Regional Housing Needs Allocation
The Reginal Housing Needs Allocation (RHNA) process begins with the California Department of Housing and Community Development (HCD). HCD determines the amount of housing that is needed for the Bay Area for the next eight-year housing element cycle, in this case 2023-2031. The regional council of governments – in our case, the Association of Bay Area Governments (ABAG) – is required by state law to allocate the housing need, by income level, to the individual jurisdictions that comprise the 9-county Bay Area. ABAG must develop a methodology to allocate RHNA according to objectives identified in State law. ABAG staff developed this methodology in conjunction with an appointed Housing Methodology Committee comprised of local jurisdiction elected officials and staff and regional stakeholders. The methodology was approved by the ABAG Executive Board in May 2021. The methodology is described in the Association of Bay Area Governments’ Draft Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031 (“RHNA Plan”).
For this housing element cycle, ABAG must allocate 441,176 housing units, which is about double what it was for the last cycle. The units breakdown into income categories as follows: 114,442 units for very low income households (25.9% of total); 65,892 low income units (14.9% of total); 16.5% moderate income units (42.6%); and 188,130 above moderate income units (42.6%).
ABAG developed a RHNA methodology that utilized three steps.
- Baseline Allocation. ABAG assigned a baseline allocation to each jurisdiction, which, according to the RHNA Plan, is based on each jurisdiction’s share of the total households in the year 2050 from the Plan Bay Area Final Blueprint (“Final Blueprint”). The Final Blueprint does not actually project the number of households, or the household growth rate, at the jurisdiction level. Instead, it allocates housing at the county and sub-county level. According to the Final Blueprint, the number of households in Marin County is expected to grow by 34% between 2015 and 2050, and the number of households in the South Marin subcounty area, which includes Belvedere, is expected to grow 21%.
- Factor Weighting. Next, ABAG’s methodology applies weights to the baseline allocation. The formula is a little complex, but essentially it allocates more housing to jurisdictions that are “Access to High Opportunity Areas” (the AHOA factor) and have “Proximity to Jobs”, either jobs that can be accessed with a 30-minute auto commute (the JPA factor) or by a 45-minute transit commute during the morning peak period (the JPT factor). To rank high on the AHOA scale, a jurisdiction will have high performing schools, less exposure to environmental and health hazards, higher employment, a higher percentage of adults with a bachelor’s degree, and lower poverty rates. ABAG gives the jurisdiction a score between 0.5 and 1.5 on each factor. If a jurisdiction receives a 1.5, it will receive 150% of the housing that was originally calculated. If it receives 0.5, it will get half. Belvedere was assigned a 1.5 AHOA, a 0.6 JPA factor, and a 0.5 JPT factor.
- Equity Adjustment. Finally, ABAG applies an equity adjustment to jurisdictions that exhibit racial and socioeconomic demographics and that did not receive an allocation of lower-income units that are at least proportional to its share of the region’s households in 2020. Belvedere was determined to be “exclusionary,” but the equity adjustment did not apply because the City had already received a lower-income unit allocation that met the threshold.
Our appeal and analysis are impeded by the following constraints:
- The appeal must be based on ABAG’s failure to apply the methodology, not on the methodology itself. The jurisdictions have already had the opportunity to appeal the methodology, and the methodology has been approved by both the ABAG Executive Board and HCD.
- ABAG provides the baseline allocation and factors in round numbers (e.g., 0.1%), which make it exceedingly difficult to replicate the methodology. Part of our appeal is documenting how we determined the baseline allocation ABAG assigned Belvedere by “reverse engineering” the RHNA allocation.
- ABAG has not provided the data inputs and formulas to replicate how they arrived at the factors. Despite this, we have determined that it is not worthwhile to argue the computation of the factors. Belvedere has already been assigned relatively low Jobs Proximity numbers and there is no point in disputing that Belvedere is at the highest end of the AHOA scale.
- ABAG has not provided the data inputs and formula to replicate how they arrived at the baseline allocation. Based on the wide disparity of the South Marin jurisdictions’ household growth rates, we have surmised that Belvedere’s exceptionally high growth rate is due to MTC identifying a portion of Belvedere in a Transit Rich Area within a High Resource Area.
Essentially, our appeal documents how Belvedere’s RHNA allocation is derived from a baseline allocation that assumes the number of households in Belvedere will grow 48% by 2050, which greatly exceeds the 21% growth rate projected by the Final Blueprint for the South Marin jurisdictions. Furthermore, we argue in Appeal 2 that there is little suitable land for high density multifamily housing in Belvedere, and none in the Transit Rich Area, to justify a higher growth rate and RHNA for Belvedere. We therefore request a RHNA allocation that mirrors the 21% growth rate assigned to the South Marin subcounty area.