HomeMy WebLinkAbout10/16/2001, BUS 9 - THE SAN LUIS OBISPO COUNCIL OF GOVERNMENTS' (SLOCOG) REGIONAL HOUSING NEEDS ALLOCATION PROCESS AN o�
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CITY OF SAN LUIS OBISPO
FROM: John Mandeville, Long-Ran ning Manager
Prepared By: Jeff Hook, Associate Plan
SUBJECT: The San Luis Obispo Council Of Governments' (SLOCOG) Regional
Housing Needs Allocation Process And Methodology.
CAO RECOMMENDATION: Receive a report on the SLOCOG housing allocation process
and adopt a resolution on a preferred methodology for
determining regional housing needs that includes a
"development suitability" factor.
DISCUSSION
State law requires local governments to update their housing elements following a state-adopted
schedule. Jurisdictions in San Luis Obispo County must update their housing elements by
December 2003. A critical, early step in the update process is the determination of regional
housing need. To accomplish this task, state law (Gov. Code 65580-65589.8) charges regional
councils of government (COGS) with the responsibility of determining existing and projected
housing need for their regions. If a COG does not assume this responsibility, the State
Department of Housing and Community Development (HCD) will determine regional housing
needs for each jurisdiction. The San Luis Obispo Council of Governments (SLOCOG) has, in
cooperation with the cities and County, begun that task. Councilmember Schwartz is the
Council's representative on the SLOCOG Board of Directors.
At the invitation of SLOCOG, representatives from the cities, the County, and stakeholder
groups first met in April. The meeting was to gauge support for a cooperative, countywide
approach to allocating regional housing need and to serve as a multi-agency task force to advise
the SLOCOG Board of Directors. With the unanimous support of those attending the start-up
meeting, the SLOCOG Board authorized its staff to proceed with the Regional Housing Needs
Assessment (RHNA) process and to establish a committee composed of city and county
representatives to assist that effort. Members appointed were: Ed Gallagher, City of Paso
Robles; Susan Clark, City of Grover Beach; Greig Cummings, City of Morro Bay; Carolyn
Johnson, City of Pismo Beach; Kerry McCants, City of Arroyo Grande; Jeff Hook, City of San
Luis Obispo; and Dana Lilley, County of San Luis Obispo. Non-voting stakeholders who have
attended the committee meetings include: Paul Hood, LAFCo Executive Director; George
Moylan, City of San Luis Obispo Housing Authority; Dick Willhoit, Home Builders Association;
Linda Dalton, Cal Poly; Pam Marshall Heatherington and Eric Greening, ECOSLO; Carlyn
Christianson, Action for Healthy Communities; and SLOCOG staff Steve Devencenzi and Josh
Chapman.
Since the initial meeting, the committee has met monthly to develop a method for allocating San
Luis Obispo County's assigned regional housing need equitably among the jurisdictions. In
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Council Agenda Report—Regional Housing Needs Allocation
Page 2
December 2001, HCD is expected to announce San Luis Obispo County's share of statewide
housing needs. SLOCOG is then charged with two tasks: 1) to evaluate HCD's numbers and
provide the state with our own determination of our regional housing need, and 2) to allocate the
regional housing need among County jurisdictions once that number is firmly established. As
with other COGS in California, SLOCOG's determination may differ from the HCD's. In that
case, SLOCOG will be asked to explain and justify the difference. HCD will then make a final
need determination on which the regional allocations will be based.
On September 18th, the committee reviewed a draft methodology recommended by SLOCOG
staff consisting of two "Formula Factors" and four "Adjustment Factors." Following a model
patterned after one used by the Association of Bay Area Governments, two formula factors were
recommended: job growth and population growth. A third formula factor suggested by City of
San Luis Obispo staff, Development Suitability, was also considered. After lengthy discussion,
the committee took these actions:
1) recommended that population growth, rather than "household" growth be used as one of
the suitability factors;
2) recommended that job growth be used as a suitability factor;
3) continued the "Development Suitability" factor to the October Subcommittee meeting to
allow City of San Luis Obispo staff to work with each jurisdiction to refine the suitability
criteria; and
4) continued discussion of the "adjustment factors" to the October meeting.
The selection of suitability and adjustment factors and the design of how those factors are used in
the needs allocation formula merit careful consideration and judgment. The process will
determine how many dwellings each jurisdiction will need to plan for in its General-Plan, and
may provide a basis for challenging HCD assigned regional housing need countywide.
Consequently, city staff has supported a comprehensive approach to the allocation process – one
that considers not only those factors generating housing demand, but also those factors that may
physically limit a jurisdiction's ability to meet its housing needs. To this end, city staff has
strongly supported including a development suitability factor in the calculation of housing needs.
Statewide, we have not found a precedent for this approach among other COGS, however state
law does require that the determination of housing need take into account a variety of factors,
including "...the availability of suitable sites (for housing)." At its September meeting, the
committee was split on the desirability and/or feasibility of including a development suitability
factor.
The attached SLOCOG staff report and supporting information explain the proposed draft
methodology and alternatives under consideration. Also included are a description of the initial
proposal for a development suitability factor and a follow-up memo to the committee addressing
some of the concerns. City staff will provide additional information at the Council meeting, and
SLOCOG representative Ken Schwartz will add his perspective. By resolution, staff is seeking
Council confirmation of the use of a development suitability factor in the allocation method
before the next committee meeting on October 23`d and the next SLOCOG Board meeting on
November 1=`.
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Council Agenda Report—Regional Housing Needs Allocation
Page 3
ATTACHMENTS
1. Draft Council Resolution
2. SLOCOG Staff Report
3. Revised Housing Needs Determination Schedule
4. Staff memo
Council Reading File: Regional Housing Needs Subcommittee minutes.
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Attachment 1
RESOLUTION NO. (2001 Series)
A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO
TO RECOMMEND A PREFERRED METHOD FOR
DETERMINING REGIONAL HOUSING NEEDS.
WHEREAS, the City Council has reviewed a San Luis Obispo Council of Governments
staff report and supporting information dated September 18, 2001 describing a draft regional
housing allocation method and possible factors to use in the calculation of housing needs;
WHEREAS, the City Council recognizes the importance of establishing an equitable and
comprehensive method for determining regional housing needs which considers not only factors
generating housing demand but also physical constraints on a jurisdiction's ability to meet its
regional housing need;
WHEREAS, State Government Code (Section 65584) provides that the distribution of
regional housing needs shall, based on available data, take into consideration market demand for
housing, employment opportunities, the availability of suitable sites and housing need, among
other specified factors;
WHEREAS, the General Plan Housing Element (1.31.3) says the City should prevent
new housing development on sites that should be preserved for open space or parks, or on sites
subject to natural hazards or unacceptable manmade hazards.
BE IT RESOLVED by the Council of the City of San Luis Obispo that based on its
deliberations and those of the San Luis Obispo County Housing Methodology Committee, public
testimony, the staff report, and on State law, the following:
SECTION 1. Regional Housing Needs Allocation Method. The City Council recommends
that the method used to determine regional housing needs in San Luis Obispo County be
designed as follows:
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Attachment 1
Council Resolution No. (2001 Series)
Page 2
1. The method shall include a "Development Suitability" factor which takes into account
physical factors which may limit a jurisdiction's ability to fully accommodate its assigned
regional housing needs.
2. Physical factors should include, but are not limited to, supply of developable land, slope,
prime farm land, creeks and designated habitat for threatened or endangered species, state
or federal lands, airport land use restrictions, geologic, seismic or other natural hazards,
and preservation of historic resources is a key component of the community's sense of
place and quality of life.
Section 2. San Luis Obispo Council of Governments Action. The Council hereby forwards
this recommendation to the San Luis Obispo Council of Governments.
Upon motion of seconded by
and on the following roll call vote:
AYES:
NOES:
ABSENT:
the foregoing resolution was adopted this day of 2001
Mayor Allen Settle
ATTEST:
Lee Price, City Clerk
APP AS TO FORM:
Jeffrey G. J gensen, City Attorney
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Attachment 2
SAN LUIS OBISPO COUNCIL OF GOVERNMENTS
STAFF REPORT
MEETING DATE: September 18, 2001
SUBJECT: Housing Distribution Methodology Factors
BACKGROUND
The San Luis Obispo County Housing Methodology Committee has been meeting for the
past six months in the effort of developing a methodology that would distribute San Luis
Obispo County's regional housing need equitably to each jurisdiction. SLOCOG staff
has researched distribution factors that have been used by other Council of
Governments that have completed their Regional Housing Needs Plan. The committee
has asked that SLOCOG present these factors as well as any others that have been
proposed locally and develop a proposed local methodology.
At the September 18`", 2001 Housing Methodology Committee SLOCOG will ask a
representative from each jurisdiction to vote on whether or not to include the proposed
factors in the housing distribution methodology. SLOCOG staff will then submit staff
recommendations along with the Housing Methodology Committee recommendations to
the SLOCOG Board for their approval. The approved factors will then be added to a
distribution formula that will be presented to the Housing Methodology Committee at the
October 23, 2001 meeting.
RECOMMENDATION
Staff: Recommend the use of the following factors in the housing distribution
methodology:
Formula Factors
1. Job Growth
2. Household Growth
Adjustment Factors
1. Vacancy Need Adjustment
2. Replacement Need Adjustment-Pending Data Availability
3. Sphere of Influence Adjustment
4. Fair Share Adjustment
Housing Methodology Committee:
DISCUSSION
SLOCOG has presented housing distribution factors that have been used in the
Sacramento Area Council of Governments (SACOG) plan, the Association of Bay Area
Governments (ABAG) plan, and the Southern California Association of Governments
(SCAG) plan. SLOCOG staff has modified these factors for local application. The City
of San Luis Obispo has proposed an additional distribution factor for consideration.
All of the factors proposed fall in one of two categories. The first is to be referred to as a
Formula Factor. The Second is to be referred as an Adjustment Factor. These two
classifications are important when applying the factor in the housing distribution formula.
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- Attachment 2
The proposed Formula Factors under consideration are:Job Growth, Household Growth,
and Development Suitability. These factors determine the jurisdictional share of the
total regional housing need. A weighting factor would be applied to each based on its
importance in the overall formula. All other proposed factors would be considered
Adjustment Factors; Sphere of Influence Adjustment, Vacancy Need, Replacement
Need, Fair Share Adjustment, and Housing Unit type Adjustment. These adjustment
factors would be applied to each jurisdictions share of the regional total or would be off
the top adjustments that would be divided up between each jurisdiction. Each factor type
is discussed in the following factor descriptions. Attachment 1 is a draft housing
distribution formula.
FORMULA FACTORS-Three factors are considered: Job Growth, Household Growth,
and Development Suitability. Each is described below.
Formula Factor #1 - Job Growth
Agencies using factor in RHNP: ABAG
Description
The Job Growth factor would place an emphasis on a jurisdiction's employment growth
rate in the allocation of San Luis Obispo County's Regional Housing Need. In many
areas of the county, growth in the housing market has not kept pace with the growth in
the job market. This factor would require that jurisdictions plan for new housing based
on the amount of job growth projected over the next seven years.
SLOCOG has contracted with the Economic Development.Department(EDD)to prepare
Job growth projections for each community in San Luis Obispo County. The projections
are based on quarterly tax reports (ES-202 Reports) submitted by employers. EDD uses
historic data from 1991 to 1999 to make their projections through 2008. Data is
unavailable for individual communities in the county prior to 1991.
There has been some discussion on using data from 1980, 1990, and 2000 for the basis
of making job growth projections. In 1983, EDD began using a new methodology for
collecting job figures. No comparison can be made between data gathered prior to 1983
to data gathered in subsequent years. Data is also unavailable for individual
communities for the year 2000. The only consistent data available for each jurisdiction
that would provide us with meaningful projected job growth is the EDD data from 1991 to
1999.
Application
This factor would use projected Job Growth for each jurisdiction over a seven-year
period divided by total region job growth over the same time period to get the percent of
the job growth for each jurisdiction.
Jobs _ Jobs Total Regional _ % Share of
2008 2001 Job Growth Job Growth
The percent of job growth for each jurisdiction is then inserted into the Regional Housing
Distribution Formula as a formula factor. A weighting factor is applied to the jurisdiction's
percent of job growth based on the importance it is given in the housing allocation
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Attachment 2
formula. This weighting factor will be recommended by the Committee and considered
by the SLOCOG Board in November 2001.
Implications
Distributing housing need based on a community's job growth would help promote a jobs
housing balance.
SLOCOG Staff Recommendation
Staff recognizes that San Luis Obispo County has a unique housing market. Currently
workers can live just about anywhere in the county and commute to work in less than an
hour. With a projected population of more than 300,000 people, an increase of more
than 60,000 by the year 2008, we can expect to see far greater congestion on county
streets and highways. The development of housing in areas that have the highest
concentration of jobs would help create a jobs housing balance, which would help reduce
the demand on the transportation system.
SLOCOG staff recommends the use of the Job Growth factor in the housing distribution
methodology.
Formula Factor #2 - Household Growth
Agencies using factor in RHNP: ABAG, SCAG, SACOG
Description
The Household Growth factor can be viewed from two different perspectives.
(A) Household growth is projected through 2008 using average annual growth over the
last decade. These figures reflect the current trends in the housing market. The
assumption is that communities that have been growing at a higher than average pace
would continue to do so and communities that have shown very little growth would
continue that trend as well. (B) The alternative approach is the concept that those
jurisdictions that have been making their regional contribution to housing growth should
receive some relief in upcoming allocations.
Application
A Household Growth for each jurisdiction over a seven year period divided by total
region household growth over the same time period.
-Househan _ Households Total Regional % Share of
2008 2001 Household Household
Growth Growth
B. From a regional standpoint, it may be appropriate to use for a correction factor in the
adjustment formula phase that moves the allocation away from areas with recently
high unit growth and toward the areas with recent low growth.
Either way the factor would be applied as formula factors and would receive a weighting
based on their relative importance to other factors in the distribution formula.
Implications
Approach A. Most accurately reflects the current market conditions.
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Attachment 2
Approach B. Continues to perpetuate recent patterns in housing development.
SLOCOG Staff Recommendation
Staff recommends approach (A) based on the fact that it gives the most accurate
representation of the current market conditions.
SLOCOG staff recommends the use of the Household Growth factor in the housing
distribution methodology.
Formula Factor #3 - Development Suitability
Agencies using factor in RHNP: None. Factor has been proposed by the City of San Luis
Obispo
Description
The City of San Luis Obispo has proposed a Development Suitability Factor for
distributing the regional housing need total between local jurisdictions (refer to
Attachment 2 for a complete description of this factor). This factor uses a combination of
environmental and physical constraints along with the availability of vacant land to
determine the amount of land suitable for development.
Application
Uses the availability of"suitable sites" as a factor for determining a jurisdictions ability to
accommodate future construction. The proposed Development Suitability factor would
be applied in a similar manner as the Job Growth factor and the Housing Growth factor.
It would receive a weight factor based on its relative importance to the other factors in
the distribution formula
Implications
Jurisdictions with a limited supply of vacant land and a high amount of environmental
constraints would have their share of regional housing needs reduced. However the
Regional Housing Need Total would not be reduced, therefore shifting one jurisdictions
share of housing needs to another because they have less constraints.
Table A lists of the criteria proposed by the City of San Luis Obispo for determining the
amount of suitable land for development. SLOCOG has reviewed the criteria and
provided comments for each element.
Table A- Development Suitability Criteria and SLOCOG Staff Comments
Criteria SLOCOG Staff Comments
A Vacant or essentially so. Developable land is limited to existing vacant
or essentially vacant sites. This does not
take into account the potential for infill
(density intensification, granny units, etc.)
B. Located on land with an average Residential development can and has been
slope not exceeding 30%. built on areas with a 30% slope or greater.
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^ tachment 2
C. Located outside of the 100-year Residential development can and has been
floodplain, as shown in the latest built in areas located within a 100-year
FIRM map. floodplain with proper design standards.
D. Located outside of mapped Residential development can and has been
geological or safety hazard areas, built in areas located within the described
such as areas subject to risks of hazards with proper design standards.
slope instability, landslides,
subsidence, liquefaction, dam failure,
seismic, wildland fire and airport
hazards.
E. Located outside of environmentally Residential development can and has been
sensitive areas, including mapped built in areas located within the described
creeks, rivers and wetlands, tidal and areas with proper mitigation measures.
submerged lands, designated open
space and habitat areas for
threatened or endangered species,
or for species of special concern as
designated by the California
Department of Fish and Game.
F. Not located on prime agricultural Residential development can and has been
soils, defined as land which qualifies built in areas located within the described
for rating as class I or II in the Soil areas with approved zoning changes and
Conservation Service land use various mitigation measures defined in
capability classifications, or which environmental documents or permits.
qualifies for rating 80 through 100 in
the Storie Index Rating.
G. Located within Ya mile of existing New roads can be built.
public access roads.
Status of local jurisdiction data availability
Arroyo Grande Could provide necessary data given a reasonable amount
of time.
Atascadero Fully capable of determining the amount of land suitable for
development using the proposed criteria. Data available in
a GIS format.
Grover Beach Could provide necessary data where applicable in Grover
Beach. Limited GIS Capabilities
Morro Bay Could provide an estimate of suitable land for development
using the proposed criteria.
Paso Robles Lacks the mapping of environmental constraints listed in
the proposed criteria.
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-'Attachment 2
Pismo Beach Could provide an estimate of suitable land for development
using the proposed criteria.
San Luis Obispo City Fully capable of determining the amount of land suitable for
development using the proposed criteria. Data available in
a GIS format.
San Luis Obispo County Could provide estimates of land falling into the proposed
criteria except for land classified as "vacant"or"essentially
vacant". Partial data available in a GIS format.
SLOCOG Recommendation
All of the proposed elements in the Development Suitability factor are much too strict in
determining the availability of developable land for a jurisdiction. Every city in San Luis
Obispo County has some sort of residential development that would fall under one of the
criteria listed. Additionally, each jurisdiction was asked how much of the data they
currently have available and its format. While most cities have indicated that they could
gather the required data, staff feels the consistency and level of accuracy of the data
across all jurisdictions would not provide reliable results.
SLOCOG staff recommends that the Development Suitability factor not be used in the
housing methodology allocation.
ADJUSTMENT FACTORS - Four factors are considered: Vacancy Need, Replacement
Need, Sphere of Influence Adjustment, and Fair Share Adjustment. Each is described
below.
Adjustment Factor #1 - Vacancy Need
Agencies using factor in RHNP: SCAG
Description
A Vacancy Need factor can be approached from either a housing or rental perspective. It
would put an emphasis on jurisdictions that have low rates and therefore are in need of
additional units in order to allow for supply to move toward demand. Local general plans
describe an ideal homeowner vacancy rate of 2% and an ideal renter vacancy rate of
6%.
Appl icatio
When HCD determines San Luis Obispo County's regional housing need they will have
applied a vacancy adjustment in order to promote a healthy vacancy rate statewide.
SLOCOG will work with HCD to determine how many vacant units were designated in
SLO County. SLOCOG will than allocate those to the individual jurisdictions as an
adjustment factor based on their current vacancy rates.
SCAG assigns a vacancy need in between an "ideal" rate and the "current " rate to each
community to make a progression towards a healthy housing market for each
community.
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Attachment 2
Implications
Vacancy Need Factor would promote residential choice, moderate cost of units, and
provide sufficient incentive for unit upkeep and repair. Excessively low vacancy rates
create over-priced, poorly maintained housing units.
SLOCOG Recommendation
Vacancy Need is a straightforward way of measuring the demand for housing in any
given jurisdiction. Many jurisdictions have vacancy rates well below what is considered
an "ideal'rate.
SLOCOG recommends the use of the Vacancy Need Adjustment in the housing
distribution methodology.
Adjustment Factor #2 - Replacement Need
Agencies using factor in RHNP: SCAG
Description
A Replacement Need factor compensates for lost housing units and is a valuable
variable in dynamic areas where there exists significant percentages of housing loss as a
result of a variety of factors.
Application
SLOCOG would work with each jurisdiction to determine the average amount of housing
units that have been replaced over the past ten years. SLOCOG would then determine
the total number of housing units that could be expected to be replaced by the year
2008. Each jurisdiction would then receive a share of the total replacement need as an
adjustment factor based on their average replacement rates.
SCAG developed a sub-regional rate based upon trends in demolition permits,
conversions to non-residential uses, and housing loss due to natural disaster. To date
SLOCOG has not contacted individual jurisdictions to determine the availability of data
required for the Replacement Need factor.
Implications
Replacement Need factor would take into account lost housing unitsthatnormally would
be overlooked if distribution of housing need is based solely on growth patterns. A
Replacement Need factor would take into account those units in our county that are
presently being converted from rental units into vacation rental units, those lost by
natural disaster, and those being converted from low to high-income residential uses.
SLOCOG Recommendation
While more applicable in large urban centers, many areas like San Luis Obispo County
do experience significant housing losses due to these reasons.
SLOCOG recommends the use of the Replacement Need Adjustment in the housing
distribution methodology, if data is available.
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Attachment 2
Adjustment Factor#3 - Sphere of Influence Adjustment
Agencies using factor in RHNP: ABAG
Description
A Sphere of Influence (SOI) is defined as "a plan for the probable ultimate physical
boundaries and service area for a local government agency." This factor would shift the
responsibility for planning future growth in areas within a city's SOI to that city, relieving
the unincorporated county of planning for future households in areas that would no
longer fall in their jurisdiction.
Application
ABAG used a Sphere of influence (SOI) adjustment that shifted 75% of the projected
household growth from the unincorporated county U the applicable city. Household
growth was determined using ABAG's previously prepared growth estimates for the
SOI's.
Locally we would need to determine the current number of housing units within each
city's SOI. Then determine the projected amount of household growth within each SOI
using adopted Local Agency Formulation Committee (LAFCO) maps with the most
recently adopted SOI's, local jurisdictions approved (or planning commission
recommended) general plans, and any other information that might assist in determining
the level of household growth with in SOI's. In many instances a local jurisdiction may
have pre-zoned and/or planned an area in anticipation that the land would be annexed
into the city limits sometime in the near future.
The Sphere of Influence factor is an adjustment factor that would occur after the
unincorporated county and all cities received their share of the regional housing need.
This effort would take considerable time and effort on the part of County, City's, LAFCO,
and SLOCOG staff.
Implications
A Sphere of Influence adjustment would reduce the burden on the unincorporated county
to plan for future construction. Cities would be required to plan for future housing in
areas that are within their SON. These are areas that are within the service area of a
local city and in many cases may be annexed in the near future.
SLOCOG Recommendation: Staff recommends the use of the Sphere of Influence
factor in the adjustment of the jurisdictional share of the regional housing need.
Adjustment Factor #4 - Fair Share Adjustment
Agencies using factor in RHNP: SCAG, ABAG, SACOG
Description
Most cities in San Luis Obispo County have a good mix of people from different income
levels. To continue this, HCD requires SLOCOG to distribute each jurisdictions housing
allocation between four income levels; very low, low, moderate, and above moderate.
The Fair Share Adjustment would ensure that a city that currently has a higher proportion
of low-income residents is not over burdened with more low-income housing.
HCD has defined the following household income limits for San Luis Obispo County.
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Very Low Income up to 50% of the area median family income
Low Income between the very low-income limit and 80% of the area
median family income
Moderate Income between the lower income limit and 120 percent of the area
median family income
Above Moderate Income exceeding the moderate-income limit
Application
SCAG Shift the existing income distribution closer to the regional average. Shift
depends on the current income distribution.
ABAG Income distributions were shifted 50%towards the regional average.
SACOG Set a 2020 target in which all jurisdictions would have a uniform income
distribution. Then applies an annual adjustment over the 7 1/2year period of
the housing needs plan that would meet the 2020 target.
Implications
Shifts construction need from one income category to another to reduce the over
concentration of low-income households in one community versus another.
SLOCOG Recommendation
A 50% shift towards the regional average would help encourage communities with
diverse income groups without requiring a major shift all at one time.
SLOCOG staff recommends the use of the Fair Share Adjustment in the housing
distribution methodology.
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Attachment I -Draft Housing Distribution Formula Attachment 2
Share Share of Regional Sphere Vacancy Replacemen Total
x + x x Housing of Job Weight Household Weight Jurisdiction of Need t Need
Growth Factor Growth(h Factor ng = al Need(n) + Influence + Adjustment Adajument = Projected
(j) ) Need(r) Need Need(T)
Cj x 0.5 + h x 0.51x r n + SOI + v + r T
Share of lob Growth-job growth for each jurisdiction between 2000 and 2007 divided by total
County job growth over the same time period
Share of Household Growth- household growth for each jurisdiction between 2000 and 2007 divided
by total County household growth over the same time period
Weight Factor-the 0.5 weight factor gives household growth and job growth an equal(50%-50%)
representation in determining jurisdictional need. Can be altered(60%-40%,70%-30%)to have
greater influence by either job growth or household growth.
Regional Housing Need-San Luis Obispo County total housing need
Jurisdictional Need-total housing need byjurisdictlon based on household and job growth
Sphere of Influence-any additional housing units added to a jurisdictions total based on project
growth in the City's Sphere of Influence. ABAG used a 75/25 ratio with the City being responsible for
75%of the projected housing units and the Unincorporated area picking up the remaining 2S%of the
Vacancy Need-Adjust jurisdictional share of housing need to reflect an agreed upon vacancy rate.
Total Proiected Need-total number of housing units needed based on its share of job and
household growth for the region,with additional units from the jurisdictions sphere of influence.
Fair Sahre Adiustment-Applied to each jurisdictions Toatal Projected Need
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Attachment 3
8702/01
DRAFT REGIONAL HOUSING NEED ALLOCATION FORMULA — "DEVELOPMENT
SUITABILITY"FACTOR
Prepared by Jeff Hook
City of San Luis Obispo
Background
The calculation of Regional Housing Need Allocations in some jurisdictions(ABAG, for example)has been
based solely on population and job growth,without regard to the inherent differences between jurisdictions
in their physical capacity to accommodate new housing. This approach does not yield a realistic or
equitable allocation within the region since it does not take into account the availability of"suitable sites"for
new housing. While redevelopment will help meet some of a jurisdiction's rental and ownership housing
needs, the bulk of new housing will be built on vacant, developable land within expansion areas.
Consequently, a "development suitability" factor should be used to reflect each jurisdiction's ability to
accommodate new housing.
Development Suitability Factor
The Development Suitability Factor equals the number of acres of developable land within each
jurisdiction's urban reserve, CSD or Village Reserve limits, divided by the total number of acres within the
jurisdiction's corporate boundaries,expressed as a decimal fraction. "Developable land" is defined as land
that is:
A Vacant or essentially so.
B. Located on land with an average slope not exceeding30%.
C. Located outside of the 100 year floodplain, as shown in the latest FIRM map.
D. Located outside of mapped geological or safety hazard areas, such as areas subject to risks of
slope instability, landslides, subsidence, liquefaction, dam failure, seismic, wildland fire and
airport hazards.
E. Located outside of environmentally sensitive areas, including mapped creeks, rivers and
wetlands, tidal and submerged lands, designated open space and habitat areas for threatened
or endangered species, or for species of special concern as designated by the California
Department of Fish and Game.
F. Not located on prime agricultural soils, defined as land which qualifies for rating as class I or II
in the Soil Conservation Service land use capability classifications, or which qualifies for rating
80 through 100 in the Storie Index Rating.
G. Located within '/a mile of existing public access roads.
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- Attachment 3
Development Suitability Factor
Page 2
Development Suitability Factor"S" is a measure of a jurisdiction's ability to accommodate new residential
development and can be described by the formula
DS=DATA
where DA equals number of developable acres within a jurisdiction's urban reserve(including Village areas
and CSDs) and TA equals total acreage within the jurisdiction's corporate limits, expressed as a decimal
fraction.
For example, City A has 65 acres that would qualify as developable, based on the above factors, and a
total acreage the City of 2,050 acres. Then DS= 65/10,000= .03.
Plugging this into the ABAG model we discussed at the last meeting, modified to include development
suitability:
Share of Job Growth X Wt. Factor+Share of Household Growth X Wt. Factor +Development Suitability X Wt. Factor
X Regional Housing Need=Jurisdictional need+sphere of influence need=Total projected need
Using City of SLO as an example,and weighting all factors equally:
0.19 X .33+0.0945X.33+.055X.33 X19,538 = .11X19,538=2,149 dwellings
How the formula would affect housing need:
Jurisdictions which are nearly built out, that is, have few developable acres available compared with their
total acreage, would have relatively low"development suitability factors" which would act to reduce their
housing allocation. Jurisdictions with higher ratios of developable land to total acreage would have
relatively higher"development suitability factors,"thus increasing their housing allocation. Note that in the
example above, all three factors are weighted equally; however we may want to weight development
suitability more or less than 33%,depending upon the importance assigned to this factor.
Statutory Basis for Using Development Suitability in Allocating Regional Need
The California Government Code, Section 65100 et. seq., includes a number of policies which not only
allow, but require local government to consider environmental, safety and land suitability factors in its land
use and housing planning. Ag land preservation, geological and seismic safety, airport land use liars
consistency, open space preservation, flood hazard, and water supply coordination are specifically
mentioned as areas of special concem to be addressed in city and county general plans. These issues; in
turn, shape
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how, where and when cities and counties can expand housing opportunities. Some of the relevant State
policies include(emphasis added):
65584.Regional housing needs
(a)For purposes of subdivision (a) of Section 65583,the share of a city or county of the
regional housing needs includes that share of the housing need of persons at all
income levels within the area significantly affected by a general plan of the city or
county. The distribution of regional housing needs shall, based upon available data,
take into consideration market demand for housing, employment opportunities, the
availability of suitable sifesand public facilities, commuting patterns, type and
tenure councils of governments shall provide each city and county with the
department 's information.
653OO.9.Balance of local situation/compliance with
state and federal laws
The Legislature recognizes that the capacity of California cities and counties to
respond to state planning laws varies due to the legal differences between cities and
counties, both charter and general law, and to differences among them in physical
size and characteristics, population size and density, fiscal and administrative
capabilities, land use and development issues, and human needs. It is the intent of
the Legislature in enacting this chapter to provide an opportunity for each city and
county to coordinate its local budget planning and local planning for federal and state
program activities, such as community development, with the local land use planning
process, recognizing that each city and county is required to establish its own
appropriate balance in the context of the local situation when allocating resources to
meet these purposes.
(Added by Stats.19841 C17.1OO9.)
65302.8.Findings on housing limits
If a county or city, including a charter city, adopts or amends a mandatory general
plan element which operates to limit the number of housing units which may be
constructed on an annual basis, such adoption or amendment shall contain findings
which justify reducing the housing opportunities of the region. The findings shall
include all of the following:
(a) A description of the city's or county's appropriate share of the regional need for
housing.
(b) A description of the specific housing programs and activities being undertaken by
the local jurisdiction to fulfill the requirements of subdivision (c) of Section 65302.
(c) A description of how the public health, safety, and welfare would be promoted by
such adoption or amendment.
(d)The fiscal and environmental resources available to the local jurisdiction.
(Added by Slats.19801 Ch.82.3.)
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Development Suitability Factor
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Article 10.6.Housing Elements
65580.Policy
The Legislature finds and declares as follows:
(a) The availability of housing is of vital statewide importance, and the early attainment
of decent housing and a suitable living environment for every Californian, including
farmworkers, is a priority of the highest order.
(b) The early attainment of this goal requires the cooperative participation of
government and the private sector in an effort to expand housing opportunities and
accommodate the housing needs of Californians of all economic levels.
(c) The provision of housing affordable to low-and moderate-income households
requires the cooperation of all levels of government..
(d) Local and state governments have a responsibility to use the powers vested in
them to facilitate the improvement and development of housing to make adequate
provision for the housing needs of all economic segments of the community. ,
(e) The Legislature recognizes that in carrying out this responsibility, each local
government also has the responsibility to consider economic, environmental, and
fiscal factors and community goals set forth in the general plan and to cooperate with
other local go vemments and the state in addressing regional housing needs.
(Added by Stats,1980, C17.1143;Amended by Stats.
1989,C17.1140;Amended by Stals 1990, Ch.1441.)
65583(b). Housing Element Content
(2) It is recognized that the total housing:needs identified pursuant to subdivision
(a)may exceed available resources and the community 'F ability to satisfy this need
within the content of the general plan requirements outlined in Article S(commencing
with Section 65300).Under these circumstances, the quantified objectives need not
be identical to the total housing needs
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Attachment 4
�il�llh I�III IIfl81111�� ���I�II)IIIIII 111111 II�
Cl of Sa1�1 l�l1S oBispo�
990 Palm Street, San Luis Obispo, CA 93401-3249
TO: Regional Housing Needs Subcommittee
FROM: Jeff Hook
DATE: September 18, 2001
SUBJECT: Objections to the use of a "development suitability" factor.
There seem to be three main objections to using some form of a development suitability
factor:
1. It won't change the overall countywide allocation, but merely shift
allocations between jurisdictions.
When we embarked on this effort last spring, the focus was on a unified, coordinated
effort to do two things: ensure that cities and counties had a role in developing
appropriate needs figures, and that total county needs were equitably distributed among
the County and cities. It was recognized that HCD method for allocating needs was not
clearly understood, and that all signs pointed to high RHNA numbers for this County. It
was also pointed out that regardless of job or population growth, ability to accommodate
housing depended on several factors that varied by jurisdiction.
Whether a suitability factor is used to adjust total county need or merely "shift"
allocations is choice we make. It can be used as a tool for "ground truthing" HCD
numbers, as a basis for appealing our overall County RHNA assignment. It should not be
the basis of suspicion or conflict between cities. All the jurisdictions can and must make
a good faith effort to accommodate their"fair share" within their physical ability to do so.
2. It's not realistic. Development is possible in 100-year flood zones,on steep
slopes, in hazardous areas, on environmentally sensitive sites, on prime ag
land, and in areas over'/4 mile from the nearest public roads.
Most cities' general plans discourage, if not prohibit, development in these situations.
Just because it can be done, with or without mitigation, does that justify going against our
own development policies, citizens' wishes, and State Planning Law? Most in our
profession would agree our responsibility includes considering smart growth principles as
we attempt to meet housing needs. Using some form of suitability criteria makes sense
since unlike the State, each city and county will eventually have to consider
environmental effects of its actions.
�� The City of San Luis Obispo is committed to include the disabled in all of its services,programs and activities. 9-W
Telecommunications Device for the Deaf(805)7814410.
' ! I
Development Suitability Factor
Attachment 4
Page 2
3. It's too difficult. Not all jurisdictions have the necessary data or mapping to
consider development suitability.
HCD is not expected to show its RHNA numbers until December, at the earliest. We are
ahead of the curve in terms of setting a methodology. The results of our
recommendations will have important repercussions for all County residents. We need to
take the time necessary to make sound, well considered recommendations to SLOCOG
Board. As staff, the decisionmakers are looking to us to ask the right questions, explore
alternatives, and consider implications carefully. We could modify suitability criteria to
better fit the available data or use our shared resources to provide the necessary data. But
to say we can't do it because it's too difficult or time consuming will probably be viewed
first as a disservice to our decisionmakers and ultimately, to the citizens.
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