RHNA Double Counting and Overestimation of California's Future Housing Needs

At the 12.1.20 Council meeting, I made two requests for future items.  The first was to send a letter calling out the errors of the latest RHNA statewide allocation.  The second was to consider reducing the zoning density around downtown.  Both were not included in the next meeting agenda on 12.15.20 but I thought it important to elaborate on why I think these are important matters that should be considered.

California HCD determines the number of housing units that will need to be planned for in future years, and distributes these to regional bodies throughout the state.  The regional body that is responsible for allocating these units to cities in the Bay Area is the Association of Bay Area Governments (ABAG).   Normally, after the units are divvied up by ABAG to the local cities, there is an appeal process.  The appeal process however does not address the fundamental problems with the latest allocation.  This is because upon appeal, ABAG can shift units from one municipality to another, but the total number of units region wide would be unchanged.

Based on the latest information however, it appears that the total number was arrived at based on faulty methodology.  Below is the letter that I drafted:

In southern California, they are slightly ahead of us so many of their local governments have already raised this complaint.  Here is a letter signed by 32 cities in Orange County raising the same concerns.  It is time for us as northern California cities to join their efforts in raising these concerns in hopes that the total housing figure could be reexamined.  I hope to get support from the Council to send this on behalf of the city.

The letter references certain attachments.  Report on double counting.  Freddie Mac report on total CA housing need.