2022 State Income Limits Briefing Materials
California Code of Regulations, Title 25, Section 6932
For households of more than eight persons, refer to the formula at the end of the table for 2022 Income Limits. Due to the adjustments HUD can make to income limits in a given county, table data should be the only method used to determine program eligibility. Arithmetic calculations are applicable only when a household has more than eight members. Please refer to HUD’s briefing material for additional information on family size adjustments.
HCD Methodology
State law (see, e.g., Health & Safety Code Section 50093) prescribes the methodology HCD uses to update the State Income Limits. HCD utilizes HUD’s Public Housing and Section 8 Income Limits.
HCD’s methodology involves: (1) if necessary, increasing a county’s median income established by HUD to equal California’s non-metropolitan county median income determined by HUD, (2) applying HCD’s HH Policy, in effect since 2013, to not allow decreases in area median income levels and household income category levels, (3) applying to the median income the same family size adjustments HUD applies to the income limits, and (4) determining income limit levels applicable to California’s moderate-income households defined by law as household income not exceeding 120 percent of county area median income.
Area Median Income and Income Category Levels
HCD, pursuant to federal and State law, adjusts median income levels for all counties so they are not less than the non-metropolitan county median income established by HUD ($80,300 for 2022). Next, HCD applies its HH policy to ensure area median income and income limits for all household income categories do not fall below any level achieved in the prior year. Health and Safety Code section 50093 requires HCD to adjust the AMI for family size in accordance with adjustment factors adopted by HUD and illustrated on the previous page. This establishes that the MFI published by HUD equals the fourperson AMI for California counties.
Acutely low-Income Levels
Chapter 345, Statues of 2021 (Assembly Bill 1043) established California’s acutely low-income levels.
See Health & Safety Code, § 50063.5. After calculating the 4-person area median income (AMI) level as previously described, HCD sets the maximum acutely low-income limit to equal 15 percent of the county’s AMI, adjusted for family size.
Moderate-Income Levels
HCD is responsible for establishing California’s moderate-income limit levels. After calculating the 4- person area median income (AMI) level as previously described, HCD sets the maximum moderateincome limit to equal 120 percent of the county’s AMI, adjusted for family size.
Applicability of California’s Official State Income Limits Applicability of the State Income Limits are subject to particular programs as program definitions of factors such as income, family, and household size vary. Some programs, such as Multifamily Tax Subsidy Projects (MTSPs), use different income limits. For MTSPs, separate income limits apply per provisions of the Housing and Economic Recovery Act (HERA) of 2008 (Public Law 110-289). Income limits for MTSPs are used to determine qualification levels as well as set maximum rental rates for projects funded with tax credits authorized under Section 42 of the Internal Revenue Code (Code). In addition, MTSP income limits apply to projects financed with tax-exempt housing bonds issued to provide qualified residential rental development under Section 142 of the Code. These income limits are available at http://www.huduser.org/datasets/mtsp.html.
2022 State Income Limits Briefing Materials
California Code of Regulations, Title 25, Section 6932
Questions and Answers
In Los Angeles, as well as several other counties in the state, why does the very low-income limit not equal 50% of the AMI (or the low-income limit not equal 80% of the AMI)? There are many exceptions to the arithmetic calculation of income limits. These include adjustments for high housing cost relative to income, the application of state nonmetropolitan income limits in low-income areas, and national maximums in high-income areas. In Los Angeles County, as well as several others, the magnitude of these adjustments results in the low-income limit exceeding the AMI.
These exceptions are detailed in the FY 2022 Income Limits Methodology Document, https://www.huduser.gov/portal/datasets/il//il22/IncomeLimitsMethodology-FY22.pdf.
For further information on the exact adjustments made to an individual area of the country, please see HUD’s FY 2022 Income Limits Documentation System. The documentation system is available at https://www.huduser.gov/portal/datasets/il.html#2022 query. Once the area in question is selected, a summary of the area’s median income, Very Low-Income, Extremely Low-Income, and Low-Income Limits are displayed. Detailed calculations are obtained by selecting the relevant links.
Why don’t the income limits for my area reflect recent gains? Although HUD uses the most recent data available concerning local area incomes, there is still a lag between when the data are collected and when the data are available for use. For example, FY 2022 Income Limits are calculated using 2015-2019 5-year American Community Survey (ACS) data, and oneyear 2019 data where possible. This is a three-year lag, so more current trends in median family income levels are not available.
How does HUD calculate Median Family Income (MFI)?
HUD estimates Median Family Income (MFI) annually for each metropolitan area and non-metropolitan county. The basis for HUD’s median family incomes is data from the American Community Survey, table B19113 - MEDIAN FAMILY INCOME IN THE PAST 12 MONTHS. A Consumer Price Index (CPI) forecast as published by the Bureau of Labor Statistics is used in the trend factor calculation to bring the 2018 ACS data forward to FY 2022.
For additional details concerning the use of the ACS in HUD’s calculations of MFI, please see HUD’s FY 2022 Median Family Income methodology document,
at https://www.huduser.gov/portal/datasets/il.html#2022 data.
Additionally, full documentation of all calculations for Median Family Incomes are available in the FY 2022 Median Family Income and the FY 2022 Income Limits Documentation System. These systems are available at https://www.huduser.gov/portal/datasets/il.html#2022 query.
Why didn’t the income limits for my county change from last year? HCD’s Hold Harmless Policy likely prevented the income limits from decreasing from last year’s levels and has maintained them despite a decrease in median income and/or income limits published by HUD.
Why do the income limits or area median income for my county not match what was published by HUD?
HCD adjusts each county’s area median income to at least equal the state non-metropolitan county median income, as published by HUD. Further, HCD’s Hold Harmless Policy prevents any decrease in income limits or median family income published by HUD to be applied to State Income Limits.
This Page
Intentionally
Left Blank
From: KENNETH ARENDT
Sent: Monday, June 20, 2022 10:29 AM
To: Ken Arendt ; Pat Arendt ; Barry Bakken
; Candy Bakken ; Annemone Barnett
Chris Bearden ;
Jeanette Bearden ; Amy and Dave Bowser ;
Rachel Brodie ; Brodie, Paul >; Hal Chase
>; Karen Chase >; Gary and Heidie Collins
>; Heidi Collins >; David Demaria
>; dawn demaria >; Bob and Nancy Derham
>; Jim Finkle >; Douglass G Heath
>; Bill Highstreet >; Shirley Highstreet
Brian Kaefer >; Kristen Kaefer
>; Jenannie and Kayvan Kimyai >; Zlata Kovac
>; Chris and Frank Lawrence >; lesliepennington
>; Patricia Madison >; Arnold and Suzanne Moore
>; Gary Neuner ; Gary & Rene NEUNER
>; rene neuner ; Richard Neuschaefer
Kathryn Parkman ; Phil Parkman
; Brad and Leslie Pennington Tom Pulley
; Tom and Karen Pulley ; jim tatsukawa
>; Hsiao-in Wang >; Romy Zeid
>
Cc: Matthew Hudes <[email protected]>; GP2040 <[email protected]> Subject: Fwd: Council Will Vote Soon on Housing and General Plan
EXTERNAL SENDER
HI all, please do take a minute or two to read this from Matt Hudes. What the TC will do tonight will have an impact on us all.
FYI, as best I can determine, this high density movement by the town manager, Provetti, exceeds her authority to establish policy for the town. And yet, there is no documentation that the TC has extended that authority to her. Nor has any action been taken, that I can determine, to correct that by the TC. We are in trouble.
Suggest you write to the TC to express your concerns.
Ken
---------- Original Message ----------
From: Matthew Hudes <[email protected]>
To: Kenneth Arendt
Date: 06/18/2022 2:23 PM
Subject: Council Will Vote Soon on Housing and General Plan
HI Kenneth,
On Monday night at 7:00 PM the Los Gatos Town Council will consider the Draft 2040 General Plan which includes as many as 3,904 additional homes in Los Gatos. This is an opportunity, before a vote is taken, for your voice to be heard regarding Housing, Neighborhood Character, and the Future of Our Town.
Town Council
7:00 PM June 20, 2022
https://losgatoscagov.zoom.us/j/88004227157?pwd=ZG1pc3pscTZwZXdCWjc2SkM3b2Nzdz0 Passcode: 320795.
In April, the Planning Commission reviewed the Draft 2040 General Plan and made some recommendations to the Council. I have had many conversations with folks around Town, and I am summarizing three key areas and some questions that remain:
1. Should virtually every residential area in Town be "upzoned" into more dense neighborhoods?
2. Will services and infrastructure keep pace with the safety and quality of life that our residents expect?
3. How can we preserve the character of our community while guiding the Town into the future?
As always, please feel free to reach out to me at [email protected] and you can send your comments to the Town at [email protected] Thanks for your engagement,
Matthew Hudes
Councilmember, Town of Los Gatos
_________________________________________
Key questions:
1. Density on top of Density
Increased density is when additional homes are built in spaces previously zoned for fewer homes. The Draft 2040 General Plan and the Planning Commission Recommendation call for increased density (also called "upzoning") in virtually every residential area in Los Gatos. The State's SB9 mandate also allows for additional density on top of the upzoning.
• Do we need that additional upzoned density? And can our town handle the associated impacts of traffic, parking, water-use, and wildfire hazard? • Why should any properties be upzoned in the Very High Fire Hazard Severity Zone, some of which are on narrow roads with flammable vegetation?
• And what is the goal of this transformation of Los Gatos neighborhoods—will increased density result in affordable housing or just many large luxury residences on small lots?
2. Overall growth
As drafted, the 2040 General Plan, would allow Los Gatos to grow by at least 8,971 people or 28%, which is almost three times greater than the Town’s growth rate in the last 20 years. Infrastructure and services will need to keep pace with growth in order for safety and quality of life to be maintained. Town-wide upzoning could result in even greater stress on our services and infrastructure, yet the fiscal impact of this growth has not been analyzed in the Draft 2040 General Plan.
• Why would Los Gatos plan for nearly double the amount that the State is mandating in its latest Regional Housing Needs Allocation (RHNA)? (California’s and Santa Clara County's populations have decreased over the last several years.)