RHNA vs. Reality: What Counts as a Housing Unit?

Downtown Chula VistaThis article is the first in a series examining how the Regional Housing Needs Allocation (RHNA) works – and doesn’t work – to guide housing production and meet the needs of the people living in and moving into the community.  In this first installment, we’ll look at the basic nuts and bolts of RHNA and explain why housing being built in the City of Chula Vista won’t count toward satisfying the city’s RHNA assessment.

The Basics of RHNA

Known in the housing industry as RHNA, the Regional Housing Needs Allocation is a housing assessment produced by the State of California’s Housing and Community Development Department (HCD) in conjunction with each local Council of Governments. HCD uses the U.S. Department of Housing and Urban Development’s (HUD) median family income estimates to calculate California’s Area Median Income (AMI) levels, which are then used to determine applicants’ eligibility for federal housing programs.  Each local Council of Governments (COG) then provides HCD with data on the population, household size, demographics, vacancy rates, and the balance or imbalance between jobs and housing.  HCD uses the data to determine how many units of housing at each income level each jurisdiction needs to meet local demand for housing.

What Counts as a Dwelling Unit?

In reality, staff in jurisdictions are not always familiar with what will and will not qualify as a dwelling unit under RHNA.  Recently, the City of Chula Vista agreed to allow developer Baldwin and Sons to build 100 dormitory rooms to fulfill its inclusionary housing requirements. Inclusionary housing or zoning laws require that a share of new construction is affordable to people with low to moderate incomes.  The city considered the dorm units, which will serve Olympic athletes in training, to be “affordable housing” because it’s generally understood that elite athletes tend to have lower incomes unless they are among the few that are sponsored.  To this end, the Chula Vista City Council amended its definition of affordable housing so that the dorm rooms would qualify.

Unfortunately for Chula Vista, HCD’s definition of a “housing unit” does not include dorm rooms, even if they house low-income residents once they are built.  Therefore, the construction of the dormitory does not count toward satisfying the City’s RHNA requirements.

This begs the question: Is RHNA broken?  We’ll answer this question and others with our next installment, which will explore Senator Weiner’s newly introduced bill, SB 828: Fixing RHNA.

Artemis Spyridonidis covers housing policy issues, including structural solutions to the housing affordability crisis, consolidated plans, housing elements, accessory dwelling unit policy implementation, and regional issues across the state of California. To learn more about LDC’s policy services, contact Artemis Spyridonidis, Senior Associate, at artemis@lesardevelopment.com.