☆ Opinion: Bay Area cities “set up to fail” via impossible RHNA demands (3/3)
Image by David Sawyer
Former Los Altos mayor Anita Enander breaks down CA's Regional Housing Needs Allocation process, and what she considers indefensible calculations and harmful rigidity. Enander thinks cities like SJ could better address community needs without RHNA's req'ts. An Opp Now exclusive.
Opportunity Now: You've discussed some local (city-level) decisions that you believe harm our housing market and drive up costs. How do state mandates like RHNA—our Regional Housing Needs Allocation—play into all of this?
Anita Enander: The total number of housing units for the State of California in this RHNA cycle (an eight-year period) was just shy of 2.5 million.
ON: Meaning, California's required to build that many units before the cycle's over. Right?
AE: Yes, its cities and counties, which is roughly 300k units per year. Now, using HCD's own data going back 50 years, we find there was one year (three decades ago) where California built 300k. One year. And since then, we've averaged a little over 100k per year (including the big dip we had after the 2008 recession).
Go Deeper:
So through RHNA, California cities are being told to find a way—not just to allow and permit, but magically to get built almost 3x as many units per year for eight years as what has been built each year in the last 30. Did the calculation to get 2.5 million consider factors like materials, builders, and how construction actually happens?
And then there's the commensurate bludgeon that if the big number isn't reached, a city loses all ability to decide what gets built and where. That's unreasonable.
ON: How flexible is RHNA over those eight years to account for fluctuating data, such as population losses?
AE: Not at all. The RHNA process is very long and has no mid-way adjustment process. This cycle started back in 2016. The Dept of Finance took their projections on economic development, birthrates, demographics of population, etc., and in 2017 and 2018 projected the number of jobs, ages, etc., through modeling. HCD then used that data to determine how many housing units should be built. (Note that HCD's internal process was found by a state auditor to be neither transparent nor defensible.)
ON: Can you give us an example?
AE: On top of the units already included by the Department of Finance for overcrowding, HCD applied their own, very inflated calculation to generate additional required units under RHNA. “Overcrowding” according to the HCD means you don't have one room (excluding the kitchen and bathrooms) for each person, regardless of age; and they add one required unit for California to fulfill for each person overcrowded. That “overcrowded” person could be a baby or young child.
HCS was also legislatively required to account for certain percentages of vacant properties. Historically, they'd need 2% extra vacant owned properties and 5% extra vacant apartments to account for people moving; but now they've applied the 5% vacancy rate to owned-occupant houses, which automatically meant another 3% of owned-occupant (2% of total existing housing stock) was piled onto RHNA requirements.
As to your query: there have been population losses in California since Covid. But RHNA for this cycle won't change. According to the latest Dept of Finance projections, California won't stabilize its population until either 2050 or 2060. Why should cities be forced to push through more housing when the population is going down?
ON: That sounds like a fair question. How does HCD respond?
AE: HCD's rejoinder is that we're already short housing. But this ignores the fact that developers won't build excess housing if it can't be absorbed into the stock of housing in a way that makes them money. So in this way, cities are being set up to fail.
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