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HomeMy WebLinkAbout5b_Attachment 2 - Orange County Mayor's Letter to the Southern California Council of Governments (SCAG)Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) The Honorable Rex Richardson, RE: Reconvene the SCAG President’s RHNA Litigation Study Team September 18, 2020 Page 2 of 5 1) consider this and other new information from credible agencies; 2) justify how its 1.34 million housing unit determination is defensible in light of the new information and should be fittingly revised; and, 3) justify how its 1.34 million housing unit determination is consistent with State Statute provisions. A prompt assessment of this information, and options to pursue resolution with State HCD, would be invaluable and timely to SCAG’s member agencies, many of which are currently exploring appeals of their individual RHNA allocations. Moreover, if the SCAG President’s RHNA Litigation Study Team is reconvened, we would strongly urge SCAG to revisit the critical issue that State HCD did not follow housing statute, when it determined SCAG’s 1.34 million housing units need. We appreciate that SCAG raised this concern to State HCD. W e object, however, that State HCD has chosen to not adhere to the provisions of our Government Code, and we have provided a detailed, technical assessment of such noncompliance in Attachment 2. We thus respectfully seek your support and follow-through of your verbal commitment to Council Member Huang, that the President’s RHNA Litigation Study Team be re convened to undertake this important discussion. We look forward to your response, with the desire that the RHNA Litigation Study Team be reconvened prior to the next SCAG Regional Council meeting, October 1, 2020. With sincere respect and appreciation, Mike Munzing Harry Sidhu Mayor Mayor City of Aliso Viejo City of Anaheim Marty Simonoff Fred Smith Mayor Mayor City of Brea City of Buena Park Katrina Foley Rob Johnson Mayor Mayor City of Costa Mesa City of Cypress Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) The Honorable Rex Richardson, RE: Reconvene the SCAG President’s RHNA Litigation Study Team September 18, 2020 Page 3 of 5 Cheryl Brothers Jennifer Fitzgerald Mayor Mayor City of Fountain Valley City of Fullerton Steven R. Jones Lyn Semeta Mayor Mayor City of Garden Grove City of Huntington Beach Christina Shea Tom Beamish Mayor Mayor City of Irvine City of La Habra Peter Kim Bob Whalen Mayor Mayor City of La Palma City of Laguna Beach Janine Heft Laurie Davies Mayor Mayor City of Laguna Hills City of Laguna Niguel Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) The Honorable Rex Richardson, RE: Reconvene the SCAG President’s RHNA Litigation Study Team September 18, 2020 Page 4 of 5 Noel Hatch Neeki Moatazedi Mayor Mayor City of Laguna Woods City of Lake Forest Richard D. Murphy Brian Goodell Mayor Mayor City of Los Alamitos City of Mission Viejo Will O’Neill Mark A. Murphy Mayor Mayor City of Newport Beach City of Orange Ward Smith Bradley J. McGirr Mayor Mayor City of Placentia City of Rancho Santa Margarita Troy Bourne Miguel A. Pulido Mayor Mayor City of San Juan Capistrano City of Santa Ana Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) The Honorable Rex Richardson, RE: Reconvene the SCAG President’s RHNA Litigation Study Team September 18, 2020 Page 5 of 5 Schelly Sustarsic David J. Shawver Mayor Mayor City of Seal Beach City of Stanton Allan Bernstein Robbie Pitts Mayor Mayor City of Tustin City of Villa Park Tri Ta Beth Haney Mayor Mayor City of Westminster City of Yorba Linda Attachments: 1. Freddie Mac Economic and Housing Research Insight: February 2020 2. Orange County Technical Analysis: State Government Code Requirements to Calculate Regional Housing Need 3. Embarcadero Institute Report: Updated September 2020 cc: Council Member Peggy Huang, City of Yorba Linda and SCAG RHNA Subcommittee Chair Council Member Trevor O’Neil, Chair, OCCOG Board of Directors Council Member Wendy Bucknum, Vice-Chair, OCCOG Board of Directors Mayor Pro Tem Michael Carroll, OC Representative SCAG's RHNA Litigation Study Team Orange County Representatives on SCAG Policy Committees and Regional Council Kome Ajise, SCAG Executive Director Orange County City Managers Association Orange County Mayors Marnie O’Brien Primmer, OCCOG Executive Director Nate Farnsworth, OCCOG TAC Chair Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Orange County Technical Analysis of SCAG’s Regional Determination from HCD Government Code Section 65584.01(a) states: “If the total regional population forecast for the projection year, developed by the council of governments and used for the preparation of the regional transportation plan, is within a range of 1.5 percent of the total regional population forecast for the projection year by the Department of Finance, then the population forecast developed by the council of governments shall be the basis from which the department determines the existing and projected need for housing in the region….”. As outlined in SCAG’s September 18, 2019 objection letter to the California Department of Housing and Community Development (HCD) (see Exhibit B), SCAG’s regional population forecast for its Regional Transportation Plan (RTP) differs from the State Department of Finance (DOF) projection by 1.32%, which falls within the statutory range of 1.5% outlined in state law. Therefore, by statute, the regional determination should be based on SCAG’s population projections. However, HCD’s October 15, 2019 response letter to SCAG (see Exhibit C) cites two reasons for not using SCAG’s total regional population forecast: 1)The total household projection from SCAG is 1.96% lower than DOF’s household projection. 2)The age cohort of under 15-year old persons from SCAG’s population projections differ from DOF’s projections by 15.8%. A careful reading of Government Code Section 65584.01(a) demonstrates that HCD’s interpretation and rejection of the use of SCAG’s regional population forecast is incorrect for the following two reasons: 1)The law clearly states that that the 1.5% range is based on the total regional population forecast and not the regional household projection forecast. 2)The law clearly states that the 1.5% range is based on the total regional population forecast and not on age-cohort population forecasts. While Government Code 65584.01 provides a significant level of discretion to HCD over many of the factors used for the regional determination (i.e., vacancy adjustments, overcrowding rates, replacement adjustments, cost-burdened adjustments, etc.), this one issue is clearly written into the law without any discretion from HCD. Therefore, even though we support all of the arguments SCAG outlined in their September 18, 2019 objection letter, we also recognize that state law grants HCD the final determination for those specific factors. However, there is no discretion in HCD’s decision to ignore SCAG’s regional population forecast. Had HCD adhered to Government Code 65584.01(a), we estimate that the regional determination should have been at least approximately 133,000 housing units lower (see Exhibit A), or no more than approximately 1.2 million housing units. We would hope that HCD would reconsider the other SCAG’s recommendations as noted in their September 18, 2020 objection letter, especially in light of the change in circumstances related to the current COVID-19 pandemic, as well as the recent studies and reports stating that California’s statewide housing shortfall is significantly lower than even SCAG’s entire RHNA obligation. ATTACHMENT 2 Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Exhibit A OPTION A: SCAG region housing needs, June 30 2021-October 1 2029 (8.25 Years) 1 Population: Oct 1, 2029 (SCAG 2020 RTP/SCS Forecast) 20,725,878 2 - Less Group Quarters Population (SCAG 2020 RTP/SCS Forecast) -327,879 3 Household (HH) Population, Oct 1, 2029 20,397,998 SCAG Projected HH Population Headship rate - see Table 2 Projected Households Household Formation Groups 20,397,998 6,668,498 under 15 years 3,812,391 n/a 15 - 24 years 2,642,548 147,005 25 - 34 years 2,847,526 864,349 35 - 44 years 2,821,442 1,304,658 45 - 54 years 2,450,776 1,243,288 55 - 64 years 2,182,421 1,116,479 65 -74 years 1,883,181 1,015,576 75 - 84 years 1,167,232 637,415 85+ 590,480 339,727 4 Projected Households (Occupied Unit Stock) 6,668,498 5 + Vacancy Adjustment (2.63%) 178,896 6 + Overcrowding (6.76%)459,917 7 + Replacement Adjustment (0.50%)34,010 8 - Occupied Units (HHs) estimated June 30, 2021 (from DOF data)-6,250,261 9 + Cost-burden Adjustment ((Lower Income: 10.63%, Moderate and Above Moderate Income: 9.28%)117,505 6th Cycle Regional Housing Need Assessment (RHNA) 1,208,565 EXHIBIT A Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) September 18, 2019 Mr. Doug McCauley Acting Director Housing & Community Development (HCD) 2020 W. El Camino Ave. Sacramento, CA 95833 Subject: SCAG’s Objection to HCD’s Regional Housing Need Determination Dear Mr. McCauley, This letter represents the Southern California Association of Governments (SCAG)’s formal objection to HCD’s Regional Housing Need Determination as submitted to SCAG on August 22, 2019 and is made in accordance with Government Code Section 65584.01(c)(2)(A) and (B). At the outset, please know that SCAG is fully aware that the State of California is in the midst of a housing crisis and that resolving this crisis requires strong partnerships with state, regional and local entities in addition to private and non-profit sectors. As such, SCAG desires to be an active and constructive partner with the State and HCD on solving our current housing crisis, and this objection should not suggest otherwise. We are in fact currently setting up a housing program that will assist our local jurisdictions on activities and policies that will lead to actual housing unit construction. In the context of the 6th cycle Regional Housing Needs Assessment (RHNA) process, SCAG appreciates the collaboration with HCD as reflected in the numerous consultation sessions on the regional determination and other staff engagement on housing issues with the objective of making RHNA a meaningful step toward addressing our housing crisis. As you are aware, HCD transmitted its Regional Housing Needs Determination of 1,344,740 units for the SCAG region last month. This number reflects the housing units that local jurisdictions in the region must plan for during the 8-year period from October 2021 to October 2029. At the September 5, 2019 meeting, SCAG Regional Council authorized staff to file an objection to HCD on regional housing need determination pursuant to Government Code Section 65584.01(c). EXHIBIT B Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) I would like to note that SCAG’s objection focuses on the process and adherence to state housing law requirements and not necessarily to the regional housing need determination number. The ultimate aim of this objection, as discussed at length by the Regional Council, is to ensure the most technically and legally credible basis for a regional determination so that the 197 local jurisdictions in the SCAG region can approach the difficult task of zoning to accommodate regional needs with the backing of the most robust and realistic target that is possible. One of our major concerns is that HCD did not base its determination on SCAG’s RTP/SCS Growth Forecast, which was inconsistent with Government Code 65584.01(c)(2)(A). Another major concern is that pursuant to Government Code 65584.01(c) (2) (B), HCD’s determination of housing need in the SCAG region is not a reasonable application of the methodology and assumptions described in statute. Specifically, HCD compared household overcrowding and cost- burden rates in the SCAG region to national averages rather than to rates in comparable regions as statutorily required. These and two additional basis for objections are described in detail in the section below which also includes a deduction for household growth on tribal land and a concern that the vacancy rate standards used by HCD are not substantiated by data, analysis, or literature. In addition, the attached EXCEL worksheet and technical documentation contain SCAG’s alternative proposed 6th cycle RHNA determination, which would consist of a range of total housing unit need between 823,808 and 920,772. BASIS FOR SCAG OBJECTION Use of SCAG’s Population Forecast HCD did not base its determination on SCAG’s RTP/SCS Growth Forecast, which was provided in the original consultation package and via follow-up email to HCD. Government Code 65584.01(a) indicates [emphasis added]: “(a) The department’s determination shall be based upon population projections produced by the Department of Finance and regional population forecasts used in preparing regional transportation plans, in consultation with each council of governments. If the total regional population forecast for the projection year, developed by the council of governments and used for the preparation of the regional transportation plan, is within a range of 1.5 percent of the total regional population forecast for the projection year by the Department of Finance, then the population forecast developed by the council of governments shall be the basis from which the department determines the existing and projected need for housing in the region. If the difference between the total population projected by the council of governments and the total population projected for the region by the Department of Finance is greater than 1.5 percent, then the department and the council of governments shall meet to discuss variances in methodology used for population projections and seek agreement on a population projection for the region to be used as a basis for determining the existing and projected housing need for the region. If no agreement is reached, then the population projection for the region shall be the population projection for the region prepared by the Department of Finance as may be modified by the department as a result of discussions with the council of governments.” Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) SCAG projects total regional population to grow to 20,725,878 by October, 2029. SCAG’s projection differs from Department of Finance (DOF) projection of 20,689,591, which was issued by DOF in May, 2018, by 0.18%. The total population provided in HCD’s determination is 20,455,355, reflecting an updated DOF projection, differs from SCAG’s projection by 1.32%. As SCAG’s total projection is within the statutory tolerance of 1.5%, accordingly HCD is to use SCAG’s population forecast. While HCD has emphasized that consistency in approach to the 6th cycle RHNA across regions is a priority, deference to the Council of Governments’ forecast as specified in statute is an important aspect of regional planning. Federal requirements for SCAG’s Regional Transportation Plan necessitate a forecast of population, households, and employment for evaluating future land use patterns and measuring future travel demand as well as air quality conformity under the federal Clean Air Act. In addition, under SB 375, the State requires SCAG to develop a Sustainable Communities Strategy which is a coordination of transportation and land use in the regional planning process to achieve State’s climate goals. Both federal and State requirements are predicated on SCAG’s forecast of population, households and employment. As a result, SCAG has a long-established and well-respected process for producing a balanced forecast of population, households, and employment for the region, the details of which can be found in each Regional Transportation Plan (e.g. http://scagrtpscs.net/Documents/2016/final/f2016RTPSCS_DemographicsGrowthForecast.pdf). SCAG’s quadrennial growth forecast begins with a consensus on appropriate assumptions of fertility, migration, immigration, household formation, and job growth by a panel of state and regional experts including members of DOF’s Demographic Research Unit. In addition, SCAG co-hosts an annual demographic workshop with the University of Southern California to keep state and regional experts and stakeholders appraised of demographic and economic trends (https://www.scag.ca.gov/calendar/Pages/DemographicWorkshop.aspx). SCAG places a high priority on generating its own forecasts of population, households, and employment and ensuring the highest possible degree of consistency and integrity of its projections for transportation, land use, and housing planning purposes. Use of Comparable Regions Pursuant to Government Code 65584.01(c)(2)(B), HCD’s determination of housing need in the SCAG region is not a reasonable application of the methodology and assumptions described in statute. Specifically, HCD compared household overcrowding and cost-burden rates in the SCAG region to national averages rather than to rates in comparable regions as statutorily required. SCAG’s initial consultation package provided an approach using comparable regions to evaluate household overcrowding SCAG staff met with HCD staff in-person in both Los Angeles and Sacramento to discuss adjustment criteria and how to define a comparable region to Southern California, as our region’s size precludes a straightforward comparison. At the direction of HCD, SCAG staff refined its methodology for identifying comparable regions and provided a state-of- the-practice analysis supported by recent demographic and economic literature which determined Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) that the most appropriate comparison to the SCAG region would be an evaluation against the San Jose, New York, San Francisco, Miami, Seattle, Chicago, San Diego, Washington D.C., Houston, and Dallas metropolitan areas. Despite this collaboration on the subject between HCD and SCAG, HCD elected to reject this approach and instead used national average statistics, which include small metropolitan areas and rural areas having little in common with Southern California. HCD’s choice to use national averages:  Is inconsistent with the statutory language of SB 828, which added the comparable region standard to RHNA law in order to improve the technical robustness of measures of housing need.  Is inconsistent with empirical data as economic and demographic characteristics differ dramatically based on regional size and context. For comparison, the median-sized metropolitan region in the country is Fargo, North Dakota with a population of 207,500. That is not a meaningful basis of comparison for the nation’s largest MPO.  Is inconsistent with HCD’s own internal practice for the 6th cycle of RHNA. The regional need determination for the Sacramento Area Council of Governments (SACOG), issued on July 18, 2019, was the first 6th cycle RHNA determination following SB 828’s inclusion of the comparable region standard. During their consultation process with HCD, SACOG also produced a robust technical analysis to identify comparable regions for the purposes of using overcrowding and cost-burden statistics to determine regional housing needs. However, HCD’s final determination for SACOG used this analysis while the SCAG region was held to a different and less reasonable standard. Improved Vacancy Rate Comparison HCD seemingly uses unrealistic comparison points to evaluate healthy market vacancy, which is also an unreasonable application of the methodology and assumptions described in statute. While SB 828 specifies a vacancy rate for a healthy rental housing market as no less than 5 percent, healthy market vacancy rates for for-sale housing are not specified. HCD’s practice is to compare actual, ACS vacancy rates for the region versus a 5 percent total vacancy rate (i.e. owner and renter markets combined). During the consultation process, SCAG discussed this matter with HCD staff and provided several points of comparison including historical data, planning standards, and comparisons with other regions. In addition, SCAG staff illustrated that given tenure shares in the SCAG region, HCD’s suggestion of a 5 percent total vacancy rate is mathematically equivalent to an 8 percent rental market vacancy rate plus a 2.25 percent for-sale housing vacancy rate. However, in major metropolitan regions, vacancy rates this high are rarely experienced outside of severe economic recessions such as the recent, housing market-driven Great Recession. Given the region’s current housing shortage, the high volume of vacant units envisioned in HCD’s planning target would be rapidly absorbed, making it an unrealistic standard. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) SCAG staff’s original suggestion of 5 percent rental vacancy and 1.5 percent for-sale vacancy (resulting in a 3.17 percent total vacancy rate based on current tenure shares) is in fact higher than the observed rate in the comparable regions defined above. It is also above Federal Housing Authority standards for regions experiencing slow or moderate population growth. It is also above the very liberal standard of 6 percent for for-rent housing and 2 percent for for-sale housing suggested by the California Office of Planning and Research (equivalent to 3.90 percent total vacancy based on SCAG tenure shares) which would also be a more reasonable application of the methodology.1 Additional Considerations In addition to the three key points above, SCAG’s proposed alternative includes several other corrections to technical shortcomings in HCD’s analysis of regional housing needs. 1. HCD’s evaluation of replacement need is based on an arbitrary internal standard of 0.5 percent to 5.0 percent of total housing units. 2010-2019 demolition data provided by DOF suggest that over an 8.25-year period, it is reasonable to expect that 0.14 percent of the region’s total housing units will be demolished, but not replaced. This would form the basis of a more reasonable housing needs determination, as DOF’s survey represents the most comprehensive and robust data available. 2. Anticipated household growth on tribal land was not excluded from the regional determination as indicated in the consultation package and follow-up communications. Tribal entities within the SCAG region have repeatedly requested that this estimate be excluded from the RHNA process entirely since as sovereign nations, state law does not apply. SCAG’s proposed approach is to subtract estimates of household growth on tribal land from the regional determination and ensure that these figures are also excluded from local jurisdictions’ annual progress reports (APRs) of new unit construction to HCD during the 6th cycle. 3. A refinement to the adjustment for cost burden would yield a more reasonable determination of regional housing needs. SCAG has repeatedly emphasized the shortcomings of and overlap across various ACS-based measures of housing need. Furthermore, the relationship between new unit construction and cost burden is poorly understood (i.e., what will be the impact of new units on cost, and by extension, cost-burden). Nonetheless, SCAG recognizes that the region’s cost burden exceeds that of comparable regions and proposes one modification to HCD’s methodology, which currently considers cost burden separately by lower and higher income categories. While housing security is dependent on income, it is also heavily dependent on tenure. While spending above 30 percent of gross income on housing for renters can reflect true housing insecurity, spending above this threshold for owners is substantially less problematic. This is particularly true for higher income homeowners, who generally benefit from housing shortages as it results in home value appreciation. Thus, a more reasonable application of cost burden                                                              1 See Nelson, AC. (2004), Planner’s Estimating Guide Projecting Land-Use and Facility Needs. Planners Press, American Planning Association, Chicago. P. 25. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) statistics would exclude cost-burden experienced by moderate and above-moderate owner households and instead make an adjustment based on three of the four income and tenure combinations: lower-income renters, higher-income renters, and lower-income owners. 4. From our review, HCD’s data and use of data is not current. In large metropolitan regions, there is no reasonable basis for using 5-year ACS data, which reflects average conditions from 2013 to 2017. For cost-burden adjustments, HCD relies on 2011-2015 CHAS data. By the beginning of the 6th cycle of RHNA, some of the social conditions upon which the determination is based will be eight years old. During the consultation process, SCAG staff provided HCD with Excel-version data of all inputs needed to replicate their methodology using ACS 2017 1-year data (the most recent available); however, this was not used. The Census bureau is scheduled to release ACS 2018 1-year data on September 26, 2019. SCAG staff would support replicating the same analysis, but substituting 2018 data when it becomes available in order to ensure the most accurate estimates in planning for the region’s future. Finally, given that the manner and order in which modifications are made affects the total housing need, the attachments demonstrate two alternatives with varying interpretations of three of the above points (see boldface, red text in attachments): - Vacancy rate comparison – SCAG’s originally proposed values versus an alternative which emerged from the consultation process - Replacement need – DOF survey value versus HCD’s current practice - Cost burden measure – whether or not to include higher-income homeowners in this adjustment We appreciate your careful consideration of this objection. RHNA is a complex process and we recognize the difficult positions that both SCAG and HCD are in but are hopeful that our agencies can reach a reasonable conclusion with respect to the regional need determination. Please contact me if you have questions. I look forward to continuing our close partnership to address the housing crisis in our state. Sincerely, Kome Ajise Executive Director Attachments 1. SCAG Alternative Determination 2. Excel version: SCAG Alternative Determination and supporting data 3. HCD Letter on Regional Need Determination, August 22, 2019 Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Attachment 1 SCAG Alternative Determination                         1 OPTION A: SCAG region housing needs, June 30 2021-October 1 2029 (8.25 Years) 2 Population: Oct 1, 2029 (SCAG 2020 RTP/SCS Forecast)20,725,878 3 - Less Group Quarters Population (SCAG 2020 RTP/SCS Forecast)-327,879 4 Household (HH) Population, Oct 1, 2029 20,397,998 Household Formation Groups 20,397,998 6,668,498 under 15 years 3,812,391 n/a 15 - 24 years 2,642,548 147,005 25 - 34 years 2,847,526 864,349 35 - 44 years 2,821,442 1,304,658 45 - 54 years 2,450,776 1,243,288 55 - 64 years 2,182,421 1,116,479 65 -74 years 1,883,181 1,015,576 75 - 84 years 1,167,232 637,415 85+590,480 339,727 5 Projected Households (Occupied Unit Stock)6,668,498 6 + Vacancy Owner Renter Tenure Share (ACS 2017 1-year)52.43% 47.57% Households by Tenure 3,496,058 3,172,440 Healthy Market Vacancy Standard 1.50% 5.00% SCAG Vacancy (ACS 2017 1-year)1.13% 3.30% Difference 0.37% 1.70% Vacancy Adjustment 12,953 53,815 66,768 7 + Overcrowding (Comparison Point vs. Region ACS %)5.20% 9.82% 4.62%308,264 8 + Replacement Adj (Actual DOF Demolitions)9,335 - Household Growth on Tribal Land (SCAG Estimate)-2,766 9 - Occupied Units (HHs) estimated June 30, 2021 (from DOF data)-6,250,261 10 + Cost-burden Adjustment (Comparison Point vs. Region)23,969 823,808 SCAG Projected HH Population Headship rate - see Table 2 Projected Households 6th Cycle Regional Housing Need Assessment (RHNA) 0.14% Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) 1 OPTION B: SCAG region housing needs, June 30 2021-October 1 2029 (8.25 Years) 2 Population: Oct 1, 2029 (SCAG 2020 RTP/SCS Forecast)20,725,878 3 - Less Group Quarters Population (SCAG 2020 RTP/SCS Forecast)-327,879 4 Household (HH) Population, Oct 1, 2029 20,397,998 Household Formation Groups 20,397,998 6,668,498 under 15 years 3,812,391 n/a 15 - 24 years 2,642,548 147,005 25 - 34 years 2,847,526 864,349 35 - 44 years 2,821,442 1,304,658 45 - 54 years 2,450,776 1,243,288 55 - 64 years 2,182,421 1,116,479 65 -74 years 1,883,181 1,015,576 75 - 84 years 1,167,232 637,415 85+590,480 339,727 5 Projected Households (Occupied Unit Stock)6,668,498 6 + Vacancy Owner Renter Tenure Share (ACS 2017 1-year) 52.43% 47.57% Households by Tenure 3,496,058 3,172,440 Healthy Market Vacancy Standard 2.00% 6.00% SCAG Vacancy (ACS 2017 1-year) 1.13% 3.30% Difference 0.87% 2.70% Vacancy Adjustment 30,433 85,540 115,973 7 + Overcrowding (Comparison Point vs. Region ACS %)5.20% 9.82% 4.62%308,264 8 + Replacement Adj (HCD minimum standard)33,340 - Household Growth on Tribal Land (SCAG Estimate)-2,766 9 - Occupied Units (HHs) estimated June 30, 2021 (from DOF data)-6,250,261 10 + Cost-burden Adjustment (Comparison Point vs. Region)47,724 920,772 6th Cycle Regional Housing Need Assessment (RHNA) SCAG Projected HH Population Headship rate - see Table 2 Projected Households 0.50% Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) 1 2-5 6 7 8 9 10 Cost Burden Adjustment: A cost-burden adjustment is applied to the projected need by comparing the difference in cost-burden by income and tenure group for the region to the cost-burden by income and tenure group for comparable regions. Data are from 2017 1-year ACS and the ACS $50,000/year household income threshold is used to distinguish between lower and higher income groups. The lower income RHNA is increased by the percent difference between the region and the comparison region cost burden rate for households earning approximately 80% of area median income and below (88.89%-84.39%=4.51% for renters and 27.33%-20.97%=6.36% for owners), then this difference is applied to very low- and low- income RHNA proportionate to the share of the population these groups currently represent (Very Low=63% of lower, Low=37% of lower). The higher income RHNA is increased by the percent difference between the region and the comparison region cost burden rate (67.15%-65.53%=1.62% for renters and 23.78%-17.06%=6.72% for owners) for households earning above 80% Area Median Income, then this difference is applied to moderate and above moderate income RHNA proportionate to the share of the population these groups currently represent (Moderate=29% of higher, Above Moderate=71% of higher). SCAG's analysis of the cost-burden measure suggests that it may be less appropriate to apply for higher-income owners and it may be excluded from the adjustment. Occupied Units: Reflects DOF's estimate of occupied units at the start of the projection period (June 30, 2021). Projection period: Gov. Code 65588(f) specifies RHNA projection period start is December 31 or June 30, whichever date most closely precedes end of previous RHNA projection period end date. RHNA projection period end date is set to align with planning period end date. The planning period end date is eight years following the Housing Element due date, which is 18 months following the Regional Transportation Plan adoption rounded to the 15th or end of the month. Population, Group Quarters, Household Population, & Projected Households: Pursuant to Government Code Section 65584.01, projections were extrapolated from SCAG's Regional Transportation Plan projections. Population reflects total persons. Group Quarter Population reflects persons in a dormitory, group home, institution, military, etc. that do not require residential housing. Household Population reflects persons requiring residential housing. Projected Households reflect the propensity of persons, by age-groups, to form households at different rates based on Census trends. Vacancy Adjustment: Pursuant to Government Code 65584.01, a 5% minimum is considered to be healthy market vacancy in the for-rent housing market. Vacancy rates in the for-sale market are unspecified in statute. SCAG's analysis of vacancy rates suggests a healthy market standard of 5% for fore-rent housing and 1.5% for for-sale housing. After extensive consultation with HCD, a review of historical trends, regional and national comparison, and various planning standards, a more liberal vacancy standard of 6% for for-rent housing and 2% for for-sale housing may also be supported by this analysis. These standards are compared against ACS 2017 1-year data based on the renter/owner share in the SCAG region. Overcrowding Adjustment: In regions where overcrowding is greater than the Comparable Region Rate, an adjustment is applied based on the amount the region's overcrowding rate (9.82%) exceeds the Comparable Region Rate (5.20%). Data is from 2017 1-year ACS. Replacement Adjustment: A replacement adjustment is applied based on the current 10-year average % of demolitions according to local government annual reports to Department of Finance. While these data suggest an adjustment of 0.14% is most appropriate, SCAG recognizes that HCD's internal practice is to use an adjustment factor of 0.5%. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Income Category Percent Housing Unit Need Very-Low *25.8%212,284 Low 15.1%124,375 Moderate 17.1%140,601 Above-Moderate 42.1%346,547 Total 100.0%823,808 *Extremely-Low 14.6% Income Category Percent Housing Unit Need Very-Low *25.8%231,084 Low 15.1%135,390 Moderate 17.1%159,982 Above-Moderate 42.1%394,316 Total 100.0%920,772 *Extremely-Low 14.6% Option A: Regional Housing Need Allocation (RHNA) Determination SCAG Region June 30, 2021 through October 1, 2029 Option B: Regional Housing Need Allocation (RHNA) Determination SCAG Region June 30, 2021 through October 1, 2029 included in Very-Low Category Income Distribution : Income categories are prescribed by California Health and Safety Code (Section 50093, et.seq.). Percents are derived based on ACS reported household income brackets and county median income, then adjusted based on the percent of cost-burdened households in the region compared with the percent of cost burdened households nationally. included in Very-Low Category Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) 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 Avenue, Suite 500 Sacramento, CA 95833 (916) 263-2911 / FAX (916) 263-7453 www.hcd.ca.gov October 15, 2019 Kome Ajise Executive Director Southern California Association of Governments 900 Wilshire Boulevard, Suite 1700 Los Angeles, CA 90017 Dear Executive Director Ajise, RE: Final Regional Housing Need Assessment The California Department of Housing and Community Development (HCD) has received and reviewed your objection to the Southern California Association of Governments (SCAG)’s Regional Housing Needs Assessment (RHNA) provided on August 22, 2019. Pursuant to Government Code (Gov. Code) section 65584.01(c)(3), HCD is reporting the results of its review and consideration, along with a final written determination of SCAG’s RHNA and explanation of methodology and inputs. As a reminder, there are several reasons for the increase in SCAG’s 6th cycle Regional Housing Needs Assessment (RHNA) as compared to the 5th cycle. First, as allowed under Gov. Code 65584.01(b)(2), the 6th cycle RHNA applied housing need adjustment factors to the region’s total projected households, thus capturing existing and projected need. Second, overcrowding and cost burden adjustments were added by statute between 5th and 6th cycle; increasing RHNA in regions where incidents of these housing need indicators were especially high. SCAG’s overcrowding rate is 10.11%, 6.76% higher than the national average. SCAG’s cost burden rate is 69.88% for lower income households, and 18.65% for higher income households, 10.88% and 8.70% higher than the national average respectively. Third, the 5th cycle RHNA for the SCAG region was impacted by the recession and was significantly lower than SCAG’s 4th cycle RHNA. This RHNA methodology establishes the minimum number of homes needed to house the region’s anticipated growth and brings these housing need indicators more in line with other communities, but does not solve for these housing needs. Further, RHNA is ultimately a requirement that the region zone sufficiently in order for these homes to have the potential to be built, but it is not a requirement or guarantee that these homes will be built. In this sense, the RHNA assigned by HCD is already a product of moderation and compromise; a minimum, not a maximum amount of planning needed for the SCAG region. For these reasons HCD has not altered its RHNA approach based on SCAG’s objection. However, the cost burden data input has been updated following SCAG’s objection due to the availability of more recent data. Attachment 1 displays the minimum RHNA of 1,341,827 total homes among four income categories for SCAG to distribute among its local governments. Attachment 2 explains the methodology applied pursuant to Gov. Code section 65584.01. EXHIBIT CHousing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Page 2 of 7 The following briefly responds to each of the points raised in SCAG’s objection: Use of SCAG’s Population Forecast SCAG’s overall population estimates for the end of the projection period exceed Department of Finance’s (DOF) population projections by 1.32%, however the SCAG household projection derived from this population forecast is 1.96% lower than DOF’s household projection. This is a result of SCAG’s population forecast containing 3,812,391 under 15-year old persons, compared to DOF’s population projection containing 3,292,955 under 15-year old persons; 519,436 more persons within the SCAG forecast that are anticipated to form no households. In this one age category, DOF’s projections differ from SCAG’s forecast by 15.8%. Due to a greater than 1.5% difference in the population forecast assessment of under 15-year olds (15.8%), and the resulting difference in projected households (1.96%), HCD maintains the use of the DOF projection in the final RHNA. Use of Comparable Regions While the statute allows for the council of government to determine and provide the comparable regions to be used for benchmarking against overcrowding and cost burden, Gov. Code 65584.01(b)(2) also allows HCD to “accept or reject information provided by the council of governments or modify its own assumptions or methodology based on this information.” Ultimately, HCD did not find the proposed comparable regions an effective benchmark to compare SCAG’s overcrowding and cost burden metrics to. HCD used the national average as the comparison benchmark, which had been used previously throughout 6th cycle prior to the addition of comparable region language into the statute starting in January 2019. As the housing crisis is experienced nationally, even the national average does not express an ideal overcrowding or cost burden rate; we can do more to reduce and eliminate these worst-case housing needs. Vacancy Rate No changes have been made to the vacancy rate standard used by HCD for the 6th cycle RHNA methodology. Replacement Need No changes have been made to the replacement need minimum of adjustment .5%. This accounts for replacement homes needed to account for homes potentially lost during the projection period. Household Growth Anticipated on Tribal Lands No changes have been made to reduce the number of households planned in the SCAG region by the amount of household growth expected on tribal lands. The region should plan for these homes outside of tribal lands. Overlap between Overcrowding and Cost Burden No changes have been made to overcrowding and cost burden methodology. Both factors are allowed statutorily, and both are applied conservatively in the current methodology. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Page 3 of 7 Data Sources No changes have been made to the data sources used in the methodology. 5-year American Community Survey data allows for lower margin of error rates and is the preferred data source used throughout this cycle. With regard to cost burden rates, HCD continues to use the Comprehensive Housing Affordability Strategy, known as CHAS data. These are custom tabulations of American Community Survey requested by the U.S. Department of Housing and Urban Development. These customs tabulations display cost burden by income categories, such as lower income, households at or below 80% area median income; rather than a specific income, such as $50,000. The definition of lower income shifts by region and CHAS data accommodates for that shift. The 2013-2016 CHAS data became available August 9, 2019, shortly prior to the issuance of SCAG’s RHNA determination so that data is now used in this RHNA. Next Steps As you know, SCAG is responsible for adopting a RHNA allocation methodology for the projection period beginning June 30, 2021 and ending October 15, 2029. Pursuant to Gov. Code section 65584(d), SCAG’s RHNA allocation methodology must further the following objectives: (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. (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. (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. (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. (5) Affirmatively furthering fair housing. Pursuant to Gov. Code section 65584.04(e), to the extent data is available, SCAG shall include the factors listed in Gov. Code section 65584.04(e)(1-12) to develop its RHNA allocation methodology. Pursuant to Gov. Code section 65584.04(f), SCAG must explain in writing how each of these factors was incorporated into the RHNA allocation methodology and how the methodology furthers the statutory objectives described above. Pursuant to Gov. Code section 65584.04(h), SCAG must consult with HCD and submit its draft allocation methodology to HCD for review. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Page 4 of 7 HCD appreciates the active role of SCAG staff in providing data and input throughout the consultation period. HCD especially thanks Ping Chang, Ma’Ayn Johnson, Kevin Kane, and Sarah Jepson. HCD looks forward to its continued partnership with SCAG to assist SCAG’s 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 SCAG region this cycle include: • SB 2 Planning Grants and Technical Assistance (application deadline November 30, 2019) • Regional and Local Early Action Planning Grants • Permanent Local Housing Allocation 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, at megan.kirkeby@hcd.ca.gov. Sincerely, Douglas R. McCauley Acting Director Enclosures Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Page 5 of 7 ATTACHMENT 1 HCD REGIONAL HOUSING NEED DETERMINATION SCAG: June 30, 2021 – October 15, 2029 (8.3 years) Income Category Percent Housing Unit Need Very-Low* 26.2% 351,796 Low 15.4% 206,807 Moderate 16.7% 223,957 Above-Moderate 41.7% 559,267 Total 100.0% 1,341,827 * Extremely-Low 14.5% Included in Very-Low Category Notes: Income Distribution: Income categories are prescribed by California Health and Safety Code (Section 50093, et.seq.). Percents are derived based on ACS reported household income brackets and regional median income, then adjusted based on the percent of cost-burdened households in the region compared with the percent of cost burdened households nationally. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Page 6 of 7 ATTACHMENT 2 HCD REGIONAL HOUSING NEED DETERMINATION SCAG: June 30, 2021 – October 15, 2029 (8.3 years) Methodology SCAG: June 30, 2021-October 15, 2029 (8.3 Years) HCD Determined Population, Households, & Housing Need 1. Population: DOF 6/30/2029 projection adjusted +3.5 months to 10/15/2029 20,455,355 2. - Group Quarters Population: DOF 6/30/2029 projection adjusted +3.5 months to 10/15/2029 -363,635 3. Household (HH) Population: October 15, 2029 20,079,930 Household Formation Groups HCD Adjusted DOF Projected HH Population DOF HH Formation Rates HCD Adjusted DOF Projected Households 20,079,930 6,801,760 under 15 years 3,292,955 n/a n/a 15 – 24 years 2,735,490 6.45% 176,500 25 – 34 years 2,526,620 32.54% 822,045 35 – 44 years 2,460,805 44.23% 1,088,305 45 – 54 years 2,502,190 47.16% 1,180,075 55 – 64 years 2,399,180 50.82% 1,219,180 65 – 74 years 2,238,605 52.54% 1,176,130 75 – 84 years 1,379,335 57.96% 799,455 85+ 544,750 62.43% 340,070 4. Projected Households (Occupied Unit Stock) 6,801,760 5. + Vacancy Adjustment (2.63%) 178,896 6. + Overcrowding Adjustment (6.76%) 459,917 7. + Replacement Adjustment (.50%) 34,010 8. - Occupied Units (HHs) estimated (June 30, 2021) -6,250,261 9. + Cost Burden Adjustment (Lower Income: 10.63%, Moderate and Above Moderate Income: 9.28%) 117,505 6th Cycle Regional Housing Need Assessment (RHNA) 1,341,827 Explanation and Data Sources 1-4. Population, Group Quarters, Household Population, & Projected Households: Pursuant to Government Code Section 65584.01, projections were extrapolated from Department of Finance (DOF) projections. Population reflects total persons. Group Quarter Population reflects persons in a dormitory, group home, institution, military, etc. that do not require residential housing. Household Population reflects persons requiring residential housing. Projected Households reflect the propensity of persons, by age-groups, to form households at different rates based on Census trends. 5. Vacancy Adjustment: HCD applies a vacancy adjustment based on the difference between a standard 5% vacancy rate and the region’s current "for rent and sale" vacancy percentage to provide healthy market vacancies to facilitate housing availability and resident mobility. The adjustment is the difference between standard 5% and region’s current vacancy rate (2.37%) based on the 2013-2017 5-year American Community Survey (ACS) data. For SCAG that difference is 2.63%. 6. Overcrowding Adjustment: In region’s where overcrowding is greater than the U.S overcrowding rate of 3.35%, HCD applies an adjustment based on the amount the region’s overcrowding rate (10.11%) exceeds the U.S. overcrowding rate (3.35%) based on the 2013- 2017 5-year ACS data. For SCAG that difference is 6.76%. Continued on next page 7. Replacement Adjustment: HCD applies a replacement adjustment between .5% & 5% to total housing stock based on the current 10-year average of demolitions in the region’s local Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Page 7 of 7 government annual reports to Department of Finance (DOF). For SCAG, the 10-year average is .14%, and SCAG’s consultation package provided additional data on this input indicating it may be closer to .41%; in either data source the estimate is below the minimum replacement adjustment so the minimum adjustment factor of .5% is applied. 8. Occupied Units: Reflects DOF's estimate of occupied units at the start of the projection period (June 30, 2021). 9. Cost Burden Adjustment: HCD applies an adjustment to the projected need by comparing the difference in cost-burden by income group for the region to the cost-burden by income group for the nation. The very-low and low income RHNA is increased by the percent difference (69.88%-59.01%=10.88%) between the region and the national average cost burden rate for households earning 80% of area median income and below, then this difference is applied to very low- and low-income RHNA proportionate to the share of the population these groups currently represent. The moderate and above-moderate income RHNA is increased by the percent difference (18.65%-9.94%=8.70%) between the region and the national average cost burden rate for households earning above 80% Area Median Income, then this difference is applied to moderate and above moderate income RHNA proportionate to the share of the population these groups currently represent. Data is from 2013-2016 Comprehensive Housing Affordability Strategy (CHAS). Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) ATTACHMENT 3 Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Do the Math: The state has ordered more than 350 cities to prepare the way for more than 2 million homes by 2030. But what if the math is wrong? Senate Bill 828, co-sponsored by the Bay Area Council and Silicon Valley Leadership Group, and authored by state Sen. Scott Wiener in 2018, has inadvertently doubled the “Regional Housing Needs Assessment” in California. Use of an incorrect vacancy rate and double counting, inspired by SB-828, caused the state’s Department of Housing and Community Development (HCD) to exaggerate by more than 900,000 the units needed in SoCal, the Bay Area and the Sacramento area. The state’s approach to determining the housing need must be defensible and reproducible if cities are to be held accountable. Inaccuracies on this scale mask the fact that cities and counties are surpassing the state’s market-rate housing targets, but falling far short in meeting affordable housing targets. The innacuracies obscure the real problem and the associated solution to the housing crisis—the funding of affordable housing. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Sierra DelNorte Humboldt Trinity Shasta Lassen Tehama Plumas Butte Nevada Placer Sonoma Napa Yolo Solano Stanislaus SantaClara SanBenito SanJoaquinContraCosta Alameda Marin San Francisco San Mateo Santa Cruz Monterey San LuisObispo Santa Barbara Ventura Los Angeles Orange San Bernardino Riverside San Diego Imperial Yuba GlennMendocino Lake Colusa Sutter Sacra-mento El Dorado Alpine Calaveras Tuolumne Mono Mariposa Madera Fresno Kings Kern Tulare Inyo Merced Amador Siskiyou Modoc Every five to eight years the Department of Housing and Community Development (HCD) supervises and publishes the results of a process referred to as the Regional Housing Needs Assessment (RHNA). Four regional planning agencies cover the 21 most urban counties and account for 80% of California’s housing. All four regions saw a significant jump in the state’s assessment of their housing need for the years 2021 to 2030. Double counting (not surprisingly) doubled the assessed housing need for the four major planning regions. Four Regions Contain 80% of the State’s HousingHousing Units Needed According to the State, (1996–2030) 0 0.5M 1.0M 1.5M 2.0M 2.5M Sacramento Area Council of Governments (SACOG) 1996–2006 2005–2014 2013–2022 2021–2030 Association of Bay Area Governments (ABAG) San Diego Association of Governments (SANDAG) Greater Sacramento San Diego Region Greater Bay Area Six SoCal Counties Southern California Association of Governments (SCAG) 1 Impacted by Great Recession foreclosure crisis Made before COVID impact Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) 0 500,000 1,000,000 Cost burdening double-count Overcrowding double-count Extra units needed to replace demolished units Extra units needed to achieve healthy vacancy rate Households needed as determined by the Dept. of Finance (factors in overcrowding and cost burdening) Conventional Economist Approach Conventional Economist Approach Conventional Economist Approach Conventional Economist Approach Six SoCal Counties Greater Bay Area San Diego Region Greater Sacramento California plans for its housing needs in “cycles.” The four regions are on cycles that last roughly eight years with staggered start dates. In the 2021–2030 housing cycle, errors introduced by language in SB-828 nearly equal the entire 1.15M units of new housing required during the 2013–2022 “cycle.” As illustrated, Southern California and the Bay Area are the most impacted by the state’s methodology errors. The double count, an unintended consequence of Senate Bill 828, has exaggerated the housing need by more than 900,000 units in the four regions below.Number of Housing Units(1,341,827) (153,512)(122,000)(112,000) (283,000) (441,176) (171,687) (651,000) SB-828 Double Count SB-828 Double Count SB-828 Double Count SB-828 Double Count 2 Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Senate Bill 828 was drafted absent a detailed understanding of the Department of Finance’s methodology for developing household forecasts, and absent an understanding of the difference between rental and home-owner vacancies. These misunderstandings have unwittingly ensured a series of double counts. State’s erroneous benchmark of 5%Annual Homeowner Vacancy Rates for the United States and Regions: 1968º2019 Typical benchmark is 1.5% 3 1. SB-828 wrongly assumed ‘existing housing need’ was not evaluated as part of California’s previous Regional Housing Need Assessments, or RHNA. There was an assumption that only future need had been taken into account in past assess- ments. (In fact, as detailed in The Reality section, the state’s existing housing need was fully evaluated in previous RHNA assessment cycles). 2. SB-828 wrongly assumed a 5% vacancy rate in owner-occupied housing is healthy (as explained in the column on the right, 5% vacancy in owner-occupied homes is never desir- able, and contradicts Government Code 65584.01(b)(1)(E) which specifies that a 5% vacancy rate applies only to the rental housing market). 3. SB-828 wrongly assumed overcrowding and cost-burdening had not been considered in Department of Finance projections of housing need. The bill sought to redress what it mistaken- ly thought had been left out by requiring regional planning agencies to report overcrowding and cost-burdening data to the Dept. of Housing and Community Development (as explained in the right column). SB-828 MISTAKENLY ASSUMED:THE REALITY IS: 1. Existing housing need has long been incorporated in California’s planning cycles. It has been evaluated by comparing existing vacancy rates with widely accepted benchmarks for healthy market vacancies (rental and owner-occupied). The difference between actual and benchmark is the measure of housing need/surplus in a housing market. Confusion about the inclusion of “existing need” may have arisen because vacancy rates at the time of the last assessment of housing need (”the 5th cycle”) were unusually high (higher than the healthy benchmarks) due to the foreclosure crisis of 2007–2010, and in fact, the vacancy rates suggested a surplus of housing. So, in the 5th cycle the vacancy adjustment had the effect of lowering the total housing need. Correctly seeing the foreclosure crisis as temporary, the state Department of Finance did not apply the full weight of the surplus, but instead assumed a percentage of the vacant housing would absorbed by the time the 5th cycle began. The adjustment appears in the 5th cycle determinations, not as ‘Existing Housing Need’ but rather as “Adjustment for Absorption of Existing Excess Vacant Units.” 2. While 5% is a healthy benchmark for rental vacancies, it is unhealthy for owner-occupied housing (which typically represents half of existing housing). Homeowner vacancy in the U.S. has hovered around 1.5% since the ‘70s, briefly reaching 3% during the foreclosure crisis. However, 5% is well outside any healthy norm, and thus does not appear on the Census chart (to the right) showing Annual Homeowner Vacancy Rates for the United States and Regions: 1968–2019. 3. Unknown to the authors of SB-828, the Department of Finance (DOF) has for years factored overcrowding and cost-burdening into their household projections. These projections are developed by multiplying estimated population by the headship rate (the proportion of the population who will be head of a household). The Department of Finance (DOF) in conjunction with the Department of Housing and Community Development (HCD) has documented its deliberate decision to use higher headship rates to reflect optimal conditions and intentionally “alleviate the burdens of high housing cost and overcrowding.” Unfortunately, SB-828 has caused the state to double count these important numbers. Five Percent Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) 1. Incorrect use of a 5% benchmark vacancy rate for owner-occupied housing. The vacancy rate was incorrectly used for both existing and projected owner-occupied households. 2. Current vacancies were assumed to exist in household projections. This error is unrelated to SB-828, but is an accounting error introduced by HCD methodology. 3. Overcrowding and cost-burdening were double counted.** In addition to the household projection methodology outlined by the Department of Finance (shown to account for overcrowding and cost-burdening), the matter is also mentioned in meeting notes available on the Association of Bay Area Government’s (ABAG) website.*** Quote from ABAG’s Housing Methodology Committee Agenda Packet for the 4th RHNA Cycle, July 2006 “There was also a lot of discussion about the headship rates used by HCD/DOF. Several people commented that headship rates in the Bay Area are generally lower than the State’s estimates because the region’s high housing costs limit household formation. In response, Mr. Fassinger noted that HCD uses these higher headship rates because the RHNA process is intended to alleviate the burdens of high housing cost and overcrowding.” Despite this, overcrowding and cost-burdening were counted a second time as adjustment factors required by SB-828. + 229,000 housing units + 734,000 housing units – 22,000 housing units + 941,000 housing units 4 The forced double-counting errors are significant.* * All errors are rounded to the nearest thousand. ** Overcrowding measures the number of households with more than 1 person per room. Cost-burdening measures the number of households that spend more than 30% of the household income on housing. Cost-burdening is measured by five income levels — extremely low, very low, low, moderate, above moderate *** P-4 tables are created by the Department of Finance—Household Projection table 2020–2030 and their methodology is fully explained in ‘read me’ notes that accompany the table. TOTAL: Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) * Based on permit progress reports published by the Dept of Housing and Community Development and updated July 2020, reporting progress through April 2019. ** Only the Bay Area is shown because other regions have not kept detailed records of permit progress through the 3rd and 4th cycles. 5th Cycle Targets (as of April 2019) 500K 250K Permit Progress in the 5th Cycle (2013-2022)* (all 4 regions) Very low + low income Market rate Permits Issued (as of April 2019) Affordable Housing Languishes as Market-Rate Housing Overachieves (Bay Area only)* 4th Cycle 2007–2014 5th Cycle 2014–2022 3rd Cycle 1996–2006 +150% +100% +50% -50% 0% Very-low + Low Income PermitsMarket-Rate Permits 5 The state has shown, with decades of data, that it cannot dictate to the market. The market is going to take care of itself. The state’s responsibility is to take care of those left behind in the market’s wake. Based on housing permit progress reports published by the Dept. of Housing and Community Development in July 2020, cities and counties in the four most populous regions continue to strongly outperform on the state’s assigned market-rate housing targets, but fail to achieve even 20% of their low-income housing target. In the Bay Area where permit records have been kept since 1997, there is evidence that this housing permit imbalance has propagated through decades of housing cycles. The state’s exaggerated targets unfortunately mask the real story: Decades of overachieving in market-rate housing has not reduced housing costs for lower income households. Great Recession (2007–2010) impacted housing. Market-rate meets but does not exceed state target in the 4th cycle. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Cities are charged by the state to build one market-rate home for every one affordable home. But state laws, such as the density bonus law, incentivize developers to build market-rate units at a far higher rate than affordable units. As a result, California has been building four market-rate units for every one affordable unit for decades. And with the near-collapse of legislative funding for low-income housing in 2011, that ratio has grown to seven to eight market-rate units to each affordable unit. Yet we need one-to-one. This worsening situation can’t be fixed by zoning or incentives which are the focus of many recent housing bills and only reinforce or worsen the ever-higher market-rate housing ratios. From the data it appears that the shortage of housing resulted not from a failure by cities to issue housing permits, but rather a failure by the state to fund and support affordable housing. Future legislative efforts should take note. Market-Rate to Low-Income Housing Permits in the Bay Area has grown from a ratio of 4 : 1 to 7 : 1 (Bay Area only)** 4th Cycle 2006–2014 5th Cycle 2014–2022 3rd Cycle 1999–2006 4 2 6 8 0 Effect of reduced state funding for affordable housing . 2008 2010 2012 2014 2016 2018 $3.0 $2.0 $1.0 $0 The ratio mandated by the state State Funds for Affordable Housing, 2008–2019* $ Billion Actual ratio Redevelopment agencies shuttered 6 It’s clear. Market-rate housing doesn’t need state incentives. Affordable housing needs state funding. * “The Defunding of Affordable Housing in California”, Embarcadero Institute, update June 2020 www.embarcaderoinstitute.com/reports/ ** Only Bay Area is shown because other regions have not kept detailed records of permit progress through the 3rd and 4th cycles. Data is from ABAG’s permit progress reports for 3rd and 4th cycle and Dept. of Housing and Community Development’s 5th cycle Annual Progress Report. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Finally, since penalties are incurred for failing to reach state targets for housing permits, the methodology for developing these numbers must be transparent, rigorous and defensible. Non-performance in an income category triggers a streamlined approval process per Senate Bill 35 (2017). These exaggerated 6th cycle targets will make it impossible for cities and counties to attain even their market-rate targets, ensuring market-rate housing will qualify for incentives and bonuses meant for low income housing. Yet again low-income housing will lose out. The state needs to correct the errors in the latest housing assessement, and settle on a consistent, defensible approach going forward. 1. Conventional Economist Approach 2. SB-828 Double Count 3. McKinsey’s New York Benchmark Jobs-to- Housing Ratio of 1.5 1.17M 2.11M 2.88M 0.23M 1. The Conventional Economist Approach: uses goldilocks (not too big, not too small, just right) benchmarks for vacancies - 1.5% for owner-occupied and 5% for rental housing. 2. SB-828 Double Count: incorrectly uses a benchmark of 5% vacancy for owner-occupied housing. It also double counts overcrowding and cost-burdening 3. McKinsey’s New York Benchmark: the over-simplified approach generated an exaggerated housing gap of 3.5 Million for California. McKinsey multiplied California’s population by New York’s housing per capita to get 3.5M. New York is not a proper benchmark for California and NY’s higher housing per capita is more reflective of NY’s declining population rather than a healthy benchmark for housing 4. Jobs-to-housing ratio of 1.5: according to state planning agencies 1.5 is the optimal benchmark. Employment in the four regions is estimated to grow to 17 million by 2030 (job growth estimates prepared before COVID).** Forecast 2030 Housing Need for the Four RegionsAt Least Four Different Methodologies Have Been Used Simultaneously by the State to Discuss Housing Need: We Only Need One * California’s Employment Development Department (EDD) estimates employment by county through 2026. Using annualized growth (2016 to 2026) as a basis for future growth 2030 employment is estimated for the four regions. ** The 17 million includes estimates of self employed, private household workers, farm and nonfarm employment. Occupations with employment below 100 in 2016 are excluded. McKinsey’s 3.5 Million Housing Gap for California (New York as comparable) 7 McKinsey’s Housing Gap for the four regions Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Dept. of Finance (DOF) How it Works : A multi-agency collaborative effort has generated past state housing targets. However, in 2018, SB-828 annointed the Dept. of Housing and Community Development with final veto powers. STEP 1 STEP 2 STEP 3 STEP 4 Dept. of Housing and Community Development (HCD) APPENDIX A-1 The Dept. of Finance (DOF) generates household forecasts by county based on population growth and headship rates. This is the step where overcrowding and cost-burdening are factored in . The Dept. of Housing and Community Development (HCD) then takes the DOF household projections and adds in a healthy vacancy level (1.5% for owner-occupied, 5% for rental housing) to determine the number of housing units needed to comfortably accommodate the DOF household projections. Cities and Counties report annual progress on housing permits to the Dept. of Housing and Community Development (HCD) The regional agencies allocate housing targets to cities and counties in their jurisdiction. These allocations collectively meet their RHNA assessments, and are based on algorithms that may include employment, transit accessibility and local housing patterns Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) + 228,000 housing units + 734,000 housing units – 22,000 housing units Six SoCal Counties = +578,000 Greater Bay Area = +104,000 San Diego Area = +39,000 Greater Sacramento = +13,000 Southern California and the Bay Area were most impacted by the double counting. San Diego was not assessed for cost-burdening although it is more cost-burdened than the Bay Area. It was perhaps overlooked because its assessment cycle began in July, 2018, a few months before SB-828 passed into law. Six SoCal Counties = -13,000 Greater Bay Area = -4,000 San Diego Area = -2,000 Greater Sacramento = -3,000 Six SoCal Counties = +126,000 Greater Bay Area = +59,000 San Diego Area = +23,000 Greater Sacramento = +21,000 A-2 APPENDIX SB-828 introduced errors in Step 2 (when the Dept. of Housing and Community Development made adjustments to the Dept. of Finance’s household projections). 1. Used a benchmark of 5% vacancy rate for BOTH owner-occupied and rental housing. The Department of Housing and Community and Development 2. Assumed vacancies in household projections * 3. Double counted overcrowding and cost-burdening * P-4 tables are created by the Department of Finance—Household Projection table 2020–2030 and their methodology is fully explained in ‘read me’ notes that accompany the table ** Overcrowding measures the number of households with more than 1 person per room. Cost-burdening measures the number of households that spend more than 30% of the household income on housing. Cost-burdening is measured by five income levels—extremely low, very low, low, moderate, above moderate. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) (10,000) (39,000) * Owner-occupied has a lower healthy vacancy rate because it is usually only vacant while a house is for sale ** All numbers are rounded to the nearest thousand. *** Seasonal Vacancies represent second homes, coprorate housing, and short-term rentals such as AIrBnBs EXISTING HOUSING: Six SoCal Counties The Department of Housing and Community Development (HCD) have traditionally arrived at a number for pent-up demand or housing shortfall by comparing vacancy rates in owner-occupied and rental housing to healthy benchmarks (1.5% for owner-occupied* and 5% for rental housing). The largest of the four regions, six SoCal Counties (covering Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura counties) is considered in the example below**. 1.2%Home-owned (3.3 Million) Vacant Housing Units Actual Vacancies (40,000) Healthy Benchmark (50,000)1.5% 3.7% 5.0% Existing Need Rentals (3 Million) Occupied Housing Units Actual Vacancies (111,000) Healthy Benchmark (150,000) Seasonal Vacancies (500,000)*** 1 circle = 10,000 households A-3 APPENDIX Detailed explanation of the errors using SoCal Counties as an example: First—the correct approach. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) PROJECTED HOUSING NEED: Six SoCal Counties Healthy Vacancy New Housing: Replacement Adjustment: Existing NeedAdditional HH by 2030 Home-owned (290,000) Rentals (261,000) Total Housing Need by 2030 1.5% (4,000)(10,000) 5.0% (13,000)(39,000) (34,000) The Dept. of Finance (DOF) supplies the Dept. of Housing and Community Development (HCD) with an estimate of additional households (HH) needed by the end of the cycle. The DOF forecast the 2030 population and using an optimal household formation rate determine the number of households needed to comfortably house that population*. The DOF also supply the HCD with the number of existing households at the start of the cycle. The HCD adds to the base number of additional households needed, factoring in vacancies for a healthy market, and adding a replacement adjustment (also supplied by the DOF)**. * Households represent occupied housing units. The number of housing units is always higher as at any given time than the number of households because some housing will be vacant or unutilized. The DOF is responsible for the base projection because they manage population projections for the state, and determine those by analyzing births, deaths and net migration. ** Replacement represents houses that may be demolished or replaced during the cycle*. 651,000 housing units 1 circle = 10,000 households A-4 APPENDIX The housing need also takes into account for future growth. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) (125,000) (38,000) EXISTING HOUSING: Six SoCal Counties Instead of the typical 1.5% benchmark for owner-occupied housing, they used a 5% vacancy rate usually reserved for rental housing. A 5% vacancy in owner-occupied housing is indicative of a distressed housing market. At 5%, SoCal’s existing housing need is increased by 115,000 housing units. Existing need for rental housing is unchanged. However, the Dept. of Housing and Community Development has adopted an unusual methodology in evaluating existing need in the 6th housing cycle. 1.2%Home-owned (3.3 Million) Vacant Housing Units Actual Vacancies (40,000) Healthy Benchmark (165,000)5.0% 3.7% 5.0% Existing Need Rentals (3 Million) Occupied Housing Units Actual Vacancies (110,000) Healthy Benchmark (149,000) Seasonal Vacancies (500,000) 1 circle = 10,000 households A-5 APPENDIX Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) (34,000) PROJECTED HOUSING NEED: Six SoCal Counties Healthy Vacancy New Housing: Assumed Vacancy New Housing Replacement Adjustment: Existing Need Additional HH by 2030 Home-owned(290,000) Rentals (261,000) 5% (15,000)1.2%(3,000)(125,000) 5.0% (13,000)(39,000) Again, instead of using the separate benchmark of 1.5% for owner-occupied housing, 5% was used for all housing. It was also assumed that new projected households had existing vacancies. The full benchmark was not applied to new households. Instead, the difference between the benchmark and the current vacancy rate was applied. The replacement adjustment was applied as it has been in the past. 3.7%(10,000) 763,000 housing units 1 circle = 10,000 households A-6 APPENDIX The Dept. of Housing and Community Development have also taken an unual approach in evaluating projected housing need. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) (460,000) PROJECTED HOUSING NEED: Six SoCal Counties Overcrowding Adjustment* Additional HH by 2030 Home-owned(290,000) Rentals (261,000) (118,000) Cost Burdening Adjustment** Two new factors were introduced into the 6th assessment — overcrowding and cost burdening. These factors had already been rolled into the DOF’s household projections. The DOF explicitly recognized that regional household formation rates might be depressed (a symptom of overcrowding and cost-burdening) because of the affordable housing crisis. The household formation rate used by the DOF is higher than the actual rate experienced. As such it generates a higher housing target meant to relieve overcrowding and cost-burdening. Projected Households already factors in overcrowding and cost-burdening From the Department of Finance “The argument was that the Great Recession and the affordability crisis which impact recent trends in headship should not be allowed to solely dominate the projection, rather some return to underlying socio-cultural norms of homeownership/fewer roommates is a beneficial assumption” A DOUBLE COUNT 1 circle = 10,000 households A-7 APPENDIX Lastly, the Dept. of Housing and Community Development double counted by adding two new factors that had already been factored into household forecasts made by the Dept. of Finance (DOF). * In addition to double counting, HCD incorrectly calculated the overcrowding factor. They assumed that for every house that was overcrowded another house would be required to relieve overcrowding. The more accurate analysis would be to assess the number of extra people to be housed and divide by the average household size. ** HCD only applied cost-burdening adjustments to future households not existing households. It is unclear why cost-burdening would only be considered an issue for future households, as the data is for current households. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) (34,000) (460,000) HCD 6TH CYCLE METHODOLOGY Healthy Vacancy New Housing: Assumed Vacancy New Housing Replacement Adjustment: Overcrowding Adjustment Existing Need Additional HH by 2030 Home-owned(290,000) Rentals (261,000) (118,000) Cost Burdening Adjustment Total Housing Need by 2030 5% (15,000)1.2%(3,000)(125,000) 5.0% (13,000)(39,000) 1,342,000 housing units TYPICAL METHODOLOGY Healthy Vacancy New Housing: Replacement Adjustment: Existing NeedAdditional HH by 2030 Home-owned (290,000) Rentals (261,000) Total Housing Need by 2030 1.5% (4,000)(10,000) 5.0% (13,000)(39,000) (34,000) 651,000 housing units 3.7% (10,000) 1 circle = 10,000 households A-8 APPENDIX The vacancy errors and double counting resulted in a doubling of the housing needs assessment for the six counties of SoCal. Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG) Complete data tables: www.embarcaderoinstitute.com References used in the analysis : Dept. of Housing and Community Development (HCD) https://www.hcd.ca.gov Regional Housing Needs Allocation and Housing Elements Regional Housing Needs Allocations for 6th Cycle Housing Elements: Association of Bay Area Governments Regional Housing Need Determination Plan for the Sixth Housing Element Update Sacramento Area Council of Governments Regional Housing Need Determination for the Sixth Housing Element Update Southern California Association of Governments Regional Housing Need Determination for the Sixth Housing Element Update San Diego Association of Governments Regional Housing Need Determination and Plan for the Sixth Housing Element Update Allocations for 5th Cycle Housing Elements: Association of Bay Area Governments (February 24, 2012) Sacramento Area Council of Governments (September 26, 2011) San Diego Association of Governments (November 23, 2010) Southern California Association of Governments (August 17, 2011) Annual Progress Reports Annual Progress Report APR: 5th Cycle Annual Progress Report Permit Summary (updated 730/2020) Allocations for Earlier Cycles and Housing Element RHNA 2007-2014 - Housing Methodology Committee Agenda Packet 07-27-06 Regional Housing Needs Plan 2006 to 2013 SACOG February 2008 3rd and 4th Cycle RHNA allocations (data sent in personal communication witthe Department of Housing and Comunity Development) Department of Finance Methodology for Household Forecasts “Read Me” P4 Tables : Household Projections 2020 to 2030 Association of Bay Area Governemnets Digital Library: RHNA Documents, Regional Housing Neeed Allocation Documents RHNA 2007-2014 - Housing Methodology Committee Agenda Packet 07-27-06, Regional Housing Need Allocation p 2 Other Housing Assessment Methodologies “Mckinsey & Company: A TOOL KIT TO CLOSE CALIFORNIA’S HOUSING GAP: 3.5 MILLION HOMES BY 2025”, October 2016 Jobs to Housing Employment Development Department, State of California, Employment Projections : Long Term Projections https://www.labormarketinfo.edd.ca.gov/data/employment-projections.html END NOTES Housing Element Update Advisory Committee - October 21, 2020 Item No. V(b) - Attachment 2 Orange County Mayor's Letter to the Southern California Council of Governments (SCAG)