Final

November 22, 2019

6th Cycle
Regional Housing Needs
Assessment Methodology
 Table of Contents

Overview ....................................................................................................................................................... 2
Final Regional Housing Needs Assessment Methodology ............................................................................ 2
Underlying Data and Assumptions ............................................................................................................... 3
Transit ....................................................................................................................................................... 3
Jobs ........................................................................................................................................................... 5
Equity Adjustment .................................................................................................................................... 6
Local Government Conditions....................................................................................................................... 8
Board of Directors ..................................................................................................................................... 9
Regional Housing Needs Assessment Subcommittee ............................................................................... 9
Regional Planning Technical Working Group ............................................................................................ 9
Regional Planning Committee................................................................................................................. 10
Regional Housing Needs Assessment Objectives and Factors .................................................................... 10
Objectives ............................................................................................................................................... 10
Factors..................................................................................................................................................... 13
Appendix ..................................................................................................................................................... 20
1. Supplemental Information dated August 23, 2019 ........................................................................ 20
2. Frequently Asked Questions dated September 5, 2019 ................................................................. 20
3. Response to Public Comments on Draft Methodology .................................................................. 20
4. HCD Letter dated November 1, 2019.............................................................................................. 20
Overview
On July 5, 2018, the State Department of Housing and Community Development (HCD) determined the
San Diego region would need to plan for 171,685 housing units (Regional Housing Needs Assessment
[RHNA] Determination) during the 6th Housing Element Cycle (2021-2029). As the council of governments
for the San Diego region, the San Diego Association of Governments (SANDAG) is responsible for developing
a methodology for allocating the regional housing need among the region’s 19 jurisdictions. The
methodology must distribute each jurisdiction’s housing unit allocation among the four income categories –
low, very-low, moderate, and above moderate – and further the objectives set forth in state law.
State housing element law requires SANDAG to provide a discussion of the methodology that includes the data
and assumptions relied upon, and an explanation of how information about local government conditions and how
each of the factors required by law was used to develop the draft methodology. (See Government Code Section
65584.04.) SANDAG must also describe how the methodology would further the five objectives in Government
Code Section 65584. This document is meant to provide the information required by statute.
State law also prohibits consideration of certain criteria. The following justifications have not been used in
development of the methodology and cannot be the basis for a determination of a jurisdiction’s share of the
regional housing need:
1. Any ordinance, policy, voter-approved measure, or standard of a city or county that directly or indirectly limits
the number of residential building permits issued by a city or county.
2. Prior underproduction of housing in a city or county from the previous regional housing need allocation.
3. Stable population numbers in a city or county from the previous regional housing needs cycle.
In addition to state housing element law, state law associated with development of Regional Transportation
Plans (RTPs) requires that there be consistency between transportation planning, development of housing,
and reduction of greenhouse gas (GHG) emissions. (See Government Code Sections 65080 and 65584.)
Increased use of public transportation leads to reduced GHG emissions compared to driving alone. This is why
the methodology was developed with an eye toward maximizing access between public transportation and
all housing types.
On July 26, 2019, the SANDAG Board of Directors released a draft methodology for public review. The Board
held a public hearing and concluded the public review period on September 6, 2019. SANDAG received over
2,000 comments on the draft methodology from jurisdictions, organizations, and members of the public.
SANDAG posted all supplemental information, a series of frequently asked questions (FAQs), all public
comments received during the public comment period, and responses to comments online. The supplemental
information, FAQs, and responses to comments are included for reference in the Appendix.
After consideration of the comments received, the Board authorized staff to submit the draft methodology to
HCD for review on September 6, 2019. HCD reviewed the draft methodology and submitted a letter to
SANDAG on November 1, 2019. HCD found that the methodology furthers the five statutory objectives in
Government Code section 65584(d), and did not provide any proposed amendments to the methodology for
the Board’s consideration.
On November 22, 2019, the Board adopted the final methodology.

Final Regional Housing Needs Assessment Methodology

The final methodology adopted by the Board on November 22, 2019, includes the following components.

1. Of the total housing units, 65% will be allocated to jurisdictions with access to transit,
including rail stations, Rapid bus stations, and major transit stops. Significant investments in
transit have been made throughout the region, and the methodology prioritizes housing growth in those

Final 6th Cycle Regional Housing Needs Assessment Methodology | 2

 areas with access to transit. Encouraging housing growth near transit can promote infill development
(developing vacant or under-used land within existing urban areas that are already largely developed) and
preserve open space, as most transit is located in urbanized areas. Improved access to transit also can
lower the vehicle miles traveled in a car and reduce GHG gas emissions.
2. Within the housing units allocated for jurisdictions with access to transit, 75% of the units will
be allocated to jurisdictions with rail stations and Rapid bus stations and 25% will be allocated
to jurisdictions with major transit stops. To ensure future growth is located near transit, the
methodology prioritizes 75% of the housing units in areas with rail and Rapid bus stations. Rail stations
and Rapid bus stations usually are located along fixed routes that require significant capital investment to
construct. Unlike bus stops or routes, rail and Rapid stations and routes are not amended or eliminated
on a regular basis.
The remaining 25% of the housing units will be allocated in jurisdictions with major transit stops. Major
transit stops, as defined in state law, have two intersecting bus routes that arrive at 15-minute intervals
during peak commute hours.
3. Of the total housing units, 35% will be allocated to jurisdictions based on the total number of
jobs in their jurisdiction. Jurisdictions should plan for housing to provide opportunities for more
residents to live near their place of employment, promoting infill development, and improving the
intraregional relationship between jobs and housing.
4. The methodology further applies an equity adjustment. The RHNA Determination divided the
number of housing units needed in the region into four income categories based on the region’s current
percentages of households in each income category. The equity adjustment includes a calculation of the
existing households in each jurisdiction in each income category. To promote equity and fair housing, as
well as to meaningfully address patterns of segregation, the methodology will allocate more housing
units within each income category to jurisdictions with a percentage of households in that same category
that is lower than the regional percentage.

Underlying Data and Assumptions

The methodology consists of a transit component, jobs component, and equity adjustment. The underlying
data and assumptions used in each component and the equity adjustment are discussed below.

Transit
Of the total housing units, 65% (111,595 housing units) will be allocated based on each jurisdiction’s share
of regional transit services. Because most transit infrastructure is located in the urbanized areas of the San
Diego region, heavily weighting the transit component will promote infill development, preserve open space,
lower-vehicle miles traveled, and reduce GHG emissions.
The transit component measures each jurisdiction’s share of rail & Rapid Stations and major transit stops,
which are defined below.
§ Rail & Rapid (R&R) Stations: Stations served by rail (North County Transit District [NCTD] COASTER; NCTD
SPRINTER; and Metropolitan Transit System [MTS] Trolley, including planned Mid-Coast stations) and
Rapid bus routes (NCTD BREEZE Route 350; MTS Rapid Routes 215, 225, and 235; and MTS Rapid
Express Routes 280 and 290).
§ Major Transit Stops: The intersection of two or more major local bus routes with a frequency of service
interval of 15 minutes or less during the morning and afternoon peak commute periods.
Of the units allocated based on the transit component, 75% (83,696 housing units) will be allocated based
on each jurisdiction’s share of R&R Stations, while 25% (27,899 housing units) will be allocated based on

Final 6th Cycle Regional Housing Needs Assessment Methodology | 3

each jurisdiction’s share of major transit stops. This reflects the significant investment the region has made to
build and improve rail lines and Rapid routes as well as the permanency of rail lines relative to local bus
service. Additionally, rail and Rapid routes have higher capacities and are among the more popular
transportation services in the region. Therefore, the methodology assumes these services can have a larger
impact on changing commute behavior and achieving mode shift goals.
Data Source
The data source for the transit component is the SANDAG Activity Based Model (ABM). For R&R stations,
SANDAG ABM Forecast Year 2025 No Build was used in order to capture the Mid-Coast Trolley stations
currently under construction and anticipated to be open for service to the public by 2021. For major transit
stops, SANDAG ABM Forecast Year 2020 was used as the specific data source to align with the start of the
6th Housing Element Cycle planning period.
For Rapid stations and major transit stops that have stops on either side of the road, which correspond to
northbound/southbound or eastbound/westbound travel, stop pairs were counted as one station or stop.
Stations that serve more than one rail and/or Rapid route were counted once in the R&R data. For example,
the Oceanside Transit Center, which is served by two rail lines (NCTD COASTER and NCTD SPRINTER),
accounts for only one of the seven R&R stations in Oceanside. Some R&R stations are also considered major
transit stops because they are also served by two or more bus lines with 15-minute frequencies during peak
commute. The Old Town Transit Center in the City of San Diego, for example, is both a R&R station (served
by the NCTD COASTER and MTS Trolley) and major transit stop (served by MTS Bus routes 10, 30, 35, and
44, which have 15-minute peak period frequencies).
The data underlying the proximity to transit component is included in Table 1.

Table 1: Transit Data

Rail & Rapid Stations Major Transit Stops
Jurisdiction
Count Regional Share (%) Count Regional Share (%)
Carlsbad 2 1.3% 0 0.0%
Chula Vista 9 5.8% 18 12.9%
Coronado 0 0.0% 0 0.0%
Del Mar 0 0.0% 0 0.0%
El Cajon 3 1.9% 0 0.0%
Encinitas 1 0.6% 0 0.0%
Escondido 14 9.1% 0 0.0%
Imperial Beach 0 0.0% 6 4.3%
La Mesa 5 3.2% 0 0.0%
Lemon Grove 2 1.3% 0 0.0%
National City 2 1.3% 15 10.7%
Oceanside 7 4.5% 0 0.0%
Poway 0 0.0% 0 0.0%
San Diego 100 64.9% 101 72.1%
San Marcos 3 1.9% 0 0.0%
Santee 1 0.6% 0 0.0%
Solana Beach 1 0.6% 0 0.0%
Unincorporated County 2 1.3% 0 0.0%
Vista 2 1.3% 0 0.0%
Region 154 100.0% 140 100.0%
Sources: R&R Stations - SANDAG ABM, Forecast Year 2025 No Build ; Major Transit Stops - SANDAG ABM, Forecast
1

Year 20202

1
SANDAG ABM, Forecast Year 2025 No Build, Release v14.0.1, Reference Scenario #242, January 2019.
2
SANDAG ABM, Forecast Year 2020, Release v14.0.1, Reference Scenario #243, January 2019.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 4

Jobs
Of the total housing units, 35% (60,090 units) will be allocated based on each jurisdiction’s share of jobs in
the region.
Data Source
The data source for the jobs component is the SANDAG Employment Estimates, which are also being used to
develop the latest Regional Growth Forecast. SANDAG Employment Estimates are derived from Quarterly
Census of Employment and Wages (QCEW) data from the Economic Development Department (EDD) and the
Longitudinal Employer-Household Dynamics Origin-Destination Employment Statistics (LODES) data from the
Center for Economic Studies at the U.S. Census Bureau. The LODES data combines federal, state, and Census
Bureau survey data on employers and employees and SANDAG uses the QCEW dataset for its detailed
geographic information on businesses to geolocate “job spaces” throughout the region. Then LODES data
(average of the last five years), which are available at the census block level, are used to fill the job spaces to
determine total jobs within various geographies. SANDAG Employment Estimates are also supplemented by
other data sources including the San Diego Military Advisory Council (SDMAC) and Defense Manpower Data
Center (DMDC). Of note, SDMAC and DMDC assign jobs associated with a Navy ship to the installation that
is the ship’s homeport. Finally, the jobs data are validated against published job totals for the County from
the EDD Labor Market Information’s yearly data.
The jobs data consists of all job types and includes jobs that are classified as a primary source of income,
which can be part-time or full-time, year-round or seasonal. The data underlying the jobs component is
included in Table 2.

Table 2: Jobs Data

Regional Share
Jurisdiction Total Jobs
(%)
Carlsbad 76,779 4.6%
Chula Vista 72,403 4.4%
Coronado 27,594 1.7%
Del Mar 4,484 0.3%
El Cajon 45,468 2.7%
Encinitas 27,871 1.7%
Escondido 55,059 3.3%
Imperial Beach 4,936 0.3%
La Mesa 29,773 1.8%
Lemon Grove 7,492 0.5%
National City 37,497 2.3%
Oceanside 45,178 2.7%
Poway 36,349 2.2%
San Diego 921,054 55.6%
San Marcos 40,964 2.5%
Santee 18,634 1.1%
Solana Beach 9,151 0.6%
Unincorporated County 154,686 9.3%
Vista 40,629 2.5%
Region 1,656,001 100.0%
Source: SANDAG Employment Estimates and/or SANDAG 2019
Regional Growth Forecast; U.S. Department of Defense

Final 6th Cycle Regional Housing Needs Assessment Methodology | 5

Equity Adjustment
In addition to distributing the RHNA Determination among jurisdictions, SANDAG must distribute units for
each jurisdiction among the four income categories defined by HCD. Each income category is defined as a
range of household incomes that represents a percentage of the area median income (AMI). The AMI for the
San Diego region is $66,529, as provided by HCD. Table 3 provides the definition for each income category
and the income ranges for San Diego region households per category.

Table 3: Income Categories

Percent of Regional Households
Income Category Definition Income Range*
(RHNA Determination)
Very Low Less than 50% of AMI $33,259 or less 24.7%
Low 50-80% of AMI $33,260 - $53,219 15.5%
Moderate 80-120% of AMI $53,220 - $79,829 17.3%
Above Moderate Over 120% of AMI $79,830 or more 42.5%
Source: HCD Determination Letter; 2012-2016 American Community Survey 5-Year, DP03

Household income data was used to determine the number of households per category in each jurisdiction
and subsequently each jurisdiction’s percentage breakdown of households per category, which is included in
Table 4. The jurisdictional percentages were then compared to the regional percentages for each income
category to determine a multiplier, which is an “adjustment” toward the regional percentages.
A jurisdiction’s multiplier for a given income category is applied to the total RHNA units allocated to the
jurisdiction to determine how many of its total RHNA units are allocated to that income category.
Jurisdictions that have a higher percentage of existing households in a given income category than the region
receive a downward adjustment toward the regional percentage, which results in a smaller share of the
allocated housing units within that income category than if no adjustment were applied. Jurisdictions that
have a lower percentage of households in a given income category than the region receive an upward
adjustment toward the regional percentage, which results in a greater share of the allocated housing units
within that income category than if no adjustment were applied.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 6

Table 4: Households per Income Category

Existing Households by Income Category

Total
Jurisdiction Above
Households Very Low % Low % Moderate % %
Moderate
Carlsbad 42,926 6,981 16.3% 4,644 10.8% 5,940 13.8% 25,360 59.1%
Chula Vista 77,804 19,459 25.0% 11,987 15.4% 13,643 17.5% 32,715 42.0%
Coronado 8,986 1,506 16.8% 1,109 12.3% 1,442 16.1% 4,929 54.9%
Del Mar 2,258 430 19.0% 102 4.5% 248 11.0% 1,478 65.5%
El Cajon 32,937 12,434 37.8% 5,754 17.5% 5,615 17.0% 9,135 27.7%
Encinitas 23,695 4,287 18.1% 2,168 9.2% 3,182 13.4% 14,058 59.3%
Escondido 45,217 13,880 30.7% 8,239 18.2% 8,245 18.2% 14,853 32.8%
Imperial Beach 9,044 2,888 31.9% 2,105 23.3% 1,726 19.1% 2,325 25.7%
La Mesa 23,767 6,368 26.8% 4,468 18.8% 4,609 19.4% 8,322 35.0%
Lemon Grove 8,465 2,316 27.4% 1,643 19.4% 1,730 20.4% 2,776 32.8%
National City 15,870 6,436 40.6% 3,271 20.6% 2,848 17.9% 3,315 20.9%
Oceanside 61,480 16,148 26.3% 11,348 18.5% 11,297 18.4% 22,687 36.9%
Poway 15,797 2,418 15.3% 1,675 10.6% 2,281 14.4% 9,422 59.6%
San Diego 490,219 119,014 24.3% 75,283 15.4% 82,616 16.9% 213,305 43.5%
San Marcos 29,125 7,707 26.5% 4,212 14.5% 5,043 17.3% 12,163 41.8%
Santee 19,517 3,493 17.9% 2,812 14.4% 3,683 18.9% 9,528 48.8%
Solana Beach 5,750 883 15.4% 698 12.1% 854 14.9% 3,315 57.7%
Unincorporated County 159,642 35,996 22.5% 26,493 16.6% 27,598 17.3% 69,555 43.6%
Vista 30,629 9,016 29.4% 5,746 18.8% 6,112 20.0% 9,754 31.8%
Region 1,103,128 271,661 24.6% 173,760 15.8% 188,713 17.1% 468,995 42.5%
Source: 2012-2016 American Community Survey (ACS) 5-Year, B19001 “Household Income In The Past 12 Months (In 2016 Inflation-Adjusted Dollars)”

Final 6th Cycle Regional Housing Needs Assessment Methodology | 7

Table 5 below shows this inverse relationship by using plus (+) and minus (-) signs in the Adjustment (Adjust)
column. The regional percentages of household per income category are included in the first row and shaded
in blue. The jurisdictions’ percentages of household per income category are included in the “Percent of
Households” (% of HH) and shaded in grey.

Table 5: Determining an Equity Adjustment

Above
Region Very Low 24.7% Low 15.5% Moderate 17.3% 42.5%
Mod.
Jurisdiction % of HH Adjust. % of HH Adjust. % of HH Adjust. % of HH Adjust.
Carlsbad 16.3% + 10.8% + 13.8% + 59.1% -
Chula Vista 25.0% - 15.4% + 17.5% - 42.0% +
Coronado 16.8% + 12.3% + 16.1% + 54.9% -
Del Mar 19.0% + 4.5% + 11.0% + 65.5% -
El Cajon 37.8% - 17.5% - 17.0% + 27.7% +
Encinitas 18.1% + 9.2% + 13.4% + 59.3% -
Escondido 30.7% - 18.2% - 18.2% - 32.8% +
Imperial Beach 31.9% - 23.3% - 19.1% - 25.7% +
La Mesa 26.8% - 18.8% - 19.4% - 35.0% +
Lemon Grove 27.4% - 19.4% - 20.4% - 32.8% +
National City 40.6% - 20.6% - 17.9% - 20.9% +
Oceanside 26.3% - 18.5% - 18.4% - 36.9% +
Poway 15.3% + 10.6% + 14.4% + 59.6% -
San Diego 24.3% + 15.4% + 16.9% + 43.5% -
San Marcos 26.5% - 14.5% + 17.3% + 41.8% +
Santee 17.9% + 14.4% + 18.9% - 48.8% -
Solana Beach 15.4% + 12.1% + 14.9% + 57.7% -
Unincorporated 22.5% + 16.6% - 17.3% + 43.6% -
Vista 29.4% - 18.8% - 20.0% - 31.8% +
Source: 2012-2016 American Community Survey (ACS) 5-Year, B19001

Data Source
SANDAG used data from the 2012-2016 ACS 5-Year, Table B19001 “Household Income In The Past
12 Months (In 2016 Inflation-Adjusted Dollars)” to determine the jurisdictions’ household breakdown among
income categories. This dataset was also used by HCD to calculate the unit distribution across income
category for the San Diego region’s RHNA Determination.

Local Government Conditions

The methodology was developed with input and recommendation from the Board of Directors, RHNA
Subcommittee (a subcommittee of the SANDAG Board), the Regional Planning Technical Working Group
(including planning directors from each jurisdiction and housing stakeholders), the SANDAG Regional
Planning Committee (a policy advisory committee of the Board), and public stakeholders. Several meetings
were held with each stakeholder group and meetings were open to the public. Attendees at each meeting
provided information regarding the types of data SANDAG should use, assumptions that should be made, as
well as information regarding conditions in their individual jurisdictions that should be taken into
consideration. Jurisdictions and stakeholders also provided written comments during the process.
There was general consensus at the meetings that the approach chosen should keep the methodology simple
and easy to explain to the public. Nuanced adjustments that may have modified the methodology in marginal
ways in relation to the overall objectives and factors were discussed and considered. Factors and adjustments

Final 6th Cycle Regional Housing Needs Assessment Methodology | 8

that would have created a complicated formula, however, ultimately were not pursued since the
methodology was developed with the intent to keep it transparent and understandable.
A discussion of each stakeholder group and their major contributions to the development of the
methodology is included below.

Board of Directors
At its September 14, 2018, meeting, the Board was surveyed to determine each member jurisdiction’s
priorities for the upcoming RHNA cycle, including which RHNA objectives and factors would be most
important when determining the distribution of housing units in the region. The member jurisdictions
requested that their initial set of priorities be further discussed by the Regional Planning Technical Working
Group (TWG), which consists of the planning or community development director from each jurisdiction,
among other members. The Board also directed the formation of a RHNA Subcommittee to review and
provide input and guidance on potential policy and technical options for developing the RHNA methodology
for allocation of housing units to each jurisdiction in the RHNA Plan. The Board received an update on the
preliminary methodology in May 2019 and approved the release of the draft methodology for public
comment at its July 26, 2019, meeting. The Board also conducted a public hearing for the draft methodology
on September 6, 2019, and adopted the final methodology on November 22, 2019, following HCD’s review.

Regional Housing Needs Assessment Subcommittee

In December 2018, the Board formed the RHNA Subcommittee, which was comprised of Board members
from each SANDAG subregion to reflect the diversity of geography, jurisdiction size, and other attributes of
member jurisdictions. To develop its recommendation, the RHNA Subcommittee explored options for how to
build consensus around a RHNA methodology that complies with state law while best achieving the goals of
the Board. The RHNA Subcommittee held six meetings prior to the Board releasing the draft methodology. All
meetings were publicly noticed and open to the public. Critical direction provided by the RHNA
Subcommittee included the following:
§ Create a narrative around housing that promotes regional unity in addressing the housing need
§ Establish a framework that incorporates transit and jobs to further the objective of increasing transit use,
reducing vehicle miles traveled and GHG emissions, and relieving traffic congestion
§ Include an equity adjustment to ensure the allocation furthered fair housing and increased affordability in
all cities and the County of San Diego
§ Evaluate opportunities for the military installations within the region to provide housing for military and
their families

Regional Planning Technical Working Group

The TWG is a SANDAG working group that consists of the planning or community development director from
each jurisdiction and representatives from other single-purpose regional agencies, such as the transit
operators. The TWG advises the Regional Planning Committee and Board on the development and
implementation of San Diego Forward: The 2021 Regional Plan, which includes, and must be consistent with,
the RHNA plan. The TWG discussed and provided input on the development of the methodology at
11 meetings, including two workshops specifically focused on RHNA.
Information on local government conditions provided by TWG members included:
§ Preserved open space, agricultural lands, and airports and associated safety zones

Final 6th Cycle Regional Housing Needs Assessment Methodology | 9

§ Universities and community colleges
§ Military installations
§ Low-wage jobs
§ Voter requirements
Feedback provided by TWG members for which there was general consensus that was incorporated into the
methodology included:
§ Prioritizing transit, with greater weight given to major transit investments (R&R stations) over local bus
service
§ Improving the job-housing relationship
§ Encouraging the development of a mix of housing types across the region and addressing historical
patterns of inequity in housing development

Regional Planning Committee

The Regional Planning Committee (RPC) is one of the SANDAG policy advisory committees, which provides
oversight for the preparation and implementation of San Diego Forward: The 2021 Regional Plan.
The RPC discussed the RHNA process at two of their meetings.
Information on local government conditions provided by RPC members included:
§ Airport safety zones
§ Housing development opportunities at major employment centers
§ Sea level rise
Feedback received from the RPC that informed the development of the methodology included:
§ Aligning priorities for the RHNA methodology with priorities adopted by jurisdictions through other
planning efforts such as climate action plans

Regional Housing Needs Assessment Objectives and Factors

Objectives
The methodology and allocation further the five objectives listed in Government Code Section 65584.
1. Increasing the housing supply and the mix of housing types, tenure, and affordability in all cities and
counties within the region in an equitable manner, which shall result in each jurisdiction receiving an
allocation of units for low- and very low-income households.
Per state law, the methodology allocates units in all four income categories to each of the region’s
19 jurisdictions. The methodology does so equitably, ensuring each jurisdiction receives an allocation for
low- and very low-income units, and further, allocating a higher share of low- and very-low units to
jurisdictions that currently have a smaller share of low- and very low-income households than the
regional share. State law requires jurisdictions to zone at higher densities to accommodate their low- and
very low-income housing allocations. As jurisdictions plan for and build housing, the mix of housing types
will increase.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 10

2. Promoting infill development and socioeconomic equity, the protection of environmental and agricultural
resources, the encouragement of efficient development patterns, and the achievement of the region’s
GHG gas reductions targets provided by the State Air Resources Board pursuant to Section 65080.
The methodology prioritizes transit and jobs to encourage efficient development patterns and reduce
GHG emissions. By allocating housing units based on these two factors, SANDAG sets a guiding principle
for local jurisdictions to zone and build housing near transit and jobs. Transit and job centers are located
in the urbanized areas of the region. Therefore, an allocation based on transit and jobs will lead to more
infill development while protecting natural resources and open space. Because infill development does
not rely on available space and can occur in areas that already have a dense population, the
methodology supports provision of housing even in areas that are currently considered built-out.
SANDAG’s GHG reduction target, as set by the California Air Resources Board, is to reduce the region’s
per capita emissions of GHG from cars and light trucks by 15% by 2020, compared with a 2005
baseline. By 2035, the target is to reduce GHG emissions by 19% per capita. The methodology
encourages the development of housing near jobs and transit, which will provide the region’s residents
with opportunities to live where they work and/or readily access transit, which can facilitate shorter
commutes, reduce vehicle miles traveled, and increase trip-taking by transit or alternative modes.
3. Promoting an improved intraregional relationship between jobs and housing, including an improved
balance between the number of low-wage jobs and the number of housing units affordable to low-wage
workers in each jurisdiction.
SANDAG conducted an analysis of the number of low-wage jobs and the number of housing units
affordable to low-wage workers in each jurisdiction. The analysis shows that the number of low-wage
jobs far exceeds the number of existing housing units affordable to low-wage workers in each
jurisdiction.
The methodology allocates 35% of the 171,685-unit regional housing need based on each jurisdiction’s
share of existing regional total jobs to encourage development of housing near job centers so that
jurisdictions can improve the jobs-housing relationship.
The methodology’s Equity Adjustment (see Objective 4) also improves the balance between the number
of low-wage jobs and the number of housing units affordable to low-wage workers in each jurisdiction
by allocating a higher share of low- and very low-income housing units to jurisdictions that currently have
a smaller share of low-and very low-income households than the regional share.
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, as compared to the countywide
distribution of households in that category from the most recent ACS.
This objective guided the development of the Equity Adjustment used to ensure the methodology will
result in allocation of housing units to each of the income categories. This adjustment results in a
jurisdiction receiving a lower proportion of its total housing units within an income category when it has
a higher share of households within that income category compared to the region. This method shifts
units across income categories, rather than adding units to a jurisdiction’s total housing unit allocation,
allowing for a mix of housing types and affordability near transit and jobs.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 11

5. Affirmatively furthering fair housing. For purposes of this section, “affirmatively furthering fair housing”
means taking meaningful actions, in addition to combating discrimination, that overcome patterns of
segregation and foster inclusive communities free from barriers that restrict access to opportunity based
on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful
actions that, taken together, address significant disparities in housing needs and in access to opportunity,
replacing segregated living patterns with truly integrated and balanced living patterns, transforming
racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and
maintaining compliance with civil rights and fair housing laws.
During development of the methodology, SANDAG reviewed the California Tax Credit Allocation
Committee (TCAC) 2019 Opportunity Map for the San Diego region. The TCAC map demonstrates how
public and private resources are spatially distributed within the region. The map is part of a larger study
that shows how communities with better air quality, higher educational attainment, and better economic
indicators are communities that have higher “opportunity”, or pathways that offer low-income children
and adults the best chance at economic advancement. The study finds that historically communities with
higher opportunity – through plans, policies, and practices – may have systematically denied equal
opportunity to low socioeconomic and minority populations.
Areas of “low resource” and “high segregation & poverty” on the TCAC maps are also many of the
same areas with a high concentration of low-income households in the San Diego region. The Equity
Adjustment within the methodology addresses the disparities in access to resource-rich areas by
providing housing opportunities for people in all income levels to reside in any given community. This is
meant to foster and maintain compliance with civil rights and fair housing laws. The Equity Adjustment in
the methodology also assists in overcoming patterns of discrimination and transforming racially and
ethnically concentrated areas of poverty into areas of opportunity by allocating a higher proportion of
low-income housing units to jurisdictions with a lower share of low-income households, which tend to
be jurisdictions with a high concentration of resource-rich areas. The six jurisdictions that will receive the
highest percentage of low- and very low- income housing units under the methodology also do not
contain areas of high segregation and poverty or low resource census tracts, and compared to other
jurisdictions in the region have the highest percentage of area in high or highest resource census tracts
(76-100% of the jurisdiction). Conversely, the jurisdictions that currently have more area in low resource
census tracts or census tracts that demonstrate high segregation and concentrations of poverty, generally
receive a lower percentage of low- and very low-income housing units than the regional percentage.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 12

California Tax Credit Allocation Committee Opportunity Map

Factors
In addition to furthering the objectives outlined above, state law requires that SANDAG consider several
factors in the development of the methodology, to the extent sufficient data is available pertaining to each
factor. See Government Code Section 65584.04(e). The RHNA factors and how each were considered in the
development of the methodology are described below.
1. Each jurisdiction’s existing and projected jobs and housing relationship. This shall include an estimate
based on readily available data on the number of low-wage jobs within the jurisdiction and how many
housing units within the jurisdiction are affordable to low-wage workers as well as an estimate based on
readily available data, of projected job growth and projected household growth by income level within
each member jurisdiction during the planning period.
The methodology prioritizes jobs as a factor in allocating the regional housing need. The jobs factor seeks
to encourage development of housing near job centers so that jurisdictions can achieve greater jobs-
housing balance. The jobs factor uses current data on existing jobs instead of a projection. Given the
housing shortage within the region, it is critical that housing is built where existing jobs are located to
begin to address the current jobs-housing imbalance. Although data for projected job and household
growth by income level for the next Regional Plan update is not yet available, SANDAG used the most
recent readily available data for projected job growth and projected household growth by income level
within each member jurisdiction to conduct its analysis.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 13

 SANDAG analyzed the number of low-wage jobs and the number of housing units affordable to low-
wage workers in each jurisdiction. The analysis showed that the number of low-wage jobs far exceeds
the number of existing housing units affordable to low-wage workers in each jurisdiction. The
methodology is expected to increase the supply of affordable housing by allocating each jurisdiction low-
and very low-income housing units. The methodology’s Equity Adjustment (see Objective 4) also should
improve the balance between the number of low-wage jobs and the number of housing units affordable
to low-wage workers in each jurisdiction by allocating a higher share of low- and very low-income
housing units to jurisdictions that currently have a smaller share of low- and very low-income households
than the regional share.
2. The opportunities and constraints to development of additional housing in each member jurisdiction,
including all of the following:
a. Lack of capacity for sewer or water service due to federal or state laws, regulations or regulatory
actions, or supply and distribution decisions made by a sewer or water service provider other than
the local jurisdiction that preclude the jurisdiction from providing necessary infrastructure for
additional development during the planning period.
SANDAG notes that general plans for some jurisdictions may account for constraints to housing
development arising from lack of capacity for sewer or water service. For example, rural areas may rely
more heavily on well water and septic systems, which constrains housing development due to lack of
sufficient infrastructure. For the methodology, however, the transit factor allocates housing units based
on each jurisdiction’s share of regional rail and Rapid bus stations as well as major transit stops. Rail and
Rapid bus stations are located in the region’s more developed areas where land uses generate enough
ridership to support the investment to the transit infrastructure. Major transit stops also are located in the
region’s urbanized areas and surrounded by land uses that support higher service frequencies. By
prioritizing transit connectivity, the methodology encourages infill development in urban areas that are
likely to have existing capacity for sewer or water service.
b. The availability of land suitable for urban development or for conversion to residential use, the
availability of underutilized land, and opportunities for infill development and increased residential
densities. The council of governments may not limit its consideration of suitable housing sites or land
suitable for urban development to existing zoning ordinances and land use restrictions of a locality
but shall consider the potential for increased residential development under alternative zoning
ordinances and land use restrictions. The determination of available land suitable for urban
development may exclude lands where the Federal Emergency Management Agency or the
Department of Water Resources has determined that the flood management infrastructure designed
to protect that land is not adequate to avoid the risk of flooding.
The methodology is not constrained by existing zoning ordinances and land use restrictions. Instead
the methodology prioritizes transit and jobs, which aligns with several beneficial land use planning
principles, such as promoting infill and increasing residential densities. The availability of land suitable
for urban development or for conversion to residential use, the availability of underutilized land, and
opportunities for infill development and increased residential densities are accounted for due to the
methodology’s use of the jobs and transit factors. When development of housing is promoted near
transit and jobs in areas that are already more densely populated and developed than other areas of
each jurisdiction, it allows the jurisdictions to focus on infill development that can occur without
reliance on the availability of additional land, but instead on underutilized land that can be converted
to uses that allow for increased residential density.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 14

 The transit factor allocates housing units based on each jurisdiction’s share of regional rail and Rapid
bus stations as well as major transit stops. Rail and Rapid bus stations are located in the region’s
urbanized areas where land uses generate enough ridership to support the investment to the transit
infrastructure. Major transit stops are also located in the region’s urbanized areas and surrounded by
land uses that support higher service frequencies. By prioritizing transit, the methodology encourages
infill development in areas that are suitable for urban development. A transit-focused methodology
also promotes increased densities as jurisdictions must plan for housing in urban areas already served
by high quality transit.
The methodology aligns with the region’s priorities for growth. As shown in Figure 3.1, general plans
in the San Diego region have focused growth and development in existing urban areas, preserved
more land for habitat and open space, and looked to accommodate more housing near transit and
key destinations.

Figure 3.1: Priorities for Growth Then and Now

c. Lands preserved or protected from urban development under existing federal or state programs, or
both, designed to protect open space, farmland, environmental habitats, and natural resources on a
long-term basis, including land zoned or designated for agricultural protection or preservation that is
subject to a local ballot measure that was approved by the voters of that jurisdiction that prohibits or
restricts conversion to non-agricultural uses.
General plans for individual jurisdictions may account for constraints to housing development arising
from lands preserved or protected from urban development under existing federal or state programs.
As shown in the figures below though, preserved land, farmland, and habitats are primarily in the
eastern portion of San Diego County. The methodology focuses housing units in areas with access to
transit and jobs, which are located in existing urbanized areas. Therefore, the methodology will not
encourage encroachment upon open space areas.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 15

Final 6th Cycle Regional Housing Needs Assessment Methodology | 16
 d. County policies to preserve prime agricultural land, as defined pursuant to Section 56064, within an
unincorporated and land within an unincorporated area zoned or designated for agricultural
protection or preservation that is subject to a local ballot measure that was approved by the voters of
that jurisdiction that prohibits or restricts its conversion to non-agricultural uses.
The County of San Diego General Plan accounts for some constraints to housing development arising
from policies to preserve prime agricultural land and incorporates local ballot measure provisions
prohibiting or restricting the conversion of agricultural to non-agricultural uses. The methodology
allocates housing units based on access to jobs and transit, which are located in existing urbanized
areas. Therefore, this constraint is not expected to impact the methodology’s capacity to allow for
development of additional housing.
3. The distribution of household growth assumed for purposes of a comparable period of regional
transportation plans and opportunities to maximize the use of public transportation and existing
transportation infrastructure.
As shown in Figure 3.1, plans for growth are focused on the urbanized areas of the region. The
methodology prioritizes transit as a factor – specifically high-quality transit, which is located in the
urbanized areas. The emphasis on transit allows local jurisdictions that have invested in transit the
opportunity to maximize the use of existing transportation infrastructure.
4. Agreements between a county and cities in a county to direct growth toward incorporated areas of the
county, and land within an unincorporated area zoned or designated for agricultural protection or
preservation that is subject to a local ballot measure that was approved by the voters of the jurisdiction
that prohibits or restricts conversion to non-agricultural uses.
Regional planning undertaken by SANDAG and its member agencies during the past 15 to 20 years, has
focused the region’s growth in the western third of the region, primarily in its incorporated cities and
near transit service (Figure 3.1). SANDAG has funded “smart growth” grants to encourage growth in
incorporated areas of the county with sufficient density to support transit-oriented development.
Consistent with this, the methodology prioritizes transit and jobs. High-quality transit service and a high
concentration of the region’s jobs are located in the urbanized, incorporated areas of the region. Thus,
the methodology is consistent with agreements between SANDAG, the County of San Diego, and the
cities to develop public transportation infrastructure and supporting land uses away from areas that are
zoned or designated for agricultural protection or preservation. Interjurisdictional agreements may
account for some development constraints; however, those agreements are not expected to be in conflict
with the methodology due to the prioritization of transit and jobs.
5. The loss of units contained in assisted housing developments, as defined in paragraph (9) of subdivision
(a) of Section 65583, that changed to non-low-income use through mortgage prepayment, subsidy
contract expirations, or termination of use restrictions.
The data for these units is not readily available and varies by jurisdiction. The loss of assisted housing
developments for lower income households is an issue that should be addressed by the jurisdictions
when preparing their housing elements.
6. The percentage of existing households at each of the income levels listed in subdivision (e) of
Section 65584 that are paying more than 30% and more than 50% of their income in rent.
This factor was not included in state law at the time the HCD was making its determination on the
regional housing need of the San Diego region, and sufficient data for this factor is not readily available.
The San Diego region received its largest RHNA Determination this cycle, however, and it is expected that
an influx of housing units in each income category will help alleviate the rent burden in the region.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 17

7. The rate of overcrowding.
HCD used the 2012-2016 ACS to determine the rate of overcrowding in the San Diego region when
making its RHNA Determination. HCD then compared the San Diego region’s overcrowding rate
(6.43% of all households) to the national rate (3.34% of all households). To address the needs of
overcrowding in the region, HCD’s RHNA Determination included an overcrowding adjustment of
3.09%, which added 38,700 housing units to the regional housing need to alleviate overcrowding in the
region. Thus, this factor has already been accounted for in the methodology.
8. The housing needs of farmworkers.
The methodology prioritizes jobs as a factor in allocating the regional housing need. Farmworkers are
included in the data on existing jobs. Therefore, their housing needs along with the housing needs of all
the region’s workers are considered.
The methodology increases the supply of affordable housing by allocating each jurisdiction low- and very
low-income housing units. The methodology’s Equity Adjustment (see Objective 4) also improves the
balance between the number of low-wage jobs, including farming jobs, and the number of housing units
affordable to low-wage workers in each jurisdiction by allocating a higher share of low- and very low-
income housing units to jurisdictions that currently have a smaller share of low-and very low-income
households than the regional share. Although the low-income housing needs of farmworkers are unique
given their low wages and job locations, the allocation expected from the methodology is expected to
provide more low-income housing in every jurisdiction and accordingly should provide farmworkers the
ability to live in more areas of the region and commute shorter distances to their seasonal jobs.
9. The housing needs generated by the presence of a private university or a campus of the California State
University or the University of California within any member jurisdiction.
The major universities and community colleges in the San Diego region are located in urban areas served
by the existing transportation network. The City of San Diego is home to San Diego State University;
University of California San Diego; University of San Diego; Point Loma Nazarene University; various
smaller, private universities; and three community colleges: San Diego City College, San Diego Mesa
College, and San Diego Miramar College. It also has the greatest share of the region’s transportation
system in part because of transportation investments near universities and colleges located within its
jurisdiction.
Similarly, the cities of Chula Vista (Southwestern Community College), El Cajon (Cuyamaca College),
Oceanside (Mira Costa College), and San Marcos (California State University San Marcos and Palomar
College) have made transportation investments to improve access to transit near colleges and
universities. By prioritizing transit, the methodology encourages housing development near existing
transit and the key destinations that transit links, including the region’s universities and colleges. The
methodology will result in additional housing units being allocated based on transit. This will help these
jurisdictions address the housing needs of students, faculty, and staff beyond what these colleges or
universities may provide.
10. The loss of units during a state of emergency that was declared by the Governor pursuant to the
California Emergency Services Act (Chapter 7 (commencing with Section 8550) of Division 1 of Title 2),
during the planning period immediately preceding the relevant revision pursuant to Section 65588 that
have yet to be rebuilt or replaced at the time of the analysis.
Jurisdictions report demolished units to the Department of Finance on an annual basis. Demolished units
include those lost during a state of emergency. Between 2011 and 2018, states of emergency in the
San Diego region declared by the Governor pursuant to the California Emergency Services Act, and in

Final 6th Cycle Regional Housing Needs Assessment Methodology | 18

 which homes were lost, include the following wildfires: the 2014 wildfires (Cocos Fire and
Poinsettia Fire), 2017 Lilac Fire, and 2018 West Fire.
HCD analyzed the most recent ten-year average rate of demolition within the San Diego region based on
jurisdictions’ annual reports to the Department of Finance. The ten-year average rate of demolition in the
San Diego region is 0.32% of the total housing stock. The RHNA Determination included HCD’s
minimum replacement adjustment of 0.5%, which exceeds the region’s demolition rate. This adjustment
added 6,255 housing units to the RHNA Determination. SANDAG does not have readily available data
broken down by jurisdiction to use for this factor and has therefore relied on HCD’s data and adjustment
to address this factor at a regional level.
11. The region’s GHG emissions targets provided by the State Air Resources Board pursuant to
Section 65080.
SANDAG’s GHG reduction target, as set by the California Air Resources Board, is to reduce the region’s per
capita emissions of GHG from cars and light trucks by 15% by 2020, compared with a 2005 baseline. By
2035, the target is to reduce GHG emissions by 19% per capita. The methodology encourages the
development of housing near jobs and transit, which will provide the region’s residents with opportunities to
live where they work and/or readily access transit, which can facilitate shorter commutes, reduce GHG
emissions, and increase trip-taking by transit or alternative modes.
12. Any other factors adopted by the council of governments, that further the objectives listed in subdivision (d) of
Section 65584, provided that the council of governments specifies which of the objectives each additional
factor is necessary to further. The council of governments may include additional factors unrelated to
furthering the objectives listed in subdivision (d) of Section 65584 so long as the additional factors do not
undermine the objectives listed in subdivision (d) of Section 65584 and are applied equally across all household
income levels as described in subdivision (f) of Section 65584 and the council of governments makes a finding
that the factor is necessary to address significant health and safety conditions.
No other factors were included in the methodology.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 19

Appendix

1. Supplemental Information dated August 23, 2019

2. Frequently Asked Questions dated September 5, 2019

3. Response to Public Comments on Draft Methodology

4. HCD Letter dated November 1, 2019

Final 6th Cycle Regional Housing Needs Assessment Methodology | 20

Regional Housing Needs Assessment:
Response to Board Requests – August 23, 2019
On July 26, 2019, the Board of Directors released for public comment a draft methodology for the 6th Cycle Regional
Housing Needs Assessment (RHNA). The estimated allocation based upon the draft methodology is shown in Table 1.
The estimated allocation is subject to changes if the draft methodology is modified by the Board of Directors due to
comments from the public or the review for consistency with RHNA laws that will be performed by the California
Department of Housing and Community Development. The RHNA laws can be found in the California Government
Code starting at Section 65584.

Table 1: Estimated Allocation Per Income Category based on the Draft 6th Cycle RHNA Methodology

Total
Above
Jurisdiction Very Low Low Moderate Estimated
Moderate
Allocation
Carlsbad 1,311 784 749 1,029 3,873
Chula Vista 2,750 1,777 1,911 4,667 11,105
Coronado 343 185 174 299 1,001
Del Mar 37 64 31 31 163
El Cajon 481 414 518 1,867 3,280
Encinitas 469 369 308 408 1,554
Escondido 1,864 1,249 1,527 4,967 9,607
Imperial Beach 233 127 190 825 1,375
La Mesa 859 487 577 1,874 3,797
Lemon Grove 295 166 193 705 1,359
National City 645 506 711 3,575 5,437
Oceanside 1,268 718 883 2,574 5,443
Poway 468 268 241 342 1,319
San Diego 27,510 17,311 19,297 43,783 107,901
San Marcos 728 530 542 1,316 3,116
Santee 406 200 188 425 1,219
Solana Beach 316 159 160 240 875
Unincorporated County 1,834 992 1,165 2,709 6,700
Vista 515 321 369 1,356 2,561
Region (Totals) 42,332 26,627 29,734 72,992 171,685

Several SANDAG Board members requested that staff provide additional information during the public comment
period on potential modifications to the draft methodology. These requests pertain to the following topics:

1. Equal Weighting to Transit and Jobs Component

2. High Frequency Transit Stop Dataset
3. Increase Equity Adjustment

A description of each request, how each may or may not further the objectives in state law, and how each would
change the estimated allocation are included below.

Several SANDAG Board members requested staff apply a methodology that recognizes challenges for small cities by
potentially reducing the number of housing units in small cities. SANDAG staff consulted with the California
Department of Housing Community Development (HCD) on the potential for small cities to receive a reduced
allocation. HCD expressed concerns about an adjustment based on the size of a city rather than being an alteration to
the methodology driven by data showing that the adjustment would further the objectives in RHNA law. HCD advised
that such an adjustment would be seen as a red flag in the methodology that would likely lead to a negative
response. HCD suggested that a small cities adjustment would not be justifiable or consistent with RHNA laws.
Therefore, a description of a small cities’ adjustment is not included in the information below.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 21

Request #1: Equal Weighting to Transit and Jobs Component
More than one SANDAG Board member requested that staff apply a methodology that would weigh the transit and
jobs components equally such that each would allocate 50 percent of the RHNA Determination (171,685 housing
units). Table 2 shows an estimated allocation based on this request. Since 171,685 housing units cannot be split
evenly, the component with one more housing unit is the jobs component.

Considerations
Providing equal weighting to the transit and jobs components could meet the objectives in state law as both the
transit and jobs components can lead to reduced greenhouse gas reductions, promote infill development, and provide
a mix of housing types to all jurisdictions.

Table 2: Estimated Allocation based on Request #1: Equal Weighting to Transit and Jobs Component

Transit Jobs Total Estimated Difference from

Jurisdiction
Weighting: 50% Weighting: 50% Allocation Draft Methodology
Carlsbad 836 3,980 4,816 943
Chula Vista 6,522 3,753 10,275 (830)
Coronado - 1,430 1,430 429
Del Mar - 232 232 69
El Cajon 1,254 2,357 3,611 331
Encinitas 418 1,445 1,863 309
Escondido 5,853 2,854 8,707 (900)
Imperial Beach 920 256 1,176 (199)
La Mesa 2,090 1,543 3,633 (164)
Lemon Grove 836 388 1,224 (135)
National City 3,135 1,944 5,079 (358)
Oceanside 2,926 2,342 5,268 (175)
Poway - 1,884 1,884 565
San Diego 57,290 47,747 105,037 (2,864)
San Marcos 1,254 2,123 3,377 261
Santee 418 966 1,384 165
Solana Beach 418 474 892 17
Unincorporated County 836 8,019 8,855 2,155
Vista 836 2,106 2,942 381
Region (Totals) 85,842 85,843 171,685 -

Request #2: High Frequency Transit Stop Dataset

One SANDAG Board member requested that staff apply a methodology that uses “high frequency transit stops”
instead of “major transit stops” to calculate the proximity to transit component. The definitions for “high frequency
transit stops” and “major transit stops” are included below.

▪ High Frequency Transit (HFT) Stops: Stops or stations served by high frequency transit as defined as local bus
routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak
commute periods.
▪ Major Transit Stops: The intersection of two or more major local bus routes with a frequency of service interval of
15 minutes or less during the morning and afternoon peak commute periods.
The high frequency transit stops and major transit stops data are included in Table 3 for reference. Table 4 shows an
estimated allocation based on this request.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 22

Considerations
Using high frequency transit stops instead of major transit stops to calculate the proximity to transit component could
meet the objectives in state law, as housing units would be allocated to areas with access to transit. Major transit
stops are recognized in state law as places where development can occur with fewer environmental impacts including
fewer vehicle miles traveled. For these reasons, the use of major transit stops was recommended by both the RHNA
Subcommittee and the Regional Planning Technical Working Group.

Table 3: Transit Data – High Frequency Transit and Major Transit Stops

High Frequency Share of High Major Transit Share of Major

Jurisdiction
Transit Stops Frequency Stops Stops Transit Stops
Carlsbad - - - -
Chula Vista 126 11.07% 18 12.86%
Coronado 29 2.55% - -
Del Mar - - - -
El Cajon 22 1.93% - -
Encinitas - - - -
Escondido - - - -
Imperial Beach 26 2.28% 6 4.29%
La Mesa 7 0.62% - -
Lemon Grove - - - -
National City 78 6.85% 15 10.71%
Oceanside 41 3.60% - -
Poway - - - -
San Diego 789 69.33% 101 72.14%
San Marcos - - - -
Santee - - - -
Solana Beach - - - -
Unincorporated County 9 0.79% - -
Vista 11 0.97% - -
Region (Totals) 1,138 100% 140 100%

Table 4: Estimated Allocation based on Request #2: High Frequency Transit Stops Data Set

Transit Jobs Total Estimated Difference from

Jurisdiction
Weighting: 65% Weighting: 35% Allocation Draft Methodology
Carlsbad 1,087 2,786 3,873 -
Chula Vista 7,980 2,627 10,607 (498)
Coronado 711 1,001 1,712 711
Del Mar - 163 163 -
El Cajon 2,170 1,650 3,820 540
Encinitas 543 1,011 1,554 -
Escondido 7,609 1,998 9,607 -
Imperial Beach 637 179 816 (559)
La Mesa 2,889 1,080 3,969 172
Lemon Grove 1,087 272 1,359 -
National City 2,999 1,361 4,360 (1,077)
Oceanside 4,810 1,639 6,449 1,006
Poway - 1,319 1,319 -
San Diego 73,692 33,423 107,115 (786)
San Marcos 1,630 1,486 3,116 -
Santee 543 676 1,219 -
Solana Beach 543 332 875 -
Unincorporated County 1,308 5,613 6,921 221
Vista 1,357 1,474 2,831 270
Region (Totals) 111,595 60,090 171,685 -

Final 6th Cycle Regional Housing Needs Assessment Methodology | 23

Request #3: Increase Equity Adjustment
A SANDAG Board member requested that staff apply a methodology that intensifies the equity adjustment. The
equity adjustment increases a jurisdiction’s share of its housing allocation in an income category where the jurisdiction
has a smaller share of households in that category than the region and vice versa. A potential application of this
request could apply a 20 percent weighting to the equity adjustment to increase the relative difference between a
jurisdiction’s share and the region’s share, therefore, amplifying the effect.
To demonstrate how an increase to the equity adjustment might be accomplished, a weight of 20 percent was
chosen to intensify the effects of the equity adjustment while still allowing for an allocation that improves the mix,
tenure, and affordability of housing in each jurisdiction, as required in Government Code Section 65584.
Table 5 shows an estimated allocation based on this request, which assigns a weighting of 20 percent to the equity
adjustment.

Considerations
Using a 20 percent weighting to the equity adjustment could meet the objectives in state law. State law objectives for
RHNA include promotion of socioeconomic equity and allocation of a lower proportion of housing need to an income
category when a jurisdiction already has a disproportionately high share of households in that income area compared
to the countywide distribution in that category.

Table 5: Estimated Allocation based on Request #3: Increased Equity Adjustment

Total
Above
Jurisdiction Very Low Low Moderate Estimated
Moderate
Allocation
Carlsbad 1,385 819 793 876 3,873
Chula Vista 1,939 1,858 1,347 5,961 11,105
Coronado 365 195 185 256 1,001
Del Mar 39 65 33 26 163
El Cajon 312 265 505 2,198 3,280
Encinitas 495 386 325 348 1,554
Escondido 1,314 871 1,077 6,345 9,607
Imperial Beach 157 84 128 1,006 1,375
La Mesa 614 344 412 2,427 3,797
Lemon Grove 209 115 136 899 1,359
National City 421 326 463 4,227 5,437
Oceanside 917 513 638 3,375 5,443
Poway 494 280 254 291 1,319
San Diego 29,926 18,619 20,993 38,363 107,901
San Marcos 482 520 538 1,576 3,116
Santee 462 226 142 389 1,219
Solana Beach 334 167 169 205 875
Unincorporated County 2,107 751 1,338 2,504 6,700
Vista 360 223 258 1,720 2,561
Region (Totals) 42,332 26,627 29,734 72,992 171,685

Final 6th Cycle Regional Housing Needs Assessment Methodology | 24

Regional Housing Needs Assessment:
Frequently Asked Questions

1. What data and assumptions did SANDAG rely on in developing the draft RHNA methodology?

SANDAG relied on the data it maintains on jobs, housing and transportation for the region and on data
provided by the jurisdictions, community based organizations, and the public during the many public
meetings it held on the topic of the RHNA Plan. The information relied upon is described in the draft
methodology for the 6th Cycle Regional Housing Needs Assessment (RHNA).

2. Do the RHNA laws require that SANDAG have a public comment period on the draft RHNA
methodology that lasts for a particular number of days?

No. Although prior versions of the RHNA laws contained a particular number of days, the section of the
law that provides for a public comment period (Section 65584.04(d)) no longer requires that the
comment period last for a particular length of time.

3. Why isn’t the breakdown (or allocation) of RHNA units to each city included in the draft
methodology?

Housing law provides two separate approval processes for the methodology and the allocation, which is
why the allocation is not included in the methodology document. Following the Board of Director’s
adoption of a methodology, the draft allocation will be distributed to the jurisdictions consistent with
Section 65584.05.

4. Can SANDAG decide on a number of housing units to allocate to jurisdictions first and then
back into a methodology that results in the predetermined number of units?

No. This is not the way the Legislature designed the RHNA laws. SANDAG is required to determine the
methodology first using the factors and objectives in Sections 65584 and 65584.04. Then, after SANDAG
submits the methodology to the California Department of Housing and Community Development and
adopts the final methodology, SANDAG is required to distribute the allocations to the jurisdictions
pursuant to Section 65584.05. The methodology and allocation procedures are separated into different
statutes with two different review processes. Right now, SANDAG is in the RHNA Plan phase of
determining the methodology, not the allocation.

5. Can SANDAG limit its consideration of suitable housing sites or land suitable for urban
development to existing zoning ordinances and land use restrictions of a locality?

No. See Section 65584.04(e)(2)(B).

6. When developing the methodology can SANDAG consider a jurisdiction’s ordinances, policies,
voter-approved measures or standards that directly or indirectly limits the number of
residential building permits issued?

No. See Section 65584.04(g)(1).

Final 6th Cycle Regional Housing Needs Assessment Methodology | 25

7. Can a jurisdiction’s prior inability to meet its RHNA allocation numbers in a prior RHNA cycle be
taken into consideration when SANDAG is preparing its methodology?

No. See Section 65584.04(g)(2).

8. Can information received by SANDAG from a local government be used as a basis for reducing
the total housing need established for the region?

No. See Section 65584.04(b)(4). The regional housing need (also known as the RHNA Determination) for
the San Diego region is 171,685 housing units. It was determined by the Department of Housing and
Community Development in consultation with SANDAG and cannot be changed. The Board of Directors
voted to accept the HCD RHNA Determination at its June 8, 2018, meeting.

9. Can SANDAG take Federal Emergency Management Agency (FEMA) or Department of Water
Resources information regarding areas subject to flooding into consideration when
determining what land is suitable for urban development?

Yes. See Section 65584.04 (e)(2)(B). SANDAG reviewed FEMA data on flood plains to determine the
acreage of floodplain land areas in each jurisdiction as a share of the jurisdiction’s land acres. The table
below shows the percentage of land acres within a flood plain. With the exception of the cities of
Del Mar and Imperial Beach, the acreage of land at risk of flooding in each jurisdiction makes up less
than ten percent of the jurisdiction’s land acres. Following allocation of housing units, individual
jurisdictions will undergo the process of updating their general plans to accommodate the housing need.
It is during this local planning process that jurisdictions may consider limitations such as risk of flooding
when planning for where housing can be accommodated.

Land Acres in % of Land Acres

Jurisdiction Total Acres Land Acres
Flood Plain in a Flood Plain
Carlsbad 25,028 24,189 1,202 5.0%
Chula Vista 33,354 31,967 1,629 5.1%
Coronado 9,021 5,132 168 3.3%
Del Mar 1,144 1,078 397 36.8%
El Cajon 9,303 9,303 161 1.7%
Encinitas 12,531 12,292 752 6.1%
Escondido 23,971 23,905 714 3.0%
Imperial Beach 2,842 2,797 868 31.0%
La Mesa 5,783 5,783 15 0.3%
Lemon Grove 2,504 2,504 51 2.0%
National City 5,908 4,801 387 8.1%
Oceanside 26,991 26,909 1,339 5.0%
Poway 25,039 25,037 708 2.8%
San Diego 219,200 210,757 15,611 7.4%
San Marcos 15,595 15,595 646 4.1%
Santee 10,686 10,686 539 5.0%
Solana Beach 2,184 2,181 37 1.7%
Unincorporated County 2,283,964 2,276,211 54,183 2.4%
Vista 11,944 11,944 267 2.2%
Region (Totals) 2,726,992 2,703,071 79,674 2.9%

Final 6th Cycle Regional Housing Needs Assessment Methodology | 26

10. Can SANDAG consider factors to develop the methodology that are not specifically listed as
factors in the RHNA laws?

Yes, as long as the factor considered will still further the objectives in Section 65584(d), ; if the additional
factor is unrelated to the objectives in state law, then the Board of Directors must establish that the
additional factor does not undermine the objectives in state law, the factor is applied equally across all
household income levels, and SANDAG can make a finding that the factor it is necessary to address
significant health and safety conditions. See Section 65584.04(e)(12).

11. Can SANDAG take sea level rise into consideration when determining what land is suitable for
urban development?

Sea level rise is not specifically included among the objectives and factors in state law that must be
considered in the development of a RHNA methodology. The Board of Directors, at its discretion, may
pursue sea level rise as a factor pursuant to Government Code Section 65584.04(e)(12). See response to
Question 9.

12. What data and methodology were used to determine the health and safety impacts caused by
increased urban development and traffic/congestion/safety/air quality to the jurisdictions?

The draft methodology does not include this factor and it is not required to do so by RHNA laws;
however, the Board of Directors, at its discretion, may pursue additional factors pursuant to Government
Code Section 65584.04(e)(12). See response to Question 9. SANDAG has included promotion of
achievement of the region’s greenhouse gas reduction target into the draft methodology as required by
Section 65584(d)(5).

13. What data and methodology were used to determine that military housing was not considered
in the equation?

At its July 26, 2019, meeting, the Board of Directors voted to release a draft methodology for public
comment that does not include an adjustment for housed military in the jobs data. The Board’s
deliberations and reasoning can be heard by listening to the audio recording of the meeting (Item 23).

14. What data and methodology were used to determine if the transit system in Coronado would
facilitate shorter commutes considering SANDAG’s regional mass transit plan is not a viable
system that facilitates shorter commutes in and out of Coronado to job sites scattered
throughout the San Diego Region?

The draft methodology uses existing rail & Rapid stations and major transit stops as part of the transit
component. Based on the definitions of these transit services, Coronado does not have any rail, Rapid, or
major transit stops within its boundaries and, therefore, does not receive a housing allocation based on
the transit component.

15. *NEW* How is the equity adjustment calculated?

In calculating the equity adjustment, a jurisdiction’s share of households in an income category is

compared to the region’s share of households in the same income category by determining the relative
difference between the two percentages. The relative difference is found by taking the inverse ratio of a
jurisdiction’s share of households within an income category to the region’s share. See formula below,
with the very low income category as an example.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 27

 = 1/ (Jurisdiction’s Percent of Very Low Households / Regional Percent of Very Low Households)

The relative difference is used as a scaling factor that adjusts the region’s percentage of households in an
income category (e.g. 24.7 percent for very low income) and uses this adjusted percentage as the
jurisdiction’s share of its housing allocation for that income category. Table 5 demonstrates how the
equity adjustment works. In the table, a scaling factor greater than one causes an upward adjustment and
a scaling factor less than one causes a downward adjustment. The percentage being adjusted is the
region’s share of households in the income category, which also is the regional housing allocation for the
income category as determined by HCD. This is included in the top row of Table 1.

The equity adjustment increases a jurisdiction’s share of its housing allocation in an income category if the
jurisdiction has a smaller share of households in that category than the region. Conversely, the adjustment
decreases a jurisdiction’s share of its housing allocation in an income category if the jurisdiction has a
greater share of households in that category than the region. In this way, the equity adjustment seeks to
increase jurisdictions’ mix of housing (housing for each income category) and combat historical patterns of
segregation. Below are two examples of how the equity adjustment in the draft methodology is applied to
the cities of Carlsbad and National City, chosen for comparison purposes.

Example A

In Carlsbad, 16.3 percent of households are very low income. In the region, 24.7 percent of households
are very low income. Carlsbad’s share of very low income households is less than the region’s. This means,
using the equity adjustment in the draft methodology, Carlsbad receives a greater share (greater than
24.7 percent) of its housing unit allocation in the very low income category. In fact, 37.4 percent of
Carlsbad’s housing units are in the very low income category.

Example B

Conversely, 40.6 percent of households in National City are very low income. This is much greater than
the region’s 24.7 percent of households. Therefore, based on the equity adjustment in the draft
methodology, National City receives a smaller share (less than 24.7 percent) of its housing unit allocation
in the very low income category. Only 15 percent of National City’s housing units are in the very low
income category.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 28

Table 1: Equity Adjustment Calculation

RHNA
Determination Very Low 24.7% Low 15.5% Moderate 17.3% Above Moderate 42.5%
Scaling Scaling Scaling Scaling
% % % %
% Factor % Factor % Factor % Factor
Jurisdiction Housing Housing Housing Housing
Households (⬆ or ⬇ Households (⬆ or ⬇ Households (⬆ or ⬇ Households (⬆ or ⬇
Allocation Allocation Allocation Allocation
adjustment) adjustment) adjustment) adjustment)
Carlsbad 16.3% 1.52 ⬆ 37.4% 10.8% 1.43 ⬆ 22.2% 13.8% 1.25 ⬆ 21.7% 59.1% 0.72 ⬇ 30.6%
Chula Vista 25.0% 0.99 ⬇ 24.3% 15.4% 1.01 ⬆ 15.6% 17.5% 0.99 ⬇ 17.1% 42.0% 1.01 ⬆ 43.0%
Coronado 16.8% 1.47 ⬆ 36.3% 12.3% 1.26 ⬆ 19.5% 16.1% 1.08 ⬆ 18.7% 54.9% 0.78 ⬇ 33.0%
Del Mar 19.0% 1.29 ⬆ 31.9% 4.5% 3.44 ⬆ 53.3% 11.0% 1.58 ⬆ 27.3% 65.5% 0.65 ⬇ 27.6%
El Cajon 37.8% 0.65 ⬇ 16.1% 17.5% 0.89 ⬇ 13.8% 17.0% 1.02 ⬆ 17.6% 27.7% 1.53 ⬆ 65.2%
Encinitas 18.1% 1.36 ⬆ 33.6% 9.2% 1.69 ⬆ 26.3% 13.4% 1.29 ⬆ 22.3% 59.3% 0.72 ⬇ 30.5%
Escondido 30.7% 0.80 ⬇ 19.8% 18.2% 0.85 ⬇ 13.2% 18.2% 0.95 ⬇ 16.4% 32.8% 1.29 ⬆ 55.0%
Imperial Beach 31.9% 0.77 ⬇ 19.0% 23.3% 0.67 ⬇ 10.3% 19.1% 0.91 ⬇ 15.7% 25.7% 1.65 ⬆ 70.3%
La Mesa 26.8% 0.92 ⬇ 22.7% 18.8% 0.82 ⬇ 12.8% 19.4% 0.89 ⬇ 15.5% 35.0% 1.21 ⬆ 51.6%
Lemon Grove 27.4% 0.90 ⬇ 22.2% 19.4% 0.80 ⬇ 12.4% 20.4% 0.85 ⬇ 14.7% 32.8% 1.30 ⬆ 55.1%
National City 40.6% 0.61 ⬇ 15.0% 20.6% 0.75 ⬇ 11.7% 17.9% 0.96 ⬇ 16.7% 20.9% 2.04 ⬆ 86.5%
Oceanside 26.3% 0.94 ⬇ 23.1% 18.5% 0.84 ⬇ 13.0% 18.4% 0.94 ⬇ 16.3% 36.9% 1.15 ⬆ 49.0%
Poway 15.3% 1.61 ⬆ 39.7% 10.6% 1.46 ⬆ 22.7% 14.4% 1.20 ⬆ 20.8% 59.6% 0.71 ⬇ 30.3%
San Diego 24.3% 1.02 ⬆ 25.0% 15.4% 1.01 ⬆ 15.7% 16.9% 1.03 ⬆ 17.8% 43.5% 0.98 ⬇ 41.5%
San Marcos 26.5% 0.93 ⬇ 23.0% 14.5% 1.07 ⬆ 16.6% 17.3% 1.00 ⬆ 17.3% 41.8% 1.02 ⬆ 43.3%
Santee 17.9% 1.38 ⬆ 34.0% 14.4% 1.08 ⬆ 16.7% 18.9% 0.92 ⬇ 15.9% 48.8% 0.87 ⬇ 37.0%
Solana Beach 15.4% 1.61 ⬆ 39.6% 12.1% 1.28 ⬆ 19.8% 14.9% 1.17 ⬆ 20.2% 57.7% 0.74 ⬇ 31.4%
Unincorporated
22.5% 1.09 ⬆ 27.0% 16.6% 0.93 ⬇ 14.5% 17.3% 1.00 ⬆ 17.4% 43.6% 0.98 ⬇ 41.5%
County
Vista 29.4% 0.84 ⬇ 20.7% 18.8% 0.83 ⬇ 12.8% 20.0% 0.87 ⬇ 15.0% 31.8% 1.34 ⬆ 56.8%

Final 6th Cycle Regional Housing Needs Assessment Methodology | 29

16. *NEW* How does the draft methodology take into account companion units and new
residential units that have been converted to short term vacation rentals?

The RHNA methodology does not take into account unit types. That is decided by the local jurisdictions
through preparation of the housing element in consultation with HCD following the housing unit
allocations.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 30

Regional Housing Needs Assessment:
Response to Public Comments on Draft Methodology
Public comments on the draft methodology for the 6th Cycle Regional Housing Needs Assessment (RHNA),
received between July 26, 2019, and September 5, 2019, at 3:30 p.m., have been posted online at
sandag.org/rhna. The public comments were uploaded in three sets and can be viewed by following the
direct links below.

View public comments received prior to August 23, 2019, at 5 p.m.

View public comments received between August 23, 2019, at 5:01 p.m. to August 28, 2019, at 5 p.m.
New!: View public comments received between August 28, 2019, at 5:01 p.m. to September 5, 2019, at
3:30 p.m.
The following responses have been prepared to address issues that were common to multiple comment
letters on the draft methodology.
To the extent that members of the public submitted questions in advance of providing public comment,
SANDAG prepared a list of Frequently Asked Questions (FAQs). Some themes arising from public comments
are the same or similar to questions answered in the FAQs. These are repeated here along with a reference to
the response to FAQ as applicable.

Timeline and Public Notice

SANDAG received a few inquiries about the timeline of the RHNA process as it pertains to the public
comment period and review by the California Department of Housing and Community Development (HCD).
State law does not include any time requirements for public participation. State law only requires that a
public hearing be held to solicit input on the draft methodology. The public comment period opened on
July 26, 2019, and was scheduled to close on the day of the public hearing, August 23, 2019. The public
hearing was rescheduled for September 6, 2019, and the public comment period was extended, with the
closing date to coincide with the new public hearing date.
Per SANDAG Board Policy No. 025, SANDAG published notifications for the public hearing in newspapers of
general circulation. Additionally, SANDAG provided public notice online at sandag.org and emailed members
of the Regional Planning Technical Working Group and housing stakeholders. Public notices were published,
and emails sent, for the original as well as the rescheduled public hearing date.

See also the response to FAQ #2.

Population, Geographic Size, and Current Density

SANDAG received various comments that suggest geographic size, population, and/or current density of
jurisdictions be included in the draft methodology.

During the development process, the RHNA Subcommittee (subcommittee of the Board of Directors), the
Regional Planning Technical Working Group (TWG), and other stakeholders evaluated population as a
component of a potential methodology. Ultimately, stakeholders requested that population be removed from
the methodology because it did not specifically further any objectives or factors in state RHNA laws
(Government Code Section 65584 et seq.). Additionally, a jurisdictions’ geographic size was considered and
rejected as a component of the methodology for the same reason. State law does not include population,
geographic size, or density as factors in developing a RHNA methodology.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 31

Instead, state law includes “promoting infill development” and promoting “the encouragement of efficient
development patterns” as an objective (Government Code Section 65584(d)(2)). The draft methodology
prioritizes “proximity to transit” and “proximity to jobs”. By allocating housing units based on transit and
jobs, the draft methodology sets a guiding principle for local jurisdictions to zone and build housing near
transit and jobs. Transit and job centers are located in the urbanized areas of the region. Therefore, the draft
methodology encourages infill development. Because infill development does not rely on available space and
can occur in areas that already have a dense population, the draft methodology supports provision of
housing even in areas that are currently considered built-out.

Available Land
A number of commenters suggested SANDAG consider the availability of land in each jurisdiction. One of the
factors in state law requires that SANDAG consider “the opportunities and constraints to development of
additional housing in each member jurisdiction” including “the availability of land suitable for urban
development or for conversion to residential use, the availability of underutilized land, and opportunities for
infill development and increased residential densities” (Government Code Section 65584.04(e)(2)(b)).
The availability of land suitable for urban development or for conversion to residential use, the availability of
underutilized land, and opportunities for infill development and increased residential densities are accounted
for by the draft methodology’s use of the transit and jobs components. When development of housing is
promoted near transit and jobs, it allows the jurisdictions to focus on infill development that can occur
without reliance on the availability of additional land, but instead on underutilized land that can be converted
to uses that allow for increased residential density.

Existing Zoning
SANDAG received a number of comments stating that a jurisdiction’s existing zoning should be considered in
the draft methodology. State law (Government Code Section 65584.04(e)(2)(B)) prohibits SANDAG from
considering existing zoning in the development of a methodology.
See also the response to FAQ #5.

Military Housing
SANDAG received several comments about how military jobs and housing are considered in the draft
methodology. At the July 26, 2019, Board meeting, staff presented a methodology recommended by the
RHNA Subcommittee that included an adjustment for housed military in the jobs data. Ultimately, however,
the Board voted to release a draft methodology for public comment that does not include an adjustment for
housed military in the jobs data. The Board’s deliberations and reasoning can be heard by listening to the
audio recording of the meeting.
See also the response to FAQ #13.
SANDAG also received comments suggesting the military build housing on their installations. A representative
from the Department of Defense sits on the Board and will have the opportunity to review public comments
and provide input on the draft RHNA methodology. The military, however, is not subject to the RHNA laws.

Tribes
SANDAG received a comment stating that the methodology does not account for tribes on tribal land. Tribal
land is not subject to the RHNA laws.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 32

Traffic, Congestion, and Parking
A number of commenters cited traffic, congestion, and parking as issues in their communities and expressed
concern that these issues will be exacerbated with additional housing. Impact on traffic and parking is not
included among the objectives and factors in state law that must be considered in the development of a
RHNA methodology. Improving the relationship between jobs and housing and maximizing use of public
transit as well as reducing greenhouse gas emission are objectives in state law. The RHNA Subcommittee
sought to prioritize these objectives, which led to the development of the transit and jobs components in the
draft methodology.
By prioritizing jobs and transit, the draft methodology encourages the development of housing near jobs and
transit. Co-location of housing, jobs, and transit will provide the region’s residents with opportunities to live
where they work and/or readily access transit, which can facilitate shorter commutes, reduce vehicle miles
traveled, and increase trip-taking by transit or alternative modes. With more housing and mobility options,
traffic and parking demands may change.

Community Character
A number of commenters also stated additional housing jeopardizes the character of their community.
Community character is not included among the objectives and factors in state law that must be considered
in the development of a RHNA methodology. Following allocation of housing units, individual jurisdictions
will undergo the process of updating their general plans to accommodate the housing need. It is during this
local planning process that jurisdictions may consider community characteristics when planning for housing.

Infrastructure and Local Resources

SANDAG received comments referencing aging infrastructure and expressing concerns about the impact of
additional housing on local resources such as roads; water services; fire, police, and other public safety
services; and schools. With the exception of water and sewer services, the objectives and factors in state law
do not include infrastructure and local resources as considerations in developing a methodology.
State law (Government Code Section 65584.04(e)(2)(a)) requires SANDAG to consider “lack of capacity for
sewer or water service.” SANDAG notes that general plans for some jurisdictions may account for constraints
to housing development arising from lack of capacity for sewer or water service. For example, rural areas may
rely more heavily on well water and septic systems, which constrains housing development due to lack of
sufficient infrastructure. The draft methodology would allocate housing units based on transit and jobs,
which are predominately located in the region’s urbanized area. (All rail and Rapid stations and major transit
stops are located in the urbanized area.) By prioritizing transit connectivity and an improved jobs-housing
relationship, the draft methodology encourages infill development in urban areas that are likely to have
existing capacity for sewer or water service.
Following the allocation of housing units, individual jurisdictions will undergo the process of updating their
general plans to accommodate the housing need. It is during this local planning process that jurisdictions may
consider infrastructure and local resources when planning for housing.

Exempt California Counties

A number of commenters stated that other counties in California are exempt from the RHNA process and
that, because these counties are exempt, the number of housing units the San Diego region must plan for is
higher.
All counties and cities in California are subject to RHNA. There are no counties or cities that are exempt. In
fact, state law requires that every city and county receive housing units in each of the four income categories:
low, very low, moderate, and above moderate.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 33

The HCD performs a housing needs assessment for every region in the state and provides each with a RHNA
Determination – the number of housing units the region must plan for to address current and projected
housing need. HCD determines a region’s housing need by considering its projected population and
household growth, existing vacancy rates and overcrowding, housing replacement needs, and other data.
Housing need is determined region by region. One region’s housing need is independent from the housing
need of other regions in the state.
Comments about exemptions may have relied on misinformation about housing legislation proposed during
the 2019 California state legislative session. The California Legislature introduced numerous bills seeking to
address the housing crisis through various avenues including rent control, tenant protections, developer
incentives, and zoning densities. For example, Senate Bill (SB) 50 proposed increasing zoning densities around
high-frequency transit. The bill underwent numerous revisions as it made its way through various state
legislative committees. Ultimately, however, the vote on SB 50 was postponed to 2020, and is not currently
in state law.
These comments also may have relied on misinformation about SB 106, passed in 2017. State law
(Government Code Section 65583.2(c)) makes a distinction between jurisdictions in a census-defined
metropolitan statistical area (MSA) and those in suburban counties when considering appropriate densities
for affordable housing. Jurisdictions in an MSA must accommodate lower income housing by zoning at a
density of 30 units or more per acre. Jurisdictions in a suburban county must accommodate lower income
housing by zoning at a density of 20 units or more per acre. Marin County is within the San Francisco-
Alameda MSA. SB 106 recognizes Marin as a suburban county for the purposes of developing affordable
housing. Marin, like all other counties and cities in California, is subject to the RHNA process and receives a
RHNA Determination from HCD. SB 106 allows Marin County to zone for the affordable housing allocated in
its RHNA Determination at a lower density than jurisdictions in an MSA.

Transit Service Area

SANDAG received a comment suggesting that SANDAG take into consideration the broader population and
geographic area served by transit stations within the draft methodology. SANDAG recognizes that mobility
hub areas include not just the transit station itself but all those services and destinations that are accessible
within a 5-minute walk, bike, or drive to/from high-frequency transit. The distance of a 5-minute drive can be
much greater than a 5-minute walk or bike, extending the reach and access to transit. Housing proximate to
transit, however, increases access to transit by modes other than driving, which helps relieve traffic
congestion and reduce greenhouse gas emissions. The transit component of the draft methodology furthers
both the objectives in state law and the priorities of the RHNA Subcommittee to maximize use of public
transit and reduce greenhouse gas emissions by encouraging transit-oriented development.

Environmental Concerns
SANDAG received comments suggesting the draft methodology account for “the environmental factors that
the Coastal Commission will need to assess before coastal regions are further developed.” To the extent that
state law (Government Code Section 65584.04(e)(2)(B)) allows SANDAG to consider lands at high risk for
flooding when determining the suitability of land available for urban development, SANDAG reviewed flood
plain maps by the Federal Emergency Management Agency. See response to FAQ #9.
State law requires SANDAG to allocate housing units to jurisdictions in the region based on a methodology
that furthers state law and objectives. This process, and the methodology, does not dictate where within a
jurisdiction these housing units are to be located. Following allocation of housing units, individual jurisdictions
will undergo the process of updating their general plans to accommodate the housing need. It is during this
local planning process that jurisdictions may consider environmental factors such as those affecting coastal
zones.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 34

Market Forces and Historic Building Patterns
SANDAG received comments that the draft methodology should account for market forces and the fact the
region has not met its RHNA goals from the 5th Cycle. Market forces are not included among the objectives
and factors in state law as a consideration in the development of a RHNA methodology. Additionally, state
law (Government Code Section 65584.04(g)(2)) prohibits SANDAG from determining or reducing a
jurisdiction’s housing unit allocation based on underproduction in previous RHNA cycles.
Public Safety
A number of public commenters expressed concerns about the impact of additional housing on public safety,
including the event of a natural disaster or other states of emergency. The Board, at its discretion, may
pursue an additional factor that takes this potential impact into consideration as long as it can be established
that the factor is necessary to further an objective in state law; if the additional factor is unrelated to the
objectives in state law, then it must be established that it does not undermine the objectives in state law, it
will apply equally across all household income levels, and it is necessary to address significant health and
safety concerns. See Section 65584.04(e)(12). See also the response to FAQ #10.

New!
The following responses are new since the last publication of this document on August 28, 2019.

Major Transit Stops and Vehicle Miles Traveled

SANDAG received several comments about “major transit stops” as a part of the transit component in the
draft methodology. Comments state that switching from the “high frequency transit” definition – considered
at one point in the development of the methodology – to the “major transit stops” definition resulted in
fewer jurisdictions receiving housing units based on this specific transit subcomponent. Comments varied in
identifying areas and/or subpopulations this result disproportionately burdened (e.g. communities south of
Interstate 8, low-income communities, etc.). Another comment specifically stated that the change in
definitions will result in increased vehicle miles traveled.
These comments are addressed within the supplemental information SANDAG provided based on requests
from Board members at the July 26, 2019, Board meeting. The response to Request #2 addresses a potential
application of using the high frequency transit stop definition and dataset.
5th Cycle Housing Unit Allocation
A number of commenters referenced the housing unit allocations made to jurisdictions through the 5th Cycle
RHNA process (2010-2020 planning period) and compared these housing unit allocations to those estimated
for the 6th Cycle (2021-2029 planning period) based on the draft methodology. Comments expressed
concern about disproportionate increases/decreases in housing unit allocations among jurisdictions from the
5th Cycle to the 6th Cycle.
When SANDAG staff solicited input from the Board on an approach for the methodology in September 2018,
the Board expressed a desire to take a different approach than the previous 5th Cycle RHNA Methodology by
not relying on existing housing capacities as a starting point. The draft methodology released by the Board
for public comment on July 26, 2019, prioritizes proximity to transit and jobs and furthers the objectives in
state law.
Housing unit allocations from previous RHNA cycles are not included among the objectives and factors in
state law that must be considered in the development of a RHNA methodology. Each RHNA cycle is
independent from the previous cycle. In fact, Government Code Section 65584.04(g) states that neither

Final 6th Cycle Regional Housing Needs Assessment Methodology | 35

stable population numbers from a previous cycle, nor prior underproduction of housing, may be considered
in determining a jurisdiction’s share of the regional housing need.

Equity Adjustment
SANDAG received several comments regarding the equity adjustment in the draft methodology. One
comment suggested that jurisdictions that have a greater or an over-concentration of lower income
households receive zero housing units in the low and very-low income category. This would be contrary to
state law which requires that each jurisdiction receive housing units in the low and very-low income
categories. (See Government Code Section 65584.04(m)(2)).
Other comments indicated that the equity adjustment does not go far enough in addressing the state
objective (Objective #4) to allocate 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. These
comments are addressed within the supplemental information SANDAG provided based on requests from
Board members at the July 26, 2019, Board meeting. The response to Request #3 addresses a potential
application of intensifying the equity adjustment.
A specific comment suggested the equity adjustment be modified to redistribute units among jurisdictions
rather than adjust the proportion of units in each income category per jurisdiction. The RHNA Subcommittee
and TWG prioritized transit and jobs as the basis of distributing the region’s total housing need determined
by HCD. The equity adjustment addresses Objective #4 which requires that a RHNA plan allocate 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 as compared to the region. A detailed description of how the
equity adjustment is calculated and applied is included in the response to FAQ #15.
Fair Housing
SANDAG received a few comments inquiring how the state objective of “affirmatively furthering fair
housing” (Objective #5) is being met through the draft methodology. Per Government Section 65584.04(d),
SANDAG provided a description of how the draft methodology furthers the objectives in state law, which is
available online.
Jobs-Housing Ratio
SANDAG received a few comments suggesting SANDAG incorporate each jurisdiction’s jobs-housing ratio
(sometimes referred to as jobs-housing balance) in the draft methodology. A jobs-housing ratio represents
the relationship between the total number of jobs and total number of housing units within a given
jurisdiction. SANDAG calculated the jobs-housing ratio for each jurisdiction and provided this information to
stakeholders through outreach. Ultimately, however, the RHNA Subcommittee and TWG supported a
methodology that did not incorporate a jobs-housing ratio.

Final 6th Cycle Regional Housing Needs Assessment Methodology | 36

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM., Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Ave
Sacramento, CA 95833-1829
916) 263-2911 FAX: (916) 263-7453
www.hcd.ca.gov

November 1, 2019

Hasan Ikharta, Executive Director

San Diego Association of Governments
401 B Street, Suite 800
San Diego, CA 92101-4231

Dear Director Ikharta:

RE: Review of Draft Regional Housing Need Allocation (RHNA) Methodology

Thank you for submitting the draft San Diego Association of Governments (SANDAG)
Sixth Cycle Regional Housing Need Allocation (RHNA) Methodology. Pursuant to
Government Code Section 65584.04(i), the California Department of Housing and
Community Development (HCD) is required to review draft RHNA methodology to
determine whether the methodology furthers the statutory objectives described
Government Code Section 65584(d).

The draft SANDAG methodology uses jobs and transit to set the overall RHNA number
for a city and uses an equity adjustment to adjust for income distribution among the sub-
categories of RHNA by income. HCD has completed its review and finds that the draft
SANDAG RHNA Methodology furthers the five statutory objectives of RHNA. 1

Below is a brief summary of findings related to each statutory objective described within
Government Code Section 65584(d):

1. Increasing the housing supply and the mix of housing types, tenure, and affordability in
all cities and counties within the region in an equitable manner, which shall result in each
jurisdiction receiving an allocation of units for low- and very low-income households.

HCD’s analysis shows that this methodology generally allocates more lower income
RHNA in jurisdictions with more single-family homes, which will encourage higher density
planning in these jurisdictions and a mix of housing types. Also, in support of the
affordability objective, the draft methodology allocates more lower income RHNA in more
costly areas of the region.

2. Promoting infill development and socioeconomic equity, the protection of environmental

and agricultural resources, the encouragement of efficient development patterns, and the
achievement of the region’s greenhouse gas reductions targets provided by the State Air
Resources Board pursuant to Section 65080.

The draft allocation furthers the infill and environmental principles of this objective, as the
overall allocation is based on the location of jobs and transit access. Particularly relevant
to supporting infill development and climate change goals is the fact that this methodology

1 While HCD finds that this methodology furthers the objectives of RHNA, HCD's determination may change in
regards to a different region or cycle, as housing conditions in those circumstances may differ.
Final 6th Cycle Regional Housing Needs Assessment Methodology | 37
 (continued from previous page)
does not consider land capacity or vacant land as a determinant of RHNA, and instead
focuses on where housing is needed to encourage transit ridership and reduced
commutes.

3. Promoting an improved intraregional relationship between jobs and housing, including

an improved balance between the number of low-wage jobs and the number of housing
units affordable to low-wage workers in each jurisdiction.

Overall jobs, rather than low-wage jobs, are included as a factor in the methodology, but
further analysis shows that using overall jobs combined with the equity adjustment in the
methodology leads to a strong overlap between low-wage jobs and lower income RHNA
as a percentage of the region’s lower income RHNA.

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, as
compared to the countywide distribution of households in that category from the most
recent American Community Survey.

This objective is furthered directly by the equity adjustment included in the draft
methodology. The SANDAG equity adjustment provides an upward adjustment toward the
regional average for jurisdictions that have a lower percentage of households in a given
income category compared to the region. While the equity adjustment explicitly responds
to objective four, it also assists in the methodology furthering each of the other objectives.

5. Affirmatively furthering fair housing, which means taking meaningful actions, in addition
to combating discrimination, that overcome patterns of segregation and foster inclusive
communities free from barriers that restrict access to opportunity based on protected
characteristics. Specifically, affirmatively furthering fair housing means taking meaningful
actions that, taken together, address significant disparities in housing needs and in
access to opportunity, replacing segregated living patterns with truly integrated and
balanced living patterns, transforming racially and ethnically concentrated areas of
poverty into areas of opportunity, and fostering and maintaining compliance with civil
rights and fair housing laws.

To evaluate this objective HCD used the 2019 HCD/TCAC Opportunity Maps, 2 which
evaluate access to opportunity, racial segregation, and concentrated poverty on 11
dimensions, which are all evidence-based indicators related to long term life outcomes.
The six jurisdictions that would receive the highest percentage of lower income RHNA
under this methodology are also the jurisdictions that have no segregated concentrated
areas of poverty or lowest resource census tracts, and compared to other jurisdictions in
the region have the highest percentage of area in high or highest resource census tracts
(76-100% of the jurisdiction). Conversely, the jurisdictions with large amounts of area in
low resource census tracts or census tracts that demonstrate high segregation and
concentrations of poverty generally receive less lower income RHNA than the regional
average.

2
Created by the California Fair Housing Task Force and commissioned by HCD and the California Tax Credit
Allocation Committee (TCAC) to assist public entities in affirmatively furthering fair housing. The version used in
this analysis is the 2019 HCD/TCAC OpportunityFinal
Maps6thavailable at treasurer.ca.gov/ctcac/opportunity.asp.
Cycle Regional Housing Needs Assessment Methodology | 38
HCD appreciates the active role of SANDAG staff in providing data and input
throughout the draft methodology development and review period, as well as
developing a methodology that is clear and transparent. HCD especially thanks
Seth Litchney and Coleen Clementson for their significant efforts and
assistance.

Public participation in the development and implementation of the RHNA

process is essential to effective housing planning. HCD applauds SANDAG on
its efforts to date and the region should continue to engage the community,
including organizations that represent lower-income and special needs
households, by making information regularly available while considering and
incorporating comments where appropriate.

HCD looks forward to continuing our partnership with SANDAG to assist its
member jurisdictions meet and exceed the planning and production of the
region’s housing need.

Just a few of the support opportunities available for the SANDAG region this
cycle include:
• SB 2 Planning Grants and Technical Assistance (Available now,
application deadline November 30, 2019, technical assistance available
now through June 2021)
• Regional and Local Early Action Planning Grants (25% of Regional
funds available now, all other funds available early 2020)
• SB 2 Permanent Local Housing Allocation (Available April – July 2020)

If HCD can provide any additional assistance, or if you, or your staff, have any
questions, please contact Megan Kirkeby, Assistant Deputy Director for Fair
Housing, [email protected].

Megan Kirkeby
Assistant Deputy Director for Fair Housing

Final 6th Cycle Regional Housing Needs Assessment Methodology | 39