeles Gateway 3431 1022 535 555 1319
Wildomar city Riverside WRCOG 2709 795 449 433 1032
Yorba Linda city Orange OCCOG 2410 762 449 456 742
Yucaipa city San Bernardino SBCTA/SBCOG 2859 705 492 509 1153
Yucca Valley town San Bernardino SBCTA/SBCOG 749 154 116 145 334
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RHNA Timeline of Key Activities and Milestones
October 2018-January 2020
Date Type Milestone
10/29/18 Meeting RHNA Subcommittee Meeting#1: Kickoff
12/3/18 Meeting RHNA Subcommittee Meeting#2:Action-Subcommittee charter
2/4/19 Meeting RHNA Subcommittee Meeting#3:Action-subregional delegation guidelines
2/7/19 Meeting Regional Council and CEHD Meeting:Action-RHNA Subcommittee charter
3/4/19 Meeting RHNA Subcommittee Meeting#4:Action-release of methodology surveys, discussion on RHNA methodology
3/7/19 Meeting CEHD Meeting:Action-Subregional delegation guidelines
3/27/19 Panel Convened Panel of Experts on technical issues related to regional determination
4/1/19 Meeting RHNA Subcommittee Meeting#5: Discussion on RHNA methodology
4/4/19 Meeting Regional Council Meeting:Action-Subregional delegation guidelines
5/6/19 Meeting RHNA Subcommittee Meeting#6:Action-regional determination package, discussion on RHNA methodology
6/3/19 Meeting RHNA Subcommittee Meeting#7:Action-amended regional determination package, discussion on RHNA methodology
6/6/19 Meeting CEHD and Regional Council Meeting:Action—submission of regional consultation package to HCD
6/20/19 Submission Submission of regional consultation package to HCD
7/22/19 Meeting RHNA Subcommittee Meeting#8:Action-release of proposed methodology options for public review
7/29/19 Webinar RHNA 101 Webinar
8/1/19 Meeting Release of Proposed Methodology for Public Comment (CEHD and Regional Council Action)
8/1/19- Public comment Public comment period on proposed RHNA methodology
9/1/319 period
8/15/19 Hearing Proposed Methodology Public Hearing#1, SCAG Los Angeles Office
8/20/19 Hearing Proposed Methodology Public Hearing#2, SCAG Los Angeles Office
8/22/19 Correspondence Receipt of regional determination from HCD
8/22/19 Hearing Proposed Methodology Public Hearing#3, Irvine City Hall
8/22/19 Hearing Proposed Methodology Public Hearing#4, SBCTA Board Room
8/29/19 Workshop Proposed Methodology Public Information Session,Santa Clarita
9/5/19 Meeting CEHD and Regional Council Meeting:Action-Objection to regional determination from HCD
9/13/19 Due date Comment deadline for proposed methodology
9/18/19 Submission Submission of objection letter of regional determination to HCD
9/25/19 Workshop Preview workshop of staff recommended draft RHNA methodology
RHNA Subcommittee Meeting-Feb.24,2020
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10/7/19 Meeting RHNA Subcommittee Meeting#9:Action-recommendation of draft RHNA methodology
Mayor Bailey's Substitute Motion failed in a 4-3 votes
10/15/19 Correspondence Receipt of final regional determination from HCD
10/17/19 Meeting Briefing on technical issues related to staff recommended draft RHNA methodology as part of the Technical Working
Group meeting
10/21/19 Meeting CEHD Special Meeting:Action-recommendation of draft RHNA methodology(unanimous)
10/21/19 Correspondence Commenter letter from SBCTA objecting to staff-recommended draft RHNA methodology due to inequitable regional
distribution
10/22/19 Correspondence Received e-mail from Mayor Sahli-Wells requesting staff presentation of Mayor Bailey's Alternative RHNA Methodology
for the November 7, 2019 Regional Council meeting
11/1/19 Correspondence Received letter jointly signed by Mayor Bailey, Supervisor Spiegel, Mayor Navarro & EEC Member Toni Momberger
recommending an Alternative RHNA Methodology for the November 7, 2019 Regional Council meeting
11/2/19 Staff Report Staff Report posted including analysis of Alternative Methodology
11/5/19 Correspondence Commenter letter from Mayor of Los Angeles objecting to staff-recommended draft RHNA methodology including
recommendations with some overlap with Bailey's Alternative Methodology
11/5/19 Correspondence E-mail from Kome to RC members including the letter from Mayor Bailey&the Estimator(calculator)for Alternative
Methodology,enabling side-by-side comparison of jurisdictions' estimated RHNA allocations under either scenario.
11/6/19 Staff Memo SCAG staff's initial response provided to City of Los Angeles on its Recommended Changes to RHNA methodology
11/7/19 Meeting Regional Council Meeting:Action-Approval of Bailey's Alternative Methodology by a 43-19 votes;approved
methodology submittal to HCD for review
11/14/19 Submission Submission of draft RHNA methodology to HCD as approved by Regional Council
1/13/20 Correspondence Receipt of HCD's review of SCAG's draft RHNA methodology, which is found to further the five statutory objectives of
RHNA
RHNA Subcommittee Meeting-Feb.24,2020
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611111 AGENDA ITEM 2
REPORT
Southern California Association of Governments
900 Wilshire Boulevard, Suite 1700, Los Angeles, California 90017
February 24, 2020
To: Regional Housing Needs Assessment Subcommittee (RHNA) EXECUTIVE DIRECTOR'S
APPROVAL
From: Kome Ajise, Executive Director, Executive Management, * .�
213-236-1835, Ajise@scag.ca.gov
Subject: 6th Cycle RHNA Appeals Procedures
RECOMMENDED ACTION:
Recommend that the Community, Economic and Human Development (CEHD) Committee
recommend Regional Council approval of the 6th Cycle RHNA Appeals Procedures.
STRATEGIC PLAN:
This item supports the following Strategic Plan Goal 2: Advance Southern California's policy
interests and planning priorities through regional, statewide, and national engagement and
advocacy.
EXECUTIVE SUMMARY:
Per Government Code Section 65584.05(6) within forty-five (45) days of receipt of the draft RHNA
allocation, local jurisdictions and the California Department of Housing and Community
Development (HCD) may appeal any jurisdiction's draft RHNA allocation. SCAG staff has
developed 6th Cycle RHNA Appeals Procedures that outline the appeals process, and includes
information on bases for appeals, the public hearings to hear appeals, and the reallocation of
successful appeals.
BACKGROUND:
Subsequent to the adoption of the final RHNA methodology, SCAG will release a draft RHNA
allocation plan. Per Government Code Section 65584.05(b), within 45 days of receipt of the draft
RHNA allocation, local jurisdictions and the California Department of Housing and Community
Development (HCD) may appeal any jurisdiction's draft RHNA allocation. The distribution of a draft
RHNA allocation is dependent on the adoption of a final RHNA methodology. Assuming that the
final RHNA methodology is adopted on March 5, 2020 by the Regional Council and a draft RHNA
allocation receipt date of Friday, April 10, 2020, the 45-day filing period will end on Monday, May
25, 2020.
OM MISSION OUR VISION
To foster innovative regional soIutlaas that Improve Southern California's Catalyst faro Brighter Future
the Ines of SWthwn Californians through inclusive
collaboration,visionary planning,regional advocacy, OUR CORE VALUES
Information sharing,and promoting ben practices. Be Open I Lead by Dimple I Malar an Impact I Be Courageous
RHNA Subcommittee Meeting-Feb.24,2020
Page 65 of 139
joCa
REPORT
Appeals may be filed on any draft RHNA allocation within the SCAG region by any SCAG jurisdiction
and HCD. Per Government Code Section 65584.05(b), an appeal may only be filed on at least one of
the following bases:
• Local planning factors and information relating to affirmatively furthering fair housing;
• Application of adopted final methodology
• Significant and Unforeseen change in circumstances
Regarding a "significant and unforeseen change in circumstances," Government Code Section
65584.05(b)(3) requires it is based on a local planning factor as described in Government Code
Section 65584.04(b) and by extension, subsection (e). This would require that any qualifying change
in circumstances would need to have occurred after SCAG's methodology survey packet was
distributed in Spring 2019. Additionally, an appeal based on a change in circumstances may only be
filed by a jurisdiction appealing its own draft RHNA allocation.
Additionally, in accordance with State housing law, an appeal cannot be granted based on the
following factors:
• A local jurisdiction's existing zoning ordinance and land use restrictions
• Any local ordinance, policy, voter-approved measure or standard limiting residential
development.
• Prior underproduction of housing in a jurisdiction from the previous regional housing need
allocation.
• Stable population numbers in a jurisdiction.
More detailed descriptions of these exclusions for appeals is included in Section I.D of the attached
6th Cycle RHNA Appeals Procedures, which is attached to this report.
Applicants of an appeal must complete an appeals form (Exhibit A) that will be available on the
SCAG RHNA webpage (www.scag.ca.gov/rhna) after the appeals procedures are adopted by the
Regional Council. Directions on how to electronically submit the form and supporting
documentation will be provided on the final form and on the RHNA webpage.
Following the conclusion of the filing period, all jurisdictions will be notified by SCAG of all appeals
filed and related attachments will be posted on SCAG's website. Per Government Code Section
65584.05(c) Jurisdictions and HCD will have 45 days, or until June 9, 2020 (assuming that the draft
RHNA allocation will be available in early April), to comment on filed appeals.
Within 30 days of the end of the appeal comment period, SCAG must conduct public hearings to
hear all filed appeals. The hearing body will be the RHNA Subcommittee, also known at this point as
the RHNA Appeals Board. The RHNA Appeals Board will be subject to the RHNA Subcommittee
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REPORT
amiNgt
Charter, hich was adopted by the SCAG Regional Council at their February 7, 2019 meeting. All
decisions made by the Appeals Board will be considered final and not reviewed by the CEHD
Committee or Regional Council.
Public notice of hearings will be posted within 21 days of the scheduled public hearings. Because it
is unknown at this time how many appeals will be filed, SCAG staff is currently unable to set the
date of the hearings. However, the public hearings will most likely take place during the latter half
of July 2020 assuming that the draft RHNA allocation will be available in early April.
The appeals hearings will be organized by each jurisdiction subject to an appeal. Appeal applicants
that have filed an appeal will be allotted time during the public hearing to present their argument
for an adjustment to the jurisdiction's draft RHNA allocation. Jurisdictions that are the subject of an
appeal but did not file an appeal on their own draft RHNA allocation will also be allotted time to
present. SCAG staff will provide a recommendation and staff report for each subject jurisdiction,
after which applicants and the subject jurisdiction which did not file an appeal but is the subject of
an appeal (if applicable) may present a brief rebuttal. The RHNA Appeals Board is encouraged to
make one finding on the subject jurisdiction after hearing all arguments and presentations on each
subject jurisdiction. A full description of the public hearing procedures, including time allotments,
are including in the 6th Cycle RHNA Appeals Procedures,which is an attachment to this report.
All successful appeals, except in determined cases as outlined in the Appeals Procedures Section H,
will be reallocated back to all jurisdictions in the SCAG region, including those who had successful
appeals. A full description of the methodology for successful appeal redistribution is described in
the 6th Cycle RHNA Appeals Procedures.
The results of the appeals process and its subsequent reallocation will be included in the proposed
final RHNA Allocation Plan, which will be reviewed by the RHNA Subcommittee, CEHD Committee,
and Regional Council between August and September 2020. The final RHNA Allocation Plan is
scheduled for adoption on October 1, 2020 by the Regional Council.
Differences between the 5th and 6th Cycles Appeals Procedures
There are several noticeable differences between the 5th and proposed 6th Cycle RHNA Appeals
Procedures. First, for the 6th Cycle any jurisdiction and HCD may file an appeal on any jurisdiction
whereas in the 5th cycle only a jurisdiction could file an appeal on its own draft RHNA allocation.
Additionally, there were two separate processes in which a jurisdiction could request a reduction to
its draft RHNA allocation —a revision request and an appeal. However, due to recent legislation the
process has been streamlined into one appeals process.
Moreover in prior RHNA cycles, an appeal could not be based on local ordinances or voter-approved
measures that limited the number of residential permits issued. For the 6th cycle, in addition to
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REPORT
these types of local ordinances, also excluded from appeals are underproduction of housing units
since the last RHNA cycle and stable population growth.
Next Steps
A draft of the proposed 6th Cycle RHNA Appeals Procedures was presented at a public workshop on
February 3, 2020. The purpose of the workshop was to provide the public a preview of SCAG staff
proposals on the procedures and solicit comments until February 10, 2020. A number of
jurisdictions provided written comments on the procedures, several of which have been directly
incorporated into the procedures and attachments. Written comments received on the draft 6th
Cycle RHNA Appeals Procedures can found posted on the RHNA webpage.
Pending action of the RHNA Subcommittee, SCAG staff will forward its recommendation to the
CEHD Committee for further recommendation of adoption by the Regional Council. Both the CEHD
Committee and Regional Council meetings are scheduled for March 5, 2020. Following Regional
Council adoption, SCAG will post the procedures along with a final appeal application form and
directions for filing an appeal on the SCAG RHNA webpage. Key dates of the appeals process will be
finalized after the adoption of the final RHNA methodology.
FISCAL IMPACT:
Work associated with this item is included in the current FY 19-20 General Fund Budget
(800.0160.03: RHNA).
ATTACHMENT(S):
1. 6th Cycle RHNA Appeals Procedures
2. Exhibit A Appeal Request Form
3. Exhibit C-GOV_65080.
4. Exhibit C-GOV_65584.
5. Exhibit C- GOV_65584.04
6. Exhibit C-GOV_65584.05
7. RHNA Subcommittee Charter
8. RHNA Appeals 022420
RHNA Subcommittee Meeting-Feb.24,2020
Page 68 of 139
6th Cycle RHNA Appeals Procedures
Pursuant to Government Code section 65584.05, any local jurisdiction within the SCAG
region may file an appeal to modify its allocated share or another jurisdiction's share of
the regional housing need included as part of SCAG's Draft Regional Housing Needs
Assessment (RHNA) Allocation Plan, hereinafter referred to as the "Draft RHNA Plan."
The California Department of Housing and Community Development, hereinafter
referred to as "HCD", may also file an appeal to one or more jurisdiction's draft RHNA
allocation. No appeal shall be allowed relating to post-appeal reallocation adjustments
made by SCAG, as further described in Section II, below.
I. APPEALS PROCESS
A. DEADLINE TO FILE
The period to file appeals shall commence on April 10, 2020', which shall be deemed as
the date of receipt by jurisdictions and HCD of the draft RHNA Plan. In order to comply
with Government Code § 65584.05(b), a jurisdiction or HCD seeking to appeal a draft
allocation of the regional housing need must file an appeal by 5:00 p.m. May 25, 20202.
Late appeals shall not be accepted by SCAG.
B. FORM OF APPEAL
The local jurisdiction shall state the basis and specific reasons for its appeal on the
appeal form prepared by SCAG, a copy of which is attached hereto as Exhibit "A".
Additional documents may be submitted by the local jurisdiction as attachments, and all
such attachments should be properly labeled and numbered.
C. BASES FOR APPEAL
Local jurisdictions shall only file an appeal based upon the criteria listed below. In order
to provide guidance to potential appellants, information regarding SCAG's allocation
methodology approved by SCAG's Regional Council on March 5, 20203, and application
of local factors in the development of SCAG's adopted Final Methodology is attached
hereto as Exhibit "B". Appeals based on "change in circumstances" can only be filed by
the jurisdiction or jurisdictions where the change in circumstances occurred.
1 This date assumes that the draft RHNA allocation will be available in early April 2020. Dates
related to the appeal process will be finalized after the adoption of the Final RHNA Methodology.
2 This date assumes that the draft RHNA allocation will be available in early April 2020. Dates
related to the appeal process will be finalized after the adoption of the Final RHNA Methodology.
3 This date is the scheduled date for adoption of the Final RHNA Methodology by the SCAG
Regional Council. In the event of a date change, this section will be amended.
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Pursuant to Government Code Section 65584.05, filed appeals must include a statement
as to why the revision is necessary to further the intent of the objectives listed in
Section 65584. Additionally, Government Code Section 65584.05(b) requires that all
filed appeals must be consistent with, and not to the detriment of, the development
pattern in the sustainable communities strategy, or SCAG's Connect SoCal Plan,
pursuant to Government Code Section 65080(b)(2).
1. Methodology — That SCAG failed to determine the jurisdiction's
share of the regional housing need in accordance with the
information described in the allocation methodology established
and approved by SCAG, and in a manner that furthers, and does
not undermine the five objectives listed in Government Code
Section 65584(d).
2. Local Planning Factors and Information Affirmatively Furthering
Fair Housing (AFFH) — That SCAG failed to consider information
submitted by the local jurisdiction relating to certain local factors
outlined in Govt. Code § 65584.04(e) and information submitted
by the local jurisdiction relating to affirmatively furthering fair
housing pursuant to Government Code § 65584.04(b)(2) and
65584(d)(5) including the following:
a. Each jurisdiction's existing and projected jobs and housing
relationship.
b. The opportunities and constraints to development of
additional housing in each jurisdiction, including the
following:
(1) 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;
(2) 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;
(3) Lands preserved or protected from urban
development under existing federal or state
programs, or both, designed to protect open space,
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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.
(4) County policies to preserve prime agricultural land,
as defined pursuant to Government Code § 56064,
within an unincorporated area, 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.
c. 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.
d. Agreements between a county and cities in a county to
direct growth toward incorporated areas of the county 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 nonagricultural uses.
e. The loss of units contained in assisted housing
developments, as defined in Government Code §
65583(a)(9), that changed to non-low-income use through
mortgage prepayment, subsidy contract expirations, or
termination of use restrictions.
f. 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.
g. The rate of overcrowding.
h. The housing needs of farmworkers.
i. The housing needs generated by the presence of a private
university or a campus of the California State University or
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the University of California within any member
jurisdiction.
j. 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. For purposes of these
guidelines, this applies to loss of units during a state of
emergency occurring since October 2013 and have not yet
been rebuilt or replaced by the time of the development
of the draft RHNA methodology, or November 7, 2019.
k. The region's greenhouse gas emissions targets provided by
the State Air Resources Board pursuant to Section 65080,
to be met by SCAG's Connect SoCal Plan.
I. Information based upon the issues, strategies, and actions
that are included, as available in an Analysis of
Impediments to Fair Housing Choice or an Assessment of
Fair Housing completed by any city or county or the
California Department of Housing and Community
Development, and in housing elements
3. Changed Circumstances—That a significant and unforeseen
change in circumstances has occurred in the jurisdiction after
April 30, 2019 and merits a revision of the information previously
submitted by the local jurisdiction. Appeals on this basis shall
only be made by the jurisdiction or jurisdictions where the change
in circumstances has occurred.
D. LIMITS ON SCOPE OF APPEAL
Existing law explicitly limits SCAG's scope of review of appeals. Specifically, SCAG shall
not grant any appeal based upon the following:
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1. Any other criteria other than the criteria in Section I.0 above.
2. A local jurisdiction's existing zoning ordinance and land use
restrictions, including but not limited to, the contents of the local
jurisdiction's current general plan. Pursuant to Government Code
Section 65584.04(e)(2)(B), SCAG 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.
3. Any local ordinance, policy, voter-approved measure or standard
limiting residential development. Pursuant to Government Code
Section 65584.04(g)(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 shall not be a
justification for a determination or a reduction in a city's or
county's share of regional housing need.
4. Prior underproduction of housing in a jurisdiction from the
previous regional housing need allocation. Pursuant to
Government Code Section 65584.04)(g)(2), prior underproduction
of housing in a jurisdiction from the previous housing need
allocation, as determined by each jurisdiction's annual production
report submitted to Government Code Section 65400(a)(2)(H)
cannot be used as a justification for a determination or reduction
in a jurisdiction's share of the regional housing need.
5. Stable population numbers in a jurisdiction. Pursuant to
Government Code Section 65584.04(g)(3), stable population
growth from the previous regional housing needs cycle cannot be
used as a justification for a determination or reduction in a
jurisdiction's share of the regional housing need.
E. COMMENTS ON APPEALS
At the close of the appeals period as set forth in I.A., SCAG shall notify all jurisdictions
within the region and HCD of all appeals and shall make all materials submitted in
support of each appeal available on its website after the close of the appeals filing
period. Local jurisdictions and HCD may comment on one or more appeals within the 45
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days following the end of the appeals filing period. All comments must be filed by 5:00
pm July 9, 20204. No late comments shall be accepted by SCAG.
F. HEARING BODY
SCAG's Regional Council has delegated the responsibility of considering appeals
regarding draft allocations to the RHNA Subcommittee, also referred to as the RHNA
Appeals Board. All provisions of the RHNA Subcommittee's charter shall apply with
respect to the conduct of the appeal hearings. Per the RHNA Subcommittee charter,
which was adopted on February 7, 2019 by the Regional Council, all decisions made by
the RHNA Appeals Board are considered final and will not be reviewed by the SCAG
CEHD Committee or Regional Council.
G. APPEAL HEARING
SCAG shall conduct one public hearing to consider all appeals filed and comments
received on the appeals no later than August 8, 20205. This public hearing may be
continued (over several days if necessary) until all appeals are heard. Notice shall be
provided to the appealing jurisdictions, commenting jurisdictions, and HCD at least 21
days in advance of the hearing. The appeal hearing may take place provided that each
county is represented either by a member or alternate of the RHNA Appeals Board.
Alternates are permitted to participate in the appeal hearing, provided however, that
each county shall only be entitled to one vote when deciding on the appeal. Ex-officio
members may participate as non-voting members of the RHNA Appeals Board and are
not counted for purposes of a quorum. In alignment with the adopted RHNA
Subcommittee charter, in the event the hearing involves the member's or alternate's
respective jurisdiction, the member or alternate may elect not to participate in the
discussion and vote by the RHNA Subcommittee regarding such appeal.
Appeal Hearing Procedures
The hearing(s) shall be conducted to provide applicants and jurisdictions that did not file
appeals but are the subject of an appeal, with the opportunity to make their case
regarding a change in their draft regional housing need allocation or another
jurisdiction's allocation, with the burden on the applicants to prove their case. The
appeals hearings will be organized by the specific jurisdiction subject to an appeal or
appeals and will adhere to the following procedures:
4 This date assumes that the draft RHNA allocation will be available in early April 2020. Dates
related to the appeal process will be finalized after the adoption of the Final RHNA Methodology.
5 This date assumes that the draft RHNA allocation will be available in early April 2020. Dates
related to the appeal process will be finalized after the adoption of the Final RHNA Methodology.
Additionally, depending on the number of appeals filed and the complexity of the appeals SCAG
may elect to extend this time period by thirty(30)days per Government Code Section
65584.05(i).
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1. Initial Arguments
Applicants who have filed an appeal for a particular jurisdiction will have
an opportunity to present their request and reasons to grant the appeal.
In the event of multiple appeals filed for a single jurisdiction, the subject
jurisdiction will present their argument first if it has filed an appeal on its
own draft RHNA allocation. Applicants may present their case either on
their own, or in coordination with other applicants, but each applicant
shall be allotted five (5) minutes each. If the subject jurisdiction did not
file an appeal on its own draft RHNA allocation, it will be given an
opportunity to present after all applicants have provided initial
arguments on their filed appeals. Any presentation from the jurisdiction
who did not appeal but is the subject of the appeal is limited to five (5)
minutes unless it is responding to more than one appeal, in which case
the jurisdiction is limited to eight (8) minutes.
2. Staff Response
After initial arguments are presented, SCAG staff will present their
recommendation to approve or deny the appeals filed for the subject
jurisdiction. The staff response is limited to five (5) minutes.
3. Rebuttal
Applicants and the jurisdiction who did not file an appeal but is the
subject of the appeal (if applicable) may elect to provide a rebuttal but
are limited to the arguments and evidence presented in the staff
response. Each applicant and the subject jurisdiction that did not file an
appeal on its own draft RHNA allocation will be allotted three (3) minutes
each for a rebuttal.
4. Extension of Time Allotment
The Chair of the Appeals Board may elect to grant additional time for any
presentation, staff response, or rebuttal in the interest of due process
and equity.
5. Appeal Board Discussion and Determination
After arguments and rebuttals are presented, the RHNA Appeals Board
may ask questions of applicants, the subject jurisdiction (if present), and
SCAG staff. The Chair of the Appeals Board may request that questions
from the Appeals Board be asked prior to a discussion among Appeals
Board members. Any voting Board member may make a motion
regarding the appeal(s) for the subject jurisdiction. The Appeals Board is
encouraged to make a single determination on the subject jurisdiction
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after hearing all arguments and presentations on each subject
jurisdiction.
The RHNA Appeals Board need not adhere to formal evidentiary rules and procedures in
conducting the hearing. An appealing jurisdiction may choose to have technical staff
present its case at the hearing. At a minimum, technical staff should be available at the
hearing to answer any questions of the RHNA Appeals Board.
H. DETERMINATION OF APPEAL
The RHNA Appeals Board shall issue a written final determination on all filed appeals
after the conclusion of the public hearing(s). The written final determination shall
consider all arguments and comments presented on revising the draft RHNA allocation
of the subject jurisdiction and make a determination for each subject jurisdiction. The
final determinations shall be based upon the information and methodology set forth in
Government Code section 65584.04 and whether the revision is necessary to further the
objectives listed in Government Code section 65584(d). The final determination shall
include written findings as to how the determination is consistent with Government
Code section 65584.05. The decision of the RHNA Appeals Board shall be final, and local
jurisdictions shall have no further right to appeal.
In accordance with existing law, the final determination on an appeal by the RHNA
Subcommittee may require the adjustment of allocation of a local jurisdiction that is not
the subject of an appeal. Specific adjustments to jurisdictions not the subject of an
appeal as a result of an appeal will be included as part of the Appeal Board's
determination. These specific adjustments may be excluded from the cumulative total
adjustments required to be reallocated as described in Section II of these Appeals
Guidelines if it is included as part of the appeals determination of the subject
jurisdiction.
I. ALTERNATIVE DATA REQUIREMENTS
To the extent a local jurisdiction submits admissible alternative data or evidentiary
documentation to SCAG in support of its appeal, such alternative data shall meet the
following requirements:
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1. The alternative data shall be readily available for SCAG's review
and verification. Alternative data should not be constrained for
use by proprietary conditions or other conditions rendering them
difficult to obtain or process.
2. The alternative data shall be accurate, current, and reasonably
free from defect.
3. The alternative data shall be relevant and germane to the local
jurisdiction's basis of appeal.
4. The alternative data shall be used to support a logical analysis
relating to the local jurisdiction's request for a change to its draft
regional housing need allocation.
II. POST-APPEAL REALLOCATION OF REGIONAL HOUSING NEED
In accordance with existing law (see, Government Code Section 65584.05(g)), after the
conclusion of the appeals process, SCAG shall total the successfully appealed housing
need allocations, except for adjustments made to jurisdictions not the subject of an
appeal as determined by the Appeals Board in Section I.H. If the adjustments total
seven percent (7%) or less of the regional housing need, SCAG shall distribute the
adjustments proportionally, to all local jurisdictions. For purposes of these procedures,
proportional distribution shall be based on the share of regional need after the appeals
are determined and prior to the required redistribution.
If the adjustments total more than seven percent (7%) of the regional housing need,
existing law requires that SCAG to develop a methodology to distribute the amount
greater than seven percent to local governments. In this situation, SCAG will
redistribute the amount greater than the seven percent based on the "residual" existing
need calculation included in the adopted final RHNA methodology. To be consistent
with the "residual" existing need calculation, successfully appealed units above the
seven percent threshold will be redistributed to each county based on their proportion
of total successful appeals. Fifty percent (50%) of each county's amount above the
regional seven percent will be redistributed within the county based on population
within a High Quality Transit Area (HQTA) and fifty percent (50%) of the amount will be
redistributed within the county based on share of regional jobs accessible. Communities
designated as disadvantaged, defined in the Final RHNA Methodology as having more
than fifty percent (50%) of their population in lower resource areas, will be exempt from
redistribution of the amount greater than seven percent. For more information
regarding the existing need distribution in the Final RHNA Methodology, please refer to
Exhibit B SCAG's adopted Final RHNA Methodology.
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III. FINAL RHNA PLAN
After SCAG reallocates units to all local jurisdictions resulting from successful appeals,
SCAG's Regional Council shall review and consider adoption of the Final RHNA Plan for
SCAG's 6th cycle RHNA. This is scheduled to occur on October 1, 2020.
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List of Exhibits
Exhibit A: Draft RHNA Appeal Form
Exhibit B: SCAG's Adopted 6th RHNA Cycle Final Methodology
Exhibit C:
• Government Code Section 65580
• Government Code Section 65584
• Government Code Section 65584.04
• Government Code Section 65584.05
Exhibit D: RHNA Subcommittee Charter
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This Page Intentionally Left Blank
Sixth Regional Housing Needs Assessment (RHNA) Cycle Appeal Request
All appeal requests must be received by SCAG May 21,2012,5 p.m.Appeals should be submitted to
housinq@scaq.ca.gov. Late submissions will not be accepted.
Date: Jurisdiction Subject to Appeal Filing:
Filing Party(Jurisdiction or HCD)
Filing Party Contact Name Filing Party Email:
APPEAL AUTHORIZED BY:
Name: PLEASE SELECT BELOW:
❑ Mayor
❑ Chief Administrative Office
❑ City Manager
❑ Chair of County Board of Supervisors
❑ Planning Director
❑ Other:
BASES FOR APPEAL
❑ RHNA Methodology
O Local Planning Factors and/or Information Related to Affirmatively Furthering Fair Housing(See
Government Code Section 65584.04(b)(2)and (e))
❑ Existing or projected jobs-housing balance
❑ Sewer or water infrastructure constraints for additional development
❑ Availability of land suitable for urban development or for conversion to residential use
❑ Lands protected from urban development under existing federal or state programs
O County policies to preserve prime agricultural land
❑ Distribution of household growth assumed for purposes of comparable Regional Transportation
Plans
❑ County-city agreements to direct growth toward incorporated areas of County
❑ Loss of units contained in assisted housing developments
❑ High housing cost burdens
❑ The rate of overcrowding
❑ Housing needs of farmworkers
❑ Housing needs generated by the presence of a university campus within a jurisdiction
❑ Loss of units during a state of emergency
❑ The region's greenhouse gas emissions targets
O Affirmatively furthering fair housing
FOR STAFF USE ONLY:
Date Hearing Date: Planner:
RHNA Subcommittee Meeting-Feb.24,2020
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Sixth Regional Housing Needs Assessment (RHNA) Cycle Appeal Request
All appeal requests must be received by SCAG May 21,2012,5 p.m.Appeals should be submitted to
housinq(u)scaq.ca.gov.Late submissions will not be accepted.
❑ Changed Circumstances(Per Government Code Section 65584.05(b)(3), appeals based on change in
circumstances can only be made by the jurisdiction or jurisdictions where the change in circumstances
occurred)
Brief statement on why this revision is necessary to further the intent of the objectives listed in
Government Code Section 65584(please refer to Exhibit C of the Appeals Guidelines):
Brief Description of Appeal Request and Desired Outcome:
Number of units requested to be reduced or added to the jurisdiction's draft RHNA allocation (circle
one):
Reduced Added
List of Supporting Documentation, by Title and Number of Pages:
1.
2.
3.
FOR STAFF USE ONLY:
Date Hearing Date: Planner:
RHNA Subcommittee Meeting-Feb.24,2020
Page 81 of 139
d STAFF OF CALIFORNIA
AUTHENTICATED
f.to vI ELECTRONIC LEGAL MATERIAL
State of California
GOVERNMENT CODE
Section 65080
65080. (a) Each transportation planning agency designated under Section 29532 or
29532.1 shall prepare and adopt a regional transportation plan directed at achieving
a coordinated and balanced regional transportation system,including,but not limited
to, mass transportation, highway, railroad, maritime, bicycle, pedestrian, goods
movement,and aviation facilities and services.The plan shall be action-oriented and
pragmatic, considering both the short-term and long-term future, and shall present
clear,concise policy guidance to local and state officials.The regional transportation
plan shall consider factors specified in Section 134 of Title 23 of the United States
Code. Each transportation planning agency shall consider and incorporate, as
appropriate,the transportation plans of cities,counties,districts,private organizations,
and state and federal agencies.
(b) The regional transportation plan shall be an internally consistent document and
shall include all of the following:
(1) A policy element that describes the transportation issues in the region,identifies
and quantifies regional needs,and describes the desired short-range and long-range
transportation goals, and pragmatic objective and policy statements. The objective
and policy statements shall be consistent with the funding estimates of the financial
element. The policy element of transportation planning agencies with populations
that exceed 200,000 persons may quantify a set of indicators including,but not limited
to,all of the following:
(A) Measures of mobility and traffic congestion, including, but not limited to,
daily vehicle hours of delay per capita and vehicle miles traveled per capita.
(B) Measures of road and bridge maintenance and rehabilitation needs,including,
but not limited to,roadway pavement and bridge conditions.
(C) Measures of means of travel, including,but not limited to,percentage share
of all trips(work and nonwork)made by all of the following:
(i) Single occupant vehicle.
(ii) Multiple occupant vehicle or carpool.
(iii) Public transit including commuter rail and intercity rail.
(iv) Walking.
(v) Bicycling.
(D) Measures of safety and security, including, but not limited to, total injuries
and fatalities assigned to each of the modes set forth in subparagraph(C).
(E) Measures of equity and accessibility,including,but not limited to,percentage
of the population served by frequent and reliable public transit,with a breakdown by
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income bracket,and percentage of all jobs accessible by frequent and reliable public
transit service,with a breakdown by income bracket.
(F) The requirements of this section may be met using existing sources of
information.No additional traffic counts,household surveys,or other sources of data
shall be required.
(2) A sustainable communities strategy prepared by each metropolitan planning
organization as follows:
(A) No later than September 30,2010,the State Air Resources Board shall provide
each affected region with greenhouse gas emission reduction targets for the automobile
and light truck sector for 2020 and 2035,respectively.
(i) No later than January 31,2009,the state board shall appoint a Regional Targets
Advisory Committee to recommend factors to be considered and methodologies to
be used for setting greenhouse gas emission reduction targets for the affected regions.
The committee shall be composed of representatives of the metropolitan planning
organizations, affected air districts, the League of California Cities, the California
State Association of Counties, local transportation agencies, and members of the
public,including homebuilders,environmental organizations,planning organizations,
environmental justice organizations, affordable housing organizations, and others.
The advisory committee shall transmit a report with its recommendations to the state
board no later than September 30,2009. In recommending factors to be considered
and methodologies to be used, the advisory committee may consider any relevant
issues,including,but not limited to,data needs,modeling techniques,growth forecasts,
the impacts of regional jobs-housing balance on interregional travel and greenhouse
gas emissions,economic and demographic trends,the magnitude of greenhouse gas
reduction benefits from a variety of land use and transportation strategies, and
appropriate methods to describe regional targets and to monitor performance in
attaining those targets. The state board shall consider the report before setting the
targets.
(ii) Before setting the targets for a region,the state board shall exchange technical
information with the metropolitan planning organization and the affected air district.
The metropolitan planning organization may recommend a target for the region.The
metropolitan planning organization shall hold at least one public workshop within
the region after receipt of the report from the advisory committee. The state board
shall release draft targets for each region no later than June 30,2010.
(iii) In establishing these targets,the state board shall take into account greenhouse
gas emission reductions that will be achieved by improved vehicle emission standards,
changes in fuel composition, and other measures it has approved that will reduce
greenhouse gas emissions in the affected regions,and prospective measures the state
board plans to adopt to reduce greenhouse gas emissions from other greenhouse gas
emission sources as that term is defined in subdivision(i) of Section 38505 of the
Health and Safety Code and consistent with the regulations promulgated pursuant to
the California Global Warming Solutions Act of 2006(Division 25.5 (commencing
with Section 38500)of the Health and Safety Code),including Section 38566 of the
Health and Safety Code.
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(iv) The state board shall update the regional greenhouse gas emission reduction
targets every eight years consistent with each metropolitan planning organization's
timeframe for updating its regional transportation plan under federal law until 2050.
The state board may revise the targets every four years based on changes in the factors
considered under clause (iii). The state board shall exchange technical information
with the Department of Transportation, metropolitan planning organizations, local
governments, and affected air districts and engage in a consultative process with
public and private stakeholders,before updating these targets.
(v) The greenhouse gas emission reduction targets may be expressed in gross tons,
tons per capita,tons per household,or in any other metric deemed appropriate by the
state board.
(B) Each metropolitan planning organization shall prepare a sustainable
communities strategy,subject to the requirements of Part 450 of Title 23 of,and Part
93 of Title 40 of,the Code of Federal Regulations,including the requirement to use
the most recent planning assumptions considering local general plans and other factors.
The sustainable communities strategy shall(i) identify the general location of uses,
residential densities, and building intensities within the region, (ii) identify areas
within the region sufficient to house all the population of the region, including all
economic segments of the population,over the course of the planning period of the
regional transportation plan taking into account net migration into the region,
population growth,household formation and employment growth,(iii)identify areas
within the region sufficient to house an eight-year projection of the regional housing
need for the region pursuant to Section 65584,(iv)identify a transportation network
to service the transportation needs of the region, (v) gather and consider the best
practically available scientific information regarding resource areas and farmland in
the region as defined in subdivisions(a)and(b)of Section 65080.01, (vi)consider
the state housing goals specified in Sections 65580 and 65581, (vii) set forth a
forecasted development pattern for the region, which, when integrated with the
transportation network, and other transportation measures and policies,will reduce
the greenhouse gas emissions from automobiles and light trucks to achieve,if there
is a feasible way to do so,the greenhouse gas emission reduction targets approved
by the state board, and(viii) allow the regional transportation plan to comply with
Section 176 of the federal Clean Air Act(42 U.S.C. Sec.7506).
(C) (i) Within the jurisdiction of the Metropolitan Transportation Commission,
as defined by Section 66502, the Association of Bay Area Governments shall be
responsible for clauses(i),(ii),(iii),(v),and(vi)of subparagraph(B);the Metropolitan
Transportation Commission shall be responsible for clauses (iv) and (viii) of
subparagraph(B);and the Association of Bay Area Governments and the Metropolitan
Transportation Commission shall jointly be responsible for clause(vii)of subparagraph
(B).
(ii) Within the jurisdiction of the Tahoe Regional Planning Agency,as defined in
Sections 66800 and 66801,the Tahoe Metropolitan Planning Organization shall use
the Regional Plan for the Lake Tahoe Region as the sustainable community strategy,
provided that it complies with clauses(vii)and(viii)of subparagraph(B).
RHNA Subcommittee Meeting-Feb.24,2020
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(D) In the region served by the Southern California Association of Governments,
a subregional council of governments and the county transportation commission may
work together to propose the sustainable communities strategy and an alternative
planning strategy,if one is prepared pursuant to subparagraph(I),for that subregional
area.The metropolitan planning organization may adopt a framework for a subregional
sustainable communities strategy or a subregional alternative planning strategy to
address the intraregional land use,transportation,economic,air quality,and climate
policy relationships. The metropolitan planning organization shall include the
subregional sustainable communities strategy for that subregion in the regional
sustainable communities strategy to the extent consistent with this section and federal
law and approve the subregional alternative planning strategy, if one is prepared
pursuant to subparagraph(I), for that subregional area to the extent consistent with
this section.The metropolitan planning organization shall develop overall guidelines,
create public participation plans pursuant to subparagraph(F),ensure coordination,
resolve conflicts, make sure that the overall plan complies with applicable legal
requirements,and adopt the plan for the region.
(E) The metropolitan planning organization shall conduct at least two informational
meetings in each county within the region for members of the board of supervisors
and city councils on the sustainable communities strategy and alternative planning
strategy, if any. The metropolitan planning organization may conduct only one
informational meeting if it is attended by representatives of the county board of
supervisors and city council members representing a majority of the cities representing
a majority of the population in the incorporated areas of that county.Notice of the
meeting or meetings shall be sent to the clerk of the board of supervisors and to each
city clerk.The purpose of the meeting or meetings shall be to discuss the sustainable
communities strategy and the alternative planning strategy,if any,including the key
land use and planning assumptions to the members of the board of supervisors and
the city council members in that county and to solicit and consider their input and
recommendations.
(F) Each metropolitan planning organization shall adopt a public participation
plan, for development of the sustainable communities strategy and an alternative
planning strategy,if any,that includes all of the following:
(i) Outreach efforts to encourage the active participation of a broad range of
stakeholder groups in the planning process, consistent with the agency's adopted
Federal Public Participation Plan, including,but not limited to, affordable housing
advocates, transportation advocates, neighborhood and community groups,
environmental advocates, home builder representatives, broad-based business
organizations,landowners,commercial property interests,and homeowner associations.
(ii) Consultation with congestion management agencies,transportation agencies,
and transportation commissions.
(iii) Workshops throughout the region to provide the public with the information
and tools necessary to provide a clear understanding of the issues and policy choices.
At least one workshop shall be held in each county in the region.For counties with
a population greater than 500,000, at least three workshops shall be held. Each
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workshop,to the extent practicable,shall include urban simulation computer modeling
to create visual representations of the sustainable communities strategy and the
alternative planning strategy.
(iv) Preparation and circulation of a draft sustainable communities strategy and
an alternative planning strategy, if one is prepared, not less than 55 days before
adoption of a final regional transportation plan.
(v) At least three public hearings on the draft sustainable communities strategy in
the regional transportation plan and alternative planning strategy, if one is prepared.
If the metropolitan transportation organization consists of a single county, at least
two public hearings shall be held.To the maximum extent feasible,the hearings shall
be in different parts of the region to maximize the opportunity for participation by
members of the public throughout the region.
(vi) A process for enabling members of the public to provide a single request to
receive notices,information,and updates.
(G) In preparing a sustainable communities strategy, the metropolitan planning
organization shall consider spheres of influence that have been adopted by the local
agency formation commissions within its region.
(H) Before adopting a sustainable communities strategy,the metropolitan planning
organization shall quantify the reduction in greenhouse gas emissions projected to be
achieved by the sustainable communities strategy and set forth the difference,if any,
between the amount of that reduction and the target for the region established by the
state board.
(I) If the sustainable communities strategy, prepared in compliance with
subparagraph(B)or(D),is unable to reduce greenhouse gas emissions to achieve the
greenhouse gas emission reduction targets established by the state board, the
metropolitan planning organization shall prepare an alternative planning strategy to
the sustainable communities strategy showing how those greenhouse gas emission
targets would be achieved through alternative development patterns, infrastructure,
or additional transportation measures or policies. The alternative planning strategy
shall be a separate document from the regional transportation plan, but it may be
adopted concurrently with the regional transportation plan.In preparing the alternative
planning strategy,the metropolitan planning organization:
(i) Shall identify the principal impediments to achieving the targets within the
sustainable communities strategy.
(ii) May include an alternative development pattern for the region pursuant to
subparagraphs(B)to(G),inclusive.
(iii) Shall describe how the greenhouse gas emission reduction targets would be
achieved by the alternative planning strategy, and why the development pattern,
measures, and policies in the alternative planning strategy are the most practicable
choices for achievement of the greenhouse gas emission reduction targets.
(iv) An alternative development pattern set forth in the alternative planning strategy
shall comply with Part 450 of Title 23 of, and Part 93 of Title 40 of, the Code of
Federal Regulations, except to the extent that compliance will prevent achievement
of the greenhouse gas emission reduction targets approved by the state board.
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(v) For purposes of the California Environmental Quality Act (Division 13
(commencing with Section 21000) of the Public Resources Code), an alternative
planning strategy shall not constitute a land use plan,policy, or regulation, and the
inconsistency of a project with an alternative planning strategy shall not be a
consideration in determining whether a project may have an environmental effect.
(J) (i) Before starting the public participation process adopted pursuant to
subparagraph(F),the metropolitan planning organization shall submit a description
to the state board of the technical methodology it intends to use to estimate the
greenhouse gas emissions from its sustainable communities strategy and,if appropriate,
its alternative planning strategy. The state board shall respond to the metropolitan
planning organization in a timely manner with written comments about the technical
methodology, including specifically describing any aspects of that methodology it
concludes will not yield accurate estimates of greenhouse gas emissions,and suggested
remedies. The metropolitan planning organization is encouraged to work with the
state board until the state board concludes that the technical methodology operates
accurately.
(ii) After adoption,a metropolitan planning organization shall submit a sustainable
communities strategy or an alternative planning strategy,if one has been adopted,to
the state board for review,including the quantification of the greenhouse gas emission
reductions the strategy would achieve and a description of the technical methodology
used to obtain that result.Review by the state board shall be limited to acceptance or
rejection of the metropolitan planning organization's determination that the strategy
submitted would, if implemented, achieve the greenhouse gas emission reduction
targets established by the state board.The state board shall complete its review within
60 days.
(iii) If the state board determines that the strategy submitted would not, if
implemented,achieve the greenhouse gas emission reduction targets,the metropolitan
planning organization shall revise its strategy or adopt an alternative planning strategy,
if not previously adopted,and submit the strategy for review pursuant to clause(ii).
At a minimum, the metropolitan planning organization must obtain state board
acceptance that an alternative planning strategy would, if implemented,achieve the
greenhouse gas emission reduction targets established for that region by the state
board.
(iv) On or before September 1,2018,and every four years thereafter to align with
target setting,notwithstanding Section 10231.5,the state board shall prepare a report
that assesses progress made by each metropolitan planning organization in meeting
the regional greenhouse gas emission reduction targets set by the state board. The
report shall include changes to greenhouse gas emissions in each region and
data-supported metrics for the strategies used to meet the targets. The report shall
also include a discussion of best practices and the challenges faced by the metropolitan
planning organizations in meeting the targets, including the effect of state policies
and funding. The report shall be developed in consultation with the metropolitan
planning organizations and affected stakeholders. The report shall be submitted to
the Assembly Committee on Transportation and the Assembly Committee on Natural
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Resources, and to the Senate Committee on Transportation, the Senate Committee
on Housing,and the Senate Committee on Environmental Quality.
(K) Neither a sustainable communities strategy nor an alternative planning strategy
regulates the use of land, nor, except as provided by subparagraph (J), shall either
one be subject to any state approval.Nothing in a sustainable communities strategy
shall be interpreted as superseding the exercise of the land use authority of cities and
counties within the region. Nothing in this section shall be interpreted to limit the
state board's authority under any other law.Nothing in this section shall be interpreted
to authorize the abrogation of any vested right whether created by statute or by common
law.Nothing in this section shall require a city's or county's land use policies and
regulations,including its general plan,to be consistent with the regional transportation
plan or an alternative planning strategy.Nothing in this section requires a metropolitan
planning organization to approve a sustainable communities strategy that would be
inconsistent with Part 450 of Title 23 of,or Part 93 of Title 40 of,the Code of Federal
Regulations and any administrative guidance under those regulations.Nothing in this
section relieves a public or private entity or any person from compliance with any
other local,state,or federal law.
(L) Nothing in this section requires projects programmed for funding on or before
December 31, 2011, to be subject to the provisions of this paragraph if they(i)are
contained in the 2007 or 2009 Federal Statewide Transportation Improvement Program,
(ii)are funded pursuant to the Highway Safety,Traffic Reduction,Air Quality, and
Port Security Bond Act of 2006(Chapter 12.49(commencing with Section 8879.20)
of Division 1 of Title 2), or(iii)were specifically listed in a ballot measure before
December 31,2008,approving a sales tax increase for transportation projects.Nothing
in this section shall require a transportation sales tax authority to change the funding
allocations approved by the voters for categories of transportation projects in a sales
tax measure adopted before December 31,2010.For purposes of this subparagraph,
a transportation sales tax authority is a district, as defined in Section 7252 of the
Revenue and Taxation Code,that is authorized to impose a sales tax for transportation
purposes.
(M) A metropolitan planning organization, or a regional transportation planning
agency not within a metropolitan planning organization, that is required to adopt a
regional transportation plan not less than every five years,may elect to adopt the plan
not less than every four years.This election shall be made by the board of directors
of the metropolitan planning organization or regional transportation planning agency
no later than June 1,2009,or thereafter 54 months before the statutory deadline for
the adoption of housing elements for the local jurisdictions within the region,after a
public hearing at which comments are accepted from members of the public and
representatives of cities and counties within the region covered by the metropolitan
planning organization or regional transportation planning agency.Notice of the public
hearing shall be given to the general public and by mail to cities and counties within
the region no later than 30 days before the date of the public hearing.Notice of election
shall be promptly given to the Department of Housing and Community Development.
The metropolitan planning organization or the regional transportation planning agency
RHNA Subcommittee Meeting-Feb.24,2020
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shall complete its next regional transportation plan within three years of the notice
of election.
(N) Two or more of the metropolitan planning organizations for Fresno County,
Kern County,Kings County,Madera County,Merced County, San Joaquin County,
Stanislaus County, and Tulare County may work together to develop and adopt
multiregional goals and policies that may address interregional land use,transportation,
economic, air quality, and climate relationships. The participating metropolitan
planning organizations may also develop a multiregional sustainable communities
strategy,to the extent consistent with federal law,or an alternative planning strategy
for adoption by the metropolitan planning organizations. Each participating
metropolitan planning organization shall consider any adopted multiregional goals
and policies in the development of a sustainable communities strategy and, if
applicable,an alternative planning strategy for its region.
(3) An action element that describes the programs and actions necessary to
implement the plan and assigns implementation responsibilities.The action element
may describe all transportation projects proposed for development during the 20-year
or greater life of the plan.The action element shall consider congestion management
programming activities carried out within the region.
(4) (A) A financial element that summarizes the cost of plan implementation
constrained by a realistic projection of available revenues.The financial element shall
also contain recommendations for allocation of funds. A county transportation
commission created pursuant to the County Transportation Commissions Act(Division
12(commencing with Section 130000)of the Public Utilities Code)shall be responsible
for recommending projects to be funded with regional improvement funds, if the
project is consistent with the regional transportation plan.The first five years of the
financial element shall be based on the five-year estimate of funds developed pursuant
to Section 14524.The financial element may recommend the development of specified
new sources of revenue,consistent with the policy element and action element.
(B) The financial element of transportation planning agencies with populations
that exceed 200,000 persons may include a project cost breakdown for all projects
proposed for development during the 20-year life of the plan that includes total
expenditures and related percentages of total expenditures for all of the following:
(i) State highway expansion.
(ii) State highway rehabilitation,maintenance,and operations.
(iii) Local road and street expansion.
(iv) Local road and street rehabilitation,maintenance,and operation.
(v) Mass transit,commuter rail,and intercity rail expansion.
(vi) Mass transit,commuter rail,and intercity rail rehabilitation,maintenance,and
operations.
(vii) Pedestrian and bicycle facilities.
(viii) Environmental enhancements and mitigation.
(ix) Research and planning.
(x) Other categories.
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(C) The metropolitan planning organization or county transportation agency,
whichever entity is appropriate, shall consider financial incentives for cities and
counties that have resource areas or farmland,as defined in Section 65080.01,for the
purposes of, for example,transportation investments for the preservation and safety
of the city street or county road system and farm-to-market and interconnectivity
transportation needs.The metropolitan planning organization or county transportation
agency,whichever entity is appropriate, shall also consider financial assistance for
counties to address countywide service responsibilities in counties that contribute
toward the greenhouse gas emission reduction targets by implementing policies for
growth to occur within their cities.
(c) Each transportation planning agency may also include other factors of local
significance as an element of the regional transportation plan, including, but not
limited to,issues of mobility for specific sectors of the community,including,but not
limited to,senior citizens.
(d) (1) Except as otherwise provided in this subdivision, each transportation
planning agency shall adopt and submit, every four years, an updated regional
transportation plan to the California Transportation Commission and the Department
of Transportation.A transportation planning agency located in a federally designated
air quality attainment area or that does not contain an urbanized area may at its option
adopt and submit a regional transportation plan every five years.When applicable,
the plan shall be consistent with federal planning and programming requirements and
shall conform to the regional transportation plan guidelines adopted by the California
Transportation Commission. Before adoption of the regional transportation plan, a
public hearing shall be held after the giving of notice of the hearing by publication
in the affected county or counties pursuant to Section 6061.
(2) (A) Notwithstanding subdivisions (b) and(c), and paragraph (1), inclusive,
the regional transportation plan,sustainable communities strategy,and environmental
impact report adopted by the San Diego Association of Governments on October 9,
2015, shall remain in effect for all purposes, including for purposes of consistency
determinations and funding eligibility for the San Diego Association of Governments
and all other agencies relying on those documents,until the San Diego Association
of Governments adopts its next update to its regional transportation plan.
(B) The San Diego Association of Governments shall adopt and submit its update
to the 2015 regional transportation plan on or before December 31,2021.
(C) After the update described in subparagraph(B),the time period for San Diego
Association of Governments'updates to its regional transportation plan shall be reset
and shall be adopted and submitted every four years.
(D) Notwithstanding clause(iv)of subparagraph(A)of paragraph(2)of subdivision
(b), the State Air Resources Board shall not update the greenhouse gas emission
reduction targets for the region within the jurisdiction of the San Diego Association
of Governments before the adoption of the update to the regional transportation plan
pursuant to subparagraph(B).
(E) The update to the regional transportation plan adopted by the San Diego
Association of Governments on October 9,2015,which will be prepared and submitted
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to federal agencies for purposes of compliance with federal laws applicable to regional
transportation plans and air quality conformity and which is due in October 2019,
shall not be considered a regional transportation plan pursuant to this section and shall
not constitute a project for purposes of the California Environmental Quality Act
(Division 13(commencing with Section 21000)of the Public Resources Code).
(F) In addition to meeting the other requirements to nominate a project for funding
through the Solutions for Congested Corridors Program(Chapter 8.5 (commencing
with Section 2390)of Division 3 of the Streets and Highways Code),the San Diego
Association of Governments,until December 31,2021,shall only nominate projects
for funding through the Solutions for Congested Corridors Program that are consistent
with the eligibility requirements for projects under any of the following programs:
(i) The Transit and Intercity Rail Capital Program (Part 2 (commencing with
Section 75220)of Division 44 of the Public Resources Code).
(ii) The Low Carbon Transit Operations Program(Part 3(commencing with Section
75230)of Division 44 of the Public Resources Code).
(iii) The Active Transportation Program (Chapter 8 (commencing with Section
2380)of Division 3 of the Streets and Highways Code).
(G) Commencing January 1,2020,and every two years thereafter,the San Diego
Association of Governments shall begin developing an implementation report that
tracks the implementation of its most recently adopted sustainable communities
strategy. The report shall discuss the status of the implementation of the strategy at
the regional and local level,and any successes and barriers that have occurred since
the last report. The San Diego Association of Governments shall submit the
implementation report to the state board by including it in its sustainable communities
strategy implementation review pursuant to clause(ii)of subparagraph(J)of paragraph
(2)of subdivision(b).
(Amended by Stats.2019,Ch.634,Sec.2. (AB 1730) Effective January 1,2020.)
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State of California
GOVERNMENT CODE
Section 65584
65584. (a) (1) For the fourth and subsequent revisions of the housing element
pursuant to Section 65588,the department shall determine the existing and projected
need for housing for each region pursuant to this article.For purposes of subdivision
(a)of Section 65583,the share of a city or county of the regional housing need shall
include that share of the housing need of persons at all income levels within the area
significantly affected by the general plan of the city or county.
(2) It is the intent of the Legislature that cities, counties, and cities and counties
should undertake all necessary actions to encourage, promote, and facilitate the
development of housing to accommodate the entire regional housing need, and
reasonable actions should be taken by local and regional governments to ensure that
future housing production meets,at a minimum,the regional housing need established
for planning purposes.These actions shall include applicable reforms and incentives
in Section 65582.1.
(3) The Legislature finds and declares that insufficient housing in job centers
hinders the state's environmental quality and runs counter to the state's environmental
goals.In particular,when Californians seeking affordable housing are forced to drive
longer distances to work,an increased amount of greenhouse gases and other pollutants
is released and puts in jeopardy the achievement of the state's climate goals, as
established pursuant to Section 38566 of the Health and Safety Code,and clean air
goals.
(b) The department, in consultation with each council of governments, shall
determine each region's existing and projected housing need pursuant to Section
65584.01 at least two years prior to the scheduled revision required pursuant to Section
65588.The appropriate council of governments,or for cities and counties without a
council of governments, the department, shall adopt a final regional housing need
plan that allocates a share of the regional housing need to each city,county, or city
and county at least one year prior to the scheduled revision for the region required by
Section 65588. The allocation plan prepared by a council of governments shall be
prepared pursuant to Sections 65584.04 and 65584.05.
(c) Notwithstanding any other provision of law,the due dates for the determinations
of the department or for the council of governments, respectively, regarding the
regional housing need may be extended by the department by not more than 60 days
if the extension will enable access to more recent critical population or housing data
from a pending or recent release of the United States Census Bureau or the Department
of Finance.If the due date for the determination of the department or the council of
governments is extended for this reason,the department shall extend the corresponding
RHNA Subcommittee Meeting-Feb.24,2020
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housing element revision deadline pursuant to Section 65588 by not more than 60
days.
(d) The regional housing needs allocation plan shall further all of the following
objectives:
(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 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 pursuant to Section 65080.
(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 furthering fair housing.
(e) 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.
(f) For purposes of this section,"household income levels"are as determined by
the department as of the most recent American Community Survey pursuant to the
following code sections:
(1) Very low incomes as defined by Section 50105 of the Health and Safety Code.
(2) Lower incomes,as defined by Section 50079.5 of the Health and Safety Code.
(3) Moderate incomes,as defined by Section 50093 of the Health and Safety Code.
(4) Above moderate incomes are those exceeding the moderate-income level of
Section 50093 of the Health and Safety Code.
(g) Notwithstanding any other provision of law, determinations made by the
department,a council of governments,or a city or county pursuant to this section or
Section 65584.01,65584.02,65584.03,65584.04,65584.05,65584.06,65584.07,or
RHNA Subcommittee Meeting-Feb.24,2020
Page 93 of 139
65584.08 are exempt from the California Environmental Quality Act(Division 13
(commencing with Section 21000)of the Public Resources Code).
(Amended by Stats.2018,Ch.989,Sec.1.5. (AB 1771) Effective January 1,2019.)
RHNA Subcommittee Meeting-Feb.24,2020
Page 94 of 139
State of California
GOVERNMENT CODE
Section 65584.04
65584.04. (a) At least two years before a scheduled revision required by Section
65588,each council of governments,or delegate subregion as applicable,shall develop,
in consultation with the department, a proposed methodology for distributing the
existing and projected regional housing need to cities,counties,and cities and counties
within the region or within the subregion,where applicable pursuant to this section.
The methodology shall further the objectives listed in subdivision (d) of Section
65584.
(b) (1) No more than six months before the development of a proposed
methodology for distributing the existing and projected housing need, each council
of governments shall survey each of its member jurisdictions to request,at a minimum,
information regarding the factors listed in subdivision (e) that will allow the
development of a methodology based upon the factors established in subdivision(e).
(2) With respect to the objective in paragraph (5) of subdivision (d) of Section
65584, the survey shall review and compile information that will allow the
development of a methodology based upon the issues,strategies,and actions that are
included,as available,in an Analysis of Impediments to Fair Housing Choice or an
Assessment of Fair Housing completed by any city or county or the department that
covers communities within the area served by the council of governments, and in
housing elements adopted pursuant to this article by cities and counties within the
area served by the council of governments.
(3) The council of governments shall seek to obtain the information in a manner
and format that is comparable throughout the region and utilize readily available data
to the extent possible.
(4) The information provided by a local government pursuant to this section shall
be used,to the extent possible,by the council of governments,or delegate subregion
as applicable,as source information for the methodology developed pursuant to this
section.The survey shall state that none of the information received may be used as
a basis for reducing the total housing need established for the region pursuant to
Section 65584.01.
(5) If the council of governments fails to conduct a survey pursuant to this
subdivision,a city,county,or city and county may submit information related to the
items listed in subdivision (e) before the public comment period provided for in
subdivision(d).
(c) The council of governments shall electronically report the results of the survey
of fair housing issues,strategies,and actions compiled pursuant to paragraph(2)of
subdivision (b). The report shall describe common themes and effective strategies
RHNA Subcommittee Meeting-Feb.24,2020
Page 95 of 139
employed by cities and counties within the area served by the council of governments,
including common themes and effective strategies around avoiding the displacement
of lower income households.The council of governments shall also identify significant
barriers to affirmatively furthering fair housing at the regional level and may
recommend strategies or actions to overcome those barriers.A council of governments
or metropolitan planning organization,as appropriate,may use this information for
any other purpose,including publication within a regional transportation plan adopted
pursuant to Section 65080 or to inform the land use assumptions that are applied in
the development of a regional transportation plan.
(d) Public participation and access shall be required in the development of the
methodology and in the process of drafting and adoption of the allocation of the
regional housing needs.Participation by organizations other than local jurisdictions
and councils of governments shall be solicited in a diligent effort to achieve public
participation of all economic segments of the community as well as members of
protected classes under Section 12955.The proposed methodology, along with any
relevant underlying data and assumptions,an explanation of how information about
local government conditions gathered pursuant to subdivision(b)has been used to
develop the proposed methodology,how each of the factors listed in subdivision(e)
is incorporated into the methodology, and how the proposed methodology furthers
the objectives listed in subdivision (e) of Section 65584, shall be distributed to all
cities,counties,any subregions,and members of the public who have made a written
or electronic request for the proposed methodology and published on the council of
governments',or delegate subregion's,internet website.The council of governments,
or delegate subregion,as applicable,shall conduct at least one public hearing to receive
oral and written comments on the proposed methodology.
(e) To the extent that sufficient data is available from local governments pursuant
to subdivision(b)or other sources,each council of governments,or delegate subregion
as applicable, shall include the following factors to develop the methodology that
allocates regional housing needs:
(1) Each member 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.
(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.
(B) The availability of land suitable for urban development or for conversion to
residential use, the availability of underutilized land, and opportunities for infill
RHNA Subcommittee Meeting-Feb.24,2020
Page 96 of 139
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.
(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 nonagricultural uses.
(D) County policies to preserve prime agricultural land, as defined pursuant to
Section 56064,within an unincorporated area 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 nonagricultural uses.
(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.
(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 nonagricultural uses.
(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.
(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.
(7) The rate of overcrowding.
(8) The housing needs of farmworkers.
(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.
(10) The housing needs of individuals and families experiencing homelessness.If
a council of governments has surveyed each of its member jurisdictions pursuant to
subdivision(b)on or before January 1,2020,this paragraph shall apply only to the
RHNA Subcommittee Meeting-Feb.24,2020
Page 97 of 139
development of methodologies for the seventh and subsequent revisions of the housing
element.
(11) 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.
(12) The region's greenhouse gas emissions targets provided by the State Air
Resources Board pursuant to Section 65080.
(13) 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.
(f) The council of governments,or delegate subregion,as applicable,shall explain
in writing how each of the factors described in subdivision(e)was incorporated into
the methodology and how the methodology furthers the objectives listed in subdivision
(d) of Section 65584. The methodology may include numerical weighting. This
information,and any other supporting materials used in determining the methodology,
shall be posted on the council of governments', or delegate subregion's, internet
website.
(g) The following criteria shall not be a justification for a determination or a
reduction in 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,as determined by each jurisdiction's annual production report
submitted pursuant to subparagraph(H)of paragraph(2)of subdivision(a)of Section
65400.
(3) Stable population numbers in a city or county from the previous regional
housing needs cycle.
(h) Following the conclusion of the public comment period described in subdivision
(d)on the proposed allocation methodology,and after making any revisions deemed
appropriate by the council of governments,or delegate subregion,as applicable,as a
result of comments received during the public comment period, and as a result of
consultation with the department,each council of governments,or delegate subregion,
as applicable,shall publish a draft allocation methodology on its internet website and
submit the draft allocation methodology,along with the information required pursuant
to subdivision(e),to the department.
RHNA Subcommittee Meeting-Feb.24,2020
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(i) Within 60 days,the department shall review the draft allocation methodology
and report its written findings to the council of governments,or delegate subregion,
as applicable. In its written findings the department shall determine whether the
methodology furthers the objectives listed in subdivision(d)of Section 65584.If the
department determines that the methodology is not consistent with subdivision(d)of
Section 65584,the council of governments,or delegate subregion,as applicable,shall
take one of the following actions:
(1) Revise the methodology to further the objectives listed in subdivision (d) of
Section 65584 and adopt a final regional, or subregional, housing need allocation
methodology.
(2) Adopt the regional, or subregional, housing need allocation methodology
without revisions and include within its resolution of adoption findings, supported
by substantial evidence,as to why the council of governments,or delegate subregion,
believes that the methodology furthers the objectives listed in subdivision (d) of
Section 65584 despite the findings of the department.
(j) If the department's findings are not available within the time limits set by
subdivision(i),the council of governments,or delegate subregion, may act without
them.
(k) Upon either action pursuant to subdivision(i),the council of governments,or
delegate subregion, shall provide notice of the adoption of the methodology to the
jurisdictions within the region, or delegate subregion, as applicable, and to the
department, and shall publish the adopted allocation methodology, along with its
resolution and any adopted written findings,on its internet website.
(1) The department may, within 90 days, review the adopted methodology and
report its findings to the council of governments,or delegate subregion.
(m) (1) It is the intent of the Legislature that housing planning be coordinated and
integrated with the regional transportation plan.To achieve this goal,the allocation
plan shall allocate housing units within the region consistent with the development
pattern included in the sustainable communities strategy.
(2) The final allocation plan shall ensure that the total regional housing need,by
income category, as determined under Section 65584, is maintained, and that each
jurisdiction in the region receive an allocation of units for low-and very low income
households.
(3) The resolution approving the final housing need allocation plan shall
demonstrate that the plan is consistent with the sustainable communities strategy in
the regional transportation plan and furthers the objectives listed in subdivision(d)
of Section 65584.
(Amended(as amended by Stats.2018,Ch.990,Sec.3.7)by Stats.2019,Ch.335,Sec.4. (AB 139)
Effective January 1,2020.)
RHNA Subcommittee Meeting-Feb.24,2020
Page 99 of 139
State of California
GOVERNMENT CODE
Section 65584.05
65584.05. (a) At least one and one-half years before the scheduled revision required
by Section 65588,each council of governments and delegate subregion,as applicable,
shall distribute a draft allocation of regional housing needs to each local government
in the region or subregion, where applicable, and the department, based on the
methodology adopted pursuant to Section 65584.04 and shall publish the draft
allocation on its interne website. The draft allocation shall include the underlying
data and methodology on which the allocation is based,and a statement as to how it
furthers the objectives listed in subdivision(d) of Section 65584. It is the intent of
the Legislature that the draft allocation should be distributed before the completion
of the update of the applicable regional transportation plan.The draft allocation shall
distribute to localities and subregions, if any, within the region the entire regional
housing need determined pursuant to Section 65584.01 or within subregions, as
applicable, the subregion's entire share of the regional housing need determined
pursuant to Section 65584.03.
(b) Within 45 days following receipt of the draft allocation, a local government
within the region or the delegate subregion, as applicable, or the department may
appeal to the council of governments or the delegate subregion for a revision of the
share of the regional housing need proposed to be allocated to one or more local
governments.Appeals shall be based upon comparable data available for all affected
jurisdictions and accepted planning methodology, and supported by adequate
documentation, and shall include a statement as to why the revision is necessary to
further the intent of the objectives listed in subdivision (d) of Section 65584. An
appeal pursuant to this subdivision shall be consistent with,and not to the detriment
of, the development pattern in an applicable sustainable communities strategy
developed pursuant to paragraph (2) of subdivision (b) of Section 65080.Appeals
shall be limited to any of the following circumstances:
(1) The council of governments or delegate subregion, as applicable, failed to
adequately consider the information submitted pursuant to subdivision(b)of Section
65584.04.
(2) The council of governments or delegate subregion, as applicable, failed to
determine the share of the regional housing need in accordance with the information
described in,and the methodology established pursuant to,Section 65584.04,and in
a manner that furthers,and does not undermine,the intent of the objectives listed in
subdivision(d)of Section 65584.
(3) A significant and unforeseen change in circumstances has occurred in the local
jurisdiction or jurisdictions that merits a revision of the information submitted pursuant
RHNA Subcommittee Meeting-Feb.24,2020
Page 100 of 139
to subdivision(b)of Section 65584.04.Appeals on this basis shall only be made by
the jurisdiction or jurisdictions where the change in circumstances has occurred.
(c) At the close of the period for filing appeals pursuant to subdivision (b), the
council of governments or delegate subregion, as applicable, shall notify all other
local governments within the region or delegate subregion and the department of all
appeals and shall make all materials submitted in support of each appeal available on
a publicly available internet website. Local governments and the department may,
within 45 days,comment on one or more appeals. If no appeals are filed, the draft
allocation shall be issued as the proposed final allocation plan pursuant to paragraph
(2)of subdivision(e).
(d) No later than 30 days after the close of the comment period,and after providing
all local governments within the region or delegate subregion,as applicable,at least
21 days prior notice,the council of governments or delegate subregion shall conduct
one public hearing to consider all appeals filed pursuant to subdivision(b) and all
comments received pursuant to subdivision(c).
(e) No later than 45 days after the public hearing pursuant to subdivision(d),the
council of governments or delegate subregion, as applicable, shall do both of the
following:
(1) Make a final determination that either accepts,rejects,or modifies each appeal
for a revised share filed pursuant to subdivision (b). Final determinations shall be
based upon the information and methodology described in Section 65584.04 and
whether the revision is necessary to further the objectives listed in subdivision(d)of
Section 65584.The final determination shall be in writing and shall include written
findings as to how the determination is consistent with this article. The final
determination on an appeal may require the council of governments or delegate
subregion,as applicable,to adjust the share of the regional housing need allocated to
one or more local governments that are not the subject of an appeal.
(2) Issue a proposed final allocation plan.
(f) In the proposed final allocation plan,the council of governments or delegate
subregion,as applicable,shall adjust allocations to local governments based upon the
results of the appeals process.If the adjustments total 7 percent or less of the regional
housing need determined pursuant to Section 65584.01, or, as applicable, total 7
percent or less of the subregion's share of the regional housing need as determined
pursuant to Section 65584.03,then the council of governments or delegate subregion,
as applicable,shall distribute the adjustments proportionally to all local governments.
If the adjustments total more than 7 percent of the regional housing need, then the
council of governments or delegate subregion, as applicable, shall develop a
methodology to distribute the amount greater than the 7 percent to local governments.
The total distribution of housing need shall not equal less than the regional housing
need,as determined pursuant to Section 65584.01,nor shall the subregional distribution
of housing need equal less than its share of the regional housing need as determined
pursuant to Section 65584.03.
(g) Within 45 days after the issuance of the proposed final allocation plan by the
council of governments and each delegate subregion, as applicable, the council of
RHNA Subcommittee Meeting-Feb.24,2020
Page 101 of 139
governments shall hold a public hearing to adopt a final allocation plan.To the extent
that the final allocation plan fully allocates the regional share of statewide housing
need, as determined pursuant to Section 65584.01 and has taken into account all
appeals, the council of governments shall have final authority to determine the
distribution of the region's existing and projected housing need as determined pursuant
to Section 65584.01.The council of governments shall submit its final allocation plan
to the department within three days of adoption.Within 30 days after the department's
receipt of the final allocation plan adopted by the council of governments, the
department shall determine if the final allocation plan is consistent with the existing
and projected housing need for the region,as determined pursuant to Section 65584.01.
The department may revise the determination of the council of governments if
necessary to obtain this consistency.
(h) Any authority of the council of governments to review and revise the share of
a city or county of the regional housing need under this section shall not constitute
authority to revise,approve,or disapprove the manner in which the share of the city
or county of the regional housing need is implemented through its housing program.
(i) Any time period in subdivision (d) or (e) may be extended by a council of
governments or delegate subregion,as applicable,for up to 30 days.
(j) The San Diego Association of Governments may follow the process in this
section for the draft and final allocation plan for the sixth revision of the housing
element notwithstanding such actions being carried out before the adoption of an
updated regional transportation plan and sustainable communities strategy.
(Amended by Stats.2019,Ch.634,Sec.4. (AB 1730) Effective January 1,2020.)
RHNA Subcommittee Meeting-Feb.24,2020
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This Page Intentionally Left Blank
RHNA SUBCOMMITTEE CHARTER—6th Cycle
Page 1 of 2
Purpose of the Subcommittee
The purpose of the RHNA Subcommittee is to review in-depth the various policy considerations
necessary to the development of SCAG's Regional Housing Needs Assessment (RHNA), and to make
critical decisions throughout the RHNA process, including but not limited to the following: the RHNA
methodology, the draft and final RHNA allocations, and appeals related to draft RHNA allocations.
The decisions of the RHNA Subcommittee will serve as recommendations to SCAG's Community,
Economic and Human Development (CEHD) Committee and the Regional Council, except that the
RHNA Subcommittee will make the final decisions regarding all appeals of draft RHNA allocations. c�
a)
a)
Authority
E
0
Authorized by the Regional Council, the RHNA Subcommittee serves as a subcommittee of the CEHD
Committee, and will be reporting to the CEHD Committee. All actions by the RHNA Subcommittee, v�
except for actions pertaining to appeals of draft RHNA allocations, are subject to the review and
approval of the CEHD Committee and the Regional Council. Recognizing the significant amount of
work undertaken by the RHNA Subcommittee, the CEHD Committee and the Regional Council will
rely on the policy judgments of the RHNA Subcommittee. The RHNA Subcommittee shall be LL
dissolved as of the date in which the final RHNA allocation is adopted by the Regional Council. a)
Composition
t
The RHNA Subcommittee will consist of twelve (12) members of the Regional Council or the CEHD c,
Committee to represent the six (6) counties of the SCAG region. Each county shall have a primary
member and an alternate member to serve on the RHNA Subcommittee. The SCAG President will U
appoint the members of the RHNA Subcommittee and will select one of the members to serve as
the Chair of the RHNA Subcommittee. Membership of the RHNA Subcommittee may also include as
non-voting members serving as stakeholder representatives appointed by the SCAG President.
ii
Meetings and Voting
E
The meetings of the RHNA Subcommittee will occur during the applicable period when SCAG is
developing the RHNA. The RHNA Subcommittee shall have the authority to convene meetings as
circumstances require. A meeting quorum shall be established when there is attendance by at least
one representative (either a primary member or an alternate member) from each of the six (6)
counties. Stakeholder representatives serving as non-voting members of the RHNA Subcommittee
are not counted for purposes of establishing a meeting quorum.
All RHNA Subcommittee members are expected to attend each meeting, to the extent feasible.
RHNA Subcommittee members may attend meetings by teleconference or video-conference. All
meetings of the RHNA Subcommittee are subject to the Brown Act. The Chair of the RHNA
Subcommittee shall preside over all meetings and the Subcommittee may select another
RHNA Subcommittee Meeting-Feb.24,2020
Page 103 of 139 Packet Pg. 36
RHNA SUBCOMMITTEE CHARTER—6th Cycle
Page 2 of 2
Subcommittee member to serve as the Vice-Chair in the Chair's absence. The RHNA Subcommittee
will invite SCAG staff or others to attend meetings and provide pertinent information, as necessary.
Meeting agendas will be prepared and provided in advance to RHNA Subcommittee members,
along with appropriate briefing materials and reports, in accordance with the Brown Act. Minutes
of each meeting will be prepared.
For purposes of voting, each county shall be entitled to one (1) vote to be cast by either the primary
member or alternate member representing the respective county. In the event of a tie vote, the
Chair of the Subcommittee may vote to break the tie except if the Chair of the Subcommittee has c�
casted a vote as a Subcommittee member. In that exception, the Vice Chair of the Subcommittee a
may break the tie vote. In the case of an appeal submitted on behalf of a Subcommittee member's
individual local jurisdiction, the Subcommittee member may elect not to participate in the
discussion and vote by the RHNA Subcommittee regarding such appeal.
U)
Responsibilities
x
ce
The RHNA Subcommittee will carry out the following responsibilities: Tts
c
ii
• Review information useful to the development of the RHNA Plan;
U
• Review and make policy decisions related to the RHNA process including policies for the
RHNA methodology, the RHNA methodology, and the draft and final RHNA allocations, and ci
forward such decisions to the CEHD Committee for review and approval. In making its a)
policy decisions, the RHNA Subcommittee should consider the integration of the RHNA with
the Regional Transportation Plan/Sustainable Communities Strategy; U
• Review and make decisions regarding guidelines for the RHNA process including guidelines cc
related to subregional delegation, and forward such decisions to the CEHD Committee for c
review and approval; and
• Review and make the final decisions regarding appeals related to the jurisdiction's draft
RHNA allocation. In this capacity, the RHNA Subcommittee shall be known as the "RHNA 0
Appeals Board." These final decisions by the RHNA Appeals Board shall not reviewable by
the CEHD Committee or by the Regional Council.
RHNA Subcommittee Meeting-Feb.24,2020
Page 104 of 139 Packet Pg. 37
RHNA Appeals Procedures
Ma'Ayn Johnson, AICP • II I
Compliance & Performance ��,
IIII
Monitoring
%T) TM
INNOVATING FOR A BETTER TOMORROW
WWW.SCAG.CA.GOV
41
RHNA Process Timeline T.J4C7'
Summer 2019 Aug 2019— Mar 2020 April 2020 Spring/Summer 2020 Oct 2020 Oct 2021
HCD Regional Draft RHNA Local Housin
g Methodology + Final RHNA Element Update
Determination Allocation Appeals Allocation
(October 2021-
October 2029
RHNA Subcommittee Meeting-Feb.24,2020
Page 105 of 139
41.
Changes to the 6th Cycle RHNA Appeals Procedures
Newl 5th cycle 31IPPP 6th cycle
Appeals procedures Two separate processes — revision Only one appeal process
request and appeals processes
Who can appeal • Jurisdiction • Jurisdiction
• Other jurisdictions
• HCD
Bases for appeal Cannot be based on: Cannot be based on:
• Local ordinances • Local ordinances
• Underproduction of housing based on
last RHNA
• Stable population growth
RHNA Appeals Timeline
Filing period Comment period Public Hearing
45 days 45 days
30 days
Early April — mid May ♦ Mid May— late June July
2020 2020 2020
RHNA Subcommittee Meeting-Feb.24,2020
Page 106 of 139
Who Can File an Appeal? C J Y
• Jurisdiction
New! • Other jurisdictions
• California Department of Housing and
Community Development (HCD)
411.
Bases for Appeal KAG
From Government Code Section 65584.05(b):
1 . Local planning factors and information on affirmatively
furthering fair housing (AFFH)
2. Application of final methodology
3. Change in circumstance
Must include statement why the revision is necessary to further
the objectives of RHNA law
• See Government Code Section 65584
RHNA Subcommittee Meeting-Feb.24,2020
Page 107 of 139
Government Code Section 65584: Objectives of RHNA
K,66
0 ) To increase the housing supply and
mix of housing types, tenure and
affordability within each region in an
equitable manner _ " .:w
2) Promoting infill development and saa
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socioeconomic equity, the protection
of environmental and agricultural t
resources, and the encouragement of ', II.° IV,
efficient development patterns � 1111
.
.
Government Code Section 65584: Objectives of RHNA
KAG.
3) Promoting an improved intraregional
relationship between jobs and
housing • ii ' . 11
4) Allocating a lower proportion of
housing need in income categories in •
jurisdictions that have a
disproportionately high share in
comparison to the county 06. A . -
distribution
5) Affirmatively furthering fair housing
RHNA Subcommittee Meeting-Feb.24,2020
Page 108 of 139
Bases for Appeal: Local Planning Factors and AFFH %TIC
1 . Planning opportunities and constraints, including:
• Existing and projected jobs and housing relationship
• Water/sewer service based on decisions by provider other
than the jurisdiction
• Open space protected by federal or State programs
• Rate of overcrowding
• Presence of a four-year college or university
4. Affirmatively furthering fair housing
• Full listing in Government Code Section 65584•04(b) and (e)
Bases for Appeal: Methodology and Change in KAG.
Circumstance
2. Application of methodology
3. Change in circumstance
• Can only be used by jurisdiction where change occurred
RHNA Subcommittee Meeting-Feb.24,2020
Page 109 of 139
Bases for Appeal %T.16G
• Appeals cannot be based on:
• Any local ordinance, policy, voter-approved measure, or
standard limiting residential development
New!
• Prior underproduction of housing from the previous
RHNA
New! • Stable population numbers
Appeals Comment Period ECA
.:
• 45-day comment period after appeals filing due date
• Mid-May to end of June 2020
• SCAG will notify all jurisdictions and HCD of all filed
appeals
• Webpage posting of filed appeals
• Local jurisdictions and HCD can comment on filed appeals
RHNA Subcommittee Meeting-Feb.24,2020
Page 110 of 139
Appeals Public Hearing .i`6G
• July 2020 (30 day period)
• All filed appeals will be reviewed and determined by the
RHNA Appeals Board (RHNA Subcommittee)
• Hearings will be organized by jurisdictions that are subjects
of appeals
11
Appeals Public Hearing: Day-of Procedure KAGT
Initial Rebuttal Questions and
Arguments Staff ,,k • Appeal Determination
• Appeal Responseapplicants • RHNA
applicants • Subjectlk Appeals
• Subject jurisdiction Board
jurisdiction
RHNA Subcommittee Meeting-Feb.24,2020
Page 111 of 139
Appeals
• Successful appeals must be reallocated back to the region
• If fewer than 93,928 units are granted, they will be
reallocated back proportionally to all jurisdictions
• If more than 93,928 units are granted, SCAG will apply a
methodology similar to final methodology existing need
formula (pending adoption) above that amount
• Proportional to county origination
• 50% based on transit access
• 50% based on job access
• Disadvantaged jurisdictions exempt from reallocation above
-94,000
41111
Final RHNA Allocation
• Appeal decisions by the RHNA Appeals Board are final and not
subject to review by CEHD and Regional Council
• Reallocation of successful units cannot be appealed
• All appeals will be included in the proposed final RHNA
allocation
• Public Hearing to adopt final RHNA allocation
• October 2020
RHNA Subcommittee Meeting-Feb.24,2020
Page 112 of 139
NIL
I.
Next Steps KAG.
'ill
February 24, 2020 March 5, 2020 April 2, 2020 Early April, 2020
CEHD
• Final RHNA
RHNA methodologyRegional Council
Subcommittee • Appeals • Release of draft
• Final RHNA procedures RHNA allocation Start of RHNA
methodology appeal filing
• Appeals period
procedures Regional Council
• Final RHNA
methodology
• Appeals
procedures
POST-APPEAL
REALLOCATION
II&
.".I.
s
5016GM
INNOVATING FOR A BETTER TOMORROW
WW W.SCAG.CA.GOV
RHNA Subcommittee Meeting-Feb.24,2020
Page 113 of 139
Post-appeal reallocation of regional housing need ,T.AG
• Regional Determination is 1 ,341 ,827 total units
• Regionally, this is greater than 20% the current housing
stock*
• HCD's determination did not provide a range. Units from
successful appeals would have to go somewhere else.
• Post-appeal redistribution must still further RHNA's statutory
objectives
• HCD can appeal
• HCD can comment on appeals
• HCD reviews the Final Allocation Plan (post-appeals)
'Per CA DOF E-5 estimates,as of 0/2059
For more information
www.scag.ca.gov/rhna
Illik
Email: housing@scag.ca.gov 4111 ,,
71111,
SC4G
INNOVATING FOR A BETTER TOMORROW
WWW.SCAG.CA.GOV
RHNA Subcommittee Meeting-Feb.24,2020
Page 114 of 139
"maSCAG- AGENDA ITEM 3
Southern California Association of Governments
900 Wilshire Boulevard, Suite 1700, Los Angeles, California 90017
February 24, 2020
REGIONAL HOUSING NEEDS ASSESSMENT(RHNA)SUBCOMMITTEE
OF THE
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
MINUTES OF THE MEETING
OCTOBER 7,2019
THE FOLLOWING MINUTES ARE A SUMMARY OF ACTIONS TAKEN BY THE RHNA SUBCOMMITTEE.AN AUDIO
RECORDING OF THE ACTUAL MEETING IS AVAILABLE FOR LISTENING.
The RHNA Subcommittee held its meeting at SCAG's downtown Los Angeles office.A quorum was present.
VOTING MEMBERS
Representing Imperial County
Primary: Hon.Jim Predmore, Holtville Present--via videoconference
Alternate: Hon. Bill Hodge,Calexico Present—in-person (late)
Representing Los Angeles County
Primary: Margaret Finlay, Duarte Present—in-person
Alternate: Hon. Rex Richardson, Long Beach Present—in-person (late)
Representing Orange County
Primary: Hon.Wendy Bucknum, Mission Viejo Present—in-person
Alternate: CHAIR Peggy Huang,Yorba Linda,TCA Present—in-person
Representing Riverside County
Primary: Hon. Rusty Bailey, Riverside Present—via videoconference
Alternate: Hon. Russell Betts, Desert Hot Springs Present—via videoconference
Representing San Bernardino County
Primary: Hon. Bill Jahn, Big Bear Lake Present—in-person
Alternate: Hon.Jim Mulvihill,San Bernardino Present—in-person
Representing Ventura County
Primary: Hon. Carmen Ramirez,Oxnard Present—via teleconference(late)
Alternate: Hon. Mike Judge,Simi Valley Absent
NON-VOTING/EX-OFFICIO MEMBERS
Academia: Paavo Monkkonen, UCLA Urban Planning Present—in-person
Non-Profit/Advocate:Cesar Covarrubias, Kennedy Commission Present—in-person
Building Industry:Jeff Montejano, BIA of Southern California Present—via teleconference
OUR MISSION OUR VISION
To foster innovative regional solutions that improve Southern California's Catalyst for a Brighter Future
the lives of Southern Californians through inclusive
collaboration,visionary planning,regional advocacy, OUR CORE VALUES
information sharing,and promoting best practices. Be Open I Lead by Example I Make an Impact I Be Courageous
RHNA Subcommittee Meeting-Feb.24,2020
Page 115 of 139
KAG,
REPORT
CALL TO ORDER & PLEDGE OF ALLEGIANCE
The Chair Peggy Huang called the meeting to order at 10:01 AM and asked Dr. Kevin Kane, SCAG
Staff, to lead the Subcommittee in the Pledge of Allegiance.
PUBLIC COMMENT PERIOD
President Bill Jahn, San Bernardino County, provided an opening statement in which he emphasized
the importance of this 6th cycle of RHNA and the significant implications it will have across the SCAG
region in the future. President Jahn reiterated that jurisdictions should not be solely focused on a
methodology that will produce the lowest RHNA allocation number possible for their respective
jurisdictions, and instead reminded everyone that the methodology chosen to be submitted to
CEHD should be one that is beneficial for the entire region.
Joann Africa, Chief Legal Counsel, then briefly acknowledged comment letters received and
addressed to the RHNA subcommittee. Ms. Africa informed that since the last RHNA Subcommittee
meeting held on July 22, about 80 letters addressed to the RHNA Subcommittee regarding the
proposed RHNA methodology options were received and reviewed by SCAG staff. Additionally, Ms.
Africa wished to acknowledge three letters received that were not included in the agenda packet
for the official record. These letters include ones received by the City of Fullerton dated August 28th,
from the City of Corona dated September 3'd, and from the City of Murrieta dated September 5th.
REVIEW AND PRIORITIZE AGENDA ITEMS
There was no prioritization of agenda items.
CONSTENT CALENDAR
Approval Item
1. Minutes of July 22, 2019 Meeting
A MOTION was made (Primary Member Wendy Bucknum, Orange County) to approve the Minutes
of the July 22, 2019 Meeting. The MOTION was SECONDED (President Bill Jahn, San Bernardino
County) and APPROVED by the following votes:
RHNA Subcommittee Meeting-Feb.24,2020
Page 116 of 139
_._
ii.,.,AIG
REPORT
AYES: Predmore (Imperial County), Finlay (Los Angeles County), Bucknum (Orange County),
Bailey (Riverside County), Jahn (San Bernardino County), Ramirez (Ventura County)
(6).
NOES: None (0).
ABSTAIN: None (0).
Receive and File
2. RHNA Subcommittee Topic Outlook
3. Summary of Written Comments Received for the 6th Cycle RHNA
4. Objection Letter to the Regional Determination
A MOTION was made (Primary Member Wendy Bucknum, Orange County) to approve the Consent
Calendar. The MOTION was SECONDED (President Bill Jahn, San Bernardino County) and APPROVED
by the following votes:
AYES: Predmore (Imperial County), Finlay (Los Angeles County), Bucknum (Orange County),
Bailey (Riverside County), Jahn (San Bernardino County), Ramirez (Ventura County)
(6).
NOES: None (0).
ABSTAIN: None (0).
ACTION ITEM
5. Recommended Draft RHNA Methodology
Kome Ajise, Executive Director of SCAG, provided context for the meeting and stated that the draft
RHNA methodology was carefully developed after reviewing the numerous amount of public
comments submitted previously regarding the other staff recommended methodology options, as
well as comments received from HCD. Mr. Ajise stressed that the high volume of comments
received has been an indicator in showcasing that many people find this 6th cycle RHNA to be of
much importance and that SCAG has been committed to abiding to state statue by incorporating
factors such as Affirmatively Furthering Fair Housing.
RHNA Subcommittee Meeting-Feb.24,2020
Page 117 of 139
vim®t
REPORT
Mr. Ajise also stated that he believes there is a misunderstanding in the public comments he has
seen regarding local input. He stated that local input is more than an aggregation of thoughts and
needs from across the region, but is rather a complex foundational database developed by SCAG.
Therefore, Mr. Ajise emphasized how local input cannot simply be disregarded as a factor in the
proposed methodology as many public comments requested because of its importance and
presence in a variety of other regional planning elements developed by SCAG.
Mr. Ajise announced the availability of the RHNA calculator tool in both Excel and PDF formats, and
the ongoing development of a 'Frequently Asked Questions' webpage regarding the 6th cycle RHNA
process. Mr. Ajise explained that the calculator tool should be used to inform users about what the
RHNA methodology could do, but that it is a work in progress as SCAG staff expects to continually
update the tool as needed to ensure more accuracy.
Ma'Ayn Johnson, SCAG staff, provided an overview of the different components of the staff
recommended draft methodology, including projected need, existing need, and social equity
adjustments. She also highlighted concepts that were developed as a result of the public comment
process on the proposed methodology, including job accessibility and the concept of disadvantaged
communities based on access to resources. The presentation also included a conceptual overview
by Dr. Kevin Kane, SCAG staff, on each methodology component and concept.
SUBCOMMITTEE MEMBER AND PUBLIC QUESTIONS
Hon. Jim Predmore, Imperial County, expressed a concern about how the current Draft
Methodology seems to favor areas with high amounts of job accessibility, but puts areas like
Imperial County at a disadvantage because of low population. Hon. Predmore asked what is being
done to help bring these jobs over.
Hon. Rusty Bailey, Riverside County, expressed his wish to look back on the objectives of RHNA to
ensure that the Draft Methodology presented is in line with the objectives of RHNA. Hon. Bailey felt
the Draft Methodology did not properly address or fulfill each RHNA objective and stated that
approval of this Draft Methodology would damage public trust in SCAG.
Hon. Carmen Ramirez, Ventura County, questioned if there could be more time for jurisdictions to
review parts of the Draft Methodology as some local planning staff felt confused over certain parts
of it. Kome Ajise, Executive Director of SCAG, mentioned that this is something SCAG staff could
address at the upcoming Technical Working Group meeting to be able to answer questions at a
jurisdictional level.
Hon. Wendy Bucknum, Orange County, requested a simplified explanation for how the number of
jobs accessible by auto commute was calculated. Dr. Kane explained that the numbers were derived
RHNA Subcommittee Meeting-Feb.24,2020
Page 118 of 139
vims.
.01161G- REPORT
from SCAG's 'activity based travel demand model' which looks at the number of jobs accessible
rather than the number of jobs within a jurisdiction.
Hon. Laura Emdee, City of Redondo Beach, commented on the importance of needing more housing
in the region to retain the younger generation workforce that's been shown to be leaving the state
because of the lack of attainable housing. Hon. Emdee indicated that a Social Equity Adjustment
that includes a jobs-housing ratio adjustment would be beneficial and would fulfill the RHNA
objective of promoting an improved intraregional relationship between jobs and housing. Hon.
Emdee also stated that HQTAs should be based on acreage and not population.
Marika Poynter, City of Irvine, expressed concerns about the limited time given to review several
new factors included in the Staff Recommended RHNA Methodology. Ms. Poynter specifically
expressed disagreement with the methodology used to obtain Transit Accessibility factors for the
City of Irvine as it took into consideration a Bus Rapid Transit line proposed for construction along
Interstate 5. Ms. Poynter stated that because there are no confirmed station stops within Irvine, it
should not qualify as part of the HQTA consideration.
Grace Peng, League of Women Voters LA County, expressed her concerns with the health and
welfare of LA County residents as the result of the current proposed Draft RHNA Methodology,
particular its heavy reliance on local input. Ms. Peng also expressed concerns with how the Draft
Methodology should focus on developing in lower density areas that can be serviced by efficient
transportation projects. Ms. Peng stated that HQTAs should be based on acreage instead of
population to avoid displacing residents in the poorest jurisdictions.
Terry Luedecke, Abundant Housing LA, stressed the importance of reducing greenhouse gas
outputs. Mr. Luedecke also advocated for reducing car usage by ensuring that cars and jobs are
within close proximity of each other.
Rachel Forester, League of Women Voters Mt. Baldy Area, emphasized that the methodology
should not be based on ensuring the lowest RHNA number to jurisdictions. Ms. Forester expressed
that the methodology should aim to build the right housing in the right areas where jobs and transit
exist to reduce car usage and subsequently allow families more money to pay for rent.
Jaime Murrillo, City of Newport Beach, pointed out that in combination with the high regional
determination number given by HCD, the State has also changed housing element laws and
constrained the type of sites that are able to count towards Housing Elements. Mr. Murrillo
expressed concerns with the City's existing need being much higher than its projected need and
asked for SCAG staff to reconsider the Social Equity Adjustment baseline of 150% as it is a much
higher number than past cycles and would inequitably allocate housing units to certain income
levels.
RHNA Subcommittee Meeting-Feb.24,2020
Page 119 of 139
...)616"m
REPORT
Leonora Camner, Abundant Housing LA, pointed out that the previous comment about RHNA
needing to be consistent with other regional plans and the need for local inputs to be included goes
against the objectives set forth for RHNA. Ms. Camner questioned how local inputs can help fulfill
RHNA objectives and goals and gave examples of inequitable housing unit allocation derived from
the inclusion of local inputs as well as how it could be more evened out with the exclusion of local
input.
Connor Finney, California YIMBY, urged SCAG and Subcommittee members to choose a
methodology that prioritizes dense, transit-oriented, in-fill development and deprioritizes a
methodology that relies heavily on public input. Mr. Finney also stressed the importance of meeting
climate change goals by reducing the amount of high commuters and car usage overall.
Eve Kaufman, Inclusive Claremont, emphasized the need on building more high density housing
around transit-oriented areas to eliminate car costs.
Hon. Jed Leano, City of Claremont, provided an example using the City of Claremont to show that it
would have been favorable to incorporate building permit activity to offset the City outpacing its
growth and expressed hope for incorporating building permit activity for future cycles to help other
jurisdictions with similar situations.
Daniel Inloes, City of Costa Mesa, expressed concerns that defining HQTAs with the incorporation of
SB 375 is too broad and called for a more thoughtful approach to defining these areas. Mr. Intoes
questioned the use of future population as a considering factor when talking about existing need
and also voiced concerns that placing such a high emphasis on housing near jobs can reduce land
available for company locations.
Hon. John Mirisch, City of Beverly Hills, advocated for protecting diverse communities from
gentrification and displacement while also considering infrastructure needs, vacancy levels, and
available land when determining where to build new housing. Hon. Mirisch also stated that if a
jurisdiction is at an equilibrium of jobs and housing, it should not be responsible for affording excess
housing units allocated to neighboring cities.
Dave Ward, County of Ventura, expressed the importance of ensuring a RHNA distribution that is
based upon the most accurate data in order to not be met with negative consequences under new
state housing laws. Mr. Ward was appreciative of permit building activity being taken out of the
existing need consideration but voiced concerns about most of Ventura County's vacant land being
in rural areas with limited infrastructures and in high fire hazard areas. Mr. Ward stated that overall
Ventura County is supportive of the Staff Recommended Draft RHNA Methodology.
RHNA Subcommittee Meeting-Feb.24,2020
Page 120 of 139
REPORT
Josh Lee, SBCTA, commented on findings made that would disproportionately allocate additional
new housing units to San Bernardino County with the use of the new Draft Methodology. Mr. Lee
expressed concerns with the elements of the Draft Methodology that led to such a high additional
increase and requested for changes to be made to ensure a more equitable distribution across all
counties in the region.
Mark Oyler, City of Palmdale, expressed support for the Draft RHNA Methodology and concurred
with most of the points made, particularly regarding the jobs-housing balance.
SUBCOMMITTEE MEMBER DISCUSSIONS
Ex-officio member Jeff Montejano, BIA of Southern California, clarified that there are a lot of
opportunities on vacant land for developers to build affordable housing and that there must be a
balance regarding high density housing to ensure affordability in the region.
Hon. Ramirez, Ventura County, expressed support for moving the Staff Recommended Draft RHNA
Methodology along but with reservations in regards to unintended consequences that could come
in the form of exacerbating disadvantaged communities when developing new housing.
Hon. Jim Mulvihill, San Bernardino County, asked staff to clarify housing units given for City of
Culver City and City of Coachella in Leonora Camner's, Abundant Housing LA, public comment.
Dr. Kevin Kane, SCAG staff, confirmed these numbers. Kome Ajise, Executive Director of SCAG, and
Chair Peggy Huang reiterated points that the RHNA allocation number given to a jurisdiction is the
baseline and that more units can be built so long as there is enough funding and available land.
Ex-officio member Paavo Monkkonen, UCLA, presented on some independent research conducted
which he found showcased a negative correlation between Jobs Accessibility and Projected
Household Growth 2020-2045, thus going against sustainable practices as it would entail
jurisdictions with larger available land being allocated higher housing unit numbers. Mr.
Monkkonen encouraged that a voting member of the Subcommittee make the motion to approve
the Staff Recommended Draft RHNA Methodology on the condition that the percentages that make
up existing need be shifted so that two-thirds would be based on jobs and transit and one-third
based on projected growth.
Several members of the RHNA Subcommittee thanked SCAG staff for the work put into formulating
the Draft RHNA Methodology and wished to point out concerns from public comments made by the
City of Irvine and SBCTA about certain factors such as HQTA consideration. Some shared personal
feelings about housing affordability and concerns regarding the need for jobs to relocate to where
people move.
RHNA Subcommittee Meeting-Feb.24,2020
Page 121 of 139
limb
11"11"SG
REPORT
Hon. Rex Richardson, Los Angeles County, spoke in support of the Staff Recommended Draft RHNA
Methodology, and indicated that the methodology adhered to the guidelines set out by the
Regional Council while also incorporating several public comments. Hon. Richardson also felt that
the Social Equity Adjustment proposed is modest for the region and that the adjustment
encourages housing development for higher income levels in certain jurisdictions and will benefit
surrounding jurisdictions.
Chair Huang thanked staff for their guidance throughout this process and indicated that there are
resources available outside of the RHNA Subcommittee to assist jurisdictions to develop more
housing.
A MOTION was made (Primary Member Wendy Bucknum, Orange County) to move forward the
staff recommended Draft RHNA Methodology to the CEHD Committee. The MOTION was
SECONDED (Primary Member Margaret Finlay, Los Angeles County).
Hon. Rusty Bailey, Riverside County, proposed a substitute motion for a draft RHNA methodology
that would incorporate comments made by Subcommittee ex-officio member Paavo Monkkonen.
The substitute motion would eliminate the "Household Growth 2030-2045" factor from allocating
the existing need so that the existing need allocation methodology would only include 'Population
within HQTAs' and 'Job Accessibility' as factors at a 50-50 ratio.
A SUBSTITUTE MOTION was made (Primary Member Rusty Bailey, Riverside County) to approve this
new option. The SUBSTITUTE MOTION was SECONDED (Primary Member Carmen Ramirez, Ventura
County) and was NOT APPROVED by the following votes:
AYES: Predmore (Imperial County), Bailey (Riverside County), Ramirez (Ventura County)
(3).
NOES: Finlay (Los Angeles County), Bucknum (Orange County), Jahn (San Bernardino
County) (3).
ABSTAIN: None (0).
With the votes resulting in a tie, pursuant to the RHNA Subcommittee Charter, RHNA Subcommittee
Chair Peggy Huang broke the tie with a vote of NO, resulting in this SUBSTITUTE MOTION to NOT
PASS.
President Bill Jahn, San Bernardino County, called to vote on the original motion to move forward
with staff the recommended Draft RHNA Methodology to the CEHD Committee. The original
MOTION was APPROVED by the following votes:
RHNA Subcommittee Meeting-Feb.24,2020
Page 122 of 139
i.
• j0. .
...i"s6"ma
REPORT
AYES: Predmore (Imperial County), Finlay(Los Angeles County), Bucknum (Orange County),
Jahn (San Bernardino County), Ramirez (Ventura County) (5).
NOES: Bailey (Riverside County) (1).
ABSTAIN: None (0).
CHAIR'S REPORT
Chair Peggy Huang announced that there would be a special meeting of the CEHD Committee to
review the Draft RHNA Methodology to be held at the Los Angeles SCAG office on Monday, October
21, 2019.
STAFF REPORT
ANNOUNCEMENT/S
ADJOURNMENT
There being no further business, Chair Peggy Huang adjourned the meeting at 12:23 PM.
The next regular meeting of the RHNA Subcommittee is tentatively scheduled for Monday, January
6, 2019 from 10:00 AM to 12:00 PM at the Wilshire Grand Center, 900 Wilshire Boulevard, Suite
1700, Los Angeles, California 90017.
RHNA Subcommittee Meeting-Feb.24,2020
Page 123 of 139
This Page Intentionally Left Blank
IIilk
-AN= AGENDA ITEM 4
REPORT
Southern California Association of Governments
900 Wilshire Boulevard, Suite 1700, Los Angeles, California 90017
February 24, 2020
To: Regional Housing Needs Assessment Subcommittee (RHNA) EXECUTIVE DIRECTOR'S
APPROVAL
From: Kome Ajise, Executive Director, Executive Management, .�
213-236-1835, Aiise@scag.ca.gov Kz.vv....L.
Subject: State HCD Review Findings of SCAG's Draft RHNA Methodology
RECOMMENDED ACTION:
Receive and File
STRATEGIC PLAN:
This item supports the following Strategic Plan Goal 1: Produce innovative solutions that improve
the quality of life for Southern Californians.
EXECUTIVE SUMMARY:
On January 13, 2020, the state Housing and Community Development (HCD) Department issued
its review findings on SCAG's Draft Regional Housing Needs Assessment (RHNA) Allocation
Methodology. HCD's review finds that SCAG's Draft RHNA Methodology furthers the five
statutory objectives described in state housing law, California Government Code Section 65584(d)
(please see HCD letter attached].
BACKGROUND:
On November 7, 2019, the Regional Council approved the Draft RHNA Allocation Methodology for
HCD's review.
On January 13, 2020, HCD issued its review findings on SCAG's Draft RHNA Allocation Methodology.
HCD's review finds that SCAG's Draft RHNA Methodology furthers the five statutory objectives set
forth in state housing law, California Government Code Section 65584(d). With HCD's review
completed, staff will proceed to recommend the Regional Council-approved Draft RHNA
Methodology as the Final RHNA Methodology(through the RHNA Subcommittee and CEHD) with RC
adoption scheduled on March 5, 2020.
Additionally, in preparing for the upcoming RHNA Appeals process scheduled to begin in April this
year, SCAG held a Workshop on RHNA Appeals on February 3, 2020. The Workshop provided a
preview of the RHNA Appeals Procedures which is also scheduled for RC adoption on March 5, 2020
after it is reviewed by the RHNA Subcommittee and CEHD respectively.
OUR MISSION OUR VISION
To foster innovative regional solutions that improve Southern California's Catalyst for a Brighter Future
the lives of Southern Californians through inclusive
collaboration,visionary planning,regional advocacy, OUR CORE VALUES
information sharing,and promoting best practices. Be Open I Lead by Example I Make an Impact I Be Courageous
RHNA Subcommittee Meeting-Feb.24,2020
Page 124 of 139
.0-v.
REPORT
For additional information about upcoming RHNA-related meetings, please visit SCAG's RHNA
webpage at www.scag.ca.gov/rhna.
FISCAL IMPACT:
None
ATTACHMENT(S):
1. HCD Letter dated, 01-13-2020
RHNA Subcommittee Meeting-Feb.24,2020
Page 125 of 139
AGENDA ITEM 5
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
10/11/2018 City of Beverly Hills Hon.John Mirisch Subcommittee membership
12/2/2018 City of Mission Viejo Gail Shiomoto-Lohr Subcommittee charter,subregional delegation,growth forecast
1/17/2019 City of Beverly Hills Hon.John Mirisch Urban sprawl
2/4/2019 City of Beverly Hills Hon.John Mirisch Role of housing supply,single family homes,subcommittee membership
3/11/2019 City of Beverly Hills Hon.John Mirisch Subcommittee membership,upzoning,single family homes
3/30/2019 City of Beverly Hills Hon.John Mirisch Upzoning,urbanism,density
5/2/2019 Central Cities Association of Los Angeles Jessica Lall Regional Determination
5/6/2019 City of Irvine Marika Poynter Regional determination,existing need distribution,social equity adjustment
5/20/2010 City of Redondo Beach Sean Scully Existing housing need and zoning
5/23/2019 UCLA Luskin School of Public Affairs Paavo Monkkonen Zoning,housing prices,and regulation
5/28/2019 Orange County Council of Governments(OCCOG) Hon.Stacy Berry Regional determination consultation package
5/29/2019 City of Anaheim Chris Zapata Regional determination consultation package
5/31/2019 City of Yorba Linda David Brantley Regional determination consultation package
6/1/2019 City of Mission Viejo Regional determination consultation package;distribution methodology
6/3/2019 City of Newport Beach Seimone Jurjis Regional determination consultation package
6/3/2019 UCLA Paavo Monkkonen Regional determination consultation package
6/4/2019 City of Tustin Elizabeth Binsack Regional determination consultation package
6/4/2019 Henry Fung Public outreach and engagement;regional determination consultation package
6/5/2019 Hunter Owens Regional determination consultation package
6/5/2019 City of Santa Ana Kristine Ridge Regional determination consultation package
6/5/2019 City of Newport Beach Seimone Jurjis Regional determination consultation package
6/5/2019 City of Calabasas Mayor David Shapiro RHNA methodology
6/5/2019 Vyki Englert Regional determination consultation package
6/5/2019 Juan Lopez Regional determination consultation package
6/5/2019 Louis Mirante Regional determination consultation package
6/5/2019 Carter Rubin Regional determination consultation package
6/6/2019 Hon.Meghan Sahli-Wells,City of Culver City Regional determination consultation package
6/5/2019 Andy Freeland Regional determination consultation package
6/5/2019 Eve Bachrach Regional determination consultation package
6/6/2019 Emily Groendyke Regional determination consultation package
6/6/2019 Timothy Hayes Regional determination consultation package
6/6/2019 Carter Moon Regional determination consultation package
6/6/2019 Jesse Lerner-Kinglake Regional determination consultation package
6/6/2019 Alex Fisch Regional determination consultation package
6/6/2019 Jed Lowenthal Regional determination consultation package
6/6/2019 City of Moorpark Karen Vaughn Proposed RHNA Methodology
6/6/2019 City of La Habra Jim Gomez Regional determination package
6/6/2019 County of Orange Supervisor Donald Wagner Regional determination package
6/18/2019 Thomas Glaz Proposed RHNA methodology
6/18/2019 Brendan Regulinski Proposed RHNA methodology
6/18/2019 Chris Palencia Proposed RHNA methodology
6/19/2019 Henry Fung Action on regional determination;proposed RHNA methodology;public hearing
and outreach process
6/21/2019 Glenn Egelko Subcommittee member remarks
6/22/2019 Donna Smith Proposed RHNA methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 126 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
6/24/2019 Fred Zimmerman Regional determination package
6/24/2019 Antoine Wakim Regional determination package
6/24/2019 Darrell Clarke Regional determination package
6/24/2019 Marcos Rodriguez Maciel Regional determination package
6/24/2019 Taylor Hallam Regional determination package
6/24/2019 Phil Lord Regional determination package
6/24/2019 Edwin Woll Regional determination package
6/24/2019 Steven Guerry Regional determination package
6/24/2019 Prabhu Reddy Regional determination package
6/24/2019 Judd Schoenholtz Regional determination package
6/24/2019 Bret Contreras Regional determination package
6/24/2019 Mark Montiel Regional determination package
6/24/2019 Hardy Wronske Regional determination package
6/24/2019 William Wright Regional determination package
6/24/2019 Nicholas Burns Ill Regional determination package
6/24/2019 Brendan Regulinski Regional determination package
6/24/2019 Gabe Rose Regional determination package
6/24/2019 Sean McKenna Regional determination package
6/24/2019 Lolita Nurmamade Regional determination package
6/24/2019 Paul Moorman Regional determination package
6/24/2019 Ryan Welch Regional determination package
6/24/2019 Gerald Lam Regional determination package
6/24/2019 Carol Gordon Regional determination package
6/24/2019 Anthony Dedousis Regional determination package
6/24/2019 Christopher Cooper Regional determination package
6/24/2019 Colin Frederick Regional determination package
6/24/2019 Joe Goldman Regional determination package
6/24/2019 David Douglass-Jaimes Regional determination package
6/24/2019 Liz Barillas Regional determination package
6/24/2019 Andy Freeland Regional determination package
6/24/2019 Grayson Peters Regional determination package
6/24/2019 Andrew Oliver Regional determination package
6/24/2019 Kyle Jenkins Regional determination package
6/24/2019 Matthew Ruscigno Regional determination package
6/24/2019 Amar Billoo Regional determination package
6/24/2019 Joshua Blumenkopf Regional determination package
6/24/2019 Leonora Camner Regional determination package
6/24/2019 Ryan Tanaka Regional determination package
6/24/2019 Partho Kalyani Regional determination package
6/24/2019 Victoria Englert Regional determination package
6/24/2019 Josh Albrektson Regional determination package
6/24/2019 Matt Stauffer Regional determination package
6/24/2019 Brooks Dunn Regional determination package
6/24/2019 Nancy Barba Regional determination package
6/24/2019 Sandra Madera Regional determination package
6/25/2019 Gregory Dina Regional determination package
6/25/2019 Brent Gaisford Regional determination package
6/25/2019 Andrew Kerr Regional determination package
6/25/2019 Hunter Owens Regional determination package
RHNA Subcommittee Meeting-Feb.24,2020
Page 127 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
6/25/2019 Alexander Murray Regional determination package
6/25/2019 Eric Hayes Regional determination package
6/25/2019 Brent Stoll Regional determination package
6/25/2019 Matthew Dixon Regional determination package
6/25/2019 Mark Yetter Regional determination package
6/25/2019 Chase Engelhardt Regional determination package
6/25/2019 Hugh Martinez Regional determination package
6/25/2019 Christopher Palencia Regional determination package
6/25/2019 Nathan Pope Regional determination package
6/25/2019 Lauren Borchard Regional determination package
6/25/2019 Shane Philips Regional determination package
6/25/2019 Alexander Naylor Regional determination package
6/25/2019 Andy May Regional determination package
6/25/2019 Jon Dearing Regional determination package
6/25/2019 David Barboza Regional determination package
6/26/2019 Sofia Tablada Regional determination package
6/26/2019 Amanda Wilson Regional determination package
6/26/2019 Mike Bettinardi Regional determination package
6/26/2019 Emily Skehan Regional determination package
6/26/2019 City of Long Beach Patrick West Proposed RHNA methodology
6/27/2019 Jesse Silva Regional determination package
6/27/2019 Ryan Rubin Regional determination package
6/27/2019 City of Garden Grove Mayor Steve Jones Regional determination package;proposed RHNA methodology
6/27/2019 County of Los Angeles Amy Bodek Proposed RHNA methodology
6/28/2019 Maggie Rattay Regional determination package
6/28/2019 Brittney Hojo Regional determination package
6/28/2019 Thomas Irwin Regional determination package
6/28/2019 Steph Pavon Regional determination package
7/3/2019 Tyler Lindberg Regional determination package
7/3/2019 Ji Son Regional determination package
7/3/2019 David Kitani Regional determination package
7/3/2019 Chase Andre Regional determination package
7/3/2019 Taily Pulido Regional determination package
7/5/2019 Stephanie Palencia Regional determination package
7/6/2019 Charlie Stigler Regional determination package
7/8/2019 Chris Rattay Regional determination package
7/9/2019 Holly Osborne Proposed RHNA Methodology
7/9/2019 City of Ojai James Vega Proposed RHNA Methodology
7/10/2019 City of South Gate Joe Perez Proposed RHNA Methodology
7/11/2019 City of Malibu Reva Feldman Proposed RHNA Methodology
7/16/2019 City of Los Angeles,15th District Aksel Palacios Affordable Housing Solutions
7/17/2019 City of Culver City Mayor Meghan Sahli-Wells Regional Determination
7/18/2019 League of Women Voters of Los Angeles Sandra Trutt Zoning and Homelessness
7/18/2019 County of Riverside Juan Perez Proposed RHNA allocation
7/19/2019 League of Women Voters of Los Angeles County Marge Nichols Regional Determination
7/20/2019 Therese Mufic Neustaedter Regional Determination
7/23/2019 County of Ventura—Board of Supervisors Supervisor Steve Bennett Proposed RHNA Methodology
7/25/2019 Jose Palencia Regional Determination
RHNA Subcommittee Meeting-Feb.24,2020
Page 128 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
7/27/2019 Henry Fung Proposed RHNA Methodology
7/29/2019 Paavo Monkkonen Proposed RHNA Methodology
7/29/2019 Paavo Monkkonen Proposed RHNA Methodology
7/29/2019 Endangered Habitats League Dan Silver Proposed RHNA methodology
7/31/2019 League of Women Voters Los Angeles County Marge Nichols Regional Determination;Proposed RHNA Methodology
7/31/2019 City of Beverly Hills Mayor John Mirisch Proposed RHNA Methodology
7/31/2019 City of Beverly Hills Mayor John Mirisch Proposed RHNA Methodology
7/31/2019 Assm.Richard Bloom Proposed RHNA Methodology
8/1/2019 League of Women Voters Santa Monica Natalya Zernitskaya Proposed RHNA Methodology
8/1/2019 City of Malibu Bonnie Blue Proposed RHNA Methodology;SB 182
8/1/2019 People for Housing OC Elizabeth Hansburg Regional Determination
8/1/2019 City of Big Bear Lake Jeff Matthieu Proposed RHNA Methodology
8/2/2019 Donna Smith ?
8/4/2019 Gary Drucker Proposed RHNA Methodology
8/5/2019 Valerie Fontaine Proposed RHNA Methodology
8/5/2019 Jay Ross Proposed RHNA Methodology
8/7/2019 Miriam Cantor Proposed RHNA Methodology
8/8/2019 Jonathan Baty Population growth
8/12/2019 City of Yucaipa Proposed RHNA methodology
8/12/2019 Paul Lundquist ?
8/12/2019 Leonora Camner Proposed RHNA Methodology
8/12/2019 Ryan Tanaka Proposed RHNA Methodology
8/12/2019 Jesse Silva Proposed RHNA Methodology
8/12/2019 Joshua Gray-Emmer Proposed RHNA Methodology
8/12/2019 Chase Engelhardt Proposed RHNA Methodology
8/12/2019 Drew Heckathorn Proposed RHNA Methodology
8/12/2019 Liz Barillas Proposed RHNA Methodology
8/12/2019 Jonah Bliss Proposed RHNA Methodology
8/12/2019 Angus Beverly Proposed RHNA Methodology
8/12/2019 Gregory Dina Proposed RHNA Methodology
8/12/2019 Eduardo Mendoza Proposed RHNA Methodology
8/12/2019 Carol Gordon Proposed RHNA Methodology
8/12/2019 Joanne Leavitt Proposed RHNA Methodology
8/12/2019 Mark Yetter Proposed RHNA Methodology
8/12/2019 Meredith Jung Proposed RHNA Methodology
8/12/2019 Nicholas Burns Ill Proposed RHNA Methodology
8/12/2019 Judd Scoenholtz Proposed RHNA Methodology
8/12/2019 Lee Benson Proposed RHNA Methodology
8/12/2019 Kate Poisson Proposed RHNA Methodology
8/12/2019 Joshua Blumenkopf Proposed RHNA Methodology
8/12/2019 Anthony Dedousis Proposed RHNA Methodology
8/12/2019 Christopher Tausanovitch Proposed RHNA Methodology
8/12/2019 Emerson Dameron Proposed RHNA Methodology
8/12/2019 Grayson Peters Proposed RHNA Methodology
8/12/2019 Tami Kagan-Abrams Proposed RHNA Methodology
8/12/2019 Lauren Borchard Proposed RHNA Methodology
8/12/2019 Alec Mitchell Proposed RHNA Methodology
8/12/2019 Andy Freeland Proposed RHNA Methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 129 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
8/12/2019 Michelle Castelletto Proposed RHNA Methodology
8/12/2019 Brent Gaisford Proposed RHNA Methodology
8/12/2019 Rebecca Mull Proposed RHNA Methodology
8/12/2019 Ryan Welch Proposed RHNA Methodology
8/12/2019 Prabhu Reddy Proposed RHNA Methodology
8/12/2019 Matthew Dixon Proposed RHNA Methodology
8/12/2019 Richard Hofmeister Proposed RHNA Methodology
8/12/2019 David Barboza Proposed RHNA Methodology
8/12/2019 Michael Drowsky Proposed RHNA Methodology
8/12/2019 Allison Wong Proposed RHNA Methodology
8/13/2019 Justin Jones Proposed RHNA Methodology
8/13/2019 Yurhe Lim Proposed RHNA Methodology
8/13/2019 Ryan Koyanagi Proposed RHNA Methodology
8/13/2019 William Wright Proposed RHNA Methodology
8/13/2019 Norma Guzman Proposed RHNA Methodology
8/13/2019 Mary Vaiden Proposed RHNA Methodology
8/13/2019 Andy May Proposed RHNA Methodology
8/13/2019 Gerald Lam Proposed RHNA Methodology
8/13/2019 Kelly Koldus Proposed RHNA Methodology
8/13/2019 Thomas Irwin Proposed RHNA Methodology
8/14/2019 Susan Decker Proposed RHNA Methodology
8/14/2019 Michael Busse Proposed RHNA Methodology
8/14/2019 Rosa Flores Proposed RHNA Methodology
8/14/2019 Pedro Juarez Proposed RHNA Methodology
8/14/2019 Zennon Ulyate-Crow Proposed RHNA Methodology
8/16/2019 Ron Javorsky
8/16/2019 County of Riverside Robert Flores RHNA Public Outreach
8/17/2019 Marianne Buchanan
8/17/2019 Carolyn Byrnes Other
8/17/2019 Sharon Willkins
8/17/2019 Natalya Zernitskaya Proposed RHNA Methodology
8/19/2019 Kawauna Reed
8/19/2019 Hon.Manuel Chavez(Costa Mesa Councilmember,District 4) Proposed RHNA Methodology
Cassius Rutherford(Parks Commissioner,Costa Mesa)
Chris Gaarder(Planning Commission Chair,Fullerton)
Brandon Whalen-Castellanos(Transportation Commission Chair,Fullerton)
Luis Aleman(Parks Commission,Santa Ana)
8/19/2019 Theopilis Hester Proposed RHNA Methodology
8/20/2019 City of Santa Monica Rick Cole Proposed RHNA Methodology
8/20/2019 City of Rancho Palos Verdes Octavio Silva Proposed RHNA Methodology
8/20/2019 City of Yorba Linda Mayor Tara Campbell Proposed RHNA Methodology
8/22/2019 City of Redondo Beach Mayor William Brand Proposed RHNA Methodology
8/22/2019 Orange County Council of Governments(OCCOG) Marnie 0.Primmer Proposed RHNA Methodology
8/23/2019 Bruce Szekes Public Outreach
8/23/2019 Center for Demographic Research Proposed RHNA Methodology
8/23/2019 Laura Smith Housing Distribution
8/23/2019 City of Beverly Hills Mayor John Mirisch Proposed RHNA Methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 130 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
8/24/2019 Sharon Commins Proposed RHNA Methodology
8/26/2019 City of El Segundo Proposed RHNA Methodology
8/26/2019 Sean McKenna Proposed RHNA Methodology
8/26/2019 Mark Chenevey Proposed RHNA Methodology
8/26/2019 Derek Ryder Proposed RHNA Methodology
8/26/2019 City of Long Beach Patrick West Proposed RHNA Methodology
8/27/2019 City of Mission Viejo Elaine Lister Proposed RHNA Methodology data correction
8/27/2019 Shawn Danino Proposed RHNA Methodology
8/27/2019 Jeffery Alvarez Proposed RHNA Methodology
8/27/2019 Claudia Vu Proposed RHNA Methodology
8/27/2019 Laila Delgado Proposed RHNA Methodology
8/27/2019 Madeline Swim Proposed RHNA Methodology
8/27/2019 Nicholas Paganini Proposed RHNA Methodology
8/27/2019 David Aldama Proposed RHNA Methodology
8/27/2019 Hannah Winnie Proposed RHNA Methodology
8/27/2019 Akif Khan Proposed RHNA Methodology
8/27/2019 Gianna Lum Proposed RHNA Methodology
8/27/2019 Bradley Ewing Proposed RHNA Methodology
8/27/2019 Anne Martin Proposed RHNA Methodology
8/27/2019 Mylen Walker Proposed RHNA Methodology
8/27/2019 Verity Freebern Proposed RHNA Methodology
8/27/2019 Ryan Oillataguerre Proposed RHNA Methodology
8/27/2019 Emma Desopo Proposed RHNA Methodology
8/27/2019 Elyssa Medina Proposed RHNA Methodology
8/27/2019 Judith Trujillo Proposed RHNA Methodology
8/27/2019 Kenia Agaton Proposed RHNA Methodology
8/27/2019 OC Business Council Alicia Berhow Proposed RHNA Methodology
8/27/2019 Palms Neighborhood Council Eryn Block Proposed RHNA Methodology
8/27/2019 County of Riverside Juan Perez Proposed RHNA Methodology
8/28/2019 Sophia Parmisano Proposed RHNA Methodology
8/28/2019 Anthony Castelletto Proposed RHNA Methodology
8/28/2019 Minh Le Proposed RHNA Methodology
8/28/2019 Carol Luong Proposed RHNA Methodology
8/28/2019 Chitra Patel Proposed RHNA Methodology
8/28/2019 Misha Ponnuraju Proposed RHNA Methodology
8/27/2019 Griffin McDaniel Proposed RHNA Methodology
8/28/2019 Lauren Walker Proposed RHNA Methodology
8/28/2019 Robert Flores Proposed RHNA Methodology
8/28/2019 Halley Maxwell Proposed RHNA Methodology
8/28/2019 Carey Kayser Proposed RHNA Methodology
8/28/2019 Annie Bickerton Proposed RHNA Methodology
8/29/2019 City of Fullerton Matt Foulkes Proposed RHNA Methodology
8/29/2019 City of Norco Steve King Proposed RHNA Methodology
8/29/2019 City of Signal Hill Mayor Lori Wood Proposed RHNA Methodology
8/29/2019 SCAN PH Francisco Martinez Proposed RHNA Methodology
8/29/2019 Ross Heckmann Proposed RHNA Methodology
8/30/2019 Dottie Alexanian Proposed RHNA Methodology
8/30/2019 Judith Deutsch Proposed RHNA Methodology
8/30/2019 City of Tustin Elizabeth Binsack Proposed RHNA Methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 131 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
8/30/2019 City of Menifee Cheryl Kitzerow Proposed RHNA Methodology
8/31/2019 Paavo Monkkonen Proposed RHNA Methodology
8/31/2019 Paavo Monkkonen and 27 professors Proposed RHNA Methodology
8/31/2019 Ryan Kelly Proposed RHNA Methodology
8/31/2019 Hydee Feldstein Proposed RHNA Methodology
8/31/2019 Alex Ivina Proposed RHNA Methodology
8/31/2019 Steve Rogers Proposed RHNA Methodology
8/31/2019 Phil Davis Proposed RHNA Methodology
8/31/2019 Kathy Hersh Proposed RHNA Methodology
9/1/2019 Jane Demian Proposed RHNA Methodology
9/1/2019 Diana Stiller Proposed RHNA Methodology
9/1/2019 Paula Bourges Proposed RHNA Methodology
9/1/2019 Raymond Goldstone Proposed RHNA Methodology
9/1/2019 Christopher Palencia Proposed RHNA Methodology
9/2/2019 Doris Roach Proposed RHNA Methodology
9/3/2019 Judy Saunders Proposed RHNA Methodology
9/3/2019 Susan Ashbrook Proposed RHNA Methodology
9/3/2019 Marcelo&Irene Olavarria Proposed RHNA Methodology
9/3/2019 Margret Healy Proposed RHNA Methodology
9/3/2019 Genie Saffren Proposed RHNA Methodology
9/3/2019 City of Rancho Santa Margarita Cheryl Kuta Proposed RHNA Methodology
9/3/2019 City of Corona Joanne Coletta Proposed RHNA Methodology
9/3/2019 City of Desert Hot Springs Rebecca Deming Proposed RHNA Methodology
9/3/2019 Karen Boyarsky Regional Determination
9/3/2019 Nancee L. Proposed RHNA Methodology
9/3/2019 Tracy St.Claire Regional Determination
9/4/2019 Shelly Carlo Housing Distribution
9/4/2019 Bill Zimmerman Proposed RHNA Methodology
9/4/2019 Mark Vallianatos Proposed RHNA Methodology
9/4/2019 Marilyn Frost Housing Distribution
9/4/2019 Matthew Stevens Proposed RHNA Methodology
9/4/2019 Georgianne Cowan Regional Determination
9/4/2019 Lisa Schecter Regional Determination
9/4/2019 Carol Watkins Regional Determination
9/4/2019 Mark Robbins Regional Determination
9/4/2019 Susan Horn Regional Determination
9/4/2019 Barbara Broide Regional Determination
9/4/2019 Joseph Sherwood Regional Determination
9/4/2019 Linda Sherwood Regional Determination
9/4/2019 Darren Swimmer Regional Determination
9/4/2019 Lee Zeldin Regional Determination
9/4/2019 Nancy Rae Stone Regional Determination
9/4/2019 Rachael Gordon Regional Determination
9/4/2019 Martha Singer Regional Determination
9/4/2019 Laurie Balustein Regional Determination
9/4/2019 Henry Fung Regional Determination
9/4/2019 Brad Pennington Regional Determination
9/4/2019 Mike Javadi Regional Determination
9/4/2019 Lauren Thomas Regional Determination
RHNA Subcommittee Meeting-Feb.24,2020
Page 132 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
9/4/2019 Keith Solomon Regional Determination
9/4/2019 Linda Blank Regional Determination
9/4/2019 Valerie Brucker Regional Determination
9/4/2019 Craig Rich Regional Determination
9/4/2019 Wansun Song Regional Determination
9/4/2019 Robert Seligman Regional Determination
9/4/2019 City of Newport Beach Seimone Jurjis Regional Determination
9/4/2019 City of Calabasas Mayor David Shapiro Regional Determination
9/4/2019 Paul Soroudi Regional Determination
9/4/2019 Terrence Gomes Regional Determination
9/4/2019 Kimberly Fox Regional Determination
9/4/2019 Mra Tun Regional Determination
9/4/2019 Laura Levine Lacter Regional Determination
9/4/2019 Stephen Resnick Regional Determination
9/4/2019 Kimberly Christensen Regional Determination
9/4/2019 Rita Villa Regional Determination
9/4/2019 City of San Clemente James Makshanoff Proposed RHNA Methodology
9/4/2019 City of Beaumont Julio Martinez Proposed RHNA Methodology
9/4/2019 City of Hawthorne Arnold Shadbehr Proposed RHNA Methodology
9/5/2019 City of Murrieta Mayor Kelly Seyarto Proposed RHNA Methodology
9/5/2019 City of Canyon Lake Jim Morrissey Proposed RHNA Methodology
9/5/2019 Hunter Owens Proposed RHNA Methodology
9/5/2019 Stephen Twining Regional Determination
9/5/2019 Paul Callinan Regional Determination
9/5/2019 C.McAlpin Regional Determination
9/5/2019 Isabel Janken Regional Determination
9/5/2019 Ann Hayman Regional Determination
9/5/2019 Meg Sullivan Housing Production
9/5/2019 City of Moreno Valley Patty Nevins Proposed RHNA Methodology
9/5/2019 Massy Mortazavi Regional Determination
9/5/2019 Fred Golan Regional Determination
9/5/2019 Debbie&Howard Nussbaum Regional Determination
9/5/2019 Devony Hastings Regional Determination
9/5/2019 League of Women Voters of Los Angeles County Marge Nichols RHNA Methodology
9/5/2019 Larry Blugrind Housing Distribution
9/5/2019 Terry Tegnazian Regional Determination
9/5/2019 Gateway Cities Council of Governments(GCCOG) M.Diane DuBois RHNA Methodology
9/5/2019 Denson Fujikawa Other
9/5/2019 Tracy Fitzgerald Regional Determination
9/5/2019 City of Pomona Anita Gutierrez Proposed RHNA Methodology
9/5/2019 Minhlinh Nguyen Regional Determination
9/5/2019 Anita Gutierrez Proposed RHNA Methodology
9/5/2019 City of Fountain Valley Steve Nagel Proposed RHNA Methodology
9/5/2019 City of Camarillo Kevin Kildee Proposed RHNA Methodology
9/5/2019 Denson Fujikawa Other
9/6/2019 City of Sierra Madre Gabriel Engeland Proposed RHNA Methodology
9/6/2019 City of Laguna Hills Donald White Proposed RHNA Methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 133 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
9/6/2019 David Oliver Regional Determination
9/6/2019 City of Chino Hills Joann Lombardo Proposed RHNA Methodology
9/7/2019 David Ting Regional Determination
9/9/2019 City of Azusa Sergio Gonzalez Proposed RHNA Methodology
9/9/2019 City of Alhambra Jessica Binnquist Proposed RHNA Methodology
9/9/2019 Los Angeles Chamber of Commerce Maria Salinas RHNA Methodology
9/9/2019 City of Ranchos Palos Verdes Octavio Silva Proposed RHNA Methodology
9/9/2019 Kathy Whooley Regional Determination
San Gabriel Valley Council of Governments
9/9/2019(SGVCOG) Cynthia Sternquist Proposed RHNA Methodology
9/9/2019 Matthew Hinsley Regional Determination
9/9/2019 City of Agoura Hills Greg Ramirez Proposed RHNA Methodology
9/10/2019 City of Redondo Beach Laura Emdee Regional Determination
9/10/2019 Jessica Sandoval Proposed RHNA Methodology
9/10/2019 City of Redondo Beach Bill Brand Proposed RHNA Methodology
9/10/2019 Yesenia Medina Regional Determination
9/10/2019 Jeannette Mazul Regional Determination
9/10/2019 Jocelyne lrineo Proposed RHNA Methodology
9/10/2019 Cristina Resendez Proposed RHNA Methodology
9/10/2019 Carla Bucio Proposed RHNA Methodology
9/10/2019 City of Redondo Beach Bill Brand Proposed RHNA Methodology
9/10/2019 City of Redondo Beach Laura Emdee Proposed RHNA Methodology
9/10/2019 City of Garden Grove Steve Jones Proposed RHNA Methodology
9/10/2019 Henry Fung Overall RHNA Process
9/10/2019 City of San Marino Aldo Cervantes Proposed RHNA Methodology
9/10/2019 City of South Gate Jorge Morales Proposed RHNA Methodology
9/10/2019 City of Torrance Patrick Furey Proposed RHNA Methodology
9/10/2019 City of Rancho Cucamonga John Gillison Proposed RHNA Methodology
9/10/2019 Jeannette Mazul Affordable Housing
9/10/2019 Tina Kim Proposed RHNA Methodology
9/11/2019 City of South Pasadena Stephanie DeWolfe Proposed RHNA Methodology
9/11/2019 City of Glendora Jeff Kugel Proposed RHNA Methodology
9/11/2019 City of Ojai John F.Johnson Proposed RHNA Methodology
9/11/2019 City of Oxnard Tim Flynn Proposed RHNA Methodology
9/11/2019 City of Westlake Village Ned E.Davis Proposed RHNA Methodology
9/11/2019 City of Cerritos Art Gallucci Proposed RHNA Methodology
9/11/2019 City of Hemet Christopher Lopez Proposed RHNA Methodology
9/11/2019 City of La Palma Laurie Murray Proposed RHNA Methodology
9/11/2019 City of Bell Ali Saleh Proposed RHNA Methodology
9/11/2019 Karen Rivera Regional Determination
9/11/2019 David Coffin Regional Determination
9/12/2019 City of Lomita Alicia Velasco Proposed RHNA Methodology
9/12/2019 City of Wildomar Matthew Bassi Proposed RHNA Methodology
9/12/2019 City of Aliso Viejo David Doyle Proposed RHNA Methodology
9/12/2019 City of Commerce Vilko Domic Proposed RHNA Methodology
9/12/2019 City of El Monte Betty Donavanik Proposed RHNA Methodology
South Bay Cities Council of Governments
9/12/2019(SBCCOG) Christian Horvath Proposed RHNA Methodology
9/12/2019 City of Huntington Beach Dave Kiff Proposed RHNA Methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 134 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
9/12/2019 City of Rosemead Gloria Molleda Proposed RHNA Methodology
9/12/2019 City of Dana Point Matt Schneider Proposed RHNA Methodology
9/12/2019 City of Placentia Rhonda Shader Proposed RHNA Methodology
9/12/2019 City of Palos Verdes Estates Carolynn Petru Proposed RHNA Methodology
9/12/2019 City of Palmdale Mark Oyler Proposed RHNA Methodology
9/12/2019 City of Hawthorne Alejandro Vargas Proposed RHNA Methodology
9/12/2019 City of Irvine Mayor Christina L.Shea Proposed RHNA Methodology
9/12/2019 City of Walnut Rob Wishner Proposed RHNA Methodology
9/12/2019 City of Maywood Jennifer Vasquez Proposed RHNA Methodology
9/12/2019 City of Culver City Meghan Sahli-Wells Proposed RHNA Methodology
9/12/2019 City of Buena Park Joel Rosen Proposed RHNA Methodology
9/12/2019 City of Santa Clarita Thomas Cole Proposed RHNA Methodology
9/12/2019 City of Temecula Luke Watson Proposed RHNA Methodology
9/12/2019 City of Lake Elsinore Richard MacHott Proposed RHNA Methodology
9/12/2019 City of San Dimas Ken Duran Proposed RHNA Methodology
9/12/2019 City of Irwindale William Tam Proposed RHNA Methodology
9/12/2019 City of Santa Ana Kristine Ridge Proposed RHNA Methodology
9/12/2019 City of La Mirada Jeff Boynton Proposed RHNA Methodology
9/12/2019 City of Anaheim Chris Zapata Proposed RHNA Methodology
9/12/2019 City of Costa Mesa Lori Ann Farrell Harrison Proposed RHNA Methodology
9/12/2019 City of Huntington Park Sergio Infanzon Proposed RHNA Methodology
9/12/2019 Westside Neighborhood Council Terri Tippit Proposed RHNA Methodology
9/12/2019 City of Eastvale Bryan Jones Proposed RHNA Methodology
9/12/2019 John Birkett Regional Determination
9/12/2019 Lourdes Petersen Regional Determination
9/12/2019 Jesse Silva Proposed RHNA Methodology
9/12/2019 Anne Hilborn Proposed RHNA Methodology
9/12/2019 Henry Fung Proposed RHNA Methodology
9/13/2019 Holly Osborne Proposed RHNA Methodology
9/13/2019 Niall Huffman Proposed RHNA Methodology
9/13/2019 Michael Hoskinson Proposed RHNA Methodology
San Bernardino County Transportation
9/13/2019 Authority/Council of Governments Darcy McNaboe Proposed RHNA Methodology
(SBCTA/SBCOG)
9/13/2019 City of Downey Aldo Schindler Proposed RHNA Methodology
9/13/2019 City of Bellflower Elizabeth Corpuz Proposed RHNA Methodology
9/13/2019 City of Lakewood Abel Avalos Proposed RHNA Methodology
9/13/2019 City of Orange Rick Otto Proposed RHNA Methodology
9/13/2019 City of Paramount John Carver Proposed RHNA Methodology
9/13/2019 City of Rolling Hills Jeff Pieper Proposed RHNA Methodology
9/13/2019 City of San Fernando Nick Kimball Proposed RHNA Methodology
9/13/2019 City of Mission Viejo Dennis Wilberg Proposed RHNA Methodology
9/13/2019 City of Moorpark Karen Vaughn Proposed RHNA Methodology
9/13/2019 American Planning Association(CA Chapter) Eric Phillips Proposed RHNA Methodology
9/13/2019 County of Ventura David Ward Proposed RHNA Methodology
9/13/2019 City of Chino Nicholas Liguori Proposed RHNA Methodology
9/13/2019 One Step A La Vez Kate English Housing Development
9/13/2019 American Planning Association(Los Angeles Ryan Kurtzman Proposed RHNA Methodology
Section)
RHNA Subcommittee Meeting-Feb.24,2020
Page 135 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
9/13/2019 City of Laguna Beach Scott Drapkin Proposed RHNA Methodology
9/13/2019 Santa Monicans for Renters'Rights Patricia Hoffman and Denny Zane Proposed RHNA Methodology
Western Riverside Council of Governments
9/13/2019(WRCOG) Rick Bishop Proposed RHNA Methodology
9/13/2019 City of Los Angeles Mayor Eric Garcetti Proposed RHNA Methodology
9/13/2019 City of West Hollywood Mayor John D'Amico Proposed RHNA Methodology
9/13/2019 City of San Juan Capistrano Joel Rojas Proposed RHNA Methodology
9/13/2019 City of Thousand Oaks Mark Towne Proposed RHNA Methodology
9/13/2019 City of Newport Beach Seimone Jurjis Proposed RHNA Methodology
9/13/2019 City of Laguna Niguel Jonathan Orduna Proposed RHNA Methodology
9/13/2019 County of San Bernardino Terri Rahhal Proposed RHNA Methodology
9/13/2019 City of Indio Kevin Snyder Proposed RHNA Methodology
9/13/2019 City of Avalon Anni Marshall Proposed RHNA Methodology
9/13/2019 City of Burbank Patrick Prescott Proposed RHNA Methodology
9/13/2019 City of Santa Monica Housing Commission Michael Soloff Proposed RHNA Methodology
9/13/2019 City of Riverside Jay Eastman Proposed RHNA Methodology
9/13/2019 City of Whittier Conal McNamara Proposed RHNA Methodology
9/13/2019 City of San Gabriel Armine Chaparyan Proposed RHNA Methodology
9/13/2019 City of San Buenaventura(Ventura) Peter Gilli Proposed RHNA Methodology
9/13/2019 City of Temple City Scott Reimers Proposed RHNA Methodology
9/13/2019 City of Palm Desert Ryan Stendell Proposed RHNA Methodology
9/13/2019 City of Monterey Park Ron Bow Proposed RHNA Methodology
9/13/2019 LA Thrives Et Al.(19 total organizations) LA Thrives Et Al.(19 total organizations) Proposed RHNA Methodology
Leadership Council for Justice and Accountability
9/13/2019 Leadership Council for Justice and Accountability Et Al.(7 total organizations) Proposed RHNA Methodology
Et Al.(7 total organizations)
Southern California Business Coalition(7 total
9/13/2019 Southern California Business Coalition(7 total organizations) Proposed RHNA Methodology
organizations)
9/15/2019 Michelle Schumacher Other
9/30/2019 Homeowners of Encino Eliot Cohen Proposed RHNA Methodology
9/30/2019 Trudy Sokol Other
10/1/2019 City of Barstow Michael Massimini Proposed RHNA Methodology
10/2/2019 County of Orange Supervisor Donald Wagner Draft RHNA Methodology
10/3/2019 County of Riverside Charissa Leach Draft RHNA Methodology
10/4/2019 City of Irvine Mayor Christina L.Shea Draft RHNA Methodology
10/6/2019 UCLA Luskin School of Public Affairs Paavo Monkkonen Draft RHNA Methodology
10/7/2019 City of Costa Mesa Lori Ann Farrell Harrison Draft RHNA Methodology
South Bay Cities Council of Governments
10/8/2019(SBCCOG) Christian Horvath Draft RHNA Methodology
10/9/2019 Del Rey Residents Association Tara Walden Other
10/10/2019 Karen Davis Ferlauto Other
10/11/2019 Abundant Housing LA David Bonaccorsi Draft RHNA Methodology
10/11/2019 City of Oxnard Mayor Tim Flynn Draft RHNA Methodology
10/16/2019 County of Riverside Charissa Leach Draft RHNA Methodology
10/21/2019 City of Newport Beach Seimone Jurjis Draft RHNA Methodology
San Bernardino County Transportation
Authority/Council of Governments
10/21/2019(SBCTA/SBCOG) Ray Wolfe Draft RHNA Methodology
10/23/2019 Barbara Broide Draft RHNA Methodology
10/23/2019 County of Riverside Supervisor Kevin Jeffries Draft RHNA Methodology
RHNA Subcommittee Meeting-Feb.24,2020
Page 136 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
10/25/2019 Robert Flores Draft RHNA Methodology
10/25/2019 Reed Bernet Draft RHNA Methodology
10/29/2019 Rancho Palos Verdes Ana Mihranian Draft RHNA Methodology
10/28/2019 Warren Hogg Draft RHNA Methodology
10/29/2019 City of Coachella Luis Lopez Draft RHNA Methodology
10/31/2019 Marilyn Brown Purpose of RHNA
Mayor Rusty Bailey(City of Riverside)
11/1/2019 Supervisor Karen Spiegel(County of Riverside) Draft RHNA Methodology
Mayor Frank Navarro(City of Colton)
Hon.Toni Momberger(City of Redlands)
11/1/2019 City of Los Angeles,4th District Hon.David Ryu Draft RHNA Methodology
11/4/2019 Central Cities Association of Los Angeles Jessica Lail Draft RHNA Methodology
11/5/2019 Orange County Council of Governments(OCCOG) Marnie 0.Primmer Draft RHNA Methodology
11/5/2019 City of Gardena Mayor Tasha Cerda Draft RHNA Methodology
11/5/2019 City of Los Angeles Vincent P.Bertoni and Kevin J.Keller Draft RHNA Methodology
11/5/2019 City of Huntington Beach Oliver Chi Draft RHNA Methodology
11/6/2019 City of Hemet Christopher Lopez Draft RHNA Methodology
11/6/2019 City of Chino Nicholos S.Liguori Draft RHNA Methodology
11/6/2019 City of Menifee Cheryl Kitzerow Draft RHNA Methodology
11/6/2019 County of Los Angeles Sachi A.Hamai Draft RHNA Methodology
11/6/2019 City of Newport Beach Seimone Jurjis Draft RHNA Methodology
11/6/2019 City of Fontana Michael Milhiser Draft RHNA Methodology
11/6/2019 City of Chino Hills Joann Lombardo Draft RHNA Methodology
11/6/2019 Henry Fung Regional Determination
11/6/2019 City of Costa Mesa Barry Curtis Draft RHNA Methodology
11/7/2019 City of Temple City Scott Reimers Draft RHNA Methodology
11/8/2019 Gateway Cities Council of Governments(GCCOG) Nancy Pfeffer Draft RHNA Methodology
11/20/2019 City of Huntington Beach Michael Gates,Mayor Erik Peterson,and Mayor Pro Tem Lyn Semeta Draft RHNA Methodology
12/12/2019 Holly Osborne Draft RHNA Methodology
12/12/2019 City of Tustin Allan Bernstein Draft RHNA Methodology
12/19/2019 City of Fountain Valley Mayor Cheryl Brothers Draft RHNA Methodology
12/16/2019 City of Chino Hills Joann Lombardo Draft RHNA Methodology
12/20/2019 City of Cerritos Naresh Solanki Draft RHNA Methodology
1/23/2020 Karen Farley Draft RHNA Methodology
1/23/2020 Steve Stowell Draft RHNA Methodology
1/27/2020 Janet Chang Draft RHNA Methodology
1/29/2020 City of Downey Mayor Blanca Pacheco Draft RHNA Methodology
2/4/2020 City of Cerritos Mayor Naresh Solanki Draft RHNA Methodology
2/6/2020 Steve Davey Draft RHNA Methodology
2/6/2020 Connie Bryant Draft RHNA Methodology
2/6/2020 Tom Wright Draft RHNA Methodology
2/10/2020 City of Irvine Marika Poynter Draft Appeals Procedures
2/10/2020 City of Laguna Hills David Chantarangsu Draft Appeals Procedures
2/10/2020 City of Mission Viejo Gail Shiomoto-Lohr Draft Appeals Procedures
2/10/2020 City of Santa Ana Melanie McCann Draft Appeals Procedures
2/10/2020 City of Oxnard Elyssa Vasquez Draft Appeals Procedures
2/10/2020 Jennifer Denmark Draft Appeals Procedures
RHNA Subcommittee Meeting-Feb.24,2020
Page 137 of 139
Written Comments Received on the 6th Cycle RHNA(as of 2/6/20)
Date of Letter Organization Name Topic(s)
All comments are posted online at www.scag.ca.gov/rhna.Comments can be submitted to:housing@scag.ca.gov
RHNA Subcommittee Meeting-Feb.24,2020
Page 138 of 139
This Page Intentionally Left Blank
AGENDA ITEM 6
DEVELOPMENT TIMELINE
6TH CYCLE RHNA (subject to change)
12/2018-08/2019 solo
Regional Determination
Process
02/2019-11/2019 Planning Factor/AFFH Survey Release
fogy Planning Factor/AFFH Survey Due Date:04/30/2019
Development
Notification to Subregional Delegation
Hearing on Subregional Delegation Determination(if needed)
Last Day for HCD to provide Final Regional Determination;
Public Hearings on Proposed RHNA Methodology
11/2019-1/2020 DE(
HCD Review 2020
JAr.
FEE
MAF Adoption of Final RHNA Methodolgy
APR Distribution of Draft RHNA Allocation
04/2020-07/2020 MA,
Draft RHNA
Appeals Process
RHNA Appeals Hearings
Proposed Final RHNA Allocation
The 6th RHNA cycle covers the housing element planning
EF
period of October 2021 through October 2029.Major
milestones for jurisdictions include the development of Adoption of Final RHNA Allocation
the RHNA methodology,distribution of the draft RHNA
allocation,the appeals process,and the adoption of the
final RHNA allocation.Housing elements for the 6th cycle
RHNA are due to HCD in October 2021.
Public Participation:Stakeholders and members of
the public are welcome to attend all public hearings
and meetings,including the RHNA Subcommittee,and 10/2021:Housing Elements Due
provide comments throughout the RHNA process.Dates
for upcoming RHNA workshops and Subcommittee
meetings are posted at scag.ca.gov/rhna.Comments
and questions regarding RHNA can also be emailed to
housirlg(A7scag.Ca.gov. RHNA Subcommittee Meeting-Feb.24,2020
Page 139 of 139 ® please recycle 2909.2020.01.21
E MA I
ik
ti O
C!`Jic r'RDE
-44111 .7
*cORPOR-D 0%
Attachment B
SCAG RHNA Methodology:
Staff Recommendation and 10/7 Substitute Motion
SCAG RHNA METHODOLOGY:STAFF RECOMMENDATION AND 10/7 SUBSTITUTE MOTION
TOTALS BY CITY
Count Subregion City2019 Staff 10/7 Substitute Inc./Dec.to
Y g Population Recommendation Motion Difference Staff Recom.
Imperial Imperial Brawley city 27,337 2,855 1420 -1435 -50.26%
Imperial Imperial Calexico city 42,198 5,462 4731 -731 -13.38%
Imperial Imperial Calipatria city 7,281 310 150 -160 -51.61%
Imperial Imperial El Centro city 46,248 5,141 3421 -1720 -33.46%
Imperial Imperial Holtville city 6,779 306 170 -136 -44.44%
Imperial Imperial Imperial city 19,929 2,703 1596 -1107 -40.95%
Imperial Imperial Westmorland city 2,461 23 33 10 43.48%
Imperial Unincorporated Unincorporated 38,033 4,815 4347 -468 -9.72%
Los Angeles Arroyo Verdugo Burbank city 105,952 7,802 9018 1216 15.59%
Los Angeles Arroyo Verdugo Glendale city 206,283 9,804 14000 4196 42.80%
Los Angeles Gateway Artesia city 16,919 349 1159 810 232.09%
Los Angeles Gateway Avalon city 3,845 408 27 -381 -93.38%
Los Angeles Gateway Bell city 36,556 228 228 0 0.00%
Los Angeles Gateway Bell Gardens city 42,972 502 502 0 0.00%
Los Angeles Gateway Bellflower city 78,308 1,048 3693 2645 252.39%
Los Angeles Gateway Cerritos city 50,711 105 1952 1847 1759.05%
Los Angeles Gateway Commerce city 13,021 246 246 0 0.00%
Los Angeles Gateway Compton city 98,711 1,001 1001 0 0.00%
Los Angeles Gateway Cudahy city 24,264 393 393 0 0.00%
Los Angeles Gateway Downey city 114,212 2,773 6552 3779 136.28%
_Los Angeles Gateway Hawaiian Gardens city 14,690 330 330 0 0.00%
Los Angeles Gateway Huntington Park city 59,350 1,601 1601 0 0.00%
Los Angeles Gateway La Habra Heights city 5,485 166 179 13 7.83%
Los Angeles Gateway La Mirada city 49,558 1,265 1964 699 55.26%
Los Angeles Gateway Lakewood city 81,352 2,355 3952 1597 67.81%
Los Angeles Gateway Long Beach city 475,013 26,440 26440 0 0.00%
Los Angeles Gateway Lynwood city 71,343 1,555 1555 0 0.00%
Los Angeles Gateway Maywood city 27,971 364 364 0 0.00%
Los Angeles Gateway Norwalk city 106,744 1,659 5057 3398 204.82%
Los Angeles Gateway Paramount city 55,497 363 363 0 0.00%
Los Angeles Gateway Pico Rivera city 64,033 2,485 3597 1112 44.75%
Los Angeles Gateway Santa Fe Springs city 18,261 950 950 0 0.00%
Los Angeles Gateway Signal Hill city 11,795 516 516 0 0.00%
Page 1
County Subregion City 2019 Staff 10/7 Substitute Difference Inc./Dec.to
Population Recommendation Motion Staff Recom.
Los Angeles Gateway South Gate city 96,777 3,627 8510 4883 134.63%
Los Angeles Gateway Vernon city 301 8 8 0 0.00%
Los Angeles Gateway Whittier city 87,526 3,116 3398 282 9.05%
Los Angeles Las Virgenes Agoura Hills city 20,842 370 310 -60 -16.22%
Los Angeles Las Virgenes Calabasas city 24,239 291 351 60 20.62%
Los Angeles Las Virgenes Hidden Hills city 1,885 48 40 -8 -16.67%
Los Angeles Las Virgenes Malibu city 12,046 108 77 -31 -28.70%
Los Angeles Las Virgenes Westlake Village city 8,378 181 141 -40 -22.10%
Los Angeles Los Angeles City Los Angeles city 4,040,079 450,744 463682 12938 2.87%
Los Angeles North LA County Lancaster city 161,604 17,129 _ 8859 -8270 -48.28%
Los Angeles North LA County Palmdale city 157,854 11,426 6638 -4788 -41.90%
Los Angeles North LA County San Fernando city 24,918 985 1739 754 76.55%
Los Angeles North LA County Santa Clarita city 218,103 12,961 9535 -3426 -26.43%
Los Angeles SGVCOG Alhambra city 86,931 3,308 6881 3573 108.01%
Los Angeles SGVCOG Arcadia city 58,891 2,641 3151 510 19.31%
Los Angeles SGVCOG Azusa city 51,313 3,047 2745 -302 -9.91%
Los Angeles SGVCOG Baldwin Park city 77,286 1,996 1996 0 0.00%
Los Angeles SGVCOG Bradbury city 1,077 30 38 8 26.67%
Los Angeles SGVCOG Claremont city 36,511 . 1,619 1647 28 1.73%
Los Angeles SGVCOG Covina city 48,876 1,146 1863 717 62.57%
Los Angeles SGVCOG Diamond Bar city 57,495 2,584 2204 -380 -14.71%
Los Angeles SGVCOG Duarte city 21,952 707 824 117 16.55%
Los Angeles SGVCOG El Monte city 117,204 8,482 8482 0 0.00%
Los Angeles SGVCOG Glendora city 52,122 2,026 2240 214 10.56%
Los Angeles SGVCOG Industry city 432 8 15 7 87.50%
Los Angeles SGVCOG Irwindale city 1,506 119 119 0 0.00%
Los Angeles SGVCOG La Canada Flintridge 20,602 343 628 285 83.09%
Los Angeles SGVCOG La Puente city 40,795 338 1679 1341 396.75%
Los Angeles SGVCOG La Verne city 33,201 658 1269 611 92.86%
Los Angeles SGVCOG Monrovia city 38,529 1,663 1602 -61 -3.67%
Los Angeles SGVCOG Montebello city 64,247 2,778 5039 2261 81.39%
Los Angeles SGVCOG Monterey Park city 61,828 3,006 5226 2220 73.85%
Los Angeles SGVCOG Pasadena city 146,312 9,199 9469 270 2.94%
Los Angeles SGVCOG Pomona city 154,310 11,109 10061 -1048 -9.43%
Los Angeles SGVCOG Rosemead city 55,097 3,073 4606 1533 49.89%
Page 2
Count Subre ion Cit 2019 Staff 10/7 Substitute Inc./Dec.to
y g y Population Recommendation Motion Difference Staff Recom.
Los Angeles SGVCOG San Dimas city 34,584 182 1197 1015 557.69%
Los Angeles SGVCOG San Gabriel city 41,178 2,837 3010 173 6.10%
Los Angeles SGVCOG San Marino city 13,352 43 424 381 886.05%
Los Angeles SGVCOG Sierra Madre city 11,135 211 214 3 1.42%
Los Angeles SGVCOG South El Monte city 21,293 576 576 0 0.00%
Los Angeles SGVCOG South Pasadena city 26,245 1,207 2118 911 75.48%
Los Angeles SGVCOG Temple City city 36,583 2,648 2149 -499 -18.84%
Los Angeles SGVCOG Walnut city 30,551 453 1073 620 136.87%
Los Angeles SGVCOG West Covina city 108,116 4,003 5397 1394 34.82%
Los Angeles South Bay Cities Carson city 93,604 4,536 5645 1109 24.45%
Los Angeles South Bay Cities El Segundo city 17,066 255 523 268 105.10%
Los Angeles South Bay Cities Gardena city 61,042 3,641 5776 2135 58.64%
Los Angeles South Bay Cities Hawthorne city 87,854 1,731 1731 0 0.00%
Los Angeles South Bay Cities Hermosa Beach city 19,847 334 566 232 69.46%
Los Angeles South Bay Cities Inglewood city 112,549 7,422 7422 0 0.00%
Los Angeles South Bay Cities Lawndale city 33,436 973 2530 1557 160.02%
Los Angeles South Bay Cities Lomita city 20,763 458 820 362 79.04%
Los Angeles South Bay Cities Manhattan Beach city 35,922 103 791 688 667.96%
Los Angeles South Bay Cities Palos Verdes Estates 13,544 200 205 5 2.50%
Los Angeles South Bay Cities Rancho Palos Verdes 42,560 93 619 526 565.59%
Los Angeles South Bay Cities Redondo Beach city 68,473 2,212 2591 379 17.13%
Los Angeles South Bay Cities Rolling Hills city 1,892 48 44 -4 -8.33%
Los Angeles South Bay Cities Rolling Hills Estates 8,247 196 188 -8 -4.08%
Los Angeles South Bay Cities Torrance city 148,054 2,563 5009 2446 95.44%
Los Angeles Unincorporated Unincorporated Los 1,046,858 95,327 88070 -7257 -7.61%
Los Angeles Westside Cities Beverly Hills city 34,627 1,368 3143 1775 129.75%
Los Angeles Westside Cities Culver City city 40,173 1,656 3372 1716 103.62%
Los Angeles Westside Cities Santa Monica city 93,593 4,832 9059 4227 87.48%
Los Angeles Westside Cities West Hollywood city 36,660 3,460 3970 510 14.74%
Orange OCCOG Aliso Viejo city 51,372 168 1142 974 579.76%
Orange OCCOG Anaheim city 359,339 17,412 17412 0 0.00%
Orange OCCOG Brea city 45,606 1,170 2302 1132 96.75%
Orange OCCOG Buena Park city 83,384 5,387 9004 3617 67.14%
Orange OCCOG Costa Mesa city 115,830 4,309 11734 7425 172.31%
Orange OCCOG Cypress city 49,833 915 3967 3052 333.55%
Page 3
2019 Staff 10/7 Substitute Inc./Dec.to
County Subregion City Difference
Population Recommendation Motion Staff Recom.
Orange OCCOG Dana Point city 34,249 509 502 -7 -1.38%
Orange OCCOG Fountain Valley city 56,652 1,371 4756 3385 246.90%
Orange OCCOG Fullerton city 142,824 7,507 13272 5765 76.79%
Orange OCCOG Garden Grove city 175,155 5,592 19252 13660 244.28%
Orange OCCOG Huntington Beach city 203,761 3,612 13321 9709 268.80%
Orange OCCOG Irvine city 280,202 20,774 22803 2029 9.77%
Orange OCCOG La Habra city 63,542 803 803 0 0.00%
Orange OCCOG La Palma city 15,820 22 792 770 3500.00%
Orange OCCOG Laguna Beach city 23,358 55 390 335 609.09%
Orange OCCOG Laguna Hills city 31,572 1,077 1970 893 82.92%
Orange OCCOG Laguna Niguel city 66,748 181 1089 908 501.66%
Orange OCCOG Laguna Woods city 16,518 102 961 859 842.16%
Orange OCCOG Lake Forest city 86,346 628 3163 2535 403.66%
Orange OCCOG Los Alamitos city 11,721 268 774 506 188.81%
Orange OCCOG Mission Viejo city 96,434 193 2187 1994 1033.16%
Orange OCCOG Newport Beach city 87,180 2,751 4832 2081 75.65%
Orange OCCOG Orange city 141,691 3,927 3927 0 0.00%
Orange OCCOG Placentia city 52,333 2,595 _ 4337 1742 67.13%
Orange OCCOG Rancho Santa 48,960 181 549 368 203.31%
Orange OCCOG San Clemente city 65,405 830 894 64 7.71%
Orange OCCOG San Juan Capistrano 36,821 1,068 995 -73 -6.84%
Orange OCCOG Santa Ana city 337,716 3,087 3087 0 0.00%
Orange OCCOG Seal Beach city 25,073 182 1228 1046 574.73%
Orange OCCOG Stanton city 39,307 1,228 1228 0 0.00%
Orange OCCOG Tustin city 81,369 4,820 6853 2033 42.18%
Orange OCCOG Villa Park city 5,933 39 289 250 641.03%
Orange OCCOG Westminster city 92,610 2,784 9823 7039 252.84%
Orange OCCOG Yorba Linda city 68,706 207 2322 2115 1021.74%
Orange Unincorporated Unincorporated 129,128 12,224 10234 -1990 -16.28%
Riverside CVAG Blythe city 19,428 991 493 -498 -50.25%
Riverside CVAG Cathedral City city 54,907 4,687 2492 -2195 -46.83%
Riverside CVAG Coachella city 46,351 15,124 7768 -7356 -48.64%
Riverside CVAG Desert Hot Springs city 29,251 8,470 3850 -4620 -54.55%
Riverside CVAG Indian Wells city 5,445 431 403 -28 -6.50%
Riverside CVAG Indio city 89,406 11,635 7745 -3890 -33.43%
Page 4
County Subregion City 2019 Staff 10/7 Substitute Inc./Dec.to
Difference
Population Recommendation Motion
Staff Recom.
Riverside CVAG La Quinta city 42,098 2,498 1473 -1025 -41.03%
Riverside CVAG Palm Desert city 53,625 5,671 2757 -2914 -51.38%
Riverside CVAG Palm Springs city 48,733 3,271 2627 -644 -19.69%
Riverside CVAG Rancho Mirage city 18,489 2,580 1732 -848 -32.87%
Riverside Unincorporated Unincorporated 394,200 46,171 40719 -5452 -11.81%
Riverside WRCOG Banning city 31,044 3,275 1654 -1621 -49.50%
Riverside WRCOG Beaumont city 48,401 6,208 4129 -2079 -33.49%
Riverside WRCOG Calimesa city 9,159 4,340 1996 -2344 -54.01%
Riverside WRCOG Canyon Lake city 11,285 192 128 -64 -33.33%
Riverside WRCOG Corona city 168,101 6,367 5849 -518 -8.14%
Riverside WRCOG Eastvale City 66,078 2,397 2913 516 21.53%
Riverside WRCOG Hemet city 84,754 12,640 6449 -6191 -48.98%
Riverside WRCOG Jurupa Valley City 106,318 4,956 4261 -695 -14.02%
Riverside WRCOG Lake Elsinore city 62,949 12,217 6656 -5561 -45.52%
Riverside WRCOG Menifee city 93,452 11,976 6567 -5409 -45.17%
Riverside WRCOG Moreno Valley city 208,297 16,275 13495 -2780 -17.08%
Riverside WRCOG Murrieta city 118,125 3,315 3019 -296 -8.93%
Riverside WRCOG Norco city 26,386 42 417 375 892.86%
Riverside WRCOG Perris city 76,971 10,040 7662 -2378 -23.69%
Riverside WRCOG Riverside city 328,101 20,126 18185 -1941 -9.64%
Riverside WRCOG San Jacinto city 48,878 6,523 3385 -3138 -48.11%
Riverside WRCOG Temecula city 113,826 7,750 4169 -3581 -46.21%
Riverside WRCOG Wildomar city 36,066 4,963 2703 -2260 -1147.21%
San SBCTA/SBCOG Adelanto city 35,136 7,198 3751 -3447 -47.89%
San SBCTA/SBCOG Apple Valley town 73,464 7,523 4274 -3249 -43.19%
San SBCTA/SBCOG Barstow city 24,150 2,736 1508 -1228 -44.88%
San SBCTA/SBCOG Big Bear Lake city 5,461 425 212 -213 -50.12%
San SBCTA/SBCOG Chino city 89,829 8,361 6503 -1858 -22.22%
San SBCTA/SBCOG Chino Hills city _ 84,364 4,039 3462 -577 -14.29%
San SBCTA/SBCOG Colton city 54,391 5,414 5257 -157 -2.90%
San SBCTA/SBCOG Fontana city 212,078 22,101 17141 -4960 -22.44%
San SBCTA/SBCOG Grand Terrace city 12,654 808 615 -193 -23.89% _
San SBCTA/SBCOG Hesperia city 96,362 15,794 8125 -7669 -48.56%
San SBCTA/SBCOG Highland city 55,778 4,097 2467 -1630 -39.79%
San SBCTA/SBCOG Loma Linda city 24,335 2,280 2039 -241 -10.57%
Page 5
County Subregion City 2019 Staff 10/7 Substitute Difference Inc./Dec.to
Population Recommendation Motion Staff Recom.
San SBCTA/SBCOG Montclair city 39,563 1,688 2558 870 51.54%
San SBCTA/SBCOG Needles city 5,085 160 86 -74 -46.25%
San SBCTA/SBCOG Ontario city 178,268 24,478 20291 -4187 -17.11%
San SBCTA/SBCOG Rancho Cucamonga 179,412 10,502 10457 -45 -0.43%
San SBCTA/SBCOG Redlands city 71,839 4,487 3343 -1144 -25.50%
San SBCTA/SBCOG Rialto city 107,271 8,252 8252 0 0.00%
San SBCTA/SBCOG San Bernardino city 219,233 8,104 8104 0 0.00%
San SBCTA/SBCOG Twentynine Palms city 28,958 2,066 1044 -1022 -49.47%
San SBCTA/SBCOG Upland city 78,481 6,456 5522 -934 -14.47%
San SBCTA/SBCOG Victorville city 126,543 16,216 8134 -8082 -49.84%
San SBCTA/SBCOG Yucaipa city 54,844 4,681 2818 -1863 -39.80%
San SBCTA/SBCOG Yucca Valley town 22,050 1,489 749 -740 -49.70%
San Unincorporated Unincorporated San 312,654 12,419 8335 -4084 -32.89%
Ventura Unincorporated Unincorporated 96,377 1,195 1247 52 4.35%
Ventura Ventura Camarillo city 69,880 1,302 1261 -41 -3.15%
Ventura Ventura Fillmore city 15,925 686 417 -269 -39.21%
Ventura Ventura Moorpark city 37,020 1,230 1287 57 4.63%
Ventura Ventura Ojai city 7,769 78 52 -26 -33.33%
Ventura Ventura Oxnard city 209,879 8,482 8529 47 0.55%
Ventura Ventura Port Hueneme city 23,526 125 125 0 0.00%
Ventura Ventura San Buenaventura 108,170 5,012 5260 248 4.95%
Ventura Ventura Santa Paula city 30,779 1,061 651 -410 -38.64%
Ventura Ventura Simi Valley city 127,716 3,332 2681 -651 -19.54%
Ventura Ventura Thousand Oaks city 129,557 3,698 2578 -1120 -30.29%
Page 6
Enter the HCD Regional Determination and the desired percentages for each category to be used to calculate existing need in the green areas below:
HCD Regional Determination
1341827
Projected
Jobs % HQTA % Growth
33.33% .33%
(Total must equal 100%)
Below is a comparison of the allocation for each city, for the current SCAG recommentation and the new percentage -based calculation:
County totals are belowthe city listings
county city
IBailey RHNA
I % Split RHNA
I +/-
%Change
71 Adelanto city
3755
6375
2620
69.77%
37 Agoura Hills city
318
369
51
16.04%
37 Alhambra city
6810
5108
-1702
-24.99%
59 Aliso Viejo city
1193
898
-295
-24.73%
59 Anaheim city
17412
17412
0
0.00%
71 Apple Valley town
4281
6287
2006
46.86%
37 Arcadia city
3205
3030
-175
-5.46%
37 Artesia city
1067
829
-238
-22.31%
37 Avalon city
27
60
33
122.22%
37 Azusa city
2644
2601
-43
-1.63%
37 Baldwin Park city
1996
1996
0
0.00%
65 Banning city
1669
2513
844
50.57%
71 Barstow city
1516
2473
957
63.13%
65 Beaumont city
4201
6569
2368
56.37%
37 Bell city
228
228
0
0.00%
37 Bell Gardens city
502
502
0
0.00%
37 Bellflower city
3725
2520
-1205
-32.35%
37 Beverly Hills city
3096
2316
-780
-25.19%
71 Big Bear Lake city
212
343
131
61.79%
65 Blythe city
493
1029
536
108.72%
37 Bradbury city
40
36
-4
-10.00%
25 Brawley city
1423
2591
1168
82.08%
59 Brea city
2360
1927
-433
-18.35%
59 Buena Park city
8900
7548
-1352
-15.19%
37 Burbank city
8752
7361
-1391
-15.89%
37 Calabasas city
353
328
-25
-7.08%
25 Calexico city
4854
5324
470
9.68%
65 Calimesa city
2012
3024
1012
50.30%
25 Calipatria city
151
252
101
66.89%
111 Camarillo city
1372
1509
137
9.99%
65 Canyon Lake city
129
160
31
24.03%
37 Carson city
5606
5348
-258
-4.60%
Calculations and data follow to the right
fips
296
33893
66637
9503
13686
19802
394
21001
22354
7496
7656
7916
884
86580
91215
30304
31070
32031
947
50261
52657
19542
19599
19704
2000
356693
416789
105927
110666
122701
2364
74313
101405
26809
31547
37386
2462
57284
62206
20219
21128
22390
2896
16818
17751
4620
4784
4956
3274
3718
4143
1455
1484
2145
3386
49593
56204
13832
14889
16366
3666
75382
81691
17311
18161
19234
3820
30960
41469
11417
13225
16143
4030
24187
36874
9030
10560
12848
4758
45502
80171
16692
21168
25052
4870
36408
37070
8994
9093
9214
4996
42810
44337
9732
9931
10216
4982
76657
77046
23269
23306
23425
6308
34662
35832
14979
15296
15676
6434
4932
6569
2194
2442
2813
7218
19750
28622
4907
5413
6281
7946
1108
1140
371
390
400
8058
26785
41125
8849
10274
12831
8100
43853
48034
15908
16059
17035
8786
83433
96187
24661
26431
28564
8954
105040
115430
42764
45219
48640
9598
24185
24939
9008
9184
9288
9710
40791
67529
16118
19197
22293
9864
8508
20554
4009
6241
10409
9878
7532
9684
1295
1468
1748
10046
68175
76093
26666
27443
28088
10928
10845
11427
3948
4048
4197
11530
93571
105169
26298
28166
30668
12048
54299
76277
15627
17841
22092
12552
49739
50062
15467
15507
15568
13210
86866
121345
24586
27983
33078
13214
79737
92822
24418
25868
28043
65
Cathedral City city
2543
4143
1600
62.92%
13756
36194
39844
12127
12803
13743
37
Cerritos city
1902
1295
-607
-31.91%
14260
45343
129288
14227
21250
35595
71
Chino city
6959
8400
1441
20.71%
14890
53705
70710
16080
19002
21668
71
Chino Hills city
3720
4012
292
7.85%
14974
13065
13759
3447
3545
3684
37
Claremont city
1705
1619
-86
-5.04%
15044
100048
103076
23682
24081
24646
65
Coachella city
7875
14143
6268
79.59%
16350
165846
185073
47358
49407
52444
71
Colton city
5418
5764
346
6.39%
16532
113916
123747
41984
42465
44185
37
Commerce city
246
246
0
0.00%
16742
49006
50547
16052
16452
16795
37
Compton city
1001
1001
0
0.00%
17498
24414
25551
5701
5870
6080
65
Corona city
6078
6353
275
4.52%
17568
40108
41573
17146
17505
18014
59
Costa Mesa city
11727
8697
-3030
-25.84%
17750
49554
51299
16374
16455
16591
37
Covina city
1908
1507
-401
-21.02%
17946
33627
35622
14662
14837
15190
37
Cudahy city
393
393
0
0.00%
18996
28999
61014
12271
16561
24721
37
Culver City city
3332
2423
-909
-27.28%
19192
57853
64663
19389
20579
22370
59
Cypress city
3924
2795
-1129
-28.77%
19766
113267
119207
32840
33327
34072
59
Dana Point city
529
560
31
5.86%
19990
22035
25098
7460
7713
8141
65
Desert Hot Springs city
3864
6398
2534
65.58%
21230
63914
72678
16688
17845
18494
37
Diamond Bar city
2514
2548
34
1.35%
21782
45467
58753
13938
16259
20486
37
Downey city
6504
4936
-1568
-24.11%
22230
114324
137503
28172
31145
36343
37
Duarte city
873
837
-36
-4.12%
22412
16710
17183
7077
7180
7323
65
Eastvale City
3021
3002
-19
-0.63%
24092
15597
18569
4405
4830
5342
25
El Centro city
3431
4047
616
17.95%
24680
210983
286666
55139
64192
77772
37
EI Monte city
8482
8482
0
0.00%
25380
56661
58966
18898
19082
19430
37
El Segundo city
491
388
-103
-20.98%
28000
141896
158323
47686
49614
52915
111
Fillmore city
413
609
196
47.46%
29000
175982
185829
46870
48350
49202
71
Fontana city
17476
20227
2751
15.74%
28168
60628
65681
21333
22414
23695
59
Fountain Valley city
4832
3534
-1298
-26.86%
30000
201173
214129
75577
78349
82295
59
Fullerton city
13180
10791
-2389
-18.13%
30014
52268
55687
17907
18474
19481
59
Garden Grove city
19124
14258
-4866
-25.44%
30658
12400
14501
4579
4975
5569
37
Gardena city
5719
4500
-1219
-21.31%
32506
14757
15706
3692
3820
4010
37
Glendale city
13391
10765
-2626
-19.61%
32548
89396
92851
29911
30839
31579
37
Glendora city
2271
1998
-273
-12.02%
33182
81491
123992
35216
42465
53454
71
Grand Terrace city
628
707
79
12.58%
33364
19739
20566
9565
9694
9887
37
Hawaiian Gardens city
330
330
0
0.00%
33434
93687
168067
30404
39503
53153
37
Hawthorne city
1731
1731
0
0.00%
33518
1881
2018
605
629
662
65
Hemet city
6451
9670
3219
49.90%
33588
54201
68942
15928
17956
21410
37
Hermosa Beach city
556
494
-62
-11.15%
34246
6215
7733
2143
2326
2573
71
Hesperia city
8135
14028
5893
72.44%
36000
196898
205310
79048
79565
80309
37
Hidden Hills city
41
45
4
9.76%
36056
59384
63965
14986
15651
16528
71
Highland city
2508
3506
998
39.79%
36280
18424
27833
6329
8156
10123
25
Holtville city
171
240
69
40.35%
36434
5413
6369
2947
3122
3385
59
Huntington Beach city
13337
9623
-3714
-27.85%
36448
88052
129262
28810
35609
44038
37
Huntington Park city
1601
1601
0
0.00%
36490
440
440
64
64
64
25
Imperial city
1598
2234
636
39.80%
36546
114344
137121
40578
43738
47728
65
Indian Wells city
381
383
2
0.52%
36770
261589
327664
103382
112404
121739
65
Indio city
7793
10550
2757
35.38%
36826
1421
1876
406
472
521
37
Industry city
17
13
-4
-23.53%
99926
100121
117799
26335
28545
31802
37 Inglewood city
7422
7422
0
0.00%
39003
20501
21640
6859
7004
7189
59
Irvine city
23555
22764
-791
-3.36%
39290
61949
66198
19844
20245
20618
37
Irwindale city
119
119
0
0.00%
39304
5451
5802
1849
1916
2009
65
Jurupa Valley City
4484
5074
590
13.16%
40032
49441
52447
14985
15525
16204
37
La Canada Flintridge city
611
574
-37
-6.06%
40256
15980
16089
5108
5115
5129
59
La Habra city
803
803
0
0.00%
40340
40448
41601
9563
9716
9889
37
La Habra Heights city
171
163
-8
-4.68%
40354
40427
47662
16008
17332
19392
37
La Mirada city
1958
1688
-270
-13.79%
40830
33117
34414
11754
12008
12388
59
La Palma city
800
551
-249
-31.13%
39178
23448
23508
10949
10970
11002
37
La Puente city
1928
1404
-524
-27.18%
39220
31155
34004
10666
11669
11704
65
La Quinta city
1526
1993
467
30.60%
39248
66084
69711
26058
26128
26232
37
La Verne city
1343
1069
-274
-20.40%
39259
16302
16532
11415
11439
11513
59
Laguna Beach city
393
273
-120
-30.53%
39486
61487
111621
20468
27745
37760
59
Laguna Hills city
1979
1843
-136
-6.87%
39496
84050
92938
30212
30717
30817
59
Laguna Niguel city
1205
934
-271
-22.49%
39892
79256
84529
26446
27456
28715
59
Laguna Woods city
992
701
-291
-29.33%
40130
157841
213310
50498
59418
74646
65
Lake Elsinore city
6666
10664
3998
59.98%
40886
33361
34410
9833
9987
10202
59
Lake Forest city
3229
2566
-663
-20.53%
42370
24474
30112
9440
10458
11985
37
Lakewood city
3915
3284
-631
-16.12%
42468
20383
21209
8072
8258
8513
37
Lancaster city
9004
13319
4315
47.92%
43000
470854
489627
172680
182872
198151
37
Lawndale city
2491
1763
-728
-29.23%
43224
11626
12262
4150
4335
4408
71
Loma Linda city
2052
2114
62
3.02%
44000
3933766
4771326
1436882
1578496
1793035
37
Lomita city
828
667
-161
-19.44%
44574
71929
76935
15042
15685
16540
37
Long Beach city
26440
26440
0
0.00%
45246
12744
12974
5236
5287
5362
59
Los Alamitos city
767
627
-140
-18.25%
45400
35409
35590
13911
13948
14010
37
Los Angeles city
455565
408128
-47437
-10.41%
46492
28019
29043
6628
6773
6979
37
Lynwood city
1555
1555
0
0.00%
46842
89592
129750
34287
41223
51226
37
Malibu city
78
89
11
14.10%
48256
96608
98578
34038
34087
34224
37
Manhattan Beach city
773
536
-237
-30.66%
48648
37963
42059
14900
15601
16655
37
Maywood city
364
364
0
0.00%
48788
38701
49150
10045
10492
11162
65
Menifee city
6593
9638
3045
46.19%
48816
63855
67808
19418
20231
21066
59
Mission Viejo city
2211
1667
-544
-24.60%
48914
61489
65591
20370
21149
22209
37
Monrovia city
1670
1590
-80
-4.79%
49138
36679
42198
11755
12545
13021
71
Montclair city
2589
2764
175
6.76%
49270
205731
266814
57735
65182
76199
37
Montebello city
5171
3969
-1202
-23.25%
50076
113574
127738
38385
41348
42287
37
Monterey Park city
5246
4056
-1190
-22.68%
50734
5031
5581
1895
1968
2096
111
Moorpark city
1287
1348
61
4.74%
51182
84877
91975
39952
40240
41825
65
Moreno Valley city
13595
16006
2411
17.73%
51560
27096
27261
7107
7127
7147
65
Murrieta city
3035
3674
639
21.05%
52526
105528
106989
26812
26977
27280
71
Needles city
86
136
50
58.14%
53476
7535
7866
3137
3178
3227
59
Newport Beach city
4832
3861
-971
-20.10%
53896
172249
269050
51841
60602
74521
65
Norco city
453
321
-132
-29.14%
53980
140885
154044
44935
47448
48718
37
Norwalk city
5024
3524
-1500
-29.86%
54652
206013
238126
53429
57211
61645
111
Ojai city
52
66
14
26.92%
55184
50448
64053
24296
26426
32311
71
Ontario city
20803
23610
2807
13.49%
55254
47124
61612
14252
15724
17989
59
Orange city
3927
3927
0
0.00%
55156
158624
207047
45820
53046
61798
111
Oxnard city
8529
8529
0
0.00%
55380
13668
14038
5089
5169
5284
65
Palm Desert city
2785
3524
739
26.54%
55618
55896
57534
14179
14311
14529
65
Palm Springs city
2554
3284
730
28.58%
56000
142147
155525
57819
61013
65083
37
Palmdale city
6625
10641
4016
60.62%
56700
74872
121038
21431
27458
33798
37
Palos Verdes Estates city
198
187
-11
-5.56%
56924
63522
67387
16778
17526
18475
37
Paramount city
363
363
0
0.00%
57526
52288
58935
16849
17864
18750
37
Pasadena city
9409
8221
-1188
-12.63%
58072
154731
187606
40973
46124
52844
65
Perris city
7786
10437
2651
34.05%
58296
21950
22361
7004
7108
7124
37
Pico Rivera city
3939
3145
-794
-20.16%
59451
176503
201255
58096
61426
66421
59
Placentia city
4363
3809
-554
-12.70%
59500
18194
25193
8885
10195
12028
37
Pomona city
10532
11277
745
7.07%
59514
42819
43037
15753
15781
15843
111
Port Hueneme city
125
125
0
0.00%
59587
48551
49752
16813
16863
16987
71
Rancho Cucamonga city
10500
10035
-465
-4.43%
59962
69531
80832
25305
27516
30832
65
Rancho Mirage city
1743
2198
455
26.10%
60018
68218
72873
29410
30057
31057
37
Rancho Palos Verdes city
637
444
-193
-30.30%
60466
99318
139068
29135
31785
37085
59
Rancho Santa Margarita city
679
563
-116
-17.08%
62000
325278
395798
98860
105649
115057
71
Redlands city
3507
3914
407
11.61%
62602
1922
2030
682
704
735
37
Redondo Beach city
2483
2202
-281
-11.32%
62644
8060
8476
2949
3040
3159
71
Rialto city
8252
8252
0
0.00%
62896
54987
60257
14462
15342
16508
65
Riverside city
18419
19447
1028
5.58%
65000
216326
230532
60905
64029
68712
37
Rolling Hills city
44
45
1
2.27%
65042
108795
123925
41809
43690
46665
37
Rolling Hills Estates city
191
187
-4
-2.09%
65084
65853
69624
24445
24977
25368
37
Rosemead city
4604
3757
-847
-18.40%
66070
34223
35031
12163
12218
12338
71
San Bernardino city
8104
8104
0
0.00%
66140
24480
27119
6197
6638
7146
111
San Buenaventura(Ventura)city
5302
5427
125
2.36%
67042
40680
45836
12992
14131
15269
59
San Clemente city
975
1098
123
12.62%
67112
44751
69861
15583
19353
24964
37
San Dimas city
1245
904
-341
-27.39%
68028
36144
41917
12077
12405
13366
37
San Fernando city
1790
1533
-257
-14.36%
68224
13467
13559
4367
4384
4408
37
San Gabriel city
3017
2790
-227
-7.52%
69000
340240
360077
77159
79637
80133
65
San Jacinto city
3385
5392
2007
59.29%
69088
218226
258826
78378
87662
95185
59
San Juan Capistrano city
1052
1239
187
17.78%
69154
17745
20627
5546
6147
6461
37
San Marino city
398
292
-106
-26.63%
70000
93556
114670
48628
49975
51410
59
Santa Ana city
3087
3087
0
0.00%
70042
30652
35396
8931
9536
10343
37
Santa Clarita city
10009
12246
2237
22.35%
70686
24957
25385
13099
13172
13274
37
Santa Fe Springs city
950
950
0
0.00%
71806
11011
11337
4821
4851
5024
37
Santa Monica city
8874
7952
-922
-10.39%
71876
11608
12523
4350
4558
4847
111
Santa Paula city
655
928
273
41.68%
72016
127062
136974
42089
43669
46080
59
Seal Beach city
1240
911
-329
-26.53%
72996
20830
22613
4743
4999
5298
37
Sierra Madre city
204
171
-33
-16.18%
73080
97958
112751
23992
24621
25597
37
Signal Hill city
516
516
0
0.00%
73220
25992
27240
10517
10831
11245
111
Simi Valley city
2788
3112
324
11.62%
73962
39323
44187
11095
11877
12278
37
South EI Monte city
576
576
0
0.00%
78120
110330
138448
35370
39727
46355
37
South Gate city
8263
7098
-1165
-14.10%
78148
35646
42334
11903
13248
15068
37
South Pasadena city
2061
1562
-499
-24.21%
78582
129484
144713
46561
48391
51316
59
Stanton city
1228
1228
0
0.00%
80000
147108
153081
55862
56408
57282
65
Temecula city
4183
6411
2228
53.26%
80854
82058
92564
27163
27221
30635
37
Temple City city
2183
2393
210
9.62%
80994
26487
33266
8835
10023
11806
111
Thousand Oaks city
2616
3561
945
36.12%
99925
39707
66213
15525
19191
20856
37 Torrance city
4929
3928
-1001
-20.31%
59 Tustin city
6777
5475
-1302
-19.21%
71 Twentynine Palms city
1044
1579
535
51.25%
25 Unincorporated Imperial Co.
4292
5043
751
17.50%
37 Unincorporated Los Angeles Co.
89849
88300
-1549
-1.72%
59 Unincorporated Orange Co.
10375
13081
2706
26.08%
65 Unincorporated Riverside Co.
40765
52608
11843
29.05%
71 Unincorporated San Bernardino Co. 8824
11595
2771
31.40%
111 Unincorporated Ventura Co.
1259
1313
54
4.29%
71 Upland city
5673
5793
120
2.12%
37 Vernon city
8
8
0
0.00%
71 Victorville city
8146
13370
5224
64.13%
59 Villa Park city
295
215
-80
-27.12%
37 Walnut city
1292
986
-306
-23.68%
37 West Covina city
5333
4768
-565
-10.59%
37 West Hollywood city
3923
3141
-782
-19.93%
37 Westlake Village city
142
153
11
7.75%
59 Westminster city
9733
7198
-2535
-26.05%
25 Westmorland city
33
36
3
9.09%
37 Whittier city
3431
3463
32
0.93%
65 Wildomar city
2709
4209
1500
55.37%
59 Yorba Linda city
2410
1747
-663
-27.51%
71 Yucaipa city
2859
4229
1370
47.92%
71 Yucca Valley town
749
1109
360
48.06%
County Totals:
Orange 179498 154284 -25214 -14.05%
Los Angeles 813071 745706 -67365 -8.29%
Ventura 24398 26527 2129 8.73%
Riverside 167062 222657 55595 33.28%
San Bernardino 129661 154698 25037 19.31%
Imperial 15953 19767 3814 23.91%
99937 1044484 1258026 335592 383057 419348
99959
125939
181008
42659
49018
56581
99965
370508
525626
121523
166633
177089
99971
308079
353053
98373
104540
113790
99111
98244
101254
32446
33122
33597
81344
76403
92963
27016
29336
32817
82422
209
211
76
76
76
82590
123309
194522
38465
47392
61813
82744
5936
6084
1985
1997
2023
83332
30118
31318
8796
8946
9232
84200
107816
118859
32013
33203
34848
84410
36735
42552
27580
28330
30125
84438
8370
8773
3283
3374
3504
84550
93249
98269
26683
27448
27795
84606
2295
2351
612
621
634
85292
87117
98904
30472
31661
33474
85446
35408
55235
12580
15542
19637
86832
67761
70552
23130
23170
23329
87042
53779
75209
19638
22439
26068
87056
21445
25810
8703
9566
10861
726639
1292649
19155405
10228964
2726158
HHGR
20 45 SHR 2020 45
HHGR
CITY
PCT HQTAPOP
JOBACC
BYPOP
6,116
0.84%
10,299
0.80%
35136
0.18%
0
0.00%
0.00%
1.51%
1006
260
0.04%
420
0.03%
20842
0.11%
0
0.00%
0.00%
4.62%
1033
961
0.13%
1,727
0.13%
86931
0.45%
81723
89.59%
0.80%
15.85%
14453
105
0.01%
162
0.01%
51372
0.27%
0
0.00%
0.00%
9.44%
4968
12,035
1.66%
16,774
1.30%
359339
1.88%
273120
65.53%
2.67%
20.89%
87067
5,839
0.80%
10,577
0.82%
73464
0.38%
15
0.01%
0.00%
1.50%
1521
1,262
0.17%
2,171
0.17%
58891
0.31%
12084
19.43%
0.12%
10.40%
6469
172
0.02%
336
0.03%
16919
0.09%
6008
33.84%
0.06%
21.61%
3836
661
0.09%
690
0.05%
3845
0.02%
0
0.00%
0.00%
0.00%
0
1,477
0.20%
2,534
0.20%
51313
0.27%
19831
35.28%
0.19%
9.04%
5081
1,073
0.15%
1,923
0.15%
77286
0.40%
32532
39.82%
0.32%
12.03%
9827
2,918
0.40%
4,726
0.37%
31044
0.16%
0
0.00%
0.00%
2.09%
867
2,288
0.31%
3,818
0.30%
24150
0.13%
4199
11.39%
0.04%
0.28%
103
3,884
0.53%
8,360
0.65%
48401
0.25%
0
0.00%
0.00%
3.15%
2525
121
0.02%
220
0.02%
36556
0.19%
36464
98.37%
0.36%
18.07%
6699
285
0.04%
484
0.04%
42972
0.22%
27332
61.65%
0.27%
19.56%
8672
119
0.02%
156
0.01%
78308
0.41%
16229
21.06%
0.16%
22.44%
17289
380
0.05%
697
0.05%
34627
0.18%
33552
93.64%
0.33%
17.74%
6355
371
0.05%
619
0.05%
5461
0.03%
0
0.00%
0.00%
0.09%
6
868
0.12%
1,374
0.11%
19428
0.10%
0
0.00%
0.00%
0.07%
20
10
0.00%
29
0.00%
1077
0.01%
0
0.00%
0.00%
10.50%
120
2,557
0.35%
3,982
0.31%
27337
0.14%
0
0.00%
0.00%
1.22%
502
976
0.13%
1,127
0.09%
45606
0.24%
6713
13.98%
0.07%
16.37%
7863
2,133
0.29%
3,903
0.30%
83384
0.44%
47524
49.41%
0.46%
20.08%
19314
3,421
0.47%
5,876
0.45%
105952
0.55%
95129
82.41%
0.93%
12.36%
14261
104
0.01%
280
0.02%
24239
0.13%
0
0.00%
0.00%
4.86%
1212
3,096
0.43%
6,175
0.48%
42198
0.22%
51334
76.02%
0.50%
1.22%
824
4,168
0.57%
6,400
0.50%
9159
0.05%
0
0.00%
0.00%
4.04%
830
280
0.04%
453
0.04%
7281
0.04%
0
0.00%
0.00%
0.23%
22
645
0.09%
1,422
0.11%
69880
0.36%
4863
6.39%
0.05%
3.82%
2907
149
0.02%
249
0.02%
11285
0.06%
0
0.00%
0.00%
2.55%
291
2,502
0.34%
4,370
0.34%
93604
0.49%
8617
8.19%
0.08%
17.96%
18888
4,251
0.59%
6,465
0.50%
54907
0.29%
6282
8.24%
0.06%
2.56%
1953
61
0.01%
101
0.01%
50711
0.26%
1727
3.45%
0.02%
21.29%
10658
5,095
0.70%
8,492
0.66%
89829
0.47%
36647
30.20%
0.36%
11.68%
14173
2,175
0.30%
3,625
0.28%
84364
0.44%
21691
23.37%
0.21%
9.78%
9078
940
0.13%
1,616
0.13%
36511
0.19%
9932
24.93%
0.10%
9.85%
3925
14,345
1.97%
21,368
1.65%
46351
0.24%
37964
29.36%
0.37%
1.83%
2366
2,666
0.37%
5,588
0.43%
54391
0.28%
40028
56.61%
0.39%
11.80%
8344
139
0.02%
237
0.02%
13021
0.07%
9919
72.09%
0.10%
23.31%
3207
565
0.08%
964
0.07%
98711
0.52%
51452
49.92%
0.50%
18.41%
18976
3,037
0.42%
5,086
0.39%
168101
0.88%
46458
25.10%
0.45%
8.30%
15361
1,720
0.24%
2,201
0.17%
115830
0.60%
98719
79.77%
0.97%
18.44%
22813
343
0.05%
743
0.06%
48876
0.26%
15370
30.41%
0.15%
10.36%
5237
210
0.03%
379
0.03%
24264
0.13%
24255
94.93%
0.24%
16.94%
4327
509
0.07%
868
0.07%
40173
0.21%
35411
85.18%
0.35%
20.64%
8581
136
0.02%
217
0.02%
49833
0.26%
21622
42.15%
0.21%
21.03%
10788
353
0.05%
528
0.04%
34249
0.18%
0
0.00%
0.00%
3.91%
1393
8,160
1.12%
12,450
0.96%
29251
0.15%
0
0.00%
0.00%
1.83%
1117
1,791
0.25%
2,981
0.23%
57495
0.30%
4094
6.33%
0.04%
12.20%
7886
745
0.10%
1,232
0.10%
114212
0.60%
40920
34.33%
0.40%
20.94%
24956
428
0.06%
681
0.05%
21952
0.11%
3862
15.39%
0.04%
11.51%
2889
649
0.09%
1,806
0.14%
66078
0.34%
16224
22.32%
0.16%
12.37%
8990
4,227
0.58%
6,548
0.51%
46248
0.24%
32438
55.21%
0.32%
1.23%
723
5,198
0.72%
8,171
0.63%
117204
0.61%
86886
63.19%
0.85%
13.51%
18577
143
0.02%
246
0.02%
17066
0.09%
16
0.10%
0.00%
13.94%
2395
512
0.07%
937
0.07%
15925
0.08%
0
0.00%
0.00%
1.66%
308
13,580
1.87%
22,633
1.75%
212078
1.11%
95565
33.34%
0.93%
11.50%
32952
348
0.05%
532
0.04%
56652
0.30%
30337
51.45%
0.30%
20.56%
12123
3,301
0.45%
5,229
0.40%
142824
0.75%
86662
54.74%
0.85%
17.05%
26994
852
0.12%
2,332
0.18%
175155
0.91%
136002
73.19%
1.33%
21.64%
40213
1,281
0.18%
2,362
0.18%
61042
0.32%
64795
98.65%
0.63%
16.99%
11159
3,946
0.54%
6,718
0.52%
206283
1.08%
135507
63.28%
1.32%
13.42%
28736
1,007
0.14%
1,574
0.12%
52122
0.27%
17014
30.55%
0.17%
9.20%
5120
594
0.08%
990
0.08%
12654
0.07%
0
0.00%
0.00%
11.71%
1697
190
0.03%
318
0.02%
14690
0.08%
12563
79.99%
0.12%
20.47%
3215
740
0.10%
1,668
0.13%
87854
0.46%
59489
64.07%
0.58%
15.02%
13946
10,989
1.51%
18,238
1.41%
84754
0.44%
0
0.00%
0.00%
1.46%
1804
193
0.03%
322
0.02%
19847
0.10%
0
0.00%
0.00%
10.47%
2152
13,650
1.88%
22,749
1.76%
96362
0.50%
0
0.00%
0.00%
1.52%
2555
33
0.00%
57
0.00%
1885
0.01%
0
0.00%
0.00%
6.17%
125
3,454
0.48%
5,482
0.42%
55778
0.29%
1546
2.24%
0.02%
6.58%
4536
247
0.03%
430
0.03%
6779
0.04%
0
0.00%
0.00%
1.21%
94
744
0.10%
1,261
0.10%
203761
1.06%
74791
36.43%
0.73%
17.56%
36052
877
0.12%
1,542
0.12%
59350
0.31%
60689
94.88%
0.59%
18.06%
11549
1,967
0.27%
3,794
0.29%
19929
0.10%
0
0.00%
0.00%
1.25%
348
263
0.04%
438
0.03%
5445
0.03%
4932
77.44%
0.05%
2.49%
159
8,429
1.16%
15,228
1.18%
89406
0.47%
37270
28.83%
0.36%
2.27%
2934
0
0.00%
0
0.00%
432
0.00%
1
0.12%
0.00%
14.62%
64
3,990
0.55%
7,150
0.55%
112549
0.59%
116380
84.87%
1.14%
15.98%
21912
9,335
1.28%
18,357
1.42%
280202
1.46%
43892
13.40%
0.43%
17.45%
57177
49
0.01%
115
0.01%
1506
0.01%
1306
69.63%
0.01%
10.97%
206
3,257
0.45%
5,467
0.42%
106318
0.56%
2905
2.47%
0.03%
13.64%
16068
185
0.03%
330
0.03%
20602
0.11%
0
0.00%
0.00%
10.54%
2281
373
0.05%
774
0.06%
63542
0.33%
20983
31.70%
0.21%
14.64%
9688
93
0.01%
160
0.01%
5485
0.03%
0
0.00%
0.00%
11.31%
656
679
0.09%
1,219
0.09%
49558
0.26%
0
0.00%
0.00%
17.05%
8940
14
0.00%
21
0.00%
15820
0.08%
803
4.99%
0.01%
20.09%
3232
173
0.02%
326
0.03%
40795
0.21%
18797
45.19%
0.18%
13.46%
5599
2,060
0.28%
3,384
0.26%
42098
0.22%
5541
11.63%
0.05%
2.04%
972
380
0.05%
634
0.05%
33201
0.17%
12296
35.73%
0.12%
9.93%
3417
32
0.00%
53
0.00%
23358
0.12%
0
0.00%
0.00%
6.92%
1627
35
0.00%
1,038
0.08%
31572
0.16%
4300
12.65%
0.04%
11.06%
3761
104
0.01%
174
0.01%
66748
0.35%
4882
7.00%
0.05%
5.25%
3660
74
0.01%
98
0.01%
16518
0.09%
7604
46.00%
0.07%
13.25%
2190
10,015
1.38%
17,292
1.34%
62949
0.33%
0
0.00%
0.00%
2.46%
2746
100
0.01%
605
0.05%
86346
0.45%
2585
2.78%
0.03%
12.34%
11469
1,259
0.17%
2,269
0.18%
81352
0.42%
5401
6.39%
0.05%
19.85%
16779
15,228
2.10%
24,148
1.87%
161604
0.84%
18362
8.61%
0.18%
1.20%
2560
215
0.03%
369
0.03%
33436
0.17%
34218
99.44%
0.33%
14.31%
4924
1,527
0.21%
2,545
0.20%
24335
0.13%
15388
51.10%
0.15%
9.74%
2933
255
0.04%
441
0.03%
20763
0.11%
7074
33.35%
0.07%
9.91%
2102
15,279
2.10%
25,471
1.97%
475013
2.48%
368745
75.31%
3.60%
17.53%
85807
73
0.01%
258
0.02%
11721
0.06%
0
0.00%
0.00%
21.55%
2642
214,539
29.52%
356,153
27.55%
4040079
21.09%
4045947
84.80%
39.55%
17.48%
834028
855
0.12%
1,498
0.12%
71343
0.37%
65241
84.80%
0.64%
18.32%
14094
75
0.01%
126
0.01%
12046
0.06%
0
0.00%
0.00%
1.03%
134
62
0.01%
99
0.01%
35922
0.19%
10
0.03%
0.00%
12.41%
4415
206
0.03%
351
0.03%
27971
0.15%
28545
98.29%
0.28%
19.35%
5620
10,003
1.38%
16,939
1.31%
93452
0.49%
0
0.00%
0.00%
3.66%
4749
137
0.02%
186
0.01%
96434
0.50%
1612
1.63%
0.02%
9.12%
8990
1,054
0.15%
1,755
0.14%
38529
0.20%
7796
18.54%
0.08%
10.24%
4307
670
0.09%
1,117
0.09%
39563
0.21%
30003
61.04%
0.29%
10.29%
5055
835
0.11%
1,648
0.13%
64247
0.34%
48794
71.96%
0.48%
20.07%
13606
1,060
0.15%
1,839
0.14%
61828
0.32%
53731
81.92%
0.53%
18.81%
12334
476
0.07%
1,266
0.10%
37020
0.19%
7368
17.46%
0.07%
3.77%
1591
11,017
1.52%
18,464
1.43%
208297
1.09%
128638
48.21%
1.26%
4.80%
12807
939
0.13%
3,902
0.30%
118125
0.62%
0
0.00%
0.00%
2.58%
3289
128
0.02%
201
0.02%
5085
0.03%
0
0.00%
0.00%
0.02%
1
1,585
0.22%
1,873
0.14%
87180
0.46%
16113
17.52%
0.16%
16.63%
15295
20
0.00%
40
0.00%
26386
0.14%
0
0.00%
0.00%
10.36%
2824
303
0.04%
468
0.04%
106744
0.56%
17489
16.35%
0.17%
21.99%
23527
49
0.01%
90
0.01%
7769
0.04%
0
0.00%
0.00%
0.39%
30
13,919
1.92%
22,680
1.75%
178268
0.93%
161877
60.17%
1.58%
13.17%
35434
1,270
0.17%
3,783
0.29%
141691
0.74%
56740
36.83%
0.55%
21.28%
32773
4,434
0.61%
8,216
0.64%
209879
1.10%
110266
46.31%
1.08%
2.67%
6358
5,885
0.81%
8,015
0.62%
53625
0.28%
17913
27.97%
0.18%
2.49%
1592
2,265
0.31%
3,737
0.29%
48733
0.25%
24932
40.47%
0.24%
2.41%
1485
8,752
1.20%
15,978
1.24%
157854
0.82%
2685
1.30%
0.03%
1.20%
2485
115
0.02%
195
0.02%
13544
0.07%
0
0.00%
0.00%
5.25%
737
218
0.03%
350
0.03%
55497
0.29%
14292
24.84%
0.14%
20.91%
12030
4,070
0.56%
7,264
0.56%
146312
0.76%
74216
47.72%
0.73%
12.86%
20001
6,340
0.87%
12,367
0.96%
76971
0.40%
46981
38.82%
0.46%
4.03%
4878
949
0.13%
1,697
0.13%
64033
0.33%
20238
30.03%
0.20%
20.99%
14145
886
0.12%
1,901
0.15%
52333
0.27%
14247
24.17%
0.14%
19.36%
11410
6,720
0.92%
11,871
0.92%
154310
0.81%
76583
40.82%
0.75%
10.35%
19417
16
0.00%
120
0.01%
23526
0.12%
13375
59.82%
0.13%
2.43%
542
4,995
0.69%
8,325
0.64%
179412
0.94%
81447
40.47%
0.80%
11.87%
23889
1,833
0.25%
3,143
0.24%
18489
0.10%
8038
31.91%
0.08%
2.53%
637
62
0.01%
90
0.01%
42560
0.22%
3280
7.62%
0.03%
6.46%
2778
124
0.02%
174
0.01%
48960
0.26%
0
0.00%
0.00%
5.55%
2761
3,316
0.46%
5,527
0.43%
71839
0.38%
12491
15.45%
0.12%
7.42%
5998
1,000
0.14%
1,647
0.13%
68473
0.36%
10630
14.59%
0.10%
11.89%
8665
5,300
0.73%
7,950
0.62%
107271
0.56%
112675
81.02%
1.10%
10.09%
14032
9,408
1.29%
16,197
1.25%
328101
1.71%
160586
40.57%
1.57%
9.79%
38729
31
0.00%
53
0.00%
1892
0.01%
0
0.00%
0.00%
7.62%
155
119
0.02%
210
0.02%
8247
0.04%
0
0.00%
0.00%
8.07%
684
1,166
0.16%
2,046
0.16%
55097
0.29%
49522
82.19%
0.48%
16.18%
9747
4,683
0.64%
7,807
0.60%
219233
1.14%
128390
55.69%
1.26%
9.07%
20909
2,975
0.41%
4,856
0.38%
108170
0.56%
67367
54.36%
0.66%
2.70%
3346
391
0.05%
923
0.07%
65405
0.34%
2324
3.34%
0.02%
2.31%
1608
120
0.02%
175
0.01%
34584
0.18%
12951
36.97%
0.13%
10.46%
3664
508
0.07%
949
0.07%
24918
0.13%
20766
76.57%
0.20%
10.66%
2891
1,138
0.16%
2,277
0.18%
41178
0.21%
18624
40.63%
0.18%
14.25%
6532
5,611
0.77%
9,381
0.73%
48878
0.26%
0
0.00%
0.00%
1.74%
1212
961
0.13%
1,289
0.10%
36821
0.19%
5723
13.65%
0.06%
4.39%
1838
24
0.00%
41
0.00%
13352
0.07%
1248
9.20%
0.01%
12.19%
1653
496
0.07%
2,974
0.23%
337716
1.76%
318168
88.36%
3.11%
20.13%
72484
7,523
1.04%
16,807
1.30%
218103
1.14%
9999
3.86%
0.10%
3.89%
10068
314
0.04%
915
0.07%
18261
0.10%
0
0.00%
0.00%
19.82%
4088
1,435
0.20%
2,782
0.22%
93593
0.49%
105160
91.71%
1.03%
15.63%
17917
807
0.11%
1,412
0.11%
30779
0.16%
0
0.00%
0.00%
2.09%
740
102
0.01%
175
0.01%
25073
0.13%
0
0.00%
0.00%
19.30%
4898
173
0.02%
203
0.02%
11135
0.06%
0
0.00%
0.00%
9.38%
1063
289
0.04%
497
0.04%
11795
0.06%
12002
95.84%
0.12%
18.51%
2318
2,411
0.33%
3,991
0.31%
127716
0.67%
3630
2.65%
0.04%
5.53%
7575
299
0.04%
555
0.04%
21293
0.11%
15635
69.14%
0.15%
16.02%
3623
976
0.13%
1,605
0.12%
96777
0.51%
95525
84.72%
0.93%
18.20%
20521
414
0.06%
728
0.06%
26245
0.14%
24094
88.45%
0.24%
15.29%
4165
401
0.06%
1,183
0.09%
39307
0.21%
40679
92.06%
0.40%
21.19%
9363
6,628
0.91%
10,985
0.85%
113826
0.59%
0
0.00%
0.00%
2.28%
3157
1,820
0.25%
3,165
0.24%
36583
0.19%
5321
12.57%
0.05%
11.31%
4788
2,925
0.40%
4,755
0.37%
129557
0.68%
0
0.00%
0.00%
4.34%
6281
874
0.12%
1,420
0.11%
148054
0.77%
33910
22.15%
0.33%
11.00%
16839
3,414
0.47%
3,472
0.27%
81369
0.42%
42023
45.40%
0.41%
19.46%
18008
1,783
0.25%
2,971
0.23%
28958
0.15%
0
0.00%
0.00%
0.19%
63
1,665
0.23%
5,331
0.41%
38033
0.20%
19689
29.74%
0.19%
1.21%
798
36.291
4.99%
83,756
6.48%
1046858
5.47%
510639
40.59%
4.99%
11.69%
147063
7,563
1.04%
13,922
1.08%
129128
0.67%
19663
10.86%
0.19%
9.02%
16327
10,456
1.44%
55,566
4.30%
394200
2.06%
19086
3.63%
0.19%
2.15%
11301
9,250
1.27%
15,417
1.19%
312654
1.63%
55249
15.65%
0.54%
0.49%
1730
475
0.07%
1,151
0.09%
96377
0.50%
545
0.54%
0.01%
2.69%
2724
3,481
0.48%
5,801
0.45%
78481
0.41%
47406
50.99%
0.46%
10.10%
9389
0
0.00%
0
0.00%
301
0.00%
148
70.30%
0.00%
19.41%
41
14,421
1.98%
23,348
1.81%
126543
0.66%
0
0.00%
0.00%
1.53%
2976
26
0.00%
38
0.00%
5933
0.03%
0
0.00%
0.00%
20.32%
1236
286
0.04%
436
0.03%
30551
0.16%
10445
33.35%
0.10%
13.09%
4100
1,645
0.23%
2,835
0.22%
108116
0.56%
40664
34.21%
0.40%
12.14%
14429
1,795
0.25%
2,545
0.20%
36660
0.19%
42473
99.81%
0.42%
19.26%
8196
130
0.02%
221
0.02%
8378
0.04%
0
0.00%
0.00%
4.46%
391
347
0.05%
1,112
0.09%
92610
0.48%
67310
68.50%
0.66%
21.61%
21236
13
0.00%
22
0.00%
2461
0.01%
0
0.00%
0.00%
0.87%
20
1,813
0.25%
3,002
0.23%
87526
0.46%
0
0.00%
0.00%
14.55%
14391
4,095
0.56%
7,057
0.55%
36066
0.19%
0
0.00%
0.00%
2.39%
1320
159
0.02%
199
0.02%
68706
0.36%
0
0.00%
0.00%
14.62%
10315
3,629
0.50%
6,430
0.50%
54844
0.29%
0
0.00%
0.00%
3.61%
2711
1,295
0.18%
2,158
0.17%
22050
0.12%
0
0.00%
0.00%
0.26%
67
HCD Regional Determination: PROJECTED NEED EXISTING NEED
23545 466958 14467 504970 1341827 9377
HH
PROJ_NEED
DEMO -LOSS
D TOT
0.04%
0.49
0.51
37
0.04%
0.74
0.26
9
0.53%
0.40
0.60
69
0.18%
0.60
0.40
0
3.19%
0.45
0.55
69
0.06%
0.65
0.35
31
0.24%
0.60
0.40
806
0.14%
0.51
0.49
14
0.00%
0.23
0.77
2
0.19%
0.53
0.47
3
0.36%
0.56
0.44
0
0.03%
0.64
0.36
3
0.00%
0.45
0.55
23
0.09%
0.74
0.26
32
0.25%
0.29
0.71
4
0.32%
0.22
0.78
8
0.63%
0.40
0.60
62
0.23%
0.41
0.59
255
0.00%
0.55
0.45
0
0.00%
0.53
0.47
59
0.00%
0.78
0.22
4
0.02%
0.53
0.47
133
0.29%
0.61
0.39
8
0.71%
0.55
0.45
28
0.52%
0.41
0.59
0
0.04%
0.70
0.30
0
0.03%
0.53
0.47
7
0.03%
0.84
0.16
5
0.00%
0.51
0.49
0
0.11%
0.67
0.33
0
0.01%
0.79
0.21
0
0.69%
0.75
0.25
469
0.07%
0.60
0.40
107
0.39%
0.79
0.21
0
0.52%
0.63
0.37
62
0.33%
0.77
0.23
3
HH
PROJ_NEED
D TOT
-NEED -BASELINE
RESIDUAL
3451
113
3601
154
0
3755
0
132
3
144
159
0
303
0
632
23
724
2218
3343
6285
0
47
1
48
763
0
811
0
3910
134
4113
13364
11172
28649
11236
3909
107
4047
233
1
4281
0
750
22
1578
993
494
3065
0
135
4
154
589
246
988
0
24
1
27
0
0
27
0
872
27
902
780
811
2494
0
701
21
722
1508
1331
3562
1565
1492
41
1536
133
0
1669
0
1262
43
1328
16
172
1516
0
3693
89
3814
388
0
4201
0
82
3
89
1028
1492
2609
2380
164
7
179
1331
1118
2628
2126
31
1
94
2654
664
3411
0
262
9
526
975
1373
2874
0
205
6
211
1
0
212
0
417
13
490
3
0
493
0
16
0
20
18
0
38
0
1176
37
1346
77
0
1423
0
125
4
136
1207
275
1618
0
1460
45
1533
2964
1944
6442
0
2025
72
2098
2189
3891
8178
0
145
4
149
186
0
335
0
2540
80
2627
126
2100
4854
0
1841
38
1884
127
0
2012
0
143
5
147
3
0
151
0
641
17
658
446
199
1303
0
83
2
84
45
0
129
0
1541
37
2047
2899
352
5299
0
1827
53
1986
300
257
2543
0
33
1
34
1636
71
1740
0
2803
78
2943
2175
1499
6617
0
1196
28
1227
1393
887
3508
0
0.14%
0.66
0.34
28
558
15
601
602
406
1609
0
0.09%
0.66
0.34
9
5794
156
5959
363
1553
7875
0
0.31%
0.51
0.49
12
2411
77
2500
1281
1637
5418
0
0.12%
0.42
0.58
2
81
3
86
492
406
984
738
0.70%
0.54
0.46
29
329
10
368
2913
2105
5386
4385
0.56%
0.65
0.35
83
1690
46
1820
2358
1900
6078
0
0.84%
0.39
0.61
0
397
14
411
3501
4038
7951
0
0.19%
0.57
0.43
0
330
10
340
804
629
1772
0
0.16%
0.15
0.85
0
139
6
146
664
992
1802
1409
0.31%
0.53
0.47
0
296
9
305
1317
1449
3071
0
0.40%
0.67
0.33
43
67
2
112
1656
884
2652
0
0.05%
0.60
0.40
60
144
4
209
214
0
422
0
0.04%
0.44
0.56
31
3539
123
3693
171
0
3864
0
0.29%
0.77
0.23
2
982
23
1006
1210
167
2384
0
0.92%
0.51
0.49
65
402
13
480
3830
1674
5984
0
0.11%
0.64
0.36
0
209
6
215
443
158
816
0
0.33%
0.76
0.24
0
955
22
977
1380
664
3021
0
0.03%
0.50
0.50
16
1915
63
1993
111
1327
3431
0
0.68%
0.40
0.60
0
2453
88
2541
2851
3554
8946
464
0.09%
0.45
0.55
0
85
3
88
368
1
456
0
0.01%
0.70
0.30
6
351
9
366
47
0
413
0
1.21%
0.64
0.36
0
7469
205
7674
5058
3909
16641
0
0.44%
0.70
0.30
21
152
4
177
1861
1241
3278
0
0.99%
0.52
0.48
0
1591
51
1641
4143
3545
9330
0
1.48%
0.54
0.46
253
1221
38
1512
6172
5563
13248
0
0.41%
0.50
0.50
23
892
29
944
1713
2651
5307
0
1.05%
0.34
0.66
123
2287
87
2497
4411
5543
12451
0
0.19%
0.71
0.29
169
468
12
649
786
696
2131
0
0.06%
0.61
0.39
7
327
9
343
261
0
604
0
0.12%
0.41
0.59
1
106
4
110
493
514
1118
788
0.51%
0.27
0.73
0
766
31
797
2141
2433
5371
3639
0.07%
0.58
0.42
15
5980
179
6174
277
0
6451
0
0.08%
0.47
0.53
84
106
4
194
330
0
524
0
0.09%
0.63
0.37
26
7507
210
7742
392
0
8135
0
0.00%
0.96
0.04
0
20
0
20
19
0
39
0
0.17%
0.65
0.35
30
1673
46
1749
696
63
2508
0
0.00%
0.57
0.43
1
151
5
157
14
0
171
0
1.32%
0.58
0.42
2
427
13
441
5534
3059
9034
0
0.42%
0.26
0.74
137
549
22
708
1773
2483
4963
3362
0.01%
0.72
0.28
0
1507
37
1544
53
0
1598
0
0.01%
0.85
0.15
8
144
3
155
24
202
381
0
0.11%
0.67
0.33
60
5609
149
5818
450
1525
7793
0
0.00%
0.18
0.82
6
0
0
6
10
0
16
0
0.80%
0.36
0.64
157
2607
98
2862
3363
4761
10986
3564
2.10%
0.48
0.52
0
7443
247
7690
8776
1795
18261
0
0.01%
0.71
0.29
19
54
1
75
32
53
160
40
0.59%
0.66
0.34
27
1823
49
1899
2466
119
4484
0
0.08%
0.89 0.11
106
120
2
228
350
0
578
0
0.36%
0.57 0.43
0
331
10
341
1487
858
2686
1883
0.02%
0.94 0.06
5
55
1
61
101
0
162
0
0.33%
0.78 0.22
1
446
10
457
1372
0
1829
0
0.12%
0.68 0.32
0
6
0
6
496
33
535
0
0.21%
0.57 0.43
16
126
4
146
859
769
1774
0
0.04%
0.71 0.29
30
1092
27
1150
149
227
1526
0
0.13%
0.74 0.26
4
210
5
219
525
503
1246
0
0.06%
0.62 0.38
0
17
0
18
250
0
267
0
0.14%
0.71 0.29
0
827
21
848
577
176
1602
0
0.13%
0.71 0.29
3
58
1
62
562
200
824
0
0.08%
0.76 0.24
0
20
0
20
336
311
668
0
0.10%
0.63 0.37
73
6004
168
6245
421
0
6666
0
0.42%
0.69 0.31
1
417
11
428
1760
106
2294
0
0.62%
0.71 0.29
0
833
21
854
2575
221
3650
0
0.09%
0.54 0.46
272
7359
229
7860
393
751
9004
0
0.18%
0.32 0.68
0
127
5
132
756
1400
2287
0
0.11%
0.36 0.64
0
840
32
871
450
629
1951
0
0.08%
0.46 0.54
0
153
5
159
323
289
771
0
3.15%
0.40 0.60
0
8408
303
8711
13170
15084
36965
10525
0.10%
0.44 0.56
0
153
5
158
406
0
564
0
30.59%
0.37 0.63
13148
116832
4336
134316
128012
165505
427832
0
0.52%
0.42 0.58
0
530
19
549
2163
2669
5381
3826
0.00%
0.74 0.26
12
42
1
55
21
0
76
0
0.16%
0.69 0.31
0
31
1
31
678
0
709
0
0.21%
0.24 0.76
1
120
5
126
863
1168
2156
1792
0.17%
0.74 0.26
5
5722
137
5864
729
0
6593
0
0.33%
0.78 0.22
0
40
1
41
1380
66
1487
0
0.16%
0.46 0.54
0
578
20
598
661
319
1578
0
0.19%
0.55 0.45
19
369
11
399
776
1227
2402
0
0.50%
0.44 0.56
7
671
23
701
2088
1996
4785
0
0.45%
0.54 0.46
106
643
20
769
1893
2198
4860
0
0.06%
0.75 0.25
16
652
16
683
244
301
1229
0
0.47%
0.61 0.39
46
6144
177
6367
1966
5262
13595
0
0.12%
0.67 0.33
20
2444
65
2530
505
0
3035
0
0.00%
0.57 0.43
24
60
2
86
0
0
86
0
0.56%
0.57 0.43
75
238
7
320
2348
659
3327
0
0.10%
0.81 0.19
3
17
0
20
433
0
453
0
0.86%
0.63 0.37
149
136
4
289
3611
715
4615
0
0.00%
0.56 0.44
12
34
1
47
5
0
51
0
1.30%
0.54 0.46
165
7228
226
7619
5439
6622
19679
0
1.20%
0.57 0.43
56
2073
62
2192
5030
2321
9543
5616
0.23%
0.53 0.47
0
3120
98
3218
976
4511
8704
176
0.06%
0.61 0.39
0
1757
50
1807
244
733
2785
0
0.05%
0.59 0.41
56
1214
36
1306
228
1020
2554
0
0.09%
0.64 0.36
8
5961
165
6134
381
110
6625
0
0.03%
0.86 0.14
7
66
1
74
113
0
187
0
0.44%
0.39
0.61
0
109
4
113
1846
585
2544
2181
0.73%
0.44
0.56
0
2635
92
2727
3070
3036
8832
0
0.18%
0.63
0.37
4
4972
140
5116
749
1922
7786
0
0.52%
0.67
0.33
23
617
16
657
2171
828
3655
0
0.42%
0.65
0.35
0
837
23
860
1751
583
3194
0
0.71%
0.53
0.47
35
4250
134
4419
2980
3133
10532
0
0.02%
0.46
0.54
0
86
3
89
83
547
719
595
0.88%
0.61
0.39
24
2747
78
2850
3667
3332
9848
0
0.02%
0.78
0.22
211
1081
24
1316
98
329
1743
0
0.10%
0.80
0.20
0
23
1
24
426
134
584
0
0.10%
0.71
0.29
1
41
1
43
424
0
467
0
0.22%
0.57
0.43
63
1824
55
1942
921
511
3373
0
0.32%
0.50
0.50
0
534
17
551
1330
435
2316
0
0.51%
0.64
0.36
71
2186
61
2318
2154
4609
9081
828
1.42%
0.54
0.46
131
5601
174
5906
5944
6569
18419
0
0.01%
0.97
0.03
0
18
0
18
24
0
42
0
0.03%
0.93
0.07
0
75
1
76
105
0
181
0
0.36%
0.50
0.50
0
726
24
750
1496
2026
4271
0
0.77%
0.47
0.53
352
2577
87
3016
3209
5252
11477
3373
0.12%
0.54
0.46
82
1552
48
1682
514
2756
4951
0
0.06%
0.66
0.34
11
439
12
462
247
95
804
0
0.13%
0.72
0.28
3
45
1
50
562
530
1142
0
0.11%
0.54
0.46
0
364
11
375
444
849
1668
0
0.24%
0.45
0.55
114
940
32
1086
1003
762
2850
0
0.04%
0.65
0.35
4
3110
85
3199
186
0
3385
0
0.07%
0.74
0.26
0
271
7
277
282
234
793
0
0.06%
0.84
0.16
50
14
0
64
254
51
369
0
2.66%
0.45
0.55
0
2044
70
2114
11125
13015
26254
23167
0.37%
0.68
0.32
9
7659
202
7870
1545
409
9824
0
0.15%
0.64
0.36
0
496
14
510
627
0
1137
187
0.66%
0.28
0.72
0
1111
45
1156
2750
4302
8208
0
0.03%
0.55
0.45
27
499
15
541
114
0
655
0
0.18%
0.75
0.25
50
60
1
112
752
0
863
0
0.04%
0.60
0.40
0
25
1
25
163
0
189
0
0.09%
0.47
0.53
0
172
6
177
356
491
1024
508
0.28%
0.72
0.28
0
1304
32
1336
1163
148
2647
0
0.13%
0.47
0.53
38
211
7
256
556
640
1452
876
0.75%
0.44
0.56
2
519
18
539
3150
3908
7596
0
0.15%
0.45
0.55
15
259
9
283
639
986
1908
0
0.34%
0.48
0.52
0
645
21
667
1437
1664
3768
2540
0.12%
0.64
0.36
5
3595
99
3698
484
0
4183
0
0.18%
0.64
0.36
0
1110
31
1140
735
218
2093
0
0.23%
0.70
0.30
0
1510
38
1548
964
0
2512
0
0.62%
0.55
0.45
118
450
14
582
2585
1387
4554
0
0.66%
0.48
0.52
0
48
2
49
2764
1719
4532
0
0.00%
0.29
0.71
15
980
39
1034
10
0
1044
0
0.03%
0.65
0.35
258
3024
82
3364
122
805
4292
0
5.39%
0.61
0.39
1998
39159
1126
42282
22572
20888
85743
0
0.60%
0.78
0.22
42
5246
119
5407
2506
804
8718
0
0.41%
0.73
0.27
126
37216
908
38250
1735
781
40765
0
0.06%
0.65
0.35
837
5088
138
6063
266
2260
8589
0
0.10%
0.68
0.32
199
558
15
771
418
22
1212
0
0.34%
0.56
0.44
5
1914
58
1977
1441
1939
5358
0
0.00%
0.23
0.77
0
0
0
0
6
6
12
12
0.11%
0.54
0.46
94
7365
230
7689
457
0
8146
0
0.05%
0.95
0.05
0
10
0
10
190
0
200
0
0.15%
0.84
0.16
9
124
3
135
629
427
1192
0
0.53%
0.64
0.36
80
982
27
1089
2215
1663
4967
0
0.30%
0.21
0.79
0
619
26
645
1258
1737
3640
0
0.01%
0.88
0.12
0
75
1
77
60
0
136
0
0.78%
0.53
0.47
58
631
20
709
3259
2753
6722
0
0.00%
0.44
0.56
22
7
0
30
3
0
33
0
0.53%
0.58
0.42
4
981
29
1014
2209
0
3223
0
0.05%
0.69
0.31
0
2444
63
2506
203
0
2709
0
0.38%
0.83
0.17
0
33
1
34
1583
0
1617
0
0.10%
0.72
0.28
36
2311
57
2404
416
0
2820
0
0.00%
0.63
0.37
6
712
20
738
10
0
748
0
COUNTY INCOME SHARES BY CATEGORY:
154.08% 93781 836857
0.00%
0.04%
1.33%
0.18%
0.00%
0.00%
0.36%
0.20%
0.00%
0.38%
0.00%
0.00%
0.00%
0.09%
0.00%
0.00%
0.79
0.56%
0.00%
0.00%
0.00%
0.02%
0.35%
1.17%
1.45%
0.04%
0.00%
0.03%
0.00%
0.15%
0.01%
0.78
0.13%
0.41%
0.88%
0.55%
9
EXIST_NEED
0
154
15
173
525
6087
382
1144
0
13299
0
234
141
1628
79
913
0
0
150
1741
0
1274
0
133
0
188
0
388
0
139
0
323
313
3631
222
2570
0
1
0
3
2
20
0
77
742
2223
2458
7367
574
6655
18
204
0
2226
0
127
0
3
69
714
0
45
307
3559
0
557
161
1868
342
4017
213
2493
TOT_RHNA
3755
318
6810
1193
17412
4281
3205
1067
27
2644
1996
1669
1516
4201
228
502
3725
3096
212
493
40
1423
2360
8900
8752
353
4854
2012
151
1372
129
5606
2543
1902
6959
3720
is the new area where % based calculations are done
Population Growth Data
Data imported from previous
Option 3 methodology
COUNTY JOB+HQTA % AND RESIDUAL:
Growth
Total: Total: Total:
2989046 278924 278924 278924 1341743
Projected Growth
% proj. growth
Jobs
HQTA
Proj. Growth I
Total Baseline
28629
0.96%
103
0
2672
6375
1186
0.04%
106
0
111
360
3997
0.13%
1479
2228
373
4804
776
0.03%
508
0
72
629
49239
1.65%
8908
7447
4595
25063
22338
0.75%
156
0
2084
6287
4071
0.14%
662
330
380
2949
791
0.03%
392
164
74
784
359
0.01%
0
0
34
60
5904
0.20%
520
541
551
2514
5461
0.18%
1005
887
510
3125
9517
0.32%
89
0
888
2513
10925
0.37%
11
114
1019
2473
26757
0.90%
258
0
2497
6569
572
0.02%
685
994
53
1822
1370
0.05%
887
745
128
1940
352
0.01%
1769
443
33
2338
1030
0.03%
650
915
96
2187
1412
0.05%
1
0
132
343
5764
0.19%
2
0
538
1029
25
0.00%
12
0
2
35
12800
0.43%
51
0
1194
2591
3022
0.10%
805
183
282
1406
10866
0.36%
1976
1296
1014
5819
9404
0.31%
1459
2594
878
7028
476
0.02%
124
0
44
317
12988
0.43%
84
1400
1212
5324
11303
0.38%
85
0
1055
3024
1094
0.04%
2
0
102
252
3795
0.13%
297
133
354
1442
495
0.02%
30
0
46
160
10237
0.34%
1933
235
955
5170
19132
0.64%
200
171
1785
4143
323
0.01%
1090
47
30
1201
29722
0.99%
1450
999
2774
8166
11998
0.40%
929
591
1120
3867
3118
0.10%
402
271
291
1564
25
37
59
65
71
111
60574
Residual
0
0
0
0
7651
0
0
0
0
0
1128
0
0
0
1594
1437
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0.24%
95
1104
1705
74012
2.48%
242
1035
6906
14143
0
0.00%
0
1916
7875
14130
0.47%
854
1091
1319
5764
0
0.00%
0
2918
5418
587
0.02%
328
270
55
739
493
0.00%
0
160
246
2675
0.09%
1942
1403
250
3963
2962
0.00%
0
632
1001
18169
0.61%
1572
1267
1695
6353
0
1.02%
0
4258
6078
6473
0.22%
2334
2692
604
6041
0
1.80%
3776
11315
11727
1429
0.05%
536
419
133
1428
0
0.34%
135
1568
1908
1038
0.03%
443
661
97
1347
953
0.00%
0
248
393
1316
0.04%
878
966
123
2272
0
0.66%
261
3027
3332
1021
0.03%
1104
590
95
1900
0
0.61%
1272
3812
3924
1429
0.05%
143
0
133
484
0
0.05%
107
321
529
27759
0.93%
114
0
2590
6398
0
0.00%
0
171
3864
5870
0.20%
807
112
548
2473
0
0.33%
130
1508
2514
5209
0.17%
2553
1116
486
4635
0
1.32%
520
6024
6504
2022
0.07%
296
105
189
804
0
0.14%
57
658
873
7103
0.24%
920
442
663
3002
0
0.49%
0
2044
3021
11741
0.39%
74
885
1096
4047
0
0.00%
0
1438
3431
21970
0.74%
1901
2369
2050
8861
379
0.00%
0
5941
8482
374
0.01%
245
0
35
368
0
0.09%
35
403
491
2269
0.08%
32
0
212
609
0
0.00%
0
47
413
64352
2.15%
3371
2606
6005
19656
0
2.14%
836
9803
17476
2113
0.07%
1240
827
197
2441
0
0.74%
1553
4655
4832
14117
0.47%
2762
2363
1317
8084
0
1.84%
3850
11538
13180
8460
0.28%
4114
3709
789
10124
0
2.80%
5877
17612
19124
4378
0.15%
1142
1767
409
4261
0
1.04%
412
4776
5719
11658
0.39%
2940
3695
1088
10220
0
2.38%
940
10894
13391
3004
0.10%
524
464
280
1917
0
0.35%
140
1622
2271
1857
0.06%
174
0
173
690
0
0.06%
24
285
628
824
0.03%
329
343
77
859
529
0.00%
0
220
330
3148
0.11%
1427
1622
294
4140
2408
0.00%
0
935
1731
35487
1.19%
185
0
3311
9670
0
0.00%
0
277
6451
662
0.02%
220
0
62
476
0
0.08%
31
362
556
64560
2.16%
261
0
6024
14028
0
0.00%
0
392
8135
116
0.00%
13
0
11
44
0
0.00%
2
21
41
13406
0.45%
464
42
1251
3506
0
0.00%
0
759
2508
787
0.03%
10
0
73
240
0
0.00%
0
14
171
4580
0.15%
3689
2039
427
6597
0
2.05%
4303
12896
13337
3981
0.13%
1182
1655
371
3916
2315
0.00%
0
893
1601
7006
0.23%
36
0
654
2234
0
0.01%
0
53
1598
824
0.03%
16
134
77
383
0
0.05%
0
226
381
36605
1.22%
300
1016
3416
10550
0
0.47%
0
1975
7793
0
0.00%
7
0
0
13
0
0.00%
1
11
17
16199
0.54%
2242
3173
1512
9789
2367
0.00%
0
4560
7422
46130
1.54%
5850
1197
4305
19041
0
2.53%
5294
15865
23555
391
0.01%
21
36
36
168
49
0.00%
0
45
119
15554
0.52%
1644
79
1451
5074
0
0.62%
0
2585
4484
998
0.03%
233
0
93
554
0
0.08%
33
383
611
2827
0.09%
991
572
264
2168
1365
0.00%
0
463
803
308
0.01%
67
0
29
157
0
0.02%
10
110
171
2585
0.09%
915
0
241
1613
0
0.33%
130
1502
1958
62
0.00%
331
22
6
364
0
0.13%
265
794
800
893
0.03%
573
513
83
1315
0
0.39%
154
1782
1928
6347
0.21%
99
151
592
1993
0
0.09%
0
376
1526
1168
0.04%
350
335
109
1013
0
0.25%
97
1125
1343
9
0.00%
166
0
1
185
0
0.06%
125
375
393
2432
0.08%
385
117
227
1577
0
0.18%
377
1130
1979
1025
0.03%
374
133
96
665
0
0.18%
381
1143
1205
229
0.01%
224
207
21
473
0
0.15%
324
971
992
44351
1.48%
281
0
4139
10664
0
0.10%
0
421
6666
2533
0.08%
1173
70
236
1909
0
0.45%
934
2800
3229
4419
0.15%
1717
147
412
3130
0
0.67%
264
3060
3915
50321
1.68%
262
501
4696
13319
0
0.00%
0
1144
9004
817
0.03%
504
933
76
1645
0
0.52%
204
2359
2491
4869
0.16%
300
420
454
2045
0
0.26%
101
1180
2052
718
0.02%
215
193
67
634
0
0.15%
58
670
828
16184
0.54%
8779
10055
1510
29056
2616
0.00%
0
17729
26440
599
0.02%
270
0
56
484
0
0.10%
203
609
767
665352
22.26%
85333
110325
62088
392062
0
70.15%
27732
321249
455565
4579
0.15%
1442
1779
427
4198
2643
0.00%
0
1006
1555
203
0.01%
14
0
19
88
0
0.00%
2
22
78
164
0.01%
452
0
15
499
0
0.16%
64
742
773
954
0.03%
575
778
89
1568
1204
0.00%
0
239
364
35232
1.18%
486
0
3288
9638
0
0.17%
0
729
6593
1641
0.05%
920
44
153
1158
0
0.35%
724
2170
2211
3062
0.10%
441
213
286
1537
0
0.23%
93
1073
1670
9662
0.32%
517
818
902
2636
0
0.48%
187
2190
2589
3455
0.12%
1392
1331
322
3746
0
0.98%
386
4470
5171
3608
0.12%
1262
1465
337
3833
0
0.98%
387
4478
5246
2619
0.09%
163
201
244
1291
0
0.13%
59
604
1287
51667
1.73%
1310
3508
4821
16006
0
0.00%
0
7228
13595
8655
0.29%
337
0
808
3674
0
0.12%
0
505
3035
535
0.02%
0
0
50
136
0
0.00%
0
0
86
5127
0.17%
1565
439
478
2802
0
0.72%
1506
4512
4832
132
0.00%
289
0
12
321
0
0.10%
0
433
453
1223
0.04%
2407
477
114
3287
0
1.03%
409
4735
5024
169
0.01%
3
0
16
66
0
0.00%
0
5
52
76978
2.58%
3625
4414
7183
22842
0
2.88%
1124
13184
20803
11012
0.37%
3353
1547
1028
8119
4193
0.00%
0
1735
3927
21281
0.71%
651
3007
1986
8861
332
0.00%
0
5311
8529
11411
0.38%
163
488
1065
3524
0
0.23%
0
977
2785
12283
0.41%
152
680
1146
3284
0
0.30%
0
1248
2554
44785
1.50%
254
73
4179
10641
0
0.00%
0
491
6625
337
0.01%
75
0
31
181
0
0.03%
11
124
198
1388
0.05%
1231
390
130
1863
1500
0.00%
0
250
363
11680
0.39%
2046
2024
1090
7887
0
1.46%
577
6683
9409
37950
1.27%
499
1281
3541
10437
0
0.00%
0
2670
7786
3482
0.12%
1447
552
325
2980
0
0.72%
283
3282
3939
6120
0.20%
1167
388
571
2987
0
0.56%
1169
3503
4363
29831
1.00%
1987
2088
2784
11277
0
0.00%
0
6113
10532
272
0.01%
55
365
25
534
410
0.00%
0
36
125
22227
0.74%
2444
2221
2074
9589
0
1.67%
652
7650
10500
6401
0.21%
65
219
597
2198
0
0.10%
0
427
1743
173
0.01%
284
89
16
413
0
0.13%
53
614
637
941
0.03%
283
0
88
414
0
0.10%
212
636
679
9929
0.33%
614
341
927
3822
0
0.34%
133
1565
3507
4054
0.14%
887
290
378
2106
0
0.42%
167
1931
2483
29812
1.00%
1436
3072
2782
9608
1356
0.00%
0
5934
8252
55720
1.86%
3963
4379
5200
19447
0
2.99%
0
12513
18419
97
0.00%
16
0
9
43
0
0.01%
2
26
44
370
0.01%
70
0
35
181
0
0.03%
10
115
191
5009
0.17%
997
1350
467
3565
0
0.84%
333
3854
4604
10333
0.35%
2139
3501
964
9620
1516
0.00%
0
5088
8104
13158
0.44%
342
1837
1228
5089
0
0.78%
351
3620
5302
3083
0.10%
165
63
288
977
0
0.08%
171
513
975
711
0.02%
375
353
66
844
0
0.26%
103
1195
1245
2412
0.08%
296
566
225
1462
0
0.31%
122
1415
1790
4619
0.15%
668
508
431
2693
0
0.42%
167
1931
3017
22176
0.74%
124
0
2069
5392
0
0.00%
0
186
3385
4672
0.16%
188
156
436
1057
0
0.12%
259
775
1052
80
0.00%
169
34
7
275
0
0.07%
29
334
398
11102
0.37%
7416
8676
1036
19242
16155
0.00%
0
973
3087
31786
1.06%
1030
273
2966
12139
0
0.47%
185
2139
10009
2259
0.08%
418
0
211
1139
189
0.00%
0
440
950
18314
0.61%
1833
2868
1709
7566
0
1.69%
666
7718
8874
3328
0.11%
76
0
311
928
0
0.00%
0
114
655
359
0.01%
501
0
34
646
0
0.18%
376
1128
1240
295
0.01%
109
0
28
162
0
0.04%
15
179
204
858
0.03%
237
327
80
822
306
0.00%
0
339
516
8216
0.27%
775
99
767
2977
0
0.31%
141
1452
2788
1587
0.05%
371
426
148
1201
625
0.00%
0
320
576
15732
0.53%
2100
2605
1468
6711
0
1.69%
667
7724
8263
1152
0.04%
426
657
107
1474
0
0.39%
154
1778
2061
4157
0.14%
958
1109
388
3122
1894
0.00%
0
561
1228
25602
0.86%
323
0
2389
6411
0
0.12%
0
484
4183
6067
0.20%
490
145
566
2341
0
0.23%
90
1043
2183
13611
0.46%
643
0
1270
3461
0
0.23%
103
1067
2616
5149
0.17%
1723
925
480
3710
0
0.95%
375
4347
4929
9195
0.31%
1843
1146
858
3896
0
1.07%
2245
6728
6777
5766
0.19%
6
0
538
1579
0
0.00%
0
10
1044
11360
0.38%
82
537
1060
5043
0
0.22%
0
928
4292
157192
5.26%
15047
13924
14668
85922
0
10.39%
4106
47567
89849
0.79%
1658
4968
10375
0.60%
0
2515
40765
0.60%
235
2761
8824
0.11%
47
488
1259
0.81%
315
3695
5673
0.00%
0
0
8
0.00%
0
457
8146
0.05%
95
285
295
0.25%
100
1156
1292
0.93%
366
4245
5333
0.72%
283
3278
3923
0.01%
6
66
142
1.44%
3011
9024
9733
0.00%
0
3
33
0.53%
209
2417
3431
0.05%
0
203
2709
0.38%
793
2376
2410
0.10%
39
455
2859
0.00%
1
11
749
46091
1.54%
1670
536
4301
11915 0
135903
4.55%
1156
520
12682
52608 0
39512
1.32%
177
1507
3687
11434 0
2177
0.07%
279
15
203
1268 0
14432
0.48%
961
1293
1347
5578 0
0
0.00%
4
4
0
8 8
57614
1.93%
305
0
5376
13370 0
124
0.00%
126
0
12
148 0
950
0.03%
419
285
89
928 0
9455
0.32%
1476
1109
882
4556 0
3595
0.12%
839
1158
335
2977 0
359
0.01%
40
0
34
150 0
3896
0.13%
2173
1835
364
5081 0
49
0.00%
2
0
5
36 0
9173
0.31%
1472
0
856
3342 0
16793
0.56%
135
0
1567
4209 0
1074
0.04%
1055
0
100
1189 0
16303
0.55%
277
0
1521
4203 0
3896
0.13%
7
0
364
1108 0
[:i1}ML!
0.26%
112.22%
21.21%
7.90%
10.78%
1.72%
Redistr
0
9
304
269
0
0
81
46
0
87
0
0
0
0
0
0
182
129
0
0
1
0
522
1729
333
10
0
0
0
67
0
178
0
93
234
145
55
Existing Need
2774
225
4385
849
13299
2241
1453
676
34
1699
1274
977
1145
2755
139
323
2426
1790
132
540
16
1246
1791
6015
5263
179
2696
1140
104
851
76
3301
2156
1261
5457
2785
1019
Total RHNA
1
24
25
37
59
65
71
111
27%
26%
25%
25%
25%
23%
15%
15%
16%
16%
16%
17%
14%
16%
18%
17%
18%
19%
44%
43%
42%
42%
42%
41%
COUNTY JOB+HQTA%AND RESIDUAL:
25
37
59
65
71
111
0.26%
112.22%
21.21%
7.90%
10.78%
1.72%
0
44368
44442
0
4202
770
Jurisdiction Incomes
Share of population in tracts of various resource levels
150%-180% Social
%LI
%VLR
M
J %VLI
43%
17%
18%
22%
89%
11%
0%
0%
0%
100%
30%
10%
15%
11%
6%
14%
69%
0%
0%
0%
0%
100%
0%
30%
38%
23%
29%
15%
17%
39%
0%
0%
8%
85%
6%
0%
0%
25%
15%
14%
13%
19%
55%
0%
0%
0%
22%
78%
0%
10%
31%
18%
31%
19%
19%
31%
6%
77%
5%
7%
5%
83%
20%
20%
14%
26%
20%
18%
37%
11%
42%
25%
21%
0%
53%
0%
24%
14%
18%
12%
13%
58%
0%
4%
0%
4%
92%
4%
30%
33%
18%
23%
14%
24%
38%
0%
19%
0%
81%
0%
19%
0%
28%
16%
27%
12%
24%
37%
0%
0%
0%
100%
0%
0%
0%
26%
17%
24%
18%
20%
39%
8%
34%
57%
0%
0%
43%
0%
27%
14%
23%
18%
22%
36%
0%
57%
43%
0%
0%
57%
0%
27%
14%
36%
24%
19%
21%
38%
35%
24%
0%
3%
73%
10%
18%
11%
42%
17%
15%
25%
43%
57%
0%
0%
0%
100%
30%
11%
15%
18%
14%
18%
50%
0%
5%
40%
48%
7%
5%
0%
28%
17%
37%
22%
21%
21%
8%
92%
0%
0%
0%
100%
30%
17%
10%
36%
27%
19%
19%
72%
28%
0%
0%
0%
100%
30%
19%
6%
27%
20%
19%
35%
6%
26%
54%
14%
0%
32%
0%
26%
13%
20%
7%
12%
62%
0%
0%
0%
0%
100%
0%
30%
31%
22%
30%
17%
18%
35%
0%
0%
28%
45%
26%
0%
0%
22%
15%
40%
19%
14%
26%
30%
41%
29%
0%
0%
71%
10%
16%
14%
13%
8%
9%
70%
0%
0%
1%
1%
98%
0%
30%
37%
21%
29%
15%
13%
43%
0%
35%
41%
24%
0%
35%
0%
27%
15%
20%
15%
19%
46%
0%
7%
44%
27%
22%
7%
0%
27%
17%
29%
18%
18%
35%
12%
31%
48%
9%
0%
43%
0%
23%
15%
23%
13%
16%
48%
0%
0%
5%
49%
47%
0%
0%
28%
16%
14%
9%
11%
65%
0%
0%
0%
0%
100%
0%
30%
36%
20%
31%
17%
15%
37%
0%
100%
0%
0%
0%
100%
30%
25%
13%
27%
21%
15%
36%
0%
0%
0%
49%
51%
0%
0%
23%
14%
34%
16%
18%
32%
0%
100%
0%
0%
0%
100%
30%
22%
14%
22%
14%
17%
47%
0%
0%
17%
80%
2%
0%
0%
24%
18%
13%
13%
15%
59%
0%
3%
0%
25%
72%
3%
10%
32%
18%
18%
13%
17%
52%
5%
30%
65%
0%
0%
35%
0%
30%
16%
34%
21%
17%
29%
26%
0%
64%
10%
0%
26%
0%
20%
14%
13%
10%
14%
63%
0%
0%
0%
22%
77%
0%
10%
34%
18%
16%
11%
18%
55%
0%
0%
30%
53%
17%
0%
0%
29%
18%
10%
8%
13%
69%
0%
0%
0%
0%
100%
0%
30%
36%
22%
0
8184
14143
16%
9%
14%
61%
0%
0%
20%
21%
59%
0%
0%
31%
18%
0
3264
5764
42%
21%
18%
18%
57%
26%
17%
0%
0%
83%
20%
12%
12%
0
160
246
27%
22%
19%
32%
27%
49%
17%
7%
0%
75%
10%
23%
12%
0
632
1001
33%
23%
17%
27%
0%
100%
0%
0%
0%
100%
30%
21%
9%
0
4534
6353
31%
19%
20%
29%
26%
73%
1%
0%
0%
99%
30%
22%
12%
2655
8285
8697
19%
14%
16%
50%
5%
0%
6%
38%
51%
5%
0%
27%
17%
78
1167
1507
27%
17%
18%
38%
5%
14%
60%
13%
8%
19%
0%
24%
15%
0
248
393
17%
18%
19%
47%
0%
0%
17%
83%
0%
0%
0%
31%
14%
151
2118
2423
36%
24%
20%
20%
51%
37%
12%
0%
0%
88%
20%
19%
9%
895
2683
2795
17%
10%
15%
58%
0%
0%
0%
23%
77%
0%
10%
32%
18%
75
351
560
18%
14%
22%
46%
0%
0%
87%
13%
0%
0%
0%
28%
17%
0
2705
6398
21%
16%
15%
47%
0%
9%
52%
19%
21%
9%
0%
26%
16%
75
1542
2548
46%
21%
17%
15%
57%
1%
38%
4%
0%
57%
0%
14%
14%
301
4457
4936
14%
11%
14%
61%
0%
0%
31%
10%
59%
0%
0%
32%
17%
33
622
837
17%
17%
20%
46%
0%
0%
20%
80%
0%
0%
0%
30%
14%
0
2025
3002
21%
13%
17%
49%
0%
23%
25%
53%
0%
23%
0%
29%
16%
0
2054
4047
10%
8%
13%
69%
0%
0%
0%
0%
100%
0%
30%
36%
22%
0
5941
8482
27%
16%
15%
42%
11%
44%
28%
12%
4%
56%
0%
28%
14%
20
301
388
34%
22%
18%
26%
20%
75%
5%
0%
0%
95%
30%
20%
10%
0
243
609
13%
12%
15%
61%
0%
0%
0%
0%
100%
0%
30%
37%
18%
571
12554
20227
32%
19%
21%
28%
0%
100%
0%
0%
0%
100%
30%
16%
14%
1092
3357
3534
18%
14%
18%
50%
7%
28%
38%
18%
9%
35%
0%
28%
17%
2708
9150
10791
22%
15%
19%
43%
0%
12%
21%
48%
19%
12%
0%
26%
16%
4133
12746
14258
28%
18%
19%
35%
3%
31%
43%
20%
4%
33%
0%
23%
15%
239
3556
4500
33%
19%
20%
29%
0%
48%
52%
0%
0%
48%
0%
21%
14%
545
8268
10765
29%
19%
17%
34%
0%
40%
44%
15%
0%
40%
0%
25%
13%
81
1349
1998
29%
14%
15%
42%
0%
0%
30%
43%
27%
0%
0%
24%
16%
17
364
707
16%
12%
14%
58%
0%
0%
22%
33%
45%
0%
0%
31%
17%
0
220
330
17%
18%
19%
46%
10%
1%
64%
25%
0%
11%
0%
28%
15%
0
935
1731
41%
19%
20%
20%
70%
0%
30%
0%
0%
70%
10%
17%
13%
0
3496
9670
30%
22%
20%
28%
6%
59%
31%
4%
0%
65%
0%
24%
12%
18
300
494
41%
22%
17%
20%
3%
95%
1%
0%
0%
99%
30%
12%
11%
0
6286
14028
9%
6%
12%
74%
0%
0%
0%
0%
100%
0%
30%
40%
23%
1
25
45
29%
17%
19%
35%
6%
57%
27%
11%
0%
62%
0%
22%
15%
0
1757
3506
11%
9%
7%
73%
0%
0%
0%
0%
100%
0%
30%
38%
20%
0
83
240
27%
15%
16%
43%
31%
22%
13%
1%
32%
53%
0%
23%
16%
3026
9182
9623
38%
6%
11%
44%
0%
0%
0%
100%
0%
0%
0%
22%
19%
0
893
1601
22%
15%
19%
44%
5%
3%
25%
30%
38%
8%
0%
26%
16%
0
689
2234
41%
20%
18%
21%
45%
37%
19%
0%
0%
81%
20%
15%
12%
0
228
383
9%
6%
8%
78%
0%
0%
0%
0%
100%
0%
30%
43%
22%
0
4732
10550
19%
10%
9%
62%
0%
0%
0%
0%
100%
0%
30%
29%
21%
1
7
13
30%
19%
19%
32%
14%
12%
57%
13%
4%
26%
0%
22%
15%
0
4560
7422
12%
18%
20%
50%
0%
12%
72%
9%
7%
12%
0%
33%
14%
3723
15075
22764
32%
20%
19%
29%
6%
60%
31%
2%
0%
67%
0%
23%
13%
0
45
119
22%
12%
17%
49%
0%
6%
14%
40%
40%
6%
0%
26%
18%
0
3175
5074
23%
23%
19%
35%
0%
91%
6%
4%
0%
91%
30%
28%
9%
19
346
574
23%
15%
20%
42%
17%
14%
34%
26%
9%
30%
0%
26%
17%
0
6
75
186
89
0
56
88
265
268
228
0
657
153
0
118
69
33
0
143
16066
0
1
37
0
0
509
54
128
224
224
56
0
0
0
1059
0
237
0
768
0
0
0
0
0
6
0
463
101
1231
545
1258
843
850
255
994
871
681
4420
2137
2429
5458
1631
1243
508
17729
469
273812
1006
34
504
239
3774
1626
993
2365
3269
3288
664
9639
1144
50
3542
301
3235
19
15991
1735
5311
1716
1978
4507
113
250
9%
6%
7%
77%
0%
0%
0%
0%
100%
0%
30%
40%
22%
27%
18%
20%
34%
0%
88%
12%
0%
0%
88%
20%
23%
14%
4%
9%
13%
73%
0%
0%
0%
3%
97%
0%
30%
44%
20%
16%
11%
16%
57%
0%
0%
0%
80%
19%
0%
0%
31%
17%
21%
13%
19%
47%
0%
0%
76%
24%
0%
0%
0%
27%
17%
25%
17%
20%
38%
0%
30%
69%
0%
0%
30%
0%
27%
14%
22%
13%
14%
52%
1%
0%
4%
46%
50%
1%
0%
26%
17%
20%
10%
15%
55%
0%
0%
0%
74%
26%
0%
0%
29%
18%
19%
10%
14%
57%
0%
0%
0%
13%
87%
0%
20%
28%
20%
19%
12%
18%
51%
0%
6%
52%
41%
0%
6%
0%
27%
18%
19%
14%
16%
50%
0%
0%
6%
45%
50%
0%
0%
27%
17%
50%
21%
15%
14%
0%
39%
42%
18%
1%
39%
0%
12%
13%
20%
15%
18%
46%
0%
44%
5%
44%
8%
44%
0%
27%
16%
17%
14%
19%
50%
0%
25%
50%
9%
16%
25%
0%
28%
17%
15%
13%
15%
57%
0%
0%
12%
76%
12%
0%
0%
32%
16%
31%
19%
19%
32%
36%
37%
26%
1%
0%
73%
10%
23%
13%
22%
21%
19%
38%
0%
0%
85%
15%
0%
0%
0%
28%
12%
25%
17%
19%
39%
22%
0%
28%
50%
0%
22%
0%
24%
15%
23%
16%
18%
43%
0%
0%
0%
98%
1%
0%
0%
27%
15%
27%
15%
17%
41%
23%
33%
13%
18%
12%
57%
0%
26%
15%
26%
17%
16%
41%
0%
0%
5%
88%
7%
0%
0%
24%
15%
30%
16%
16%
39%
24%
19%
24%
16%
17%
43%
0%
24%
15%
30%
23%
18%
29%
30%
70%
0%
0%
0%
100%
30%
23%
9%
18%
5%
10%
68%
0%
0%
0%
0%
100%
0%
30%
33%
24%
8%
7%
11%
73%
0%
0%
0%
0%
100%
0%
30%
40%
21%
41%
18%
18%
23%
51%
49%
0%
0%
0%
100%
30%
14%
13%
23%
17%
19%
41%
0%
3%
8%
59%
31%
3%
0%
25%
16%
16%
12%
17%
55%
0%
0%
18%
59%
23%
0%
0%
29%
18%
19%
14%
18%
49%
0%
0%
20%
68%
12%
0%
0%
30%
16%
23%
18%
22%
37%
23%
10%
55%
13%
0%
33%
0%
26%
15%
30%
19%
19%
33%
0%
34%
66%
0%
0%
34%
0%
24%
14%
30%
15%
16%
39%
0%
0%
11%
74%
16%
0%
0%
24%
16%
14%
14%
18%
54%
0%
0%
21%
24%
55%
0%
0%
28%
18%
21%
18%
21%
40%
8%
49%
36%
7%
0%
57%
0%
26%
15%
16%
12%
17%
55%
0%
0%
0%
5%
95%
0%
30%
32%
19%
43%
21%
17%
19%
0%
99%
1%
0%
0%
99%
30%
10%
12%
19%
11%
12%
58%
0%
4%
8%
2%
86%
4%
20%
29%
19%
13%
11%
16%
60%
0%
0%
0%
82%
17%
0%
0%
31%
19%
20%
16%
22%
42%
6%
4%
68%
22%
0%
10%
0%
29%
15%
27%
18%
18%
37%
0%
0%
45%
15%
40%
0%
0%
22%
16%
22%
16%
21%
41%
12%
13%
53%
23%
0%
24%
0%
26%
16%
22%
17%
19%
42%
0%
57%
29%
6%
8%
57%
0%
26%
15%
28%
23%
20%
29%
9%
75%
16%
0%
0%
84%
20%
20%
12%
27%
16%
19%
38%
0%
0%
0%
10%
90%
0%
20%
23%
16%
34%
17%
16%
33%
0%
0%
34%
65%
1%
0%
0%
20%
16%
27%
17%
18%
38%
18%
67%
10%
5%
0%
85%
20%
25%
14%
9%
6%
6%
79%
0%
0%
0%
0%
100%
0%
30%
40%
22%
334
5494
8221
30%
20%
20%
30%
0%
80%
20%
0%
0%
80%
20%
24%
12%
0
5321
10437
23%
10%
15%
52%
11%
17%
18%
47%
7%
28%
0%
28%
18%
164
2488
3145
25%
20%
20%
36%
26%
34%
39%
1%
0%
60%
0%
25%
14%
822
2949
3809
23%
17%
19%
41%
0%
14%
85%
1%
0%
14%
0%
28%
14%
0
6859
11277
20%
17%
18%
45%
7%
22%
51%
7%
11%
30%
0%
27%
15%
0
36
125
27%
18%
19%
36%
20%
76%
3%
1%
0%
96%
30%
25%
13%
446
7185
10035
29%
22%
24%
25%
0%
100%
0%
0%
0%
100%
30%
19%
12%
0
882
2198
15%
11%
14%
60%
0%
3%
10%
20%
67%
3%
0%
30%
18%
31
421
444
27%
12%
15%
46%
0%
0%
16%
79%
5%
0%
0%
23%
18%
149
520
563
11%
7%
11%
71%
0%
0%
0%
0%
100%
0%
30%
38%
22%
91
1972
3914
15%
13%
17%
56%
0%
0%
12%
61%
28%
0%
0%
29%
18%
97
1651
2202
21%
13%
16%
50%
10%
2%
5%
44%
38%
12%
0%
26%
17%
0
5934
8252
13%
9%
11%
67%
0%
0%
0%
0%
100%
0%
30%
36%
21%
0
13541
19447
23%
18%
20%
39%
14%
55%
26%
5%
0%
69%
0%
26%
14%
1
26
45
24%
15%
18%
43%
17%
17%
36%
17%
13%
34%
0%
25%
17%
6
110
187
7%
9%
6%
78%
0%
0%
0%
0%
100%
0%
30%
41%
20%
193
3008
3757
7%
6%
11%
75%
0%
0%
0%
0%
100%
0%
30%
41%
22%
0
5088
8104
31%
18%
19%
32%
12%
5%
82%
0%
0%
18%
0%
24%
14%
338
3745
5427
36%
19%
18%
27%
50%
36%
13%
0%
1%
86%
20%
16%
13%
120
636
1098
28%
17%
21%
34%
0%
14%
50%
24%
12%
14%
0%
21%
16%
60
854
904
19%
15%
15%
51%
0%
0%
86%
14%
0%
0%
0%
27%
17%
71
1158
1533
20%
11%
15%
55%
0%
0%
0%
99%
1%
0%
0%
29%
18%
97
1704
2790
29%
15%
17%
38%
0%
46%
54%
0%
0%
46%
0%
24%
15%
0
2193
5392
25%
18%
18%
39%
0%
0%
12%
82%
7%
0%
0%
27%
14%
182
962
1239
29%
21%
20%
30%
21%
40%
37%
2%
0%
61%
0%
22%
14%
17
227
292
25%
15%
19%
41%
0%
43%
40%
17%
0%
43%
0%
24%
16%
0
973
3087
14%
5%
7%
74%
0%
0%
0%
0%
100%
0%
30%
36%
23%
107
4376
12246
34%
22%
19%
24%
16%
73%
11%
0%
0%
89%
20%
18%
12%
0
440
950
13%
11%
15%
61%
0%
0%
10%
44%
46%
0%
0%
32%
17%
386
6796
7952
28%
12%
17%
43%
0%
54%
17%
29%
0%
54%
0%
25%
17%
0
386
928
21%
11%
12%
56%
0%
0%
0%
8%
92%
0%
30%
30%
19%
265
799
911
38%
20%
20%
22%
36%
40%
24%
0%
0%
76%
10%
15%
15%
9
145
171
35%
16%
15%
35%
0%
0%
22%
36%
42%
0%
0%
20%
16%
0
339
516
12%
11%
15%
62%
0%
0%
0%
0%
100%
0%
30%
37%
19%
136
1776
3112
19%
16%
14%
52%
0%
59%
41%
0%
0%
59%
0%
30%
15%
0
320
576
19%
15%
19%
47%
0%
2%
60%
31%
7%
2%
0%
26%
18%
386
6559
7098
32%
21%
21%
26%
37%
63%
0%
0%
0%
100%
30%
21%
11%
89
1280
1562
29%
22%
20%
29%
2%
46%
52%
0%
0%
48%
0%
24%
12%
0
561
1228
15%
10%
16%
59%
0%
0%
0%
0%
100%
0%
30%
35%
19%
0
2712
6411
40%
21%
17%
22%
14%
85%
1%
0%
0%
99%
30%
13%
12%
52
1253
2393
14%
11%
15%
59%
0%
0%
0%
22%
78%
0%
10%
31%
19%
100
2012
3561
23%
14%
15%
48%
0%
0%
10%
38%
52%
0%
0%
27%
16%
217
3345
3928
18%
13%
16%
53%
0%
0%
10%
19%
71%
0%
10%
27%
19%
1579
5425
5475
17%
12%
14%
57%
0%
0%
5%
19%
76%
0%
10%
31%
17%
0
545
1579
25%
17%
20%
37%
4%
31%
34%
15%
16%
35%
0%
24%
15%
0
1679
5043
32%
23%
18%
27%
0%
55%
34%
2%
9%
55%
0%
21%
12%
2379
46018
88300
29%
17%
14%
40%
0%
33%
22%
20%
25%
33%
0%
27%
14%
1166
7674
0
14359
161
5531
46
542
215
3815
0
0
0
5681
67
205
58
851
212
3680
164
2496
3
77
2118
6489
0
7
121
2449
0
1702
558
1713
27
1825
1
371
[11MAI
4
174
24%
15%
17%
44%
10%
29%
22%
24%
16%
39%
0%
27%
15%
16%
12%
14%
58%
0%
9%
10%
34%
48%
9%
0%
29%
18%
25%
16%
16%
42%
10%
17%
20%
13%
40%
27%
0%
24%
16%
27%
17%
19%
38%
9%
34%
24%
18%
15%
43%
0%
23%
15%
22%
14%
17%
47%
2%
24%
24%
27%
22%
26%
0%
24%
18%
21%
14%
17%
48%
9%
5%
13%
35%
38%
14%
0%
27%
17%
5%
41%
13%
42%
1%
85%
0%
15%
0%
85%
20%
41%
-3%
30%
18%
17%
35%
33%
64%
2%
0%
0%
97%
30%
20%
14%
14%
7%
12%
67%
0%
2%
0%
48%
49%
2%
0%
30%
20%
15%
11%
13%
62%
0%
0%
0%
38%
62%
0%
0%
32%
17%
19%
14%
16%
51%
0%
6%
45%
44%
5%
6%
0%
30%
16%
26%
12%
15%
47%
0%
0%
0%
0%
100%
0%
30%
26%
17%
10%
8%
8%
73%
0%
0%
0%
0%
100%
0%
30%
39%
21%
37%
18%
17%
28%
6%
32%
62%
0%
0%
38%
0%
18%
15%
40%
13%
19%
29%
0%
0%
100%
0%
0%
0%
0%
21%
16%
21%
15%
16%
48%
0%
14%
22%
43%
21%
14%
0%
28%
16%
18%
15%
20%
46%
0%
0%
20%
51%
29%
0%
0%
28%
17%
13%
10%
15%
61%
0%
0%
26%
60%
14%
0%
0%
30%
19%
27%
13%
17%
43%
0%
0%
21%
69%
10%
0%
0%
23%
17%
35%
17%
14%
34%
0%
49%
50%
1%
0%
49%
0%
20%
15%
CATEGORYADJ. 1.05 1.01 1.00 0.97
351796 206807 223957 559267
mll I KE I CPA i
INCOME DISTRIBUTION WEIGHTING STEP
334969
205602
223742
577528
Equity Adjustment
UNWEIGHTED INCOME
DISTRIBUTION
%MI %AMI
642
JVLI LI
MI
1.013
AMI
17%
58%
369
555
641
2190
17%
22%
121
72
56
68
16%
44%
1683
1027
1075
3025
17%
34%
372
214
206
402
17%
49%
3561
2367
2924
8560
17%
45%
1029
595
744
1913
19%
30%
1054
570
608
973
12%
45%
296
167
128
477
12%
46%
7
4
3
12
14%
45%
722
364
381
1177
13%
46%
546
273
262
915
17%
54%
298
190
277
905
19%
55%
161
223
295
836
17%
38%
1170
717
723
1590
12%
60%
40
23
28
137
14%
62%
93
28
71
309
15%
46%
962
483
551
1730
20%
27%
965
680
605
847
18%
45%
47
32
37
96
19%
51%
77
69
95
251
22%
20%
15
9
9
8
14%
45%
378
208
202
635
17%
39%
636
391
403
931
18%
45%
2009
1330
1565
3996
16%
40%
2430
1410
1408
3504
20%
24%
126
71
70
86
13%
49%
1211
648
610
2385
19%
44%
469
272
377
894
11%
54%
33
21
16
81
20%
38%
335
242
270
525
19%
31%
41
23
24
40
16%
38%
1688
909
876
2133
18%
48%
510
349
454
1231
18%
30%
650
345
333
574
17%
35%
2014
1279
1205
2461
21%
21%
1335
824
796
765
mll I KE I CPA i
-159
INCOME DISTRIBUTION WEIGHTING STEP
-16
VLI LI
351637
MI
AMI
ITOT CITY TOTAL ADJ.
388
558
642
2121
3708
1.013
128
73
56
66
322
0.986
1768
1033
1076
2929
6806
1.001
391
215
206
389
1200
0.994
3740
2381
2927
8289
17337
1.004
1081
598
745
1853
4276
1.001
1107
573
609
943
3231
0.992
310
168
128
462
1068
0.999
7
5
3
12
27
1.000
758
367
382
1140
2646
0.999
574
274
262
886
1996
1.000
313
191
277
876
1657
1.007
169
224
296
810
1499
1.011
1229
722
724
1540
4214
0.997
42
23
28
133
226
1.010
98
29
71
300
497
1.010
1010
486
551
1675
3722
1.001
1013
684
606
820
3122
0.992
49
33
37
93
212
1.002
81
70
95
243
489
1.007
15
9
9
8
41
0.987
397
209
202
615
1423
1.000
668
393
403
901
2365
0.998
2110
1338
1567
3869
8884
1.002
2552
1418
1409
3394
8773
0.998
132
71
70
83
357
0.989
1272
651
611
2310
4844
1.002
492
274
377
866
2009
1.001
35
21
16
79
150
1.005
352
243
270
508
1374
0.999
43
24
24
39
130
0.993
1773
914
877
2065
5630
0.996
535
351
454
1192
2532
1.004
682
347
334
556
1919
0.991
2115
1286
1206
2384
6991
0.995
1402
829
797
740
3768
0.987
-159
-60
-16
242
351637
206747
223941
559509
FINAL RE -WEIGHTED
DISTRIBUTION
VLI LI
MI
AMI
393
565
650
2148
126
72
55
65
1769
1033
1077
2931
388
213
205
386
3757
2391
2939
8325
1082
599
745
1855
1098
568
604
935
310
168
128
462
7
5
3
12
757
366
381
1139
574
274
262
886
315
192
279
882
171
227
299
819
1225
719
722
1535
42
23
29
134
99
29
72
303
1011
486
552
1676
1005
678
600
813
49
33
37
93
81
70
96
245
15
8
9
8
397
209
202
615
666
392
402
899
2113
1340
1570
3876
2546
1415
1406
3386
131
70
70
82
1274
653
612
2315
493
274
378
867
35
21
16
79
351
243
270
508
43
23
24
39
1765
911
873
2057
537
352
456
1197
676
344
331
551
2106
1281
1200
2373
1384
819
787
731
17%
33%
530
309
298
569
556
310
298
551
1716
0.994
553
308
296
548
17%
58%
970
981
1349
4576
1019
986
1350
4431
7786
1.011
1030
998
1366
4482
17%
48%
1246
660
900
2611
1309
664
901
2529
5403
1.003
1313
666
904
2536
15%
55%
51
21
38
135
54
22
38
131
244
1.006
54
22
38
132
13%
53%
221
119
130
531
233
120
130
514
996
1.005
234
120
130
517
18%
37%
1669
1035
1097
2277
1753
1041
1098
2205
6097
0.997
1748
1038
1094
2198
18%
44%
2768
1777
2079
5103
2907
1787
2081
4941
11717
1.001
2910
1789
2083
4946
15%
41%
585
267
282
775
614
268
282
750
1915
0.996
612
267
281
747
13%
58%
75
36
53
230
79
36
53
223
390
1.008
79
36
53
224
17%
33%
1058
603
562
1109
1111
606
562
1074
3354
0.993
1104
602
558
1067
16%
40%
1093
653
623
1555
1148
657
623
1506
3934
0.997
1145
655
622
1502
19%
39%
139
83
101
206
146
84
101
199
530
0.998
146
84
101
199
18%
55%
534
526
679
2125
561
529
680
2057
3827
1.010
567
534
686
2077
17%
33%
806
433
438
837
846
435
438
811
2531
0.993
841
432
435
805
14%
41%
1979
940
914
2671
2078
946
915
2587
6525
0.997
2072
943
912
2578
15%
39%
251
141
135
345
264
142
135
334
876
0.997
263
142
135
333
21%
20%
1101
676
642
603
1156
680
642
584
3062
0.987
1141
671
634
576
13%
45%
950
486
460
1535
998
489
461
1487
3433
0.999
997
488
460
1485
14%
56%
1694
840
1220
4727
1779
845
1222
4578
8424
1.007
1791
851
1230
4610
17%
28%
181
88
84
138
190
89
84
133
496
0.989
188
88
83
132
17%
52%
68
59
71
215
71
60
71
208
410
1.007
72
60
72
209
17%
38%
4866
2935
3035
6640
5111
2952
3038
6430
17531
0.997
5095
2943
3029
6410
17%
41%
1243
781
833
1975
1306
785
834
1913
4837
0.999
1304
785
833
1911
17%
45%
3032
1970
2261
5917
3184
1982
2263
5730
13159
1.002
3189
1985
2267
5739
17%
48%
3940
2768
3189
9227
4138
2784
3192
8935
19049
1.004
4154
2795
3204
8970
16%
47%
1407
753
889
2670
1477
757
890
2586
5711
1.001
1479
758
892
2589
17%
43%
3264
2145
2241
5741
3428
2157
2243
5560
13388
1.000
3429
2158
2244
5561
17%
35%
701
385
389
796
737
387
390
771
2284
0.994
732
385
387
766
17%
40%
179
91
106
252
188
92
106
244
630
0.997
187
91
106
243
14%
56%
57
43
45
185
59
43
45
179
327
1.008
60
43
46
181
14%
50%
421
202
248
860
442
203
248
833
1726
1.003
443
204
249
835
18%
59%
761
717
1156
3816
799
721
1157
3696
6374
1.012
809
730
1171
3741
19%
18%
223
128
107
98
234
128
107
95
565
0.984
231
126
105
94
17%
45%
1820
1218
1401
3696
1911
1225
1403
3579
8118
1.002
1915
1228
1406
3587
23%
19%
16
8
9
8
17
8
9
7
42
0.985
16
8
9
7
19%
42%
587
406
470
1046
617
408
470
1013
2507
1.000
617
408
470
1013
15%
44%
38
33
26
75
40
33
26
72
171
1.001
40
33
26
73
17%
40%
3481
2170
2305
5382
3656
2182
2307
5212
13357
0.999
3651
2179
2303
5204
15%
58%
248
192
240
922
260
193
240
892
1586
1.010
263
195
242
901
19%
17%
680
349
298
271
714
351
299
262
1626
0.983
702
345
294
258
24%
26%
111
81
92
98
117
81
92
95
384
0.992
116
80
91
94
17%
47%
1697
1157
1307
3632
1782
1164
1308
3517
7771
1.003
1787
1167
1312
3527
14%
39%
6
4
2
7
6
4
2
6
19
0.905
5
4
2
6
15%
49%
1716
944
1105
3657
1802
949
1106
3541
7399
1.003
1808
952
1110
3552
18%
38%
6087
4210
4304
8954
6393
4234
4308
8671
23606
0.998
6379
4225
4299
8652
14%
49%
34
11
16
58
35
11
16
56
119
1.001
35
11
16
56
16%
42%
1146
743
729
1867
1204
747
729
1808
4488
0.999
1203
747
729
1806
23%
15%
243
136
141
91
255
137
141
88
621
0.984
251
135
139
87
16%
47%
181
115
129
378
190
115
129
366
801
1.003
191
116
130
367
18%
18%
74
35
31
31
78
35
31
30
174
0.983
77
34
31
29
16%
35%
605
341
321
691
636
343
321
669
1969
0.994
632
341
319
665
17%
39%
212
139
137
312
223
140
137
302
802
0.998
222
140
137
301
14%
45%
517
273
275
863
543
275
275
836
1929
1.000
543
275
275
836
19%
37%
400
267
296
563
420
268
297
545
1530
0.997
419
268
296
544
17%
36%
394
238
224
488
414
239
224
472
1349
0.996
412
238
223
470
20%
31%
112
80
79
122
117
80
79
119
395
0.994
117
80
79
118
18%
37%
540
351
354
735
567
353
354
711
1985
0.997
565
352
353
709
19%
37%
331
201
223
450
348
202
223
436
1209
0.997
347
201
223
435
19%
56%
118
133
189
553
124
133
189
535
981
1.011
125
135
191
541
17%
40%
1787
1092
1132
2655
1876
1099
1133
2571
6679
0.998
1873
1097
1131
2566
17%
38%
910
540
559
1219
956
543
560
1181
3240
0.997
953
541
558
1177
17%
35%
1238
636
655
1386
1300
639
656
1342
3938
0.994
1293
636
652
1335
15%
49%
2106
1181
1321
4396
2212
1188
1322
4257
8979
1.003
2218
1192
1326
4269
15%
45%
695
308
370
1118
730
310
370
1082
2493
0.999
729
310
370
1082
17%
44%
497
309
352
894
522
311
352
865
2051
1.001
522
311
353
866
15%
42%
227
123
128
351
238
124
128
340
829
0.999
238
123
127
339
16%
43%
6782
4015
4146
11497
7123
4039
4150
11133
26445
1.000
7122
4038
4149
11131
19%
42%
183
117
144
322
192
118
145
312
767
1.000
192
118
145
312
16%
44%
110045
68131
74795
202594
115573
68530
74867
196188
455158
1.001
115676
68591
74934
196364
15%
53%
356
137
234
829
373
138
234
803
1548
1.005
375
138
235
807
21%
22%
26
18
17
17
27
18
17
17
79
0.989
27
18
17
17
20%
18%
310
166
157
140
326
167
157
136
785
0.984
321
164
155
133
15%
59%
50
46
54
213
53
46
54
206
360
1.011
54
47
55
209
17%
42%
1672
1043
1103
2775
1756
1049
1104
2687
6596
0.999
1755
1049
1103
2686
18%
35%
642
400
398
772
674
402
398
748
2222
0.995
671
400
396
744
15%
39%
495
261
254
659
520
263
255
638
1676
0.997
518
262
254
636
15%
44%
663
380
398
1148
696
382
399
1112
2589
1.000
696
382
399
1112
15%
47%
1244
699
772
2456
1307
703
773
2378
5161
1.002
1309
705
774
2383
16%
44%
1256
814
844
2331
1319
819
845
2258
5241
1.001
1320
820
846
2260
19%
35%
359
232
246
450
377
234
246
436
1292
0.996
376
233
245
434
16%
43%
3591
2036
2160
5808
3771
2048
2162
5624
13606
0.999
3768
2046
2161
5620
18%
31%
964
582
547
942
1013
585
547
912
3058
0.993
1005
581
543
905
18%
60%
8
10
16
52
9
10
16
50
85
1.014
9
10
16
51
22%
30%
1390
928
1053
1461
1460
933
1054
1415
4862
0.994
1451
927
1048
1406
18%
33%
138
84
82
148
145
85
82
144
456
0.994
144
84
81
143
13%
43%
1471
754
658
2141
1545
759
659
2073
5035
0.998
1542
757
657
2068
19%
43%
11
8
10
22
12
8
10
22
52
1.002
12
8
10
22
16%
43%
5358
3261
3320
8864
5627
3280
3323
8584
20814
0.999
5624
3279
3322
8579
17%
42%
1014
600
675
1638
1065
603
676
1587
3930
0.999
1064
603
676
1585
18%
49%
1739
1057
1527
4206
1826
1063
1528
4073
8491
1.004
1834
1068
1535
4092
16%
44%
640
455
459
1231
672
458
460
1192
2781
1.001
673
459
460
1193
18%
46%
516
404
459
1176
542
406
459
1139
2546
1.003
543
407
461
1142
15%
45%
1686
927
1000
3012
1771
932
1001
2917
6621
1.001
1772
933
1001
2919
24%
14%
78
44
48
27
82
45
48
26
201
0.983
81
44
47
26
13%
51%
86
43
48
187
90
43
48
181
362
1.004
90
43
48
182
17%
38%
2617
1654
1566
3572
2748
1664
1567
3459
9439
0.997
2739
1659
1562
3449
16%
45%
1926
1116
1269
3475
2023
1123
1270
3365
7781
1.001
2024
1124
1271
3367
15%
43%
1094
559
572
1713
1149
562
573
1659
3944
0.999
1148
562
572
1657
18%
40%
1170
675
769
1749
1229
679
770
1693
4371
0.998
1226
678
768
1690
14%
48%
2653
1326
1502
5051
2786
1333
1504
4891
10515
1.002
2791
1336
1506
4899
14%
54%
24
15
18
68
25
15
18
66
124
1.007
25
15
18
66
19%
33%
3099
1915
2043
3443
3254
1927
2045
3334
10560
0.994
3236
1916
2033
3315
19%
40%
408
315
327
692
429
317
328
670
1744
1.000
429
317
328
670
20%
20%
243
139
127
128
255
140
127
124
646
0.986
251
138
125
122
18%
35%
199
119
125
236
209
120
125
228
682
0.995
208
120
125
227
19%
38%
919
612
651
1325
966
615
652
1283
3516
0.998
963
614
650
1280
20%
23%
898
510
494
581
943
513
495
562
2513
0.988
932
507
489
555
17%
43%
2106
1196
1367
3584
2211
1203
1368
3470
8253
1.000
2211
1203
1368
3470
17%
41%
4620
3042
3132
7625
4852
3059
3135
7384
18431
0.999
4849
3057
3133
7379
24%
15%
18
9
11
6
19
9
11
6
45
0.983
19
9
11
6
20%
16%
78
43
39
31
82
43
39
30
194
0.983
81
42
38
30
15%
48%
1094
631
683
2196
1149
635
684
2127
4594
1.002
1151
636
685
2131
18%
53%
1333
1080
1433
4258
1400
1086
1434
4124
8044
1.007
1411
1094
1445
4154
18%
45%
1124
856
945
2377
1181
861
946
2302
5289
1.002
1184
863
948
2307
19%
37%
267
162
187
359
280
163
187
348
978
0.997
279
162
186
347
17%
37%
365
218
207
455
384
220
207
440
1250
0.996
382
219
206
438
16%
45%
437
270
283
800
459
272
283
775
1788
1.001
459
272
283
776
15%
44%
803
412
464
1337
844
414
465
1295
3018
1.000
843
414
465
1295
16%
48%
757
460
556
1611
795
463
557
1560
3375
1.003
797
464
559
1565
17%
42%
256
171
183
442
268
172
183
428
1052
1.000
268
172
183
428
23%
18%
143
91
92
71
151
92
92
69
404
0.986
149
91
91
68
17%
54%
551
356
518
1662
579
358
518
1609
3065
1.007
583
360
522
1621
17%
33%
3248
1732
1678
3351
3411
1742
1680
3245
10078
0.993
3388
1730
1668
3222
16%
42%
240
158
152
401
252
158
152
389
950
1.000
252
158
152
388
19%
32%
2670
1669
1707
2828
2804
1678
1709
2739
8930
0.994
2786
1668
1698
2721
18%
52%
95
97
120
343
100
97
120
332
650
1.008
101
98
121
335
19%
45%
243
199
237
561
256
200
238
543
1236
1.003
256
200
238
545
17%
27%
76
39
35
55
79
39
35
53
206
0.989
78
38
34
53
17%
38%
152
78
90
196
160
78
90
190
518
0.996
159
78
90
189
19%
38%
712
490
518
1068
748
493
518
1034
2793
0.998
746
492
517
1032
12%
56%
123
63
69
321
129
63
69
311
572
1.006
130
63
70
313
14%
50%
2023
983
1167
4090
2124
989
1168
3961
8242
1.003
2130
991
1171
3971
16%
29%
725
398
336
602
761
400
336
583
2081
0.990
754
397
333
578
19%
57%
154
142
228
704
162
143
228
682
1215
1.011
164
144
231
690
19%
31%
1299
800
781
1303
1364
804
782
1262
4212
0.993
1355
799
777
1253
17%
40%
599
348
369
866
629
350
370
839
2188
0.998
628
349
369
837
20%
34%
700
492
532
891
736
495
533
863
2626
0.996
733
493
531
860
17%
34%
1549
845
856
1680
1627
850
856
1627
4959
0.994
1617
844
851
1617
17%
44%
1639
1038
1129
2971
1721
1044
1130
2877
6773
1.001
1722
1045
1131
2879
18%
50%
217
125
183
519
228
126
183
502
1039
1.004
229
126
184
504
13%
46%
1142
591
578
1981
1199
594
579
1918
4291
1.000
1200
595
579
1919
16%
42%
24394
13601
14159
37695
25619
13681
14172
36503
89976
0.999
25583
13662
14152
36452
20%
34%
2994
1860
2043
3479
3144
1871
2044
3369
10428
0.995
3128
1861
2034
3352
18%
41%
9902
6610
7365
16888
10400
6649
7372
16354
40774
1.000
10398
6647
7370
16350
17%
44%
2069
1349
1519
3887
2173
1357
1521
3764
8814
1.001
2176
1358
1522
3768
20%
38%
302
223
249
484
318
225
249
469
1260
0.999
317
225
249
468
18%
39%
1507
953
1012
2201
1583
958
1013
2131
5686
0.998
1579
956
1011
2127
19%
43%
4
4
1
3
4
4
1
3
13
0.612
4
4
0
0
18%
48%
1641
1122
1493
3890
1723
1129
1494
3767
8113
1.004
1730
1133
1500
3782
21%
29%
88
60
61
86
93
60
61
84
297
0.993
92
59
61
83
18%
33%
408
225
232
427
428
226
232
414
1301
0.993
426
224
231
411
16%
38%
1575
846
866
2047
1654
851
866
1982
5353
0.996
1648
847
863
1974
17%
39%
1013
684
681
1545
1064
688
682
1496
3930
0.998
1062
687
681
1493
23%
18%
55
29
32
25
58
29
32
25
144
0.985
57
29
32
24
18%
49%
1775
1453
1769
4735
1865
1462
1771
4586
9683
1.005
1874
1469
1780
4610
11%
52%
7
5
4
17
7
5
4
16
33
1.005
7
5
4
17
16%
40%
975
534
556
1366
1024
537
556
1323
3440
0.997
1022
535
555
1319
16%
39%
759
447
434
1069
797
450
435
1035
2716
0.997
795
449
433
1032
19%
32%
730
450
459
771
767
452
459
747
2425
0.994
762
449
456
742
18%
42%
671
489
509
1190
705
492
509
1153
2858
1.000
705
492
509
1153
19%
46%
146
115
144
343
154
116
144
333
746
1.004
154
116
145
334