Can California’s RHNA Process Overcome Historical Failures?

In a recent editorial, we outlined the scope and nature of San Diego County’s housing and homelessness crisis. Now, a short explainer on how the State of California is working with regional and local governments to build affordable housing, and what the cracks in that system have historically been.

Generally speaking, housing development and planning is done by the county and cities working with housing developers. Mandates are formulated and passed down from the state, and worked out by city and regional governments in the RHNA process.

“Pronounced “REE’-nah,” the RHNA process is an eight-year cycle that formulates a number of housing units a city or region needs to build, then mandates those cities and regions build those units. Simple enough on paper, but when the rubber hits the road, the whole system tends to grind to a halt.

The housing needs formulation takes into account a variety of factors to determine regional housing needs. Those include factors depending on the jurisdiction, but generally include population, employment, and household growth. Those state allocations are then passed down to regional associations, which make final determinations of where housing will be built. Then comes the appeals process, where cities often lobby their county administrations to change their mandated totals.

The RHNA process takes place in three parts, each with their own points of failure that have made housing development such a boondoggle.

The UCLA Lewis Center’s review of the RHNA process outlines it clearly.

• First, “the state Department of Finance and regional Councils of Government, in consultation with the Department of Housing and Community Development, project population growth and household formation for each region in the state.”

• “Then each region, through its metropolitan planning organization, allocates a portion of this projected housing “need” to its constituent cities. This process involves not just assigning projected units to each city, but also subdividing those units by income groups (e.g., each city will “need” a certain number of low-, middle- and higher-income housing units). These final figures are the cities’ RHNA numbers.”

• “Lastly, the cities must then revise the Housing Elements of their General Plans to demonstrate they have more than enough zoned capacity to accommodate this number of housing units.”

Arguably the most glaring point of failure in the RHNA process is during the third phase, where the planning organization has allocated units to cities, which in turn revise their general plans to zone for those housing units. In the past, many cities with no intention of building affordable housing would zone and allocate their units, but never make any steps to actually build them, and would simply zone for affordability then pack an impossible number of units into a small space, or zone all their units, but never make moves to actually develop them. In past RHNA cycles, the state found that only 24 out of the state’s 540 jurisdictions met their RHNA goals, a failure the state seems committed to correcting.

These cities knew they would face no real consequences then, but that status quo has changed. Now cities face increased scrutiny by the state, which will reject plans that are unrealistic about actual construction. This pressure to create real housing plans, combined with state affordable and density-focused subsidies could potentially supersede city zoning if the city has no approved plan to build their mandated units. Cities now fear losing state funding, legal challenges, and loss of local control if they fail to zone and build affordable housing. There is a sense that the State of California is no longer posturing about housing, and now failure to build will have real consequences for cities across the state.

Now that we know cities will be incentivized to build their affordable units, it is up to cities across the county to prioritize and incentivize affordable housing. Housing is the root of our economic troubles, and now that the state is pressuring local governments to act, it’s up to each community, and every city to choose how we take care of everyone who lives and works in our town, instead of pushing the problem off our lawn, and down the road.

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Written by Ashleigh Padilla Goins and Colin Scharff from the Evinco Strategies Policy Department.