STAFF REPORT
DATE: December 15, 2020
TO: Justin Hess, City Manager
FROM: Patrick Prescott, Community Development Director
VIA: Fred Ramirez, Assistant Community Development Director BY: Lisa Frank, Senior Planner
SUBJECT: Status Update on the Burbank 6th Cycle Regional Housing Needs Assessment (RHNA) Allocation
RECOMMENDATION
Note and file the status update on the Burbank 6th Cycle Regional Housing Needs Assessment (RHNA) allocation of 8,751 additional housing units for the 2021 -2029 planning period.
BACKGROUND
State Housing Law
State law recognizes that the availability of housing is a matter of statewide importance , and that local governments play a n important role in facilitating the development of housing for all income levels . Most notably this is reflected in the State mandate that jurisdictions must update their housing elements every eight years, inclusive of the associated RHNA process. The RHNA quantifies the need for housing in each jurisdiction during the housing element planning period based on factors such as household growth, job and transit accessibility, and access to high-resource communities. The RHNA does not necessarily promote growth but allows communities to anticipate growth so that the region can grow in ways that enhance quality of life, improve access to jobs, promote transportation mobility, and address social equity and fair share housing needs.
DISCUSSION
Purpose of RHNA for the Housing Element
ATTACHMENT 5 - December 2020 Staff Report:
Update to Burbank’s 6th cycle RHNA requirement
ATTACHMENT 5-1
The RHNA is directly related to the Housing Element in that housing elements must include an inventory of land suitable for residential development to meet the RHNA allocation. State certification of the City’s Housing Element is in large part contingent on review of the RHNA sites inventory. Additional criteria applicable to housing elements over the last few years has raised the bar on the housing sites inventory to ensure that the sites have realistic potential to be developed ba sed on factors such as existing use on the property, land size, proximity to jobs and transit, and status of long-term leases.
Staff invited a representative from the Southern California Association of Governments (SCAG) to give a presentation to Council on the RHNA process on October 15, 2019 and presented the Housing Element Annual Progress Report, including a discussion of the 6th cycle RHNA, on June 2, 2020 (Attachment 2) . City staff began the Housing Element Update process following a study session with the City Council on July 21, 2020 (Attachment 1).
RHNA Methodology
The Department of Housing and Community Development (HCD) is required to provide a determination of existing and projected housing need to SCAG and all other regional councils of government in the State. For the 2021 -2029 6 th cycle, the SCAG region received a regional determination from HCD of 1,341,827 housing units.
SCAG is then required to develop a final RHNA methodology that can be used to distribute the 1.34 million housing units – the regional determination - to each jurisdiction within the SCAG region , subject to HCD review and approval . The detailed SCAG- developed methodology involves the following components:
• Projected housing need based on h ousehold growth projections and future vacancy need;
• Share of region’s population located within High Quality Transit Areas (HQTAs); • Share of region’s jobs accessible within 30-minute driving commute; and, • Adjustments for jurisdictions with populations living in high segregation and poverty or low resource as defined by the California Tax Credit Allocation Committee (TCAC).
SCAG’s final proposed methodology was approved by HCD on January 13, 2020 after finding that it furthered the five statutory objectives of RHNA, summarized below:
1. Increasing the housing sup ply and the mix of housing type s, tenure, and affordability;
2. Promoting infill development and socioeconomic equity;
3. Promoting an improved intraregional relationship between jobs and housing;
4. Allocating a lower proportion of housing need to an income category when a jurisdiction already has a disproportionately high share of households in that income category; and,
5. Affirmatively furthering fair housing , which means taking meaningful actions that overcome patterns of segregation and foster inclusive com munities free from barriers that restrict access to opportunity.
On March 4, 2020 , the SCAG Regional Council voted to approve the final RHNA methodology to move forward in calculating the RHNA allocation for each jurisdiction.
ATTACHMENT 5-2
Burbank RHNA Allocation
In a letter dated September 4, 2020, SCAG notified the City of the final draft RHNA allocation of 8,751 (Attachment 3). The total number is broken down as follows:
• Very‐low income units: 2,546
• Low income units: 1,415
• Moderate income units: 1,406
• Above‐moderate income units: 3,384
Comparison of Neighboring Jurisdictions
As noted in previous presentations to the Council, the 6th Cycle RHNA allocation is higher for most jurisdictions in the State relative to the 5th Cycle. The table below is a comparison of 5th and 6th Cycle RHNA allocations for Burbank and nearby cities in Los Angeles County in order of population size:
5th
Cycle
RHNA
6th
Cycle
RHNA
%
Change
Estimated
Population1
Estimated
Jobs
Total
Dwelling
Units
Jobs to
Housing
Ratio2
Los
Angeles
82,002 455,565 456% 4,010,684 1,858,972 1,480,426 1.25:1 Santa
Clarita
10,981 10,009 -9% 221,932 91,725 74,294 1.23:1
Glendale 2,017 13,391 564% 205,331 117,466 80,176 1.47:1 Pasadena 1,332 9,409 606% 144,842 144,686 62,170 1.88:1 Burbank 2,684 8,751 226% 105,861 132,6093 44,642 2.97:1 Alhambra 1,492 6,810 356% 86,792 37,493 31,721 1.18:1
Arcadia 1,054 3,205 204% 57,212 32,752 21,070 1.55:1
South
Pasadena
63 2,061 3,171% 25,458 11,440 11,157 1.03:1
West
Hollywood
77 3,923 4,995% 36,203 22,580 25,833 0.87:1
1 California Department of Finance (DOF) Population estimates as of January 1, 2020. 2 Jobs to Housing Ratio is calculated using estimated number of jobs and total dwelling units data from Southern California Association of Governments (SCAG) Local Profiles, updated May 2019. 3 This figure is the most recently available jobs estimate for Burbank, provided by Economic Modeling Specialists Intl. (EMSI) as of October 2019.
ATTACHMENT 5-3
The City of Burbank and the majority of the cities compared in the table above all experienced an increase in their RHNA allocation. Burbank’s RHNA allocation increased by 226% over the last RHNA cycle and the average increase for the other surveyed cities was 1,322%. Burbank’s RHNA allocation, although significant in comparison to previous years, is within the housing production goal set by the City Council.
RHNA Appeals
The SCAG letter (Attachment 3) provided the City’s RHNA allocation and further noted a deadline of October 26, 2020, for a ny jurisdiction to file an appeal of their RHNA allocation. As provided in SCAG's adopted RHNA Appeals Procedures (Attachment 4), SCAG’s ability to review appeals was limited in scope as jurisdictions were instructed that they must be able to express why the appeal and requested revision would be necessary to further the five statutory objectives of RHNA law noted above. The full list of appeal s criteria is detailed in Attachment 4; the criteria is limited to documentation of highly specific factors such as SCAG failure to implement its adopted methodology correctly, or SCAG failure to properly consider local planning factors such as the jurisdiction’s jobs -housing relationship. Staff did not recommend to the City Council an appeal of the City’s RHNA allocation for the following reasons:
• In addition to the narrow criteria of the RHNA Appeals Procedure, it was staff’s assessment that the City’s RHNA allocation was consistent with local need for housing in order to begin to address the jobs-to-housing imbalance as well as in alignment with the City Council’s affordable housing strategy and goals.
• On February 2, 2019 , the City Council set a goal of facilitating the building of 12,000 new units in 15 years, which is part of the City’s 2017 Affordable Housing Analysis and Strategy and Affordable Housing Action Plan. The strategy provided policy guidance for addressing the City’s jobs-to-housing imbalance and housing affordability issues by supporting the creation of new housing units, including units affordable to the City’s workforce and units for households with the highest needs.
The strategy also identifies Downtown Burbank, the Media District and Golden State Specific Plan areas along the I-5 and 134 Freeway corridors that are major employment hubs as well as current and proposed transit centers. These planning areas are optimal locations for much of this new housing, helping to address traffic and quality of life issues by facilitating new housing close to jobs and transit centers while building and protecting existing neighborhoods.
• The housing policy goals set in place by the Burbank2035 General Plan and the City Council are consistent with the RHNA allocation, which reflects a regional “fair share” of housing production at a range of affordability levels and falls within the goal of 12,000 new housing units through 2035 . Through the RHNA and the Housing Element Update process, the City will be on track to meet State-mandated housing production goals while maintain ing local control that facilitates new ATTACHMENT 5-4
buildings that not only produce new housing units but help to build and protect neighborhoods.
Consistent with City Council policy direction, the current long range planning efforts that include the Housing Element Update, the Downtown Burbank Transit Orie nted Specific Plan and the Golden State Specific Plan seek to engage the community through a visioning and plan development process that, amongst other things, provides opportunities to promote new housing for all economic segments of the community and address the City’s Jobs-to-Housing Imbalance. Collectively, staying the course with City Council direction and developing and implementing the noted long range planning efforts have the potential to positively impact the community’s quality of life by providing new housing opportunities near major transit and employment centers while protecting existing neighborhoods and maintaining Burbank’s status as the Media Capital of the World.
FISCAL IMPACT
The status update on the Regional Housing Needs Assessment for the 6th Cycle has no financial impact. The ongoing work associated with the Housing Element Update to the General Plan is covered by a previously approved budget appropriation during the 2019- 2020 fiscal year . Additionally, City staff applied for and was subsequently aw arded $500,000 in supplemental grant funds through HCD’s Local Early Action Planning (LEAP) program to support development and implementation of the Housing Element and other long-range planning efforts.
CONCLUSION
The State-mandated RHNA allocation has placed a significant burden on the City of Burbank and jurisdictions throughout California to increase housing production to meet the ongoing demand for housing at all levels of affordability. It is staff’s assessment that the City Council’s Affordable Housing Analysis and Strategy and Affordable Housing Action Plan have helped establish a plan for the City to build its share of housing not only to meet State housing requirements, but to do so in a manner that maintains local control and helps to build and protect neighborhoods. The work to implement City Council and General Plan housing goals will be undertaken as part of the Housing Element Update and the development of Golden State and Downtown Burbank specific plans as we seek to find the optimal locations for housing in proximity to employment and transit centers.
Furthermore, focusing on how to meet the City’s RHNA allocation and m aintaining a compliant and State -certified Housing Element, the City will remain eligible and competitive f or State grant funding opportunities that ultimately help the City in implementing its housing strategy and continued efforts to help build and protect neighborhoods. City Council housing policy direction to date and the long range planning efforts associated with the Housing Element Update and associated specific plans will ATTACHMENT 5-5
help ensure that the City Council , residents, property owners and staff continue to work together to help build a beautiful, safe, and thriving community.
ATTACHMENT
Attachment 1 – Consideration of Proposed Housing Element and Safety Element Attachment 2 – Approval of the 2019 General Plan Annual Implementation Progress Report and 2019 Housing Element Annual Progress Report
Attachment 3 – Letter from SCAG re: 6th Cycle Draft Regional Housing Needs Assessment (RHNA) Allocation for City of Burbank and appeals timeline notice
Attachment 4 – 6th Cycle RHNA Appeals Procedures
ATTACHMENT 5-6