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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.
Our appeal and analysis are impeded by the following constraints:
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.
2023-2031 Regional Housing Needs Assessment (RHNA) Appeal Request