California State housing law requires that each city and county plan for existing and future housing needs by mandating sufficient sites and zoning identified in the Housing Element of its General Plan to accommodate its RHNA allocation. The upcoming 6th Cycle RHNA will cover the planning period from October 2021 through October 2029. SCAG is the regional agency responsible for the development of the RHNA allocation methodology for the six counties in Southern California (Orange, Los Angeles, Imperial, Riverside, San Bernardino, and Ventura). HCD is the State agency responsible for the final determination of the total regional allocation of dwelling units and the methodology for distributing the allocation among local jurisdictions. Allocations are segmented by income levels based on the Area Median Income (AMI) and include very-low, low, moderate, and above moderate categories. The current 5th Cycle (2013-2021) RHNA allocation for Brea is identified in Table 1 below.
Table 1: 5th Cycle RHNA
| Income Level |
Dwelling Units |
| Extremely Low Income (0-30% of AMI): |
213 |
| Very-Low Income (31-50% of AMI): |
213 |
| Low Income (51-80% of AMI): |
305 |
| Moderate Income (81-120% of AMI): |
335 |
| Above Moderate Income (>120% of AMI): |
785 |
| Total: |
1,851 Dwelling Units |
RHNA outcomes are foundational to jurisdictional housing goals and policies and must be included within the Housing Element of a city's General Plan prior to certification by HCD. HCD also requires each city and county to prepare and submit an annual report documenting its progress towards achieving its RHNA numbers during the planning cycle.
In August 2019, following a local public input process, the SCAG Regional Council approved the public release of three draft 6th cycle RHNA allocation methodology options under consideration. Public hearings were held to allow SCAG staff to present the three options and receive public comments, revisions, and alterations. SCAG received 248 comment letters on the three options. Comments submitted by local jurisdictions composed 48% of the total received.
Based on public input, SCAG staff developed a single RHNA allocation methodology which was publicly introduced at a workshop conducted on September 23, 2019. Table 2 below includes a breakdown, by income level, of the City of Brea RHNA allocation in accordance with the SCAG staff recommended methodology.
Table 2: Initial SCAG Staff Recommendation - Brea RHNA Allocation
| Income Level |
Dwelling Units |
| Very-Low Income (<50% of AMI): |
334 |
| Low Income (50-80% of AMI): |
195 |
| Moderate Income (80-120% of AMI): |
200 |
| Above Moderate Income (>120% of AMI) |
444 |
| Total: |
1,172 Dwelling Units |
| AMI varies by household size. The current Orange County AMI for a four-person household is $97,900. |
On October 7, 2019, the SCAG RHNA Subcommittee, including the Orange County representative, voted to send the staff recommended RHNA methodology to the SCAG Community, Economic, and Human Development (CEHD) Committee. On October 21, 2019, the CEHD Committee voted unanimously to recommend that the SCAG Regional Council submit the methodology to HCD.
On November 7, 2019, following the lengthy vetting process by various committees, and SCAG staff, the RHNA allocation methodology recommended by SCAG staff came before the SCAG Regional Council. However, before a vote could be taken on the SCAG staff recommended methodology, a substitute motion for approval of a modified methodology was introduced by the City of Riverside representative. This modified methodology proposed to shift a significant portion of the 6th cycle RHNA regional allocation away from developing areas such as Riverside and San Bernardino County and toward coastal areas including predominately Orange County jurisdictions. Despite a lack of detail regarding the associated impacts, supporting documentation as to the merit of the proposed changes, and any opportunity for stakeholder input, the modified methodology was approved by the SCAG Regional Council for submittal to HCD by a vote of 43-19. All Orange County SCAG representatives voted in opposition to the modified methodology.
Table 3 below provides a breakdown by income level of the City of Brea RHNA allocation in accordance with the substitute motion methodology approved by the SCAG Regional Council. This allocation data was not made available to Cities until after the SCAG Regional Council vote was conducted.
Table 3: Final SCAG Regional Council Action - Brea RHNA Allocation
| Income Level |
Dwelling Units |
| Very-Low Income (<50% of AMI): |
650 |
| Low Income (50-80% of AMI): |
383 |
| Moderate Income (80-120% of AMI): |
392 |
| Above Moderate Income (>120% of AMI) |
877 |
| Total: |
2,302 Dwelling Units |
| AMI varies by household size. The current Orange County AMI for a four-person household is $97,900. |
The modified RHNA allocation methodology ultimately approved by the SCAG Regional Council increases the City's housing target for the upcoming RHNA 6th cycle to 2,302 total units. This is an increase of approximately 96% over the SCAG staff recommended methodology and a 24% increase over the City's current RHNA 5th cycle allocation. Cities did not receive sufficient or adequate advance notice that SCAG would entertain a substantially modified, unsupported methodology. The modified methodology fails to account for local input and growth forecast data and, due to the late introduction by substitute motion, was unable to be fully analyzed for potential impacts by SCAG staff before a vote of the Regional Council.
Throughout the RHNA process, City staff has and continues to monitor and participate in RHNA related meetings and hearings. Staff is also involved with the Orange County Council of Governments Technical Advisory Committee (OCCOG TAC), to ensure that the raw data submitted to SCAG for use in developing a draft methodology is accurate and consistent with local jurisdictional input. Written comments have also been provided directly to SCAG highlighting City concerns and recommendations regarding the development of the RHNA allocation methodology.
The attached Resolution has been prepared for City Council consideration, opposing the modified RHNA allocation methodology and requesting intervention by HCD to direct SCAG to reconsider its action given the related lack of specificity, lack of supporting documentation, lack of vetting by SCAG staff, and near-total absence of stakeholder engagement in the amended RHNA allocation methodology.
HCD comments on the methodology approved by the SCAG Regional Council are due to SCAG in January 2020 for consideration. SCAG is to provide resulting draft jurisdictional allocations in early spring 2020, with the jurisdictional appeal period to follow. The final RHNA allocations, including any alterations made as a result of the appeal, are tentatively scheduled for adoption in October 2020. The deadline for certification of jurisdictional housing elements, which are required to be consistent with RHNA, is October 2021 (one year from the adoption of the final RHNA allocations). |