Housing Element Update

The RHNA process, which applies to all cities and counties in the Southern California region, was completed in March 2021. The RHNA process is managed by the Southern California Association of Governments (SCAG) which prepares the RHNA, and generally takes into consideration how population changes, the regional economy, and the region’s transportation network affects the need for housing. In addition, SCAG is required to consider how growth in the region will achieve state climate change goals and requirements. 

The RHNA results in a determination of how much housing a local jurisdiction must plan for during a specific housing element planning period. The current housing element planning period for the SCAG region commenced in 2014 will end in October 2021. The upcoming housing element planning period will cover October 2021 through 2029, for which the City must plan to accommodate the 1,985 units allocated to it through the RNHA process.  For additional information about RHNA, SCAG maintains a comprehensive web page dedicated to RHNA and the RHNA process at https://scag.ca.gov/rhna. 

The state’s RHNA regulations require the City to plan for housing for all segments of a community, which requires the City to include planning for housing for people with various income levels identified by state law. These income categories are based on the county-wide median income. For Orange County, the current average median income (AMI) for 2021 is $106,700 for a family of four. Other income categories are based on the County AMI, and include Very Low Income, Lower Income, Moderate Income. Housing built to serve these income groups is generally referred to as “affordable housing”. Advocates for housing may also use the term “workforce housing” to describe affordable housing. 

While there are several factors which could establish the exact income amount needed to qualify for affordable housing, Very Low Income, Lower Income, and Moderate Income levels are typically expected to be proportionate to the County Average Median Income (AMI) as follows:

• Very Low Income:  30% to 50% of AMI
• Lower Income:  50% to 80% of AMI; the term may also be used to mean 0% to 80% of AMI
• Moderate Income:  80% to 120% of AMI

The City’s RHNA allocation of 1,985 units is divided among the following income categories.

Information from the state regarding income limits can be accessed here.

The state also publishes household income limits annually to establish the income levels for each county here. 

The current income limits published by the state for Orange County, adjusted for household size, are below:

The core purpose of a housing element is to plan for the existing and projected housing needs of all segments of the community such as seniors, families, workers, and the disabled. Existing and projected housing needs for these groups are not specifically addressed through the RHNA process.

A central component of the City’s Housing Element is the identification of policies and programs that ensure the City will meet its RHNA allocation of 1,985 units. The Housing Element must also identify properties that could accommodate the City’s RHNA requirements. It is important to note that the City must plan for, but is not obligated to build, the housing required by the RHNA allocation. Once the City identifies properties where it intends to accommodate its RHNA, the City will need to evaluate any zone changes or changes to development standards required to facilitate housing development. The state expects cities to remove barriers to housing development. To ensure barriers to housing construction are eliminated, recent changes to state housing law, such as the Housing Accountability Act, have made it more difficult for cities to deny housing projects.

State law requires local governments to adequately plan to meet their existing and projected housing needs, including their share of the regional housing needs allocation. A complete analysis should include a quantification and a descriptive analysis of the specific needs and resources available to address these needs.

The topics required to be addressed by the City’s Housing Element are identified below. Topics are hyperlinked to corresponding requirements on the California Department of Housing and Community Development’s (HCD) website. HCD is the state agency that reviews Housing Elements to determine if they comply with state law.

Existing Housing

• Assisted Housing Developments at Risk of Conversion
• Extremely Low-Income Housing Needs
• Housing Stock Characteristics
• Overpayment and Overcrowding
• Population, Employment, and Household Characteristics

Projected Housing Needs

• Projected Housing Needs - Regional Housing Needs Allocation

Special Housing

• Farmworkers
• Large Families and Female-Headed Households
• People Experiencing Homelessness
• People with Disabilities, Including Developmental Disabilities
• Seniors

Site Inventory and Analysis

Government Code Section 65583(a)(3) requires local governments to prepare an inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites. The inventory of land suitable for residential development shall be used to identify sites that can be developed for housing within the planning period.

• Adequate Sites Alternative
• Analysis of Sites and Zoning
• Inventory of Suitable Land
• Accessory Dwelling Units
• Opportunities for Energy Conservation
• Zoning for a Variety of Housing Types

Constraints

The housing element must identify and analyze potential and actual governmental constraints to the maintenance, improvement, or development of housing for all income levels, including housing for people with disabilities. The analysis should identify the specific standards and processes of these constraints and evaluate their impact on the supply and affordability of housing. The analysis should determine whether local, regulatory standards pose an actual constraint and must also demonstrate local efforts to remove constraints that hinder a jurisdiction from meeting its housing needs.

• Codes and Enforcement and Onsite Offsite Improvement Standards
• Constraints for People with Disabilities
• Fees and Exactions
• Land-Use Controls
• Non-Governmental Constraints
• Processing and Permitting Procedures

Program Requirements

Each jurisdiction must identify specific programs in its housing element that will allow it to implement the stated policies and achieve the stated goals and objectives. Programs must include specific action steps the locality will take to implement its policies and achieve its goals and objectives. Programs must also include a specific timeframe for implementation, identify the agencies or officials responsible for implementation, describe the jurisdiction’s specific role in implementation, and (whenever possible) identify specific, measurable outcomes.

• Program Overview and Quantified Objectives
• Address and Remove (or Mitigate) Constraints
• Assist in the Development of Housing
• Identify Adequate Sites
• Improve and Conserve the Existing Housing Stock
• Preserve Units at-Risk of Conversion to Market Rates
• Provide Equal Housing Opportunities

Other Requirements

• Analysis of Consistency with General Plan
• Housing Element Annual Progress
• Priority for Water and Sewer

The following videos were produced by the Orange County Council of Governments and the Association of Cities - Orange County to explain the RHNA and Housing Element process.

This short informative video explains why the RHNA process takes place (click the image to play):

The second video provides a brief overview of the RHNA process (click the image to play): 

The third video briefly explains the Housing Element document (Click image to play):

For additional video resources, click here for the OCCOG Housing Orange County webpage.